ML20134L694

Response Supporting Applicant 850718 Motion for Summary Disposition of Joint Intervenors Contention 10.7 Re Environ Qualification of Hydrogen Recombiners.Response Supported by Encl Affidavits of Hd Garg & C Li

ML20134L694
Person / Time
Site:	Vogtle
Issue date:	08/30/1985
From:	Dewey L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20134L697	List: ML20134L694 ML20134L715 ML20134L732
References
CON-#385-378 OL, NUDOCS 8509030382
Download: ML20134L694 (5)

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8/30/85

1. $79,ED UNITED STA1ES OF AMERICA NUCLEAR REGULATORY COMMISSION +85 M 30 Alf ;55 '

BEFORE THE ATOMIC SAFETY AND LICENSING BOARDr"rj _, .,,

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In the Matter of -

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

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(Vogtle Electric Generating Plant, )

Units 1 and 2) )

STAFF'S RESPONSE TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF JOINT INTERVENORS' CONTENTION 10.7 (HYDROGEN REC 0MBINERS)

I. INTRODUCTION By Motion dated July 18, 1985, Applicants have moved, pursuant to 10 CFR $ 2.749, for summary disposition of Jojnt Intervenors' Conten-tion 10.7 relating to the environmental qualification of hydrogen recombiners. Staff supports this motion on grounds that Applicants have demonstrated the absence of any issue of material fact regarding this issue, and that they are therefore entitled to a favorable decision as a matter of law.

In support of our response, Staff relies upon the Affidavits, l submitted herewith, of Hukam D. Garg and Chang-Yang Lt. In order to avoid unnecessary repetition. Staff's discussion in its July 26, 1985 response to Applicants' motion for sumrrary disposition of Joint Inter-l venors' Contention 10.3 concerning the legal principles governing summary disposition is incorporated by reference herein.

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, II. BACKGROUND As originally submitted, Joint Intervenors' Contention 10.7 stated that: -

Applicant has not shown that safety-related electrical and mechanical equipment and components will be environmentally qualified at the onset of operations and throughout the life l of the plant as required by General Design Criteria 1, 2 and

( 4 of 10 C.F.R. 50, Appendix A and other applicable NRC l rules.

The parties later agreed to the breakdown of the contention into eleven subcontentions. That portion concerning the environmental qualification of hydrogen recombiners was designated as Contention 10.7. See Georgia Power Co. (Vogtle Units 1 & 2), LBP-84-35, 20 NRC 887, 903, 905 (1984).

Joint Intervenors' main concerns in Contention 10.7 are that: (1)a hydrogen recombiner manufactured by Rockwell , International had pressure transducers that failed certain environmental tests and (2) that the i

Westinghouse hydrogen recombiners used at Vogtle had not been tested for the effects of radiation. Gane and CPG April 11, 1984 Supplements at 24.

In opposition to this contention, the Applicants responded that Vogtle l will not use Rockwell International hydrogen recombiners (May 7,1984 Response at 69) and that its Westinghouse hydrogen recombiners did not have pressure transducers (June 27, 1984 Ramsey Affidavit at i 6).

Centention 10.7 was admitted by the Board in its Order of September 5, 1984. Supra, 20 NRC at 905. The Board conceded that the information provided by Applicants may have rendered portions of this

! contention moot. However, it held that the following further inquiry is necessary:

Are there any types of transducers or sensors important to the proper functioning of the Vogtle electric-type

. I hydrogen recombiner in an accident environment that require environmental qualification testing in an accident environ- -:

ment; if so, what testing is planned or completed and with what results?

If environmental qualification testing in an accident environment of an entire prototype recombiner is not required, what is the basis for this conclusion? If such testing is planned or has been completed, what is the nature of the test and what criteria exist for assessing the adequacy of the test results?

_Id. at 906.

On July 18, 1985 the Applicants filed their present motion, supported by affidavits of Glenn H. Stolz and Richard 8. Miller, requesting summary disposition of Contention 10.7.

i III. DISCUSSION To ensure hydrogen concentration inside' containment remains at low levels follcwing a design basis accident, each Vogtle unit will utilize two 'Astinghouse Model 8 electric hydrogen recombiner systems. These systems consist of a recombination unit located inside of containment and a power supply panel and a control panel outside of containment. Yi Affidavit at 1 3.

Unlike the Rockwell International hydrogen recombiners cited by Joint Intervenors Westinghouse Model 8 hydrogen recombiners are not equipped with any transducers or sensors located in a harsh environment inside containment. Id. The Wettinghouse recombiners are manually actuated in accordance with emergency operating procedures. M. Sensors and transNcers are not required for hydrogen monitoring inside contain-ment since the Vogtle hydrogen monitoring system is located outside t

containment and receives samples by a piping system through the wall of the containment building. I_d. at 1 4 Environmental qualification of the Vogtle hydrogen recombiners has been established by various tests performed by Westinghouse for Model A and B recombiners. Garg Affidavit at 11 5-6. Westinghouse's Model A environmental testing previously has been approved by Staff on several occasions. Id. at 1 5. The Model B test program environmentally quali-fies those features of Model B which differ from Model A. Ld. a t 6.

NRC regulations allow testing of similar equipment to show that the equipment to be qualified is acceptable. See 10 CFR 50.49(f). Staff's recent review of the Model B program establishes that the differences between Model A and Model 8 are minor, and that those features of Model B which differ from Model A have been adequately environmentally qualified.

Garg Affidavit at 16.

IV. CONCLUSION In sumary, the information outlined above, submitted in response to the Board's inquiry, establishes that: (1) unlike the Rockwell International recombiners upon which Intervenors rely for their conten-tion, there are no transducers or sensors located in an accident environment in the Vogtle containment which are important to the proper functioning of the Vogtle hydrogen recombiners; and (2) there are no open issues regarding the environmental qualification of the Vogtle hydrogen recombiners since this qualification has already been performed by Westinghouse and been approved by the NRC Staff.

. Under these circumstances, there is no dispute as to any material fact concerning Joint Intervenors' Contention 10.7 and Applicants' motion i for summary disposition should be granted.

Respectfully submitted, Lee Scott Dewey Counsel for NRC Staff Dated at Bethesda, Maryland this 30** day of August,1985 l

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