ML20128E522

Statement of Matl Facts as to Which There Is No Genuine Issue Re Joint Intervenors Contention 10.3 Re Cable in Multiconductor Configuration.Certificate of Svc Encl

ML20128E522
Person / Time
Site:	Vogtle
Issue date:	07/01/1985
From:	Joiner J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20128E517	List: ML20128E513 ML20128E522 ML20128E528
References
OL, NUDOCS 8507050362
Download: ML20128E522 (8)

Text

o s 00(.KETED USNRC July 1, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g ggg y 03C1LThGh_[ph,Q

' RANcy 3

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In.the Matter.of )

)

GEORGIA POWER COMPANY, et al. ) Docket Nos. 50-424GL

) 50-425eL (Vogtle Electric Generating )

Plant, Units 1 and 2) )

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH NO GENUINE ISSUE EXISTS TO BE '

HEARD REGARDING CONTENTION 10.3 '

(CABLE IN MULTICONDUCTOR CONFIGURATION)

Pursuant to 10 C.F.R. S 2.749(a), Applicants submit in support of Applicants' Motion for Summary Disposition of Joint Intervenors' Contention 10.3 that no genuine issue exists to be heard with respect to the following material facts:

1. Joint Intervenors' Contention 10.3 challenges the environmental qualification of multiconductor cable used at the Vogtle Electric Generating Plant ("VEGP") based upon the results of testing performed by Sandia National Laboratories ("Sandia").

2. In the nuclear industry, single conductor config-urations have commonly been used in tests performed to establish the environmental qualification of multiconduc-tor cables. Because a multiconductor cable generally has 8507050362 850701 PDR ADOCK 05000424 G PDR

4 jacketing material or additional insulation or both sur-rounding the insulated single conductors that comprise it, which should provide additional protection from adverse environmental conditions not available to a single conduc-tor, performing qualification testing on a single conduc-

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tor taken from a sample of the particular~ multiconductor under scrutiny is considered to be a more conservative methodology than testing the multiconductor itself. Affi-davit of Joel Kitchens (" Kitchens Affidavit") at T 3.

3. Regulatory Guide 1.131 endorses IEEE Standard 383-1974, which in Table 1 specifically authorizes the use of single conductor configurations in type testing for qualification purposes of multiconductor cables. Regula-tory Guide 1.131, " Qualification Tests of Electrical Cables, Field Splices, and Connections for Light-Water-Cooled Nuclear Power Plants"; IEEE Standard 333-1974, "IEEE Standard for Type Testing of Class IE Electric Cables, Field Splices, and Connections for Nuclear power Generating Stations"; Kitchens Affidavit at T 3.

4. Sandia has conducted two studies in which the performance of multiconductor cable configurations under i

loss-of-coolant accident ("LOCA") conditions was compared to that of single conductor configurations obtained by dissassembling samples of the multiconductor cables. The first study was reported in L. D. Bustard, The Effect of I

i j

LOCA Simulation Procedures on Ethylene-Propylene Rubber's Mechanical and Electrical Properties, SAND 83-1258, NUREG/CR-3538, October 1983 ("the first Sandia report"),

and the second study in L. D. Bustard, The Effect of LOCA Simulation Procedures on Cross-Linked Polyolefin Cable's Performance, SAND 83-24'06, NUREG/CR-3588, April 1984 ("the second Sandia report"). Kitchens Affidavit at TT 4, 9.

5. In the first study, Sandia subjected five types of commercially available multiconductor cables to simu-lated LOCA conditions. Id. at T 4. With one exception, all five of the multiconductor cable products tested had chlorosulfonated polyethylene (CSPE) (also known as Hypa-lon) outer jackets. The one exception was a three conduc-tor cable manufactured by Anaconda Wire and Cable Company that had EPR insulation on the individual conductors and an outer thermoplastic jacket of chlorinated polyethylene (CPE). Id. at T 5.

6. Only the multiconductor cable having a thermo-plastic chlorinated polyethylene outer jacket suffered greater degradation in a multiconductor configuration than in a single conductor configuration. Id. at T 6.

7. The Sandia researchers surmised that the greater degradation shown by the multiconductor cable having a CPE outer jacket resulted from an interaction between that jacket and the EPR insulation around each of the single conductors comprising the multiconductor cable. Id. at i

1 7.

8. One of the chief purposes of the second Sandia study was to test experimentally whether qualification testing of single conductors was more severe to, equal to, or less severe than testing of multiconductor cables. Id.

at T ll.

9. In that study three commercially ava'il'able multi-conductor cable assemblies were subjected to simulated LOCA conditions. All three of the multiconductor cable products had cross-linked polyethylene insulation and thermosetting Hypalon or Neoprene outer jackets. Similar to the prior study, for two of the cable products tested the tests were performed both on the multiconductor cable products and on single conductors obtained by disassembl-ing samples of the multiconductor cables. Id. at T 10.

10. With respect to the two cable products tested in both multiconductor and single conductor configurations in the second Sandia study, the electrical properties retained by those cable products following exposure to simulated LOCA conditions "did not depend on whether sin-gle conductor or multiconductor testing was performed."

Id. at T 11.

11. Of the eight multiconductor cable products tested in both Sandia studies, only the multiconductor cable manufactured by Anaconda Wire and Cable Company that had conductors with EpR insulation and a thermoplastic CpE outer jacket suffered greater degradation in a multicon-ductor configuration. Id. at T 12.

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12. None of the multiconductors tested that had ,

Hypal'on or Neoprene outer jackets, including two ot'her

• l multiconductor cables manufactured by Anaconda, suffered greater degradation in a multiconductor configuration.

Id. at TT 12-13.

On'ly cables having a thermoplastic CPE jacket are 13.

likely to suffer greater degradati6n when tested in a

'J multiconductor' configuration rather than in a single conductor configuration. Id. at 13.

14. The Applicants have not used any multicond'uctor cable at VEGP having a thermoplastic CPE jacket. Id.

15. All electrical cable utilized at VEGP has either a chlorosulfonated polyethylene (Hypalon) or a polychloro-prene (Neoprene), outer jacket. Id.

16. Multibonductor cable products having outer jackets of these materials were tested in the Sandia studies and showed no greater degradation following expo-sure to simulated LOCA conditions when tested in a multi-conductor configuration than when tested in the correspon-

/

ding single conductor configuration. Id. at 11 5, 10, 13.

17, . The use of single conductor samples in the quali-fication testing of the multiconductor cable products used at VEGP is adequate to establish the environmental quali-fication of those multiconductors.

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Respectfully submitted, d}FI#I * .d Qdmed E. Joineg g P.C.

Cnaries W. Whikey Kevin C. Greene Hugh M. Davenport TROUTMAN, SANDERS,.LOCKERMAN ,

& ASHMORE George F. Trowbridge, P.C.

Bruce W. Churchill, P.C.

David R. Lewis SHAW, PITTMAN, POTTS

& TROWBRIDGE Counsel for Applicants Dated: July 1, 1985

e g

03LMETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g R -3 AfD 16 0FffCE OF SEtst:A: -

BEFORE THE ATOMIC SAFETY AND LICENSING BOARffMETING & SERvil;~

BRANCH In the Matter of  :

GEORGIA POWER COMPANY, et al.  : Docket Nos. 50-424 l

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

CERTIFICATE OF SERVICE I hereby certify.that copies of Applicants' Statement of Material Facts As To Which No Genuine Issue Exists To Be Heard Regarding Contention 10.3, dated July 1, 1985 were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, or where indicated by an asterisk (*) by hand delivery, this 1st day of July, 1985.

/

';1')./)

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hNY J4mjas E. Joiner /

AtWrney for Aphlicants Dated: July 1, 1985

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

). . .

GEORGIA POWER COMPANY, et hl.

) Docket Nos. 50-424

)

50-425 (Vogtle Electric Generating Plant, )

Units 1 and 2) )

SERVICE LIST Morton B. Margulies, Chairman

• Douglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle U. S. Nuclear Regulatory Commission Atlanta, Georgia 30306 Washington, D. C. 20555

• Laurie Fowler Mr. Gustave A. Linenberger Legal Environmental Assistance Atomic Safety and Licensing Board

• Foundation U. S. Nuclear Regulatory Commission 218 Flora Avenue, N. E.

Washington, D. C. 20555 Atlanta, Georgia 30307 Dr. Oscar H. Paris

• Tim Johnson Atomic Safety and Licensing Board Campaign for a Prosperous Georgia U. S. Nuclear Regulatory Commission 175 Trinity Avenue, S. W.

Washington, D. C. 20555 Atlanta, Georgia 30303 Bernard M. Bordenick, Esquire Docketing and Service Section Office of Executive Legal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C. 20555 Atomic Safety and Licensing Board Panel Bradley Jones, Esquire U. S. Nuclear Regulatory Commission Regional Counsel Washington, D. C. 20555 U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Suite 3100 Appeal Board Panel 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D. C. 20555