ML20151W878
| ML20151W878 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/10/1986 |
| From: | Bordenick B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Linenberger G, Margulies M, Paris O Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20151W882 | List: |
| References | |
| CON-#186-042, CON-#186-42 OL, NUDOCS 8602120212 | |
| Download: ML20151W878 (1) | |
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UNITED STATES
.F
'1 NUCLEAR REGULATORY COMMISSION
{
wassincrou. o. c. 2osss FEB 10198o
'86 FEB 11 P2:12 OFFICE OF u r 00CitEiwA' hib.,
Morton B. Margulies, Esq., Chairman Mr. Gustave A. LinenbEdMiC,4 Jr. '
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic' Safety and Licensing Board Panel Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Oscar H. Paris Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C..
20555 In the Matter of GEORGIA POWER CO.
(Vogtle Electric Generating Plant, Units 1 and 2)
Docket Nos. 50-424 and 50-425 (OL)
Dear Administrative Judges:
Attached are copies of "NRC Staff's Response to ' Applicants' Motion for Partial Reconsideration of Memorandum and Order Ruling on Motion for Summary Disposition of Contention 10.I'" and " 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.I'".
As to Mr. Masciantonio's Affidavit, he is presently on travel status and was not available to execute the document in question.
Upon his return, the l
Staff will file an executed copy of the Affidavit.
I presently expect this l
will be accomplished at the end of this week or the first part of next week.
Sincerely, M 0^tY l'
Bernard M. Bordenick s
L Counsel for NRC Staff
Enclosures:
As Stated cc:
Service List 8602120212 860210 PDR ADOCK 03000A24 C
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00CMETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'86 FEB 11 P2:12
[0C IN.
F BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD T G BRANCH In the. Matter.of
)
)
GEORGIA POWER COMPANY
)
Docket Nos. 50-424
-~et al.-
)
50-425
)
(OL)
(Vogtle Electric Generating Plant,
)
Units 1 and 2)
)
NRC STAFF'S RESPONSE TO " APPLICANTS' MOTION FOR PARTIAL RECONSIDERATION OF MEMORANDUM AND ORDER RULING ON MOTION FOR SUffMARY DISPOSITION OF CONTENTION 10.1" In a Memorandum an'd Order dated January 23, 1986, the Licensing
~
Board denied Applicants' rnotion for summary disposition of Contention 10.1 and designated six issues for hearing.
Applicants on January 27, 1986, have requested reconsideration of the designation of the fourth of these issues for hearing -- that Applicants have not explicity addressed the polymer applications other than cable jackets and insulation identified by Intervenors.
l For the reasons set.forth in Applicants' January 27, 1986, motion and in the attached Affidavit of Armando Masciantonio, the NRC Staff l
(Staff) fully supports the Applicants' Motion for Partial Reconsideration of the - Licensing Board's January 23, 1986, Memorandum and Order denying l
summary disposition of Contention 10.1.
l In sum, the Staff is of the view that the fourth issue designated l.
for hearing by the Licensing Board is not material to a disposition of 1.
Contention 10.1.
Intervenors have not presented any bases for even
$h0fg D CI vn
suggesting, that there are sigr'.ficant dose-rate effects for any application of Ilypalon, EPR, or Neoprene.
To the contrary, the only information put forth by Intervenors (the Sandia Study, NUREG /CR-2157) clearly
~
demonstrates ' that for the total doses expected at Vogtle the dose-rate effects are insignificant regardless of application.
Further, the only material experiencing discernible dose-rate effects, according to the Sandia Study, which is within the range of relevant total doses expected at Vogtle is XLPO which the Applicants have stated is only found in cable insulation at Vogtle.
Therefore, other applications of the Polymer XLPO have already been addressed by the applicant and were found to be nonexistent at Vogtle.
Staff also agrees with Applicant that, as a practical matter, presenting an analysis of each application of Hypalon, EPR, and Neoprene is a considereble and burdensome task which will not contribute to the resolution of Contention 10.1 by the Licensing Board.
Accordingly, the Staff fully supports Applicants' request that the Board reconsider and eliminate the fourth issue, set out above, as an unresolved issue of material fact.
Respectfully submitted, WL
/
(
Bernard M. Bordenick l
Counsel for NRC Staff Dated ft Bethesda, Maryland thisln4 day of February,1986 i
1 I
i L
3 T
UNITED STATES.OF AMERICA NUCLEAR REGULATORY COMMISSION 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 postuleted 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
. 1 Motion for Summary Disposition of Contentior. 10.1" (Applicants' Motion) which was filed on January 23, 1986.
3.
One of the issues set for hearing in the Licensing Board's Men.orandum 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, Contention 10.1 relates tc 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 -- H ypalon, 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 sa:ety at Vogtle might incur over forty years of normal plant operation.
In the case of Hypalon and EPR, Applicants' motion
~
. i for summary disposition also de.monstrated that the reduction in
- p. p9rties 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 integr&teo 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),
11 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), 11 7-9.
6.
Applicants' motion for summary disposition also stated that Applicants cross-checked the four polymers against their uses at Vogtle, including all applicaitons 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 in the other applications identified by Joint Intervenors -- O-rings, gaskets, and elastic diaphragms.
See id.,
1 30.
Since dose rate effects were not discernible in Hypalon, EPR, t
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
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- 4^-
applications 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 l
degradation, ar 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.
I 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.
Armando Masciantonio Subscribed and sworn to before me this day of February,1986 Notary Public My commission expires:
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