ML20137J345
| ML20137J345 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/26/1985 |
| From: | Garg H Office of Nuclear Reactor Regulation |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20137J349 | List: |
| References | |
| OL, NUDOCS 8508300260 | |
| Download: ML20137J345 (7) | |
Text
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UNITED STATES OF AMERICA 00 M iED NUCLEAR REGULATORY COMMISSION ggac 1
BEFORE THE ATOPIC SAFETY AND LICE'dSING BOARD
'85 AUG 29 A11 :59
~
F In the Ma ter of p[gC i G IP !C.
GEORGIA POWER CO.
Docket Nos. 50-424
--et al.
50-425
)
(0L)
(Vogtle Electric Generating Plant, )
Units 1 and 2)
)
AFFIDAVIT OF HUKAM C. GARG IN SUPPORT OF NRC STAFF RESPONSE TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 10.1 I, Hukam C. Garg, being duly sworn, state the following:
1.
I am employed by the U.S. Nuclear Regulatory Comission as an Electrical Engineer in the Equipment Qualification Branch, Division of Engineering, Office of Nuclear Reactor Regulation.
I am responsible for the technical reviews, analyses and evaluations of the adequacy of the environmental qualification of electric equipment important to safety and l
safety-related mechanical eguipment whose failure under postulated environmental conditions could adversely affect the performance of safety cystems in nuclear power plants, i
Prior to my present position, I was employed by Gilbert /Comonwealth Associates from 1973 - 1980. My most recent position was Supervising Engineer for the Instrumentation and Control Section.
In this position I was responsible for the instrumentation and control aspects, including the equipment qualification for nuclear power plants.
I had previously 8508300260 850826 ADOCK 0 % 4 DR i
1
worked for Fluor Power Inc., formerly Pioneer Service and Engineering Company (1969-1973), in the design of electrical systems for nuclear power plants.
I am-the Staff's technical reviewer for the environmental quali-fication of electrical equipment at the Vogtle plant.
I have knowledge of the matters set forth herein and believe them to be true and correct.
I 2.
This affidavit is submitted in response to Applicants' Motion for Summary Disposition of Joint Intervenors' Contention 10.1.
That contention challenges the adequacy of using high levels of radiation or integrated dose for environmental qualification testing of mechanical and electrical equipment which contain polymers.
3.
I have reviewed the Applicants' Motion and its supporting papers.
I agree with the statements made in the motion and supporting papers, except for the statements made in paragraphs 3 and 11 of
" 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)." I believe those paragraphs require some clarification, as follows.
a)
Paragraph 3 states:
The possibility of radiation dose rate effects has been recognized for at least 15 years. To compensate for such effects, a greater total dose than service lifetime dose is applied to simulate aging due to irradiation.
Industry qualification standards and NRC requirements recognize that aging effects which cannot be adequately accelerated must be accounted for in a qualification program. This includes any effects of dose rate
~
differences between actual and test conditions. However, the NRC has not formally recognized any method by which the effects of different dose rates can be accounted for by increased radiation doses during tests,anS.theStaffdoes.notagreethattheapplicationofagreater than total dose than is anticipated for the service lifetime, in and of itself, is necessarily adequate to resolve this issue, b)
Paragraph 11 states:
Duke Power Company tests of cable in Oconee Nuclear Generating Plant Unit No. 1, have also confirmed the suitability of XLP0-insulated cable for a nuclear environment. Samples of cables, including cables with EPR or XLP0 insulation and Neoprene jacketing, were removed after five and ten years of operation.
In all cases cables were in good condition with no more deterioration than would be observed over a similar period in a non-nuclear environment.
The Statements contained in Paragraph 11, recited above, are correct.
However, the Duke Power Company tests cannot be extrapolated to a forty year service life or for total integrated radiation doses higher than those to which the cables were exposed. Also, Duke Power Company did not compare these results to any test results for similar cables used in a non-nuclear environmen,t.
4.
Nothwithstanding the above clarification of paragraphs 3 and 11 of Applicants' Statement of Material Facts, I believe summary dispo-sition of Contention 10.1 is appropriate, for the following reasons.
5.
10 C.F.R. 950.49 permits accelerated aging for the purpose of i
demonstrating environmental qualification.
It states in part that the qualification program must be based on the type of radiation and total l
dose expected, including dose-rate effects. Also, IEEE Standard l
383-1974, the industry standard for type-testing of Class IE electric
- v cables, endorsed by Regulatory Guide 1.131, allows radiation doses up 6
to 1x10 rads /hr in aging cables.
6.
"The Staff recognizes that some materials deteriorate to a greater degree under long-term doses of radiation than when exposed to the same total dose over a shorter period of time. Because of this known dose-rate effect, material aging data generated at high dose rates are treated cautiously if a low dose-rate application is intended.
In order to account for dose rate effects, the Staff requires applicants for an operating license to develop and implement surveillance and maintenance procedures which will detect age-related degradation and take corrective action before a safety problem develops.
7.
Regulatory Guide 1.33, Revision 2,'" Quality Assurance Program Requirements (Operation)," and the industry standard which it endorses, ANSI N18.7-1976/ANS-3.2, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," contain recommenda-tions for surveillance and maintenance procedures acceptable to the Staff.
i 8.
The Applicants ha've described their method for complying with Regulatory Guide 1.33, Revision 2, in developing the necessary surveil-lance and maintenance procedures for the Vogtle Electric Generating Plant. The Staff has reviewed the Applicants' method and have found it to be acceptable.
9.
The Staff will verify that an appropriate surveillance and maintenance program is developed and implemented at the Vogtle Electric
5-Generating Plant which is intended to specifically address unanticipated age-related degradation of electricU cable insulation.
Summary
- 10. ' Based on the above considerations, I have concluded that there is adequate assurance that any significantly increased deterioration of cable insulation 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. My clarification of paragraphs 3 and 11 of the Appli-cants' Statement of Material Facts, as set forth above, does not alter or affect my conclusion in this regard.
- 11. The above statements are true and correct to the best of my knowledge and belief.
/
hon 2(/
Hukam C.Jiarg
(
Subscribed and sworn to before me this 26th day of August,1985 Notary P6blic My commission expires:
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION oc m tea ushaC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 85 AUG 29 N15.9
~
In the Mat'ter of GEORGIA POWER COMPANY, Docket Nos. 50-42I[0CI[OIGNE b I
--et al.
50-425 BRANCH (0L)
(VogtleElectricGeneratingPlant,)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 10.1 (DOSE RATE EFFECTS)" and Supporting Documents in the above-captioned proceeding have.been served on the folllowing by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 26th' day of August, 1985.
Morton B. Margulies, Esq., Chairman
- Mr. Gustave A. Linenberger, Jr.*
Administrative Judy Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel Panel U.S. Nuclear Regulatory Consnission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Oscar H. Paris
- Bradley Jones, Esq.
Administrative Judge Region 1 Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Panel Suite 3100 U.S. Nuclear Regulatory Commission 101 Marietta Street Washington, D.C.
20555 Atlanta, GA 30303 Bruce W. Churchill, Esq.
Douglas C. Teper David R. Lewis, E:.1 1253 Lenox Circle Shaw, Pittman, Potts & Trowbridge Atlanta, GA 30306 1800 M Street, N.W.
Washington, D.C.
20036 k
Atomic Safety and Licensing Laurie Fowler, Esq.
Board-Panel
- 218 Flora Ave. NE U.S. Nuclear Regulatory Commission Atlanta, GA 30307 Washington, D.C.
20555 Docketing.and Service Section*
Atomic Safety and Licensing Office of-the Secretary -
Appeal Board Panel
- U.S. Nuclear Regulartory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 James E. Joiner, Esq.
Ruble A. Thomas Troutman, Sanders, Lockerman, Southern Company Services, Inc.
& Ashmore P.O. Box 2625 127 Peachtree Street, N.E.
Birmingham, AL 35202 Candler Building, Suite 1400 Atlanta, GA 30043 Tim Johnson Executive Director Campaign for a Prosperous Georgia 175 Trinity Avenue, S.W.
Atlanta, GA 30303 M
/N Bernard M. Bordenick Counsel for NRC Staff O