ML20091C476

Affidavit of RM Bucci Re Eddleman Contention 11

ML20091C476
Person / Time
Site:	Harris
Issue date:	05/25/1984
From:	Bucci R EBASCO SERVICES, INC.
To:
Shared Package
ML20091C448	List: ML20091C445 ML20091C467 ML20091C476 ML20091C498
References
OL, NUDOCS 8405300577
Download: ML20091C476 (41)

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_ } !!4. A,;.I pop.4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

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(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

AFFIDAVIT OF RICHARD M. BUCCI

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8405300577 840525 PDR ADOCK 05000400 0 PDR

TABLE OF CONTENTS ,

Page No.

SUMMARY

. . . . . . . . . . . . . . . . - . . . . . . . 2 INTRODUCTION . . . . . . . . . . . . . . . . . . . . 3 Definition of Polyethylene. . . . . . . . . . . 3 i hpplications of Polyethylene in Electrical Cable . . . . . . . . . . .. . . . . . . . . . . 5 Definition of Polymer Degradation . . . . . . . 6 Radiation Aging Mechanisns in Polymers. . . . . 6 Dose-Rate Effects . . . . . . . . . . . - . . . . 8-ANALYSIS OF THE SANDIA STUDIES . . . . . . . . . . . 10-Plant Conditions vs. Test Set-Up. . . . . . . . 10 Test vs. Actual Dose Rates and Dose-Rate Threshold . . . . . . . . . . . . . . . . . . . . -11 Total Integrated Doses. . . . . . . . . . . . . 12 i

i Differences in Materials. . . . . . . . . . . . 13 Properties Measured . -

. . . . . . . . . . . . . 13 Industry Practice . . . . . . . . . . . . . . . 16-DOSE-RATE EFFECTS AT SHNPP . . - . . . . . . . . . . .

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Electrical Cable Insulation Materials At SHNPP . . . .>. . . . . . . . . . . . . . . . . 17 Radiation Environments at SHNPP . . . . . . . . 18

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i f I OPERATING EXPERIENCE AT BRUNSWICK AND ROBINSON . . . . . . 19 LSURVEILLANCE/ MAINTENANCE-. . . . . . . . . . . . . . . . . 20

, CONCLUSION . . - . . . . . . . . . . . . . . . . . . . . . . . 22 t

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

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

AFFIDAVIT OF RICHARD M. BUCCI City of New York )

ss:

State of New York )

Richard M. Bucci, being duly sworn, deposes and says as follows:

1. I, Richard M. Bucci, am Associate Consulting Engi-neer, Equipment Qualification Program Manager, EBASCO, Inc. My.

business address is Two World Trade Center, New York, New York 10048. A summary of my professional qualifications and experi-ence is attached hereto as Exhibit A. I have. personal knowl-edge of the matters set forth herein and believe them to be true and correct.

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SUMMARY

2. Eddleman Cont' tion 11 states that Applicants do not

.take into account that polyethylene, used as cable insulation, deteriorates much more rapidly under long-term doses of gamma radiation than when exposed to the same total dose over a much shorter period of time. This contention is not well founded.

The low dose-rate effect on electrical cable insulation postu-lated in the Gillen and Clough studies at Sandia National La-boratories upon which Mr. Eddleman bases his contention (4, 5, 6, 8, 12),l/ is insignificant as applied to SHNPP and would not lead to an inability of safety-related electrical cables or other electrical equipment at SHNPP to perform their proper function. This conclusion is based on a review of the litera-ture, including an anaIysis of the Sandia studies themselves, and a review of the postulated radiation environments to which safety-related electfical cables and other electrical equipment at SENPP will be exposed.

3. Even if degradation from dose-rate effects in cable insulation or other electrical equipment insulation were to occur at SHNPP, such degradation would occur only over an ex-tended period of time. Carolina Power & Light Company ("CP&L") ,

is in the process of developing a surveillance and maintenance program for SHNPP which will include features that will enable identification of equipment. degradation.

1/ References appear at the conclusion of the Affidavit.

4 INTRODUCTION D_efinition of Polyethylene

4. Polyethylene is the chemical name for a plastic mate-rial formed by the chemical linkage of hydrogen and carbon atoms. The' prefix " poly " is used to distinguish this manufac-tured material from its chemical raw material, in this casr ethylene, and indicates that it is a long, repetitive molecular

" chain." Such long-chain molecules are more generally termed

" polymers."

5. Polymers include the familiar plastics and rubbers of household and industrial use. Polymeric materials' large mo-lecular size gives them properties useful in many engineering applications. Polymers are generally arranged into three categories based on certain common characteristics (1):

t Thermoplastics - polymers that soften at high temperatures and return to their original condition when returned to a lower 4

temperature. Polyethylene is a thermoplastic. Other-common examples are cellulose, polyvinyl chloride and nylon.

Thermosetting Plastics - polymers that harden irreversibly at high temperatures. This characteristic generally allows this type of polymer to be used at higher temperatures than j thermoplastics. Examples are phenolics and epoxies.

Rubbers (or Elastomers) - polymers that are characterized by high elasticity and are usaally soft and easily extendable.

Similar to thermoplastics, elastomers tend to soften at high temperatures. Their physical properties depend more on the u

. l degree of processing in manufacture (e.g., vulcanization) than on the chemical structure. Typical examples are natural rub-ber, ethylene propylene rubber, chlorosulfonated pclyethylene (Hypalon) and fluoropolymers.

6. As can be seen from the above, polymeric materials vary widely in their physical properties. Further, the com-monly used convention of designating the type of polymeric ma-terial by the chemical name or class, although acceptable for general purposes, is a questionable basis for technical categorization. Reliance on the chemical names can gloss over important differences in the fabrication process and in fin-ished product capabilities. For example, consider the substan-tial differences between polyethylene, chlorosulfonated poly-ethylene and cross-linked polyethylene (1,2,3):

j Polyethylene - This is the simplest of all the polymeric materials. However, Varying the manufacturing process can yield different degrees of crystallinity and, consequently, a range of mechanical and electrical properties. Polyethylene that has been polymerized at low pressure (low density poly-ethylene) has markedly different characteristics from poly-ethylene polymerized at high pressure (high density polyethyl-ene) (1).

Chlet sulfonated Pclyethylene - This material, formed from a polyethy).ene base polyiner, with chlorine and sulfur addi-tives, is t.ctually flexible enough to be categorized as an elastomer;(1,2). Its irradation. properties are more dependent on the additives than on the base polymer (1).

Cross-linked Polyethylene - Cross-linking increases the molecular weight of a polymer and improves retention of mechan-ical and electrical properties at higher temperatures (1). The properties of a cross-linked polymer are a function of the den-sity of cross-links in the molecular structure, and are little ,

governed by the chemical structure. The cross-linking process changes the softer polyethylene into a rubbery material. This change substantially improves the material for use as electri-cal insulation (1).

Applications of Polyethylene in Electrical Cable

7. Polyethylene, due to its electrical and mechanical properties, ready availability and low cost, has been used as cable insulation in many applications. It was widely used in nuclear plants built prior to the mid-1970s (4). At that time, however, certain unfavorable properties, such as flammability and low thermal resistance, led to its rejection for general use as electrical cable insulation in nuclear, and other, power plant applications. Elastomers, which were known to exhibit better properties of thermal and radiation resistance, began ,

generally to be applied as cable insulation for nuclear power plants.

8. Nevertheless, because of the simplicity of its chemi-cal structure, polyethylene has served as a prototype for studying the mechanism involved when polymers are exposed to radiation (1). For example, Gillen and Clough of Sandia Na-tional Laboratories used polyethylene cable insulation samples taken from a non-commercial nuclear reactor when studying the effects of low radiation dose rate on cable insulation (6).

Definition of Polymer Degradation

9. The term " degradation" refers to the reduction of a specified property (e.g., tensile strength, elongation, resis-tivity, dielectric strength) of a polymeric material. Depend-ing upon the nature of the material's application, different levels of degradation in a specified property or set of prop-erties may be acceptable. The properties of concern when judging the significance of equipment degradation are those properties directly related to the critical functions to be performed by the material in the particular application. This is the reason that " application" tests normally employ failure criteria for inability to perform critical functions. Research tests such as the Gillen and Clough tests (5, 6), on the other hand, measure specifi'c property changes in order to study the degradation mechanisms involved, and do not employ failure criteria.

Radiation Aging Mechanisms in Polymers

10. When radiation is absorbed by polymers, the energy of their atoms is increased, producing free electrons (called

" ions"). Ionization leads to the rupture of chemical bonds, which in turn yields fragments of the large polymer molecules.

These fragments may then react to change the chemical structure of the molecule.

11. Two important effects of this process on the molecule are scission (breakup into small molecules) and cross-linking (recombination into a network-type structure). The fragments may also recombine into their original form, with no net change. The type and rate of change in the physical properties of the polymer depend on the competition between scission, cross-linking and recombination. Net cross-linking increases molecular weight and improves several other properties of a ma-terial. In polyethylene, for example, which tends to cross-link, low and sometimes intermediate doses of radiation are beneficial (3). This is why commercial cross-linked polyethyl-ene is an improvement on regular polyethylene. The effects of scission are in most respects opposite to those of cross-linking. Here, as the' molecules are broken into smaller frag-ments, the properties are degraded.

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12. Research (9, 8, 9, 12) on the radiation induced deg-l radation of polymers indicates that the presence of oxygen is critical to the above-described degradation mechanisms. Oxygen -

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) is required for the formation of radicals which break down the irradiated material. The importance of oxygen is illustrated by the fact that experiments performed in inert atmospheres produce relatively slight degradation. Because the importance of oxygen to polymer degradation has long been recognized (1, 2), cable insulation often includes antioxidants which aasist in reducing degradation.

Dose-Rate Effects

13. To simulate the cumulative effects of the relatively low radiation exposure rates to which polymeric materials in nuclear power plants are normally subjected, the generally ac-cepted industry practice has been to use dose rates on the order of 10E6 rads /hr.2/ The practice of irradiating test specimens at elevated dose rates has been questioned, however, in studies done by Gillen and Clough =t Sandia National La-boratories (5, 12). These investigaticns were prompted by the discovery of degraded electrical cable insulation at the non-commercial Savannah River K-reactor (4). On visual inspection of the cable, the polyvinyl chloride jacket showed no signs of degradation along the entire length of the cable. However, after removal of the jacket, it was found that the polyethylene insulation underneath had alternating areas of flexibility and embrittlement. Examitation of dosimetry mapping performed by i

i Savannah River personnel showed that these alternating areas of I

flexible and brittle cable insulation corresponded to differ-ences in the radiation fields experienced by the cable at those points. Continuous measurements were not made. However, over the 12 year instal'ad life of the cable, the relatively undamaged areas had been exposed to a dose rate of approxi-mately 13 rads /hr. While the damaged portions had been exposed to a dose rate of approximately 25 rads /hr.

2/ Accelerated aging is expressly permitted by 10 C.F.R. 6 50.49(e)(S).

14. Gillen and Clough postulated that the degradation was due to the dose rate to which the cable was exposed. Dose-rate 1

effect simply means that the amount of degradation experienced I

by a material is dependent not only on the total integrated i dose, but also on the rate at which the radiation is applied.

A low dose-rate effect is the occurrence of greater degradation for a given total dose administered over a time period T1, than would occur for the same total dose administered over a time period T2, where Tl is greater than T2. The effects of radia-

'T tion dose rate on polymer degradation have been discussed in the literature for many years (e.g., 2, 3, 13). Gillen and Clough's hypothesis that dose rate was responsible for the deg-radation to the Savannah River cable apparently was prompted by thefactthatthehighelstdoseratetowhichthecablewasex-posed was about 25 rads /hr. , compared to the rates of about 10E6 rads /hr. commonly used in industry testing.

15. Gillen and Clough tested their hypothesis on a number of polymer materials used in cable insulation and jacketing.

In one study (5), they tested polyvinyl chloride and polyethyl-ene cable similar to that used at Savannah River. In a second j study (12), they tested ethylene propylene rubber, cross-linked polyolefin, chloroprene (neoprene) and chlorosulfonated polyethylene. These materials were stripped from the cables.

j and irradiated in air and nitrogen at radiation dose rates ranging from approximately 10E3 to 10E6 rads /hr. Material deg-radation was measured using ultimate tensile properties

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{ Infrared spectroscopy was used as a means of gaining insight.

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16. Gillen and Clough found radiation dose-rate effects

' The mech-in air environments for all of the materials tested. ,

anism for these effects was suggested to be the result of com-j petition between cross-linking:and oxidative scission, in which

! scission becomes more important ac the dose rate is lowered, thus allowing more time for the chemical reactions and for. oxy-4 gen diffusion into the materials. Gillen and Clough concluded i

j from the Savannah River experience and these and subsequent i .

j laboratory studies (7, 8)'tnat, although there is a lower range' i

j of dose-rates below which radiation-induced oxidation effects. ,

i j- disappear (7), that range is lower than previously recognized.

l ANALYSIS OF THE SAN 3IA' STUDIES-2 I

17. Research tdating must~be carefully considered when~ "

applying the results to an engineering-application. The'Sandia i tests performed by Gillen and Clough involve a number of impor- ,

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I tant limitations regarding their applicability to SHNPP.-

I Plant' Conditions vs. Test Set-up t l -18. As discussed above, Gillen and Clough have attributed i'

the phenomenon of dose-rate effects. chiefly to radiation in- -

! duced oxidation (5). One' limitation of the Sandia tests-(5, >

f 12) is that pieces of cable insulation systems were' stripped!

from the wire for the-tests. -The-insulation material was.thus l completely, exposed to oxygen in the ambient atmosphere.

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Polyethylene, in particular, is quite susceptible to oxidation, videnced.by its behavior when exposed to radiation in thin j films (3). In actual application, insulation is covered with a i

jacket material. Although the jacket is primarily for mechani-  !

cal protection purposes (protection from abrasion, cuts, etc.),

this covering significantly reduces the oxygen available for radiation induced oxidation of the cable insulation.

Test vs. Actual Dose Rates and Dose-Rate Threshold

19. A second important limitation of Gillen and Clough's tests is that they based their conclusions on the results of

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testing performed over a range of dose rates that were far too high to be representative of the normal dose rates in commer-cial nuclear plants. As shown in Table 1, dose rates in most plant areas at SENPP will be significantly below 1 rad /hr. dur-ing normal plant operation.3/ The highest normal operational dose rate in any plant area will be 9.99 rads /hr., in Zone C5.

In contrast, Gillen and Clough in their tests used dose rates 4

ranging from 1.4 x 10E3 rads /hr. to 1.2 x 10E6 rads /hr.

20. Of course, the degraded cable from Savannah River was exposed to much lower dose rates, ranging from approximately 13 rads /hr. (for a 12 year integrated _ dose of 1.3 x 10E6 rads) to 25 rads /hr. (for a 12 year integrated dose of 2.6 x 10E6 rads).

However, it is crucial to note that the portion of the cable 13 / The dose rates in Table 1 conservatively assume a worst case location of equipment within each radiation zone.

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exposed to only 13 rads /hr. was relatively unaffected. This strongly suggests that there is a minimum threshold dose rate below which dose-rate effects are not significant. That dose rate appears to be somewhere between 13 and 25 rads /hr. All of the radiation zones at SENPP fall below this threshold. See Table 1.

Total Integrated Doses

21. A third factor revealed by the Sandia tests which limits their applicability to commercial nuclear power plants, including SENPP, has to do with the total integrated doses re-

, ceived by the materials tested. The results from several tests at different dose rates have been reproduced as Figures 1 and 2 of this report. Although dose-rate effects are apparent, the differences in the rate of degradation caused by the various dose rates decrease as[the total dose decreases. In other words, dose-rate effects are most pronounced for higher total doses. Further, Fig. 2 shows rather minor degradation for I

polyethylene until somewhere between 10E6 and lOE7 rads. This .

data agrees with the data from Savannah River, where the unaf-fected portions of the cable were exposed to a total integrated dose of 1.3 x 10E6 rads.

22. As stated above, the highest dose rate in any plant l

area at SENPP will be 9.99 rads /hr., for a 40 year total inte-grated normal dose of 3.5 x 10E6 rads. For all polymers tested

.by Gillen and Clough except the simplest polyethylene, no sig-

! nificant differences in degradation were recorded for the l

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different dose rates at a total dose of 3.5 x 10E6 rads; and neither was any significant degradation recorded. Figures 4a through 4d, based on figures from Reference 12, illustrate where the SHNPP highest total integrated normal dose lies in comparison with Gillen and Clough's test results for ethylene propylene rubber, cross-linked polyolefin, chloroprene and chlorosulfonated polyethylene.

Differences in Materials

23. A fourth limitation of Gillen and Plough's work con-cerns the differences in test results among :he various materi-als tested. A close examination of the Sandia test results (5,

12) indicates that certain materials are much less sensitive to low dose-rate effects than others. Gillen and Clough them-selves have stated in other studies (8, 14) that dose-rate ef-fects are minor in polymers such as cross-linked polyethylene, chlorosulfonated polyethylene, chloroprene and-silicone materi-als. Evidence of low dose-rate effects in simple polyethylene thus cannot necessarily be extended to predict the same effects in other, improved compounds being used-in present day nuclear plant designs.

Properties Measured

24. A fifth, and perhaps the most serious, limitation of-the Sandia tests is that the properties me,asured to detect deg-radation were mechanical properties - tensile strength and elongation. Other engineering properties of interest, particu-larly electrical properties like resistivity and dielectric.

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strength, were not measured. Yet, nuclear industry cable qual-ification tests have demonstrated that a cable with substantial degradation in mechanical properties of the insulation contin-ues to provide sufficient insulation properties to allow the cable to perform its electrical function.

25. A more recent Sandia study by Minor and Furgal (15) has demonstrated that degradation of the mechanical properties of electrical cable insulation does not prevent the cable from performing its required electrical function. In the study, cross-linked polyolefin-insulated electrical cable was exposed to a relatively low dose rate (6.2 x 10E4 rads /hr.) for a total integrated normal operational dose of 5 x lOE7 rads. Then, after elevated temperature aging, the cables were exposed to an accident dose of 1.5 x 10E8 rads at a rate of 7.7 x 10E5 rads /hr. Despite severe degradation of mechanical properties, t

the cable was able to' perform its electrical function at all times. This series of tests was conducted according to indus-try standards (IEEE 323-1974 and IEEE 383-1974) and NRC guidelines (NUREG-0588). Minor and Furgal concluded that the methodology employed by the nuclear industry to qualify elec-trical equipment, despite the dose-rate effect on mechanical properties. studied by Gillen and Clough, is adequate.

26. It should be pointed out that Minor and Furgal's en-vironmental test conditions, consistent with standard industry practice, were much more severe than the potential exposures in l

an operating nuclear power plant. To illustrate this, Figure t

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3, extracted from the Minor and Furgal report (15), has been marked to indicate the worst case SHNPP (normal plus accident) conditions. Cable qualification tests performed for SHNPP also include total exposures which are much more severe than actual potential exposures. For example, the SENPP total integrated test exposures used to qualify safety-related cable inside con-tainment range from 1 x 10E8 to 2 x 10E8 rads.

27. Gillen and Clough have acknowledged that the dielec-tric constant of organic insulation may only change insignifi-cantly at a point where the mechanical properties have changed drastically (7). Gillen and Clough nevertheless chose to study mechanical properties of insulation materials because they are conveniently measured and are related to the function of the materials in a number of different applications. In the case of electrical insulation, Gillen and C1cugh have suggested that mechanical properties ar. primarily of interest for considering a catastrophic failure under the influence of some applied stress (7). Cable qualification tests, however, currently in-clude a mechanical durability test for cable following exposure to the simulated normal and accident environmental conditions (11). This test severely stresses the cable when it is in an extremely degraded condition. All SHNPP safety-related elec-trical cables have passed this test while energized at elevated voltage levels (i.e., at voltages higher than the cables will see in service).

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28. The Minor and Furgal study, as well as the perfor-mance of electrical cables during qualification testing, demon-strate that the results of research tests, such as the Gillen and Clough tests, which do not employ failure criteria, cannot be directly applied to materials in actual nuclear power plant application.

industry Practice

29. The possibility of radiation dose-rate effects has been recognized in nuclear industry research and testing for at least the last 15 years (13, 1). Nuclear industry qualifica-tion testing standards account for such possible effects. IEEE 323-1974 (10) states as follows:

In determining the total required test radiation equivalent to that of service life, considera-tion shall be given to oxidation gas-diffusion effects.... Thus, to allow for these effects, a greater total dose than the service lifetime dose should be applied.

30. As stated above, the total integrated doses received by electrical cables at SHNPP during qualification testing far exceed the most severe doses the cables could experience in ac-tual use. Test doses of 1 x 10E8 to 2 x 10E8 rads were used to qualify cables for a maximum calculated dose of 1.3 x 10E7 rads. This maximum calculated dose includes the 40 year full power normal opetating dose p. s the accident dose. None of the Sandia tests has shown that a low total dose occurring over a long period of time, as in the 40 year normal operating life of a commercial nuclear power plant, causes more degradation t

than an extremely high total dose applied over a short period of time, as in, qualification testing.

DOSE-RATE EFFECTS AT SHNPT Electrical Cable Insulation Materials at SHNPP

31. Table 2 is a list of all safety-related electrical cables at SHNPP.4/ The type of insulation and jacket materia'l is given for each cable. As can be seen, simple polyethylene is not used either as cable insulation or jacketing. Chlori-nated and chlorosulfonated polyethylene are used as jacketing for some cables. However, these are improved versions of sim-pie polyethylene and are not as subject to dose-rate effects.

At any rate, cable jacketing is used only for mechanical pro-tection of the insulation and performs no electrical safety function.

32. In addition to insulation for electrical cables, polymer materials als'o are used as insulation for other types of electrical equipment, such as component wiring in electrical equipment, motor windings and terminal lugs. For example, cross-linked polyethylene is used at SHNPP as insulation on component wiring in electrical penetrations. I am unaware of any instance, however, in which simple polyethylene is used as insulation for any type of electrical equipment inside contain-ment at SHNPP.

4/ This list was an attachment to a letter from M. A.

McDuffie to Harold R. Denton (April 26, 1983).

Radiation Environments at SHNPP

33. Regardless of the materials used for cable and other electrical insulation at SHNPP, in none of the radiation envi-ronments calculated for SHNPP will electrical equipment be ex-posed to conditions in which dose-rate effects are of concern.

No electrical equipment will be exposed either to dose rates or total integrated doses at which significant dore-rate effects have been shown to occur.

34. Dose rates for all radiation zones at SHNPP during normal, full-power operating conditions are provided in Table

1. A description of these zones is found in SHNPP FSAR Appen-dix 3.11.b. The dose rates for all radiation zones except one are under 1 rad /hr. The exception is Zone CS, which will have a normal dose rate under 10 rads /hr.5/ As discussed earlier, at Savannah River cable insulation exposed to approximately 13 rads./hr. for 12 yeart did not show significant degradation.

35. Total integrated doses for the 40 year normal life of the plant also are shown in Table 1. The highest total inte-grated

• dose is, of course, found in Zone CS, which will have a 40 year normal dose of 3.5 x 10E6 rada. Again, with the excep-tion of simple polyethylene, thic dose is below the total inte- ,

grated dose at which Gillen and Clough found significant 3/ These calculated done rates are conservatively high, since they assume continuous reactor operation at 100 percent power for 40 years plus i percent failed fuel contribution. In all cases, maximum values rather than average or expected dose rates (as permitted by NUREG-0588) are used.

dose-rate effects or significant degradation to occur. See Figures 4a through 4d.

36. Design basis accident conditions at SENPP are not of concern with respect to radiation dose-rate effects either.

Design basis accident dose rates are typically in the range of 10E5 to 10E7 rads /hr. (16). Unlike normal dose rates, which are relatively constant over the life of the plant, design basis accident dose rates are assumed to occur instantaneously upon accident initiation (per NUREG-0588) and decay rapidly.

Considerations of long-term aging effects thus are not applica-ble in the post-accident environment. Further, the relatively high dose rates normally employed during qualification testing sufficiently simulate accidbnt conditions. It is undoubtedly for these reasons that Gillen and Clough have stated that their work is concerned with the aging (non-accident) portion of qualification testiny (7). 3, OPERATING EXPERIENCE AT BRUNSWICK AND ROBINSON

37. Although controlled laboratory studies and1 tests may_

have shown that polyethylene used as electrical. cable insula-i tionmayexhi$itdose-rateeffectsundercertainconditions, such effects cannot be fully addressed without examining the functional capabilities of. materials as currently.used in actu-al commercial nuclear power plant application. The Affidavit of Peter M. Yandow, Edward M. Steudel and Harold W. Bowles

("CP&L' Affidavit"). states that a review of the operation and~

maintenance history.of CP&L',s Brunwick and Robinson. plants, c.S _ . _-

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which have a combined operating reactor history of 29 years, reveals no evidence of degradation of electrical cable insula-

. tion or other electrical insulation due to radiation dose-rate

effects. Neither am I aware of any instance of such degrada-tion in any other commercial nuclear power plant application. ,

SURVEILLANCE / MAINTENANCE

38. The main goal of the continuing NRC sponsored re- l l

search program at Sandia is to develop improved accelerated  !

aging techniques which may ultimately be of'value to the nucle-ar industry generally. In addition, information about such in-dustry concerns is continually exchanged through industry orga--

nizations such.as the Institute of Nuclear Power Operations and the American Nuclear Society. It is thus reasonable to expect that further data on do'se-rate effects will be developed in the future. It is also likely that commercial nuclear power plant

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experience will expan'd our state of . knowledge on dose-rate ef-fects. A properly designed surveillance and maintenance pro-gram will allow for improvements in our understanding of long-term materials performance and will detect-any unexpected degradation from radiation dose-rate effects.

39. All operating commercial nuclear power: plants have -

surveillance and maintenance programs' developed in accordance:

with 10 C.F.R. Part 50, Appendix B. Failures ~ detected.in other-reactors by these programsf(or'through_other.means) will be-available to CP&L-through Licensee Event. Reports, NRC"IE Bulle-.

tins, and manufacturers'iinformation' notices. -Since other 20-V i

plants, such as Robinson and Brunswick, will have been op-erating longer than SHNPP, and since dose-rate effects on elec-trical cable insulation, if they occur, will develop over long periods of time, degradation from dose-rate effects should be detected at these other plants long before it could cause un-safe conditions to occur at SENPP. As stated in the CP&L Affi-davit, at 1 14, such data will be incorporated into SENPP's surveillance and maintenance program. Detailed procedures of the program, which are being developed, such as inspection in-tervals and test procedures, will take into account industry experience on materials performance. See CP&L Affidavit at 11 14-16.

40. The program elements for the SHNPP surveillance and maintenance program, as set forth in the CP&L Affidavit, are consistent with industry guidelines. The program will include features that will en'able identification of equipment degrada-tion.

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CONCLUSION

41. Analysis of the Sandia studies av applied to SHNPP, CP&L's review of the operation and maintenance history of the Brunswick and Robinson plants, and SHNFP's planned surveillance / maintenance program as described in the CP&L Affidavit, demonstrate that there is no reasonable basis to believe that radiation dose-rate effects on cable insulation or other electrical insulation at SHNFP will induce failures in electrical equipment or will otherwise cause unsafu conditions to occur.

,] o

. Michard M. Bucci A

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Subscribed and sworn to before me thisol l t4_ day of May, 1984. ,

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NUtARY PUSLIC Htralf T. WCAlliffY

. Notary I4blic, tilate el Neue Yadi

, No. 31.*suot970 C*'Q*ueldled in New Yedi County * * *" 888'** M*h38 1888

, My Coussiesjon Expites:

l  : .

t

(

a REFERENCES

1. W.'N. Parkinson and O. Sisman, Oak Ridge National La- ,

boratories, "The Use of Plastics and Elastomers in Nuclear Radiation,"iNuclear Engineering and Design 17

' (North-Holland Publishing Company, 1971), p. 247-280. i

2. Robert Harrington, Hanford Laboratories, " Effects of Gamma Radiation on Elastomers, Part III," 82 Rubber Age (March 1958).

3._ Robert Harrington, Hanford-Laboratories, " Effects.of Gamma ,

l' Radiation on Elastomers, Part IV," 82 Rubber Age (June 1958). -;

! 4. R. L. Clough and K. T. Gillen, Sandia National La-

. boratories, " Investigation of Cable Deterioration Inside Reactor Containment," 59 Nuclear Technology (November s 1982).

l S. R. L. Clough and'K. T. Gillen, Sandia National La-  !

2 boratories, " Radiation-Th'ermal Degradation of PE and PVC:

Mechanism of Synergism and Dose Flte Effects,"

i NUREG/CR-2156 (June 1981). i

. 6. K. T. Gillen, et al., Sandia National Laboratories, "In -

l

~

vestigation of Cable Deterioration in the Containment l Building of the Savannah River Nuclear Reactor,"

NUREG/CR-2877 (August 1982).

l I 7. R. L. Clough and K. T. Gillen, et al., " Accelerated-Aging Tests for Predicting Radiation Degradation of Organic Ma-j- terials," 25 Nuclear Safety (March-April 1984).

8. K. T. Gillen and R.'L. Clough, et al., Sandia National La-j boratories, " Loss of Coolant Accident (LOCA) Simulation

Tests and Polymers: The Important of~ Including Oxygen,"

! NUREG/CR-2763 (July 1982).

9. Georgia Institute of Technology, " Radiation Effects on Or- ,

ganic Materials in Nuclear Plants," EPRI NP-2129 (NovemS..

1981).

! 10. Institute of Electrical and Electronics-Engineers, "Stan-i dard~for Qualifying Class 1E Equipment.for Nuclear Power Generating Stations," IEEE 323-1974~(ANSI N41.5-71)

(1974).

11. Institute of'Electricali and Electronics Engineers, "Stan-dard for. Type Test of Class 1E Electric Cables, Field.

l Splices, and' Connections for Nuclear-Power Generating Sta-tions," IEEE 383-1974-(1974).

l 1-

-i s

s r -

r--'- -c -'-<e, 9e *re -

• s- <=we M,e"-'r - -e- .i-tvv ,

-*+-m==+w---&-w*- +- -+=v- .% rat *---

4

12. K.'T. Gillen and R. L. Clough, Sandia' National La-boratories, " Occurrence and Implications of Radiation Dose-Rate Effects for Material Aging Studies,"

?

NUREG/CR-2157 (June 1981). >

t

13. R.']B. Blodgett and R. G. - Fisher, " Insulations and Jackets I

for Control.and Power Cables in Thermal Reactor Nuclear Generating Stations," PAS-88 IEEE Transactions on Power 4

Apparatus and Systems (May 1969).

I

14. K. T. Gillen and E. A. Salazar, Sandia National La-

boratories, " Aging of Nuclear Power Plant Safety. Cables,"

l SAND 78-0344 (1978).

15. E. E. Minor and D. T. Furgal, Sandia National La-boratories, " Equipment Qualification Research Test of Electric Cable with Factory Splices and Insulation Rework Test No. 2," NUREG/CR-2932, 2 vols. (September 1982).

1 16. Nuclear Regulatory Commission, " Interim Staff Position on '

Environmental Qualification of Safety-Related. Electrical Equipment," NUREG-0588, Rev. 1 (July 1981).

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. 4 .L- __ .kh.. m l

TABIE 1 SHNPP SPECIFIC RADIATION ENVIR0!4fENIS

, Total Integrated Zone Normal Dose Rate Normal Dose No. ORADS/HR) (R ADS)

C1 1.42E-1 5. 0E 4 C2 1.42E-1 5. 0E 4 C3 1.42E-1 5. 0E4 i C4 1.42E-1 5. 0E4 C5 9.99E-0 3.5E6 C6 2.28E-1 8. 0E 4' R1 2.85E-3 1.0E3 R2 2.85E-3 1.0E3 R3 2.85E-3 1.0E3 R4 h.85E-1 1.0E5 RS 2.85E-1 1.0E5 R6 2.85E-3 1.0E3 R7 2.85E-3 1.0E3

) R8 2.85E-2 1. 0E 4 l

R9 2.85E-3 1.0E3 I

R9A 2.85E-3 1.0E3 R10 2.85E-3 1.0E3 R11 2.85E-3 1.0E3 R12 2.85E-3 1.0E3 R13 2.85E-3 1.0E3 R14 2.85E-1. 1.0E5 R15 2.85E-3 1.0E3

- R16 2.85E-3 1.0E3 j R17 2.85E-3 1.0E3 -

-R18 2.85E-3 1.0E3 y -

-.-r y .v - + ...m - -- - _

TABIE 1 (Cont'd)

SHNPP SPECIFIC RADIATION ENVIRONMENTS (Cont'd) 1 l

l 1

Total Integrated

Zone- Normal Dose Rate Normal Dose No. (RADS /HR) CRADS)

R19 2.85E-3 1.0E3 R20 2.85E-3 1.0E3 R21 2.85E-3 1.0E3 f

R22 2.85E-3 1.0E3 R23 2.85E-4 1.0E2 R24 2.85E-3 1.0E3 j R25 2.85E-3 1.0E3 R26 2.85E-3 1.5E3 F1 2.85E-2 1. 0E 4 F2 2.85E-3 1.0E3

'o TA1 2.85E-2 1. 0E 4 1

I 1

6 i

TABLE 2- SilEAllON llARRIS MilCI. EAR POWFR Pl. ANT CARI.E INFCHATION Shest I of 2 l

Spec Voltage Applicable No. Coble Vesador B/M Nominer Class Insulation and Jacket Type ICEA Mos.

i E-14A Anaconda DID-Ol 6.9KV INS-Ethylene Propylene Hubber Ericsson plo-02 S-19-81 6.9KV JACKET-Chlorinated polyethylene plo-03 S-68-516 6.9KV S-61-402 E-145 Kerite D25-01 to 600V INS-Ethylene Propylene Hubber D25-il S-19-81 600V JACKET-Vulcantzed Qilorinated Rubber S-68-516 D50-01 to S-61-402 4 600V INS-Etisylene Propylene Rubber j D50-15 600V JACRET-Vulcanized Cielorinated Rubber

s

, *E-14C American 140-01 to "100V INS-Ethylene Propylene Rubber S-19-81 Insulated D60-08 300V JACKET-ilypalon (chloronulforated polyethylene)

Wire D62-01 to 5-68-516 300V 142-03 S-61-402 300V

• Cables covered by Spec E-14C are for asse 144-01 300V outside containment only.

147-01 to. Telephone 147-05 Telephone IES-08 Telepinone

• E-143 Samuel D70-01 Thermo- lits-Ethylene Propylene Diene Honomer S-19-81 l hiere & D72-01 couple JACKET-lippalon (Gelorosulforated Polyethylene)

Company D83-01 S-68-516 S-61-402 .

~

E-I5A Anaconda l6l-OL to 300V IleS-Ethylesie Propylene Hubber Ericsson S-19-81 141-08 300V JACKET-Chlorinated Polyethylene S-66-524 l . 145-01 300V S-68-516 lHl0-01 600V D80-04 P-54-440 i 60tW INE-01 T-22-294 600V

D86-02 6(ww 1

t

TABLE 2- SilEAlt0N llANNIS NUCl.l'AR POWER Pl. ANT

' Sliest 2 of 2 CAMLE int'ONHATION E gac Voltage Applicable ha. Cable Vendor B/H Esenber Class Insulatlon and Jacket Type ICEA Nos.

E- 15A Anaconda D82-02 600V INS-Silicon Rubber '

(Cont'd) Ericsson JACKET-Chlorinated Polyethylene i D85-02 600V INS-Flame Retardant Etleylene Propylene

, D87-01 to 600V JACKET-Chlorinated Polyethylene D87-08 600V '

D88-01 Thereo-couple i D88-02 Thermo-

, couple -

DS9-01 600V - ,

D90-On to 300V D90-05 300V c5-155 American D80-03 600V INS-Ethylene Propylene Rubber S-19-81 Insulated D94-01 300V JACKET-ilypalon (chlorosulforated polyethylene) S-66-524 Wire D95-01 to 300v S-68-516 D95-03 300V P-54-440 i

• Cables covered by Spec E-158 are for use T-22-294 i

outside containment only.

E-15C Boston D84-01 . Triaxial INS-Fluoropolyme r S-19-81 Insulated Cable JACKET-Chlorosulphonated Polyetilylene S-66-524 .

Wire & (Rg-ilu) S-68-516 i

Cable Co. P-54-440 T-22-294  ;

i

1.0 -

O 930 kras/hr O SG kree/hr O

o se nr efn, 0.8 -

e/e, ^

0 25 50 78 100 RADIATION DOSE (Mred Figure 15.

Tensile elongation results for PVC jacketing as a function of dose at 43*C using three different dose rates.

10 3 i i i o . r.e,~

a to kreerhr a s.7 nr.e/n, 0.5 - 0 ele, ,

o.o . l 4 l 0 as so 75 100 RADIAT)ON DOSE (Mred)

Figure 16.

Tensile elongation results for PE insulation as a l function of dose at 43*C using three different dose rates.

FIGURE 1 (Reproduced From Reference 6) l l

l i

l 1

4

• I l

DOSE MATE fraosM 0 $2 1.02089 81481&8 l 8 ssales) 33 i i a s ig g gi gi g g g gsyg

• ImGv/sl 52 10.289 80 %as 15e

. g ',,3 6 &lis) 44 I IIllis at A6 Ililg po,ne, 2 17 8 34 -

~

5 i OO r: : : , %, ,

=

• ~

y _

p ~

g _

O 10 e ,

" %I VetM Yl ene "

s

=

en 0.09 ' ' I ' ' 8 81 ' ' t! ' I 81 till 8Cvl 104 108 10e 90'

! l i f f fill! I i1fifl$ l t i l ll11!

feel toe 10' 10e goe

, Oost Fig 6 Deegetsee et break earnessed to the value befees hve.

disties fee II eemsneretet polyett; lese cable 4meslettag unserish as a foncties of sheerhed dese. The messerad yelets fat wishin the shaded regiean for efferest dose roses. the detted aren for ,

l le=4 -insermeente demi rotes, as shove se the apper scala, and the hatched aren fee irradieries et bigt done estas of 90 C3 /s ilJ X 10' Cy/h, IA X 19' res/b> Th este cleart; show a pronounced deae.cese effect. Based as P. Maier and A. Seelers.

I Aetolereerd and toeg Toren Mediaries Efrets se Ceamrecief real, teseleslag Meerrials Earapene Organisettee for Nedent Metedah (Ceasef Eerspese er Recherche Neeleairva Cemeen,in prepareiine.

l .

FIGURE 2 (ReproducedFromReference7)

A

1 e

400 i i i LEGEND O HGM-RATE RAD.tiMERMAL AGING

. O THERMAL /HIGH-RATE RAD. AGING Z 300- l A '0**"^75 "^aiTHEmuAL AGiwG -

9 l L AGING  ! LOCA 0 EXPOSURE rl: EXPOSURE  ;

h l High-Rate Radiation

' l W 200 - i t b l 5 l o .

l m . .

W . .

& i 100 -  : , l -

l ERROR BARS SHOW i  ; 3 souA tuts ,

l l .

1 l t 'I I lh 2'S 50 100 150 I200 TOTAL RADIATION EXPOSURE (Mrds)

SHNPP y : SHNPP

• AGING LOCA EXPOSURE EXPOSURE (3.5 Mrds) ,

Elongation vs. Radiation Exposure FIGURE 3 (ReproducedfromFigure3-1ofReference15) i

,, 4-- SHNPP WORST CASE TOTAL NORMAL DOSE

= 3.5 Mrad 16 i i i 3,4 . / ^4 .

1.2 -

1

~ .

L/

e.s -

0 0

g O 1.2 asume O ac wome i

j A sr wmmt eie. O 9.5 womt .

O t 6 ==*r 4 31 w=mt in g 1 i -

0.5 -

0 1.

m i 90 i

100

%. lH 1

100 RA0l AflON 005[ , he AD ,

Fig. 1. Aging of crosslinked polyolefin insulation. ,

The tensile strength after aging divided by

> the tensile strength before aging (T/To) and the tensile elongation after aging divided by the tensile elongation before aging (e/e )

plotted against the total integrated radia o tion dose at the various indicated dose rates. The circled numbers refer to the weight swelling ratios corresponding to .

t the indicated experimental conditions.

FIGURE 4a (ReproducedfromReference12) l

4- SHNPP WORST CASE TOTAL NORMAL DOSE

= 3.5 Mrad i I i 1

y' 4

-- p -I-

". , 4 ,

o.s - 0 _

\

O

.@ o i. .., .

O In Wasme

,#, AN weemt O 9.3 weemt 0 i .e =*r g,3 - '" b .

L O' o

. i ,

8 4 18 l# IE 94014f19:07(, W 40 Fig. 2. Aging of ethylene propylene rubber insulation. Explanation of figure is identical to Fig. 1.

FIGURE 4b (ReproducedFromReference12) l

)

.y

l e-- SHNPP WORST CASE TOTAL NORMAL DOSE

= 3.5 Mrad 1.1 - , i i o IL-(t o 1

In, f C O

-O A N -

O e.s -

.9 o na vowe I

@A' o a womt

• 4, A at emme O I.a wwsr 1@ '

0 1 * ***c s.s - - .

'O

@',  : A

, s. . , i o e m te Ito too anointim pst . mac Fig. 3. Aging of chloroprene rubber jacket.

Explanation of figure is identical to Fig. 1.

FIGURE 4c (ReproducedFromReference12)

i I

9--- SHNPP WORST CASE TOTAL NORMAL DOSE

= 3.5 Mrad 3'

n ,

3 _T i

- n

'A. N a -

0-

. c.1 -

, a

'S -

1 A o es ener O txo west h ' aM washt

, **e O s.s wnse 0 i.i w=*,

0.s O A O

/

0' f' ' ' '

O M 19 . .

IM g g RASlafl h 005t. MtAD Fig. 4.

Aging jacket.of chlorosulfonated polyethylene Explanation of figure is identical to Fig. 1.

FIGURE 4d (ReproducedFromReference12)

T EXHIBIT _A l

RICHARD M. BUCCI Associate Consulting Engineer Equipment Cualification Program Manager

. I EXPERIENCE

SUMMARY

Registered Professional Engineer with over ten years experience in electrical and related power engineering for fossil and nuclear power plants, including five years experience in Technical Super-vision of engineering and design teams for nuclear power plants.

Responsible for managing nuclear consulting services (electrical), l development of corporate programs, guidance and positions on  !

nuclear plant electrical systems, equipment qualification and .

computer aided design (CAD) programs.

l l

Technical responsibilities have included developing, implementing and consulting on system and physical design criteria; preparation l and review of electrical one-line diagrams, physical drawings and specifications; review / analysis of equipment qualifications  !

economic and technical equipment evaluations; monitoring vendor information, specification conformance and delivery; engineering l

support of plant construction, start-up and operations; preparation  ;

of electric 1 and equipment qualification sections of PSAR, FSAR and responses to NRC. Developed and applied computer-aided methods i for electrical auxiliary system studies, cable and raceway system i design monitoring system start-up packages, analyses of plant i design for conformance fwith safety requirements, preparation / i maintenance of equipment qualification documentation and electrical design / graphics. ,

Administrative responsibilities included' planning and implementing l corporate engineering programs, project implementation of QA and  !

Equipment Qualification Programs, development of schedule and budget, manpower forecasts and performance evaluations, job control - f by monitoring / reporting on accomplishments, schedule and workdays,  ;

training and development of design engineers, and management of l multidiscipline corporate equipment qualification program efforts '

and electrical consulting projects.

t REPRESENTATIVE EXPERIENCE Client Project / Station Type Position Ebasco Corporate Nuclear Services, Section and consulting Development / Consulting Nuclear Leader l Engineering Dept. Electrical l

Ebasco Corporate Corporate Equipment Program and Consulting Qualification Pro- Nuclear Manager Engineering Dept. gram i

- - - - - ..-m._-_,.. - , _ - . - , , - . - - - - . , _ _ , . _ - . . -

Ebasco Corporate CAD Development Electrical i and consulting Program Section Engineering Dept. Leader '

Carolina Power Shearon Harris Nuclear Lead Elec-

& Light Co. Units 1 & 2 trical Engineer Florida Power & St. Lucie Units Nuclear Electrical Light Co. 1& 2 Consultant New York Power Indian Point Nuclear Electrical Authority Unit 3 Consultant Houston Lighting Allens Creek Nuclear Electrical

& Power Co. Units 1 & 2 Engineer ,

Houston Lighting Cedar Bayou Fuel Oil Electrical

& Power Co. Oil Conversion Engineer Houston Lighting PH Robinson Fuel Oil Electrical

& Power Co. Oil Engineer EMPLOYMENT HISTORY -

Ebasco Services Incorporated, New York, N.Y.: 1974-Present Associate Consulting Engineer,1984-Present Principal Engineer, 1982-1984 Senior Engineer, 1980-1982

• Engineer, 1978-1979 Associate Engineer, 1976-1977 Assistant Engineer, 1974-1975 University of Illinois, School of Engineering, Urbana, Illinois, 1972-1974 .

Research Assistant, Computer Applications Litcom Division, Litton Industries, Melville, N.Y. 1972 Junior Test Engineer, 1972 EDUCATION ,

Pratt Institute - BEE - 1972 University of Illinois-Graduate Study in Electrical Engineering, 1972-1973 ,

REGISTRATIONS I

l Professional Engineer - New York l

r a

PROFESSIONAL AFFILIATIONS IEE - Member: Power Engineering Society, Computer Society American Nuclear Society - Member Power Division, Nuclear Reactor Safety Division Tau Beta Pi Engineering Honor Society Eta Kappa Nu Electrical Engineering Honor Society PUBLICATIONS Au thor, " Developing and Maintaining Equipment Qualification Programs: A Computer-Aided Approach", TRANSACTIONS of the 1983 ANS Winter Meeting. '

O h