ML20137J317

Response Supporting Applicant Motion for Summary Disposition of Joint Intervenors Contention 10.1 Re Dose Rate Effects. Contention Alleges That Environ Qualification Testing Methods Inadequate for Mechanical & Electrical Equipment

ML20137J317
Person / Time
Site:	Vogtle
Issue date:	08/26/1985
From:	Bordenick B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20137J321	List: ML20137J317 ML20137J328 ML20137J338
References
CON-#385-365 OL, NUDOCS 8508300242
Download: ML20137J317 (5)

Text

i 3d w 8/26/85 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 9}$ycED ;

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '85 AUG 29 All ;59

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In the Matter of ) 0FFict 0; stati;..

DGChEDhG & SEvvia GEORGIA POWER CO. 1 Docket Nos. 50-424 e t a_1, . ) 50-425

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(Vogtle Electric Generating Plant, )

Units 1 and 2) )

NRC STAFF RESPONSE TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF CONTENTION 10.1 (DOSE RATE EFFECTS)

I. INTRODUCTION, On July 31, 1985, Applicants filed a Motion for Summary Disposition of Joint Intervenors' Contention 10.1. This contention alleges that Applicants' environmental qualification testing methods are inadequate

.for mechanical and electrical equipment which contain polymers because Applicants only use high levels of radiation or integrated dose which produce less degradation in,those polymers than do lower dose rates duringacceleratedaging.1/ For the reasons presented below and in the

-1/ Contention 10.1 was derived from the Applicant's identification of subissues raised in Contention 10. Contention 10, as originally proffered by Jointed Intervenors, alleged 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 of (F00TN0IE CONTINUED ON NEXT PAGE) 8508300242 850826 4 ADOCK 0500 gDR 1

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is attached Affidavit of Hukam C. Garg, the Staff submits that Applicants' .

Motion should be granted.

~ II. LEGAL STAkDARDS GOVERNING

SUMMARY

DISPOSITION The Staff previously set forth the applicable legal standards governing motions for summary disposition in its July 26, 1985 " Response to Applicants' Motion for Summary Disposition of Contention 10.3 (Cables in Multiconductor Configurations)" (at pp. 1-3). In order to avoid unnecessary repetition, that discussion is incorporated by reference herein.

III. APPLICANTS' MOTION A. Background In an Order dated September 5, 1984, 2_/ the Board admitted Joint l Intervenors' Subcontention 10.1 which alleged that Applicant's testing

! methods are inadequate to qualify equipment containing polymers (as identified in the Sandia study report, NUREG/CR-2157) "because the (F0OTNOTE CONTINUED FROM PREVIOUS PAGE) the plant as required by General Design Criteria 1, 2 and 4 of 10 CFR 50, Appendix A and other applicable NRC rules.

l As admitted by the Board, the contention was restricted to four l

polymers identified in a study conducted by Sandia Laboratory.

i NUREG/CR-2157, at 23-24. The full name of the report is "Jccurrence I

and Implications of Radiation Dose-Rate Effects for Material Aging Studies" (June 18,1981).

-2/ Memorandum and Order on Special Prehearing Conference Held Pursuant to 10 C.F.R. 9 2.715(a).

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a 3-Applicants only use high levels of radiation or integrated dose."

LBP-84-35,"20 NRC 887, 903 (1984). For the reasons presented below, this contention does not raise a genuine issue of fact nor does the issue presented by the contention constitute a problem for the safe .

operation of the Vogtle facility. Accordingly, the Staff supports Applicants' Motion for Summary Disposition of Contention 10.1.

B. Staff's Basis for Grant of Motion TFe Staff supports Applicants' motion for summary disposition for the reasons set out below. 3/

Contention 10.1 is founded upon the belief that some polymer materials used in electrical equipment identified in Sandia study report NUREG/CR-2157 deteriorate to a greater degree under long-term doses thanwhenexposedtothesametotaldoseoverashorterperiodoftime.S/

The Staff recognizes that some polymer materials deteriorate to a greater degree under long-term doses of radiation than when exposed to the same total doses over a shorter period of time. Garg Affidavit at 16.

These dose rate effects are set out at pp. 10-15 of the Affidavit of 3/ As noted in Paragraphs 3 and 4 of the attached " Affidavit of Hukam ,

C. Garg in Support of NRC Staff Response to Applicants' Motion for Summary Disposition of Contention 10.1," the Staff believes that the statements made in Paragraphs 3 and 11 of the " Applicants' Statement of Material Facts As to Which There is No Genuine Issue to be Heard Regarding Joint Intervenors' Contention 10.1 (Dose Rate Effects)"

require some clarification. However, as set out in Mr. Garg's Affidavit, the Staff nonetheless believes that Contention 10.1 1 does not raise any genuine issue of material fact.

4/ See Memorandum and Order, supra at 903.

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a Kitchens, et al. attach ~ed to Applicants' motion. Id. To account for these dose rate effects, the Staff requires operating license applicants to develop and implement surveillance and maintenance procedures to detect age.-related degradation and take corrective action before a

safety problem develops. Id.

Regulatory Guide 1.33, Revision 2 " Quality Assurance Program Requirements (Operation)" contains recommended surveillance and main-tenance procedures. Id. at 17. Applicants have submitted their method for complying with this guidance, which the Staff has reviewed and found to be acceptable. Id. at 18. The Staff will verify that an appropriate surveillance and maintenance program is developed and implemented at Vogtle to specifically address unanticipated age-related degradation of electrical cable insulation using polymer materials. Id. at 19. Based on these considerations, the Staff has concluded that there is adequate assurance that any significantly increased deterioration of cable insu-lation due to the expected lower radiation dose rate will be discovered, if any occurs, and will not cause an unsafe condition to occur at Vogtle.

Id. at 110.

In previously granting' summary disposition on Contention 10.3 (cable in multi-cable configurations), the Licensing Board relied upon the Staff's intent to conduct a review to see that only tested and approved materials would be used in multiconductor cables at Vogtle. Memorandum and Order dated August 21, 1985, at 6-7. Here, too, the Board may rely on the Staff's verification that the Applicants develop and implement a surveillance and maintenance program at Vogtle to address any age-related degradation with regard to polymers in electrical equipment. The Joint l

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Intervenors have not indicated any reason to believe that the Applicants'

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surveillance and maintenance program will be inadequate and, accordingly, there is no genuine issue as to any material fact with regard to this matter. 5/

IV. CONCLUSION For the reasons presented above and in the attached Affidavit of Hukam C. Garg, the Staff submits that the Joint Intervenors have raised no genuine issue of fact as regards Contention 10.1. The Staff therefore submits that the Motion for Summary Disposition of Contention 10.1 should be granted.

Respectfully submitted, hY W/$

Bernard M. Bordenick Counsel for NRC Staff Dated at Bethesda, Maryland this 26th day of August, 1985

-5/ The Staff recognizes that our basis for supporting the grant of summary disposition of this contention differs from that of the Applicants. Accordingly, the Staff would not oppose the grant of ten days' time to any parties opposing the motion for summary disposition, in which to reply to new matters set forth in this response, pursuant to 10 C.F.R. Q 2.749(a).

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