ML20137W772

Affidavit of a Masciantonio Supporting NRC Response to Util 860123 Motion for Partial Reconsideration of 860123 Memorandum & Order Denying Motion for Summary Disposition of Contention 1

ML20137W772
Person / Time
Site:	Vogtle
Issue date:	02/13/1986
From:	Masciantonio A Office of Nuclear Reactor Regulation
To:
Shared Package
ML20137W763	List: ML20137W758 ML20137W772
References
NUDOCS 8602200341
Download: ML20137W772 (4)

Text

r e 7 00CKETED i USNRC j

• iM FEB 19 Pl2:01 UNITED STATES OF AMERICA 0FFICE OF SEU-NUCLEAR REGULATORY COMMISSION 00CKETINS N Rt' O MANO!

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

)

GEORGIA POWER COMPANY -) Docket Nos. 50-424

-~et al. ) 50-425

) (OL)

(Vogtle Electric Generating Plant, )

Units 1 and 2) )

AFFIDAVIT OF ARMANDO MASCIANTONIO IN SUPPORT OF NRC STAFF'S RESPONSE TO " APPLICANTS' MOTION FOR PARTIAL RECONSIDERATION OF MEMORANDUM AND ORDER RULING ON MOTION FOR

SUMMARY

DISPOSITION OF CONTENTION 10.1"

1. My name is Armando Masciantonio. I am presently employed by the U.S. Nuclear Regulatory Commission as a Mechanical Engineer in the Engineering Branch of PWR-A Division of Licensing , Office of Nuclear Reactor Regulation (NRR). Before the recent NRR reorganization I was employed as an Equipment Qualification Engineer in the Equipment Oualification Branch, Division of Engineering, Office of Nuclear Reactor Regulation . I was responsible for the technical reviews, analyses and evaluations of the adequacy of the environmental qualification of electric equipment important to safety and safety-related mechanical equipment whose failure under postulated environmental conditions could adversely affect the performance of safety systems in nuclear power plants.

2. The purpose of this Affidavit is to respond to " Applicants' Motion for Partial Reconsideration of Memorandum and Order Ruling on 8602200341 860214 PDR ADOCM 05000424 0 pg

1 Motion for Summary Disposition of Contention 10.1" (Applicants' Motion) which was filed on January 23, 1986.

3. One of the issues set for hearing in the Licensing Board's Memorandum and Order dated January 23, 1986, which denied Applicants' motion for summary disposition of Contention 10.1, is that Applicants have not explicitly addressed the polymer applications other than cable jackets and insulation identified by Intervenors.

4. As noted in Applicants' recent motion, Contentic,n 10.1 relates to the significance of dose rate effects in the artificial aging of four specific polymers during environmental qualification. The contention is based on a Sandia Study (NUREG / CR-2157) , and the four polymers addressed in that study are chlorosulfonated polyethylene (Hypalon), ethylene propylene rubber (EPR), chloroprene (Neoprene), and cross-linked polyolefin (XLPO). Applicants in their motion for summary disposition specifically addressed all four polymers in terms of the various polymer applications set forth by Joint Intervenors and the bases for the Intervenors' allegations (the Sandia Study).

5. As further noted in Applicants' motion for reconsideration, for three of these polymers --

Ilypalon , EPR, and Neoprene --

Applicants demonstrated in their motion for summary disposition that the dose-rate effects that had been observed in these polymers were insignificant at and below the maximum total dose that equipment important to safety at Vogtle might incur over forty years of normal plant operation. In the case of flypalon and EPR, Applicants' motion

s

) for s,ummary disposition also demonstrated that the reduction in properties addressed by the Sandia study is virtually the same for all dose rates up to a total integrated dose of 20 megarads. In the case of Neoprene, the reduction is virtually the same up to a total integrated dose of 10 megarads. Applicants have stated that at Vogtle , no equipment important to safety will receive a total integrated dose for forty year normal operation greater than 10 megarads, and most such equipment will receive less than one megarad . Thus, only XLPO exhibited discernible dose-rate effects within the range of relevant total doses. See Affidavit of Joel Kitchens , Victor L. Gonzalez, and Mark L. Mayer (July 30, 1985),

TT 28-29 (Affidavit of Kitchens et. al.); 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)

(July 31, 1985), 15 7-9.

6. Applicants' motion for summary disposition also stated that Applicants cross-checked the four polymers against their uses at Vogtle, including all applications put forth by Joint Intervenors. See Affidavit of Kitchens et. al. ,1 18. XLPO was found only in cable insulation. ,Id., 1 30.

7. XLPO was not found la the other applications identified by Joint Intervenors -- O-rings, gaskets, and clastic diaphragms. See d.,

1 30. Since dose rate effects were not discernible in flypalon, EPR, and Neoprene at and below the maximum total dose that equipment important to safety might incur over forty years of normal plant operation , Applicants' motion states, and I agree, that the

} appliqations of these three polymers were irrelevant. Irrespective of the polymer application, artificial aging of safety-related equipment with these three polymers reasonably simulates normal life degradation, and hence the environmental qualification tests of such equipment are valid.

8. Based on the above considerations, the fourth issue designated for hearing by the Licensing Board is not material. No bases has been presented by Intervenors for suggesting that there are significant dose-rate effects for any application of Hypalon, EPR, or Neoprene.

To the contrary, the only information put forth by Joint Intervenors (the Sandia Study) demonstrates that the effects are insignificant regardless of application.

9. I also agree with Applicants that, as a practical matter, presenting an analysis of each application of Hypalon, EPR, and Neoprene is a considerable and burdensome task which will not contribute to the resolution of the contention in question by the Licensing Board.

.- /~> - ~

c Armando Masciantonio Subscribed and sworn to before me this /3d day of February,1986

$ NotaryekPublic h

My commission expires: 7///f6