ML20203A013
| ML20203A013 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/14/1986 |
| From: | Churchill B, Joiner J GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE, TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20203A011 | List: |
| References | |
| OL, NUDOCS 8604160207 | |
| Download: ML20203A013 (97) | |
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UNITED STATES OF AMERI C
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NUCLEAR REGULATORY COMMIS BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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)
GEORGIA POWER COMPANY, et al.
)
Docket Nos. 50-424 (OL)
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)
50-425 (OL)
(Vogtle Electric Generating Plant, )
Units 1 and 2)
)
APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON TECHNICAL AND ENVIRONMENTAL CONTENTIONS Bruce W.
Churchill, P.C.
David R.
Lewis SHAW, PITTMAN, POTTS &
TROWBRIDGE James E.
Joiner, P.C.
Charles W. Whitney Kevin C. Greene Hugh M. Davenport TROUTMAN, SANDERS, LOCKERMAN April 14, 1986
& ASHMORE kR R
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6 TABLE OF CONTENTS INTRODUCTION.................................................
1 PROPOSED FINDINGS OF FACT....................................
2 I.
Jurisdiction and Parties...........................
2 4
II.
Contention 7 (Ground-water)........................
9 A.
Adequacy of Geological /
Hydrological Exploration.....................
12 B.
Data on Marl Thickness, Permeability, and Continuity.................
21 C.
Direction of Ground-water Flow...............
29 D.
Ground-water Travel Time.....................
31 E.
Mr. Lawless' Testimony.......................
34 F.
Conclusion...................................
38 III. Contention 10.1...................................
39 A.
Evaluation of Electrical Insulation Property..........................
43 B.
The Significance of Duke Power Company's Cable Surveillance Program......................................
46 i
C.
The Scope and Results of the Mechanical Stress Tests on Prototype VEGP Cables........................
48 D.
Applicants' Maintenance and Surveillance Frogram.........................
49 E.
The Significance of Applicants' Maintenance and Surveillance Program...................................... 55
-i-i
o IV.
Contention 10.5...................................
55 A.
The Use of ASCO Solenoid Valves at VEGP......................................
56 l
B.
Environmental Qualification Test-ing Performed on the ASCO Solenoid Valves Used at VEGP..........................
57 1.
The Joint Westinghouse and ASCO Environmental Qualifi-cation Testing Program..................
57 2.
Environmental Qualification Testing Performed on Behalf of ASCO by Isomedix, Inc................
63 3.
The Franklin Research Center Testing Program.........................
66 C.
The ASCO Solenoid Valves Used in Safety-Related Applications at VEGP are Environmentally Qualified for Use in the Environmental Conditions to Which They Might be Exposed at VEGP..........
73 1.
The Environmental Conditions at VEGP.................................
73 (a)
Inside Containment.................
73 (b)
Outside Containment (Except the MSIV Areas)....................
73 (c)
MSIV Areas.........................
74 2.
The Model NP 8316 Valve is Environ-mentally Qualified for Use at VEGP......
75 3.
The Model NP 8321 Valve is Environ-mentally Qualified for Use-at VEGP......
76 4.
The Model NP 8320 Valve is Environ-mentally Qualified for Use at VEGP..'....
77 5.
The Model 206-381-6RF Valve is Environ-mentally Qualified for Use at VEGP......
78 D.
The Applicants Have Adequately Addressed the Five Specific Issues Designated for Hearing in the Licensing Board's January 7, 1986 Memorandum and Order....................
79 1.
Can Any Type of Failure of an ASCO Solenoid Valve Result in the L
Associated Process Valve or Damper
{
Reaching an Unsafe Configuration?....... 80 2.
Operability of ASCO Solenoid Valves Following a Design Basis Event..........
81 3.
The Unsealed Solenoid Housing on the Model NP 8316 Valve Tested by Westinghouse /ASCO.......................
83 4.
ASCO's Specifications for Acceptable l
Operating Voltage Ranges, Air Supply Requirements, and Acceptable Leakage Rates...................................
84 (a)
Operating Voltage Ranges...........
84 (b)
Air Supply.........................
85 (c)
Seat Leakage.......................
86 (d)
Leakage Shown by the Model NP 8321 Valve Tested by. Franklin...... 87 5.
Could Production Models of the Valves Show Different Performance Characteristics Than the Valves Tested?.................................
88 E.
The Testimony Presented by the Inter-venors Does not Call Into Question the Environmental Qualification of ASCO Solenoid Valves for Use at VEGP..............
91 F.
Conclusion...................................
93 V.
Proposed Conclusions of Law.......................
93
-lii-
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T p
p April 14 1986
-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD f
I t
In the Matter of
)
)
4 GEORGIA POWER COMPANY. et al.
)
Docket Nos. 50-424 (OL)
)
50-425 (OL)
(Vogtle Electric Generating Plant, )
3 Units 1 and 2)
)
APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON TECHNICAL AND ENVIRONMENTAL CONTENTIONS INTRODUCTION In accordance with 10 C.F.R.
$ 2.754 and the_ Atomic Safety and Licensing Board's directive (Tr. 324), Applicants submit their proposed findings of fact and conclusions of law on the three technical and environmental contentions remaining at issue in this operating license proceeding.
The three conten-tions are: (1) Contention 7 (Ground-water); (2) Contention-10.1 (Dose-Rate Effects); and (3) Contention 10.5 (ASCO Solenoid 1
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Valves).
These contentions have now been fully litigated, and based on the record, should be resolved in Applicants' favor.
All other technical and environmental contentions placed in issue have been resolved in Applicants' favor by summary disposition.
Only off-site emergency planning issues remain to be addressed.
Applicants therefore propose that the Board make the following findings of fact and conclusions of law in a par-tial initial decisio'n which will be dispositive of all matters other than remaining off-site emergency planning contentions.
PROPOSED FINDINGS OF FACT I.
Jurisdiction and Parties 1.
This initial decision involves the application filed in September, 1983, by Georgia Power Company, Oglethorpe Power Corporation, the Municipal Electric Authority of Georgia, and the City of Dalton (" Applicants"), for licenses to operate the Vogtle Electric Generating Plant, Units 1 and 2.
48 Fed. Reg.
46,670 (1983) (Receipt of Application for Facility Operating License).
The Vogtle Electric Generating Plant ("VEGP"), Units 1 and 2, comprises two pressurized water nuclear reactors lo-cated in Burke County, Georgia, 26 air miles south southeast of Augusta and 15 air miles east northeast of Waynesboro.
Each unit is designed to operate at a steady-state pcwer level of.
3411 megawatts thermal, with an equivalent net electrical out-put of approximately 1160 megawatts.
Id.; 48 Fed. Reg. 57,183 (1983).
2.
On December 28, 1983, the Nuclear Regulatory Commis-sion (NRC) published a Federal Register Notice of Opportunity for Hearing.
48 Fed. Reg. 57,183 (1983).. Petitions for leave to intervene and requests for hearing were subsequently filed by Campaign for a Prosperous Georgia (CPG), Georgians Against Nuclear Energy (GANE) and Coastal Citizens for a Clean Environ-ment (CCCE), and the Consumers' Utility Counsel of Georgia.
Accordingly, on January 31, 1984, this Atomic Safety and Li-censing Board was established to rule on the petitions to in-tervene and preside over the proceeding in the event a hearing was ordered.
49 Fed. Reg. 4,570 (1984).
3.
On February 20, 1984, the Consumers' Utility Counsel withdrew his petition for leave to intervene, and by Memorandum and Order dated March 9, 1984, the Licensing Board ruled that CCCE had not demonstrated the necessary interest to establish standing to intervene.
On April 11, 1984, the remaining two intervenors, CPG and GANE, submitted proposed contentions, most of which were identical.
CPG and GANE were subsequently con-solidated as Joint Intervenors.
Memorandum and Order dated November 5, 1984.
4.
On May 30, 1984, the Board conducted a prehearing conference to address proposed contentions.
Thereafter, by.
- Memorandum and Order dated September 5, 1984, the Board admit-ted for adjudication nine contentions.
LBP-84-35, 20 N.R.C.
887 (1984).1/
The admitted contentions were Contention 7 (ad-dressing whether Applicants have assured that an accidental spill of radioactive water onsite would not result in contami-nation of the aquifers underlying the site): Contention 8 (ad-dressing the adequacy of certain aspects of Applicants' quality assurance program); ' Contention 10.1 (addressing whether dose-rate effects observed in four polymers evaluated in NUREG/
CR-2157 were adequately considered in the environmental quali-fication of safety-related equipment containing these poly-mers); Contention 10.3 (addressing whether the environmental qualification of single conductor cables is representative of multiconductor performance); Contention 10.5 (addressing wheth-er ASCO solenoid valves have been environmentally qualified);
Contention 10.7 (addressing whether the VEGP hydrogen recom-biners have transducers or sensors that need to be qualified and whether the recombiners have been qualified as a unit);
Contention 11 (addressing the relevance of vibration-induced l
fatigue cracking and bubble collapse water hammer to the VEGP steam generators); Contention 12 (addressing certain emissions 1/
By Memorandum and Order dated November 12, 1985, the Board admitted a number of contentions relating to off-site emergency s
planning.
Motions for summary disposition of these contentions are pending, and hearings have not yet been held on these issues.
1 i
a a
from cooling towers); and Contention 14 (addressing the adequa-cy of the VEGP diesel generators).
Id.
5.
Extensive discovery was permitted and lasted until June, 1985.
Applicants then moved for summary disposition of each of the admitted contentions, and were supported by the NRC Staff.
Joint Intervenors responded only to the motions per-taining to Contentions 7 and 8.
Upon consideration of the mo-tions, responses, an'd all relevant filings in this proceeding, the Board granted summary disposition of Contentions 8, 10.3, 10.7, 11, 12, and 14, resolving these contentions in Appli-cants' favor.2/
6.
With respect to Contentions 7, 10.1 and 10.5, the Board granted in part and denied in part Applicants' motions for summary disposition.
In each case, the Board identified particular aspects which were designated as the issues to be litigated at hearing.3/
2/
Memorandum and Order (Ruling on Summary Disposition.of Contention 10.3 -- Cable in Multiconductor Configurations),
dated August 21, 1985; Memorandum and Order (Ruling on Motion for Summary Disposition of Contention 11 re Steam Generators),
dated September 3, 1985; Memorandum and order (Ruling,on Motion for Summary Disposition of Contention 8 re Vogtle Quality As-surance), dated October 3, 1985, reconsideration denied, Memo-randum and Order dated December 3, 1985; Memorandum and Order (Ruling on Motion for Summary Disposition of Contention 10.7 re Hydrogen Recombiners), dated November 5, 1985; Memorandum and Order (Ruling Upon Motion for Summary Disposition of Contention 14 re TDI Emergency Diesel Generators, dated November 25, 1985; and Memorandum and Order (Ruling on Motion for Summary Disposi-tion of Joint Intervenors' Contention 12 -- Cooling Tower Drift), dated December 24, 1985.
3/
Memorandum and Order (Ruling on Motion for Summary Dispo-sition of Contention 7 re: Groundwater Contamination), dated (Continued Next Page) -
7.
By-Orders dated January 14, 1986 and January 23, 1986, the hearing on Contentions 7, 10.1 and 10.5 was scheduled to commence on March 11, 1986, and the prefiling of testimony was directed.
A notice of hearing was published in the Federal Register.
51 Fed. Reg. 4,548 (1986).
In response to the Board's Orders, Applicants prefiled Applicants' Testimony of Thomas W.
Crosby, Clifford R.
Farrell, and Lewis R. West on Contention 7 (Ground-water) (hereinafter cited as " Crosby et al.,
ff. Tr. 253"); Applicants' Testimony of Dr. Stavros S.
Papadopulos on Contention 7 (Ground-water) (hereinafter " Papa-depulos, ff. Tr. 253"); Applicants' Testimony of Joel Kitchens, j
Mark L. Mayer, Patrick R. Nau, and Harold J. Quasny on Conten-tion 10.1 (Dose-Rate Effects) (hereinafter " Kitchens et al.,
ff. Tr. 561"); Applicants' Testimony of George Bockhold, Jr.,
i l
and Marold J. Quasny on Contention 10.1 (Dose-Rate Effects)
(hereinafter "Bockhold et al.,
ff. Tr. 561"); and Applicants' Testimony of George J. Baenteli,-George Bockhold, Jr.,
Stephen J. Cereghino, William V.
Cesarski' and Harold J. Quaany
{
on Contention 10.5 (ASCO Solenoid Valves) (hereinafter
)
(Continued)
)
November 13, 1985, reconsideration denied, Memorandum and Order dated January 6, 19,86; Memorandum and Order (Ruling on Motion I
[
for Summary Disposition of Contention 10.5 re ASCO Solenoid i
7alves), dated January 7, 1986; Memorandum and Order (Ruling on Motion for Summary Disposition'of Contention 10.1 re Dose Rate j
Effects), dated January 23, 1986, partial reconsideration granted, Memorandum and Order dated February 14, 1986.
i l
1 l
4 ;
"Baenteli et al., ff. Tr. 517").
The NRC Staff prefiled the NRC Staff Testimony of Lyman W. Heller and Raymond Gonzales on Contention 7 (Ground-water Contamination) (hereinafter " Heller et al.,
ff. Tr. 764"); NRC Staff Testimony of Armando Mascian-tonio on Joint Intervenors' Contention 10.1 (Dose-Rate Effects)
(hereinafter "Masciantonio on 10.1, ff. Tr. 576"); and NRC Staff Testimony of Armando Masciantonio on Joint Intervenors' Contention 10.5 (ASC'O Solenoid Valves) (hereinafter "Mascian-tonio on 10.5, ff. Tr. 550").
Joint Intervenors filed untitled testimony of Howard Deutsch (hereinafter "Deutsch, ff. Tr.
371") and "Intervenors' Testimony Before the Atomic Safety and Licensing Board March 11, 1986: Contention 7, Groundwater Con-i tamination" (hereinafter " Lawless, ff. Tr. 720").
Joint Inter-venors also filed a document entitled " Analysis of the Atomic Safety and Licensing Board's November 12, 1985 Memorandum and Order (Ruling on Motion for Summary Disposition of Contention 7 re: Groundwater Contamination," dated December 15, 1985 and designated as an attachment to the Lawless testimony (herein-after referred to as " Lawless Attachment, ff. Tr. 720").4/
Joint Intervenors filed no testimony on Contention 10.1.
8.
An evidentiary hearing on Contentions 7, 10.1 and 10.5 was conducted from March 11 to March 14, 1986.
At the 4/
See Tr.-712-18, ruling on Applicants' motion to strike and designating those portions of Mr. Lawless' testimony that were admissible.
o -
i l
l outset of the hearing, CPG withdrew from the proceeding.
Tr.
240, 246-47.
GANE remained an intervenor and litigated Conten-tions 7 and 10.5.
GANE offered no testimony on Contention 10.1 l
and conducted no cross-examination on this contention.
Accord-l ingly, with respect to Contention 10.1, GANE failed to fulfill its burden as an intervenor of going forward with evidence, ei-ther by direct testimony or by cross-examination.
Consumers Power Co. (Midland Plant, Units 1 and 2), ALAB-123, 6 A.E.C. 331, 345 (1973); Louisiana Power and Light Co. (Waterford Steam Electric Station, Unit 3), ALAB-732, 17 N.R.C.
1076, 1093 (1983).
9.
At the conclusion of the hearing, the Board directed that all parties file proposed findings of fact and conclusions of law according to the schedule set forth in 10 C.F.R. 5 2.754.
Tr. 824.
Upon consideration of the proposed findings that were submitted and of the entire record, the Board makes the following findings resolving Contentions 7, 10.1 and 10.5 in Applicants' favor.
All proposed findings of fact and con-clusions of law submitted by the parties that are not incorpo-rated directly or inferentially in this initial decision are rejected as unsupported in law or fact or as unnecessary to the rendering of the decision.
This initial decision terminates the Board's jurisdiction over these contentions and all matters other than off-site emergency planning.
.s.
II.
Contention 7 (Ground-water) 10.
To understand the context of Contention 7, a brief description of the VEGP geology and hydrology is necessary.
Plant Vogtle is located on the Coastal Plain of Georgia.
The plain is underlain by a sequence of sedimentary formations l
which have been deposited atop a basement complex of older sed-imentary, crystalline, and metamorphic rocks.
The sedimentary formations dip southeast, toward the Atlantic Ocean, at an angle slightly greater than the regional slope.
Crosby et al.,
ff. Tr. 253, at 2 and Fig. 2.
11.
The Tuscaloosa Formation overlies the basement com-plex.
The Tuscaloosa sediments were deposited in late Cretaceous time.
Id. at 3.
The Huber and Ellenton Formations were deposited on the Tuscaloosa sediments during the Paleocene Epoch (Tertiary Period).
Id.
12.
The Lisbon Formation was deposited atop the Huber and Ellenton during the Eocene Epoch (Tertiary Period).
Beneath Plant Vogtle, the Lisbon Formation is comprised of two members i
-- a lower calcareous send unit and an upper calcareous clay l
(marl).
The lower sands do not have a formal name and are there(pre called the unnamed sands.
The calcareous clay has been named the Blue Bluff marl.
Id.
l 13.
The Barnwell Group of sediments was deposited over the Lisbon Formation in the Late Eocene Epoch.
The Utley,
o Limestone, which is the lowest strata in the group and which is not present.everywhere, was locally deposited on the Blue Bluff marl.
The overlying sediments of the Barnwell Group are com-posed primarily of sands and silts, and are exposed at the sur-face in the Plant Vogtle area.
Id.
14.
There are two major aquifers recognized in the coast-al plain region, both of which are present beneath VEGP.
The lower aquifer is called the Cretaceous aquifer and consists primarily of the sands and gravels of the Tuscaloosa Formation.
It is often referred to as the Tuscaloosa aquifer.
The upper aquifer in the coastal plain region is called the Tertiary aquifer and consists primarily of permeable sands and lime-stones of several Tertiary-age geologic formations.
At Plant Vogtle, the Tertiary aquifer is represented by the " unnamed sands" member of the Lisbon Formation.
Beneath the Plant Vogtle area, both the Tertiary and Cretaceous aquifers are con-fined.
The uppermost confining layer is the Blue Bluff marl of the Lisbon Formation.
Id. at 4.
15.
In addition to that contained in the Cretaceous and Tertiary aquifers, ground-water in the vicinity of VEGP also exists under water-table (unconfined) conditions as shallow and i
discontinuous bodies in the Barnwell Group and other near-surface deposits.
These discontinuous ground-water units are referred to as the water-table aquifer.
Id. at 4-5..
o-16.
The gravamen of Contention 7-is that an accidental spill of radioactive water onsite could result in unacceptable radioactive contamination of the shallow, and possibly the deeper, aquifers under Plant Vogtle.
LBP-84-35, 20 N.R.C. 887, 900 (1984).
With respect to this contention, the Board desig-nated five sub-issues to be litigated, resolving all other issues in Applicants' favor.
Memorandum and Order (Ruling on 2
' Motion for Summary Disposition of Contention 7 re: Groundwater
)
Contamination), dated November-12, 1985, at 30.5/
The five 1
issues are:
)
(1)
Adequacy of Geological / Hydrological j
Exploration i
j (2)
Data on Marl Thickness and Permeabili-ty 1
j (3)
Data on Marl Continuity 1
(4)
Direction of Groundwater Flow (5)
Groundwater Travel Time These issues are addressed below.
For convenience and because they are related, the data on marl thickness and permeability i
and the data on marl continuity are discussed together.
i I
{
i l
j 5/
The definition and scope of the five issues are set out at pages 12-16 and 23-29 of the November 12, 1985 Memorandum and Order.
1 1 :
)
i 4
O O
A.
Adequacy of Geological / Hydrological Exploration 17.
Applicants have conducted extensive investigations of the geology and hydrology at and in the vicinity of the plant.
These studies are up to date and demonstrate the suitability of the site for a nuclear power plant.
Crosby et al.,
ff. Tr.
253, at 5.
18.
The investigations commenced with site exploration in 1971.
A thorough search of the literature, stereoscopic exam-ination of color air photographs, detailed evaluation of geo-logic conditions at and within five miles of the site, and geo-logic reconnaissance along 12 miles of the Savannah River bluff upstream and downstream were conducted.
Geologic field inves-tigations included geologic mapping, drilling, and geophysical surveys.
During this phase, 474 exploratory holes were drilled for a total of 60,000 feet of hole.
The drilling program in-cluded electric logging, natural gamma, density, neutron, cali-per, and three dimensional velocity logs in selected drill holes.
Menard pressure meter tests were performed to determine in-situ engineering properties of the marl, which is the load bearing unit for plant structures.
The geophysical surveys consisted of a total of 28,400 feet of shallow refraction seismic lines, 5,000 feet of deep refraction lines, and cross-hole velocity measurements in the upper 290 feet of materials.
Id. at 5-6..
}
19.
Also, ground-water studies were conducted during ini-tial site exploration.
These studies included in-situ perme-ability testing, installation and monitoring of observation wells, and well canvasses.
A total of 280 wells were located and inspected on the west side of the Savannah River.
These included all wells in use within seven miles of the site, and an estimated sixty percent of the wells beyond to a distance of ten miles from the s'ite.
Id. at 6.
20.
Investigations of the geology and hydrology at VEGP continued during site excavation and construction.
These in-cluded detailed geologic mapping of the soil and rock strata exposed during the power block excavation, and coring and testing of the Blue Bluff marl.
Over 100 additional explorato-ry holes were drilled in the vicinity of Plant Vogtle.
In ad-dition, since initial site exploration in 1971, 37 observation wells have been used to monitor water levels in the water-table aquifer; and the Tertiary aquifer har been monitored by 23 wells.
Data have also been obtained from four wells open to Cretaceous aquifer.
Id.
21.
In May and June of 1982, another major well canvass was conducted to accumulate a comprehensive hydrogeologic data base to evaluate the postulated Millett fault.
A total of 886 wells encompassing an. area of approximately 4,400 square miles surrounding the plant were investigated.
Geophysical well log i
data from both the State of Georgia Geological Survey and the -
o U.S. Geological Survey were obtained and analyzed.
As part of the Millett study, 12 observation wells were installed along two lines southeast of the plant.
The wells were drilled through the marl and monitored water levels in the Tertiary and Cretaceous aquifers below the marl.
The data from these and other core holes provide accurate definition of the depth of geologic units, lithology, and aquifers from the plant to nine-teen miles southeast of the plant, and evidence the lateral ex-tent of the marl in that direction.
Even more recently, in 1984, a well canvass was conducted to identify all offsite wells within a two-mile radius of the plant.
Id. at 7 and Fig. 3.
22.
During the summer of 1985, a further program of geo-technical verification work was conducted at Plant Vogtle to resolve NRC Staff questions and to acquire supplementary data on site characteristics.
The work consisted of conducting standard penetration tests of the backfill, core drilling and in-situ permeability testing of the marl, laboratory measure-ment of marl permeability, observation well installation, and laboratory measurement of the cation exchange capacity and equilibrium distribution coefficient of the backfill.
Id. at 7-8.
23.
These programs of geologic mapping, drilling, geophysical logging, well monitoring, and permeability testing have reliably determined the location and characteristics of j l
the geologic and hydrogeologic units in the vicinity of Plant
~ Vogtle.
In particular, exploratory drilling, which is the pri-mary method for determining the geologic units and aquifers at a site, has provided extensive information on the depth, char-acter, and areal extent of the subsurface units and aquifers.
At Plant Vogtle, over 600 holes have been drilled.
Over 200 of these explored the marl and provide a reliable data base on its characteristics.
Id. at 8 and Figs. 4-5.
24.
Permeability measurements have been made of the water-table aquifer, the marl, the Tertiary aquifer, and the Cretaceous aquifer.
The permeability of the Barnwell sands was measured in situ in two exploratory holes and in laboratory tests of three undisturbed samples from another hole.
The lowest strata in the water-table aquifer (the Utley limestone) was studied with pumping tests, falling head tests, and con-stant head tests in two well arrays.
The hydraulic character-istics of the Cretaceous and Tertiary aquifers were also mea-sured in pumping tests.
Id. at.8-9.
25.
During site exploration (1971-1973), the marl perme-ability was tested in situ; 80 packer tests and permeameter tests were conducted in 22 drill holes.
During the geotech-nical verification work performed in the summer of 1985, an ad-ditional 15 packer tests were performed in six new holes; and laboratory permeability measurements were taken on ten samples from these holes.
Id. at 9 and Fig. 5..
u.
s
s 26.
To provide early estimates of the permeability of the backfill material, laboratory tests of a disturbed sample of Barnwell sands and of two grab samples of backfill material
. compacted-to varying densities (enveloping the design density and percent compaction) were performed.
Much more recently, 4
the permeability of the backfill material was measured in situ by slug tests performed in four observation wells in the power block area.
Id.
27.
The extensive investigations at Plant Vogtle have de-termined the interrelationship of both geologic and hydrologic units.
Overlying the Cretaceous and Tertiary aquifers is the Blue Bluff marl, the upper member of the Lisbon Formation.
The marl, approximately 70-feet thick, is a layer of very low per-meability that confines the Tertiarj and Cretaceous aquifers.
Id.; Tr. 284-85 (Farrell).
28.
The Barnwell sands and limestone, which overlie the marl and in which the water-table aquifer exists at VEGP, are on an interfluvial ridge -- a topographically high area in which the ground-water in the water-table aquifer discharges along streams that nearly surround the area.
The water-table is, in general, a subdued reflection of the ground surface, and movement is from the central portions of the interfluye toward the bordering interceptor streams.
The streams have eroded down to the marl.
Crosby et al.,
ff. Tr. 253, at 10 and Figs.
7-9.
29.
There.is only a narrow remnant of continuity between the water-table aquifer materials beneath the site and those offsite.
That remnant is northwest of the plant between the head of the Mathes Pond drainage and the unnamed tributary to Daniels Branch west of the plant.. Ground-water beneath the narrow remnant drains either into Mathes Pond or into the unnamed tributary of Daniels Branch.
Thus, the water-table aquifer at VEGP is e'ffectively isolated, both laterally and 1
l vertically, from other aquifers.
Id. at 11 and Figs.
7-9'.
30.
The Licensing Board's designation of the adequacy of i
the geological / hydrological exploration as an issue to be liti-
)
i gated was predicated on three confirmatory items in the NRC j
Staff's June 1985 Safety Evaluation Report for VEGP.
As quoted f.
in the Licensing Board's November 12, 1985 Memorandum and
?
4 Order, these three items were as follows:
Further monitoring of the unconfined aquifer and backfill is necessary to estab-lish the design-basis groundwater level.
The level has not been conclusively estab-lished because the water level was measured 2
in the unconfined aquifer over a relatively short time and had interrupted segments as discussed in Section 2.4.12.6 of this SER.
(NUREG-1137, Section 2.4.12.7, June 1985, at 2-32);
The staff requires additional wells in the marl aquiclude because of the limited moni-toring over the full depth of the marl as discussed in Section 2.4.12.2.2 of this SER.
The required permeability testing will confirm the range of the applicant's previous permeability test results and i
i i
4 I
u I
4 4
provide the permeability of the interbedded limestone lenses.
(Id.);
This aquifer [Tuscaloosa) should.be moni-i
'tored to determine the long-term effect of withdrawing water from the Tuscaloosa aquifer.
Well No. TW-1 and any other pro-duction wells not being pumped should be read on a monthly frequency to monitor the effects of pumping from the Tuscaloosa aquifer.
(Id. at 2-33).
31.
In July 1985, a program of frequent measurement of wells monitoring the unconfined aquifer and backfill was imple-mented in response to the NRC Staff's request above.
The prin-cipal purpose of this program is to provide more detailed in-i formation to support the VEGP design basis water level.
Crosby i
et al.,
ff. Tr. 253, at 33.
32.
The design basis water level is the maximum expected ground-water level in the vicinity of the power block struc-tures.
The elevation of the water table tends to fluctuate from year to year and from season to season in response to variations in the rate of recharge.
A conservative maximum level is determined for use in varioits design calculations such as subsurface hydrostatic loading (the stresses that ground-water exerts on subsurface structures).
The design basis water level for the power block area is 165 feet msl, whereas expect-ed levels in that area range from 157 to 161 ft. mal.
Id. at 33-34.
, i I -
33.
The NRC Staff's concern was that water levels had not been monitored for a sufficient length of time to verify the i
fluctuations in level that might be expected, and the Staff designated this concern a confirmatory item.
Id. at 34; Heller et al.,
ff. Tr. 764, at 7.
It was a structural concern and not related to ground-water contamination.
Heller et al.,
ff. Tr.
764, at 7; Tr. 768 (Gonzales).
This item has little bearing on the speed or direction of ground-water flow over the power block area, since fluctuations are quite uniform over this area and do not appreciably alter the hydraulic gradients.
Crosby et al.,
ff. Tr. 253, at 34.
34.
The first six months of monitoring was completed in j
December, 1985.
The highest recorded water-level in the power block area during this period was 162 feet mal at well LT-12.
l Well LT-12 is located in a small enclosed area between the aux-iliary building and adjacent structures that, until recently, i
had been a depression (only partially backfilled).
Drainage from the auxiliary building and other structures was directed i
]
to this depression.
Until late October, when backfilling was continued, there was no attempt to drain the depression.
The i
resulting ponded water was a source of concentrated recharge i
and has created a temporary mounding of the water table aquifer.
Yet despite this abnormal recharge, the water level i
remained well below the 165 foot design basis water level.
Id.
at 34-35.
j 4 i
l 35.
The NRC Staff also requested that as part of this re-newed monitoring program two well clusters.of piezometers be installed at opposite corners of the power block to provide ad-ditional detail on the pore pressure distribution within'the i
marl.
As a result, two clusters of piezometers (A and B) were i
installed in the marl in June and July 1985.
The piezemeters i
provide a direct measurement of hydraulic head over the full depth of the marl.
The differences in hydraulic head between the piezometers within a cluster show a progressive decline in j
head with depth.
Id. at 35.
The NRC Staff considers this con-j firmatory item resolved.
Heller et al.,
ff. Tr. 764, at 8.
36.
Finally, the NRC Staff asked that the Cretaceous
[Tuscaloosa] aquifer be monitored to determine the long-term j
effect of withdrawing water from this aquifer.
The reason for i
this request is to ensure that withdrawal of water from the Cretaceous aquifer will not' adversely impact other ground-water 4
users.
Id. at 3, 8.
It does not relate to a ground-water con-j tamination concern.
Id.; Tr. 768 (Gonzales).
,F 37.
Because of the large available capacity of the Cretaceous and Tertiary aquifers, the small use rate during operation of VEGP should have no significant effect on the aquifer.
There should be no appreciable lowering of piezo-1
]
metric levels beyond 1000 feet from the pumping site, and no effect on any off-site water user.
Crosby et al.,
ff. Tr. 253,
{
at 35-36.
Applicants are currently monitoring the Cretaceous j i
aquifer,6/ and NRC Staff will require Applicants to continue to do so throughout the life of the plant.
Heller et al.,
ff. Tr.
764, at 8.
The monitoring of the Cretaceous aquifer during plant operation will provide confirmation of Applicants'-deter-i i
minations.
Crosby et al.,
ff. Tr. 253, at 36.
The NRC Staff considers this item resolved.
Heller et al.,
ff. Tr. 764, at f
8.
1 1
B.
Data on Marl Thickness, Permeability, and Continuity i
I 38.
The Blue Bluff marl is a densely-consolidated, fine-l grained calcareous clay with subordinate lenses of dense, well-1 indurated, well-cemented limestone.
The reported values of the I
permeability of unweathered marine clays, of which the marl is a
~7
-10
]
type, range from 10 to 10 cm/sec.
In engineering practice, materials with such low permeability are qualitatively considered to be impermeable.
Crosby et al.,
ff. Tr. 253, at l
12.
39.
The Blue Bluff marl is approximately 70 feet thick.
i It extends over an area well beyond the limits of the plant i
site and the interfluvial ridge on which the plant site is lo-cated.
Under the power block, the thickness of the marl is less because of excavation.
Dua to this excavation, the marl
}
6/
Applicants are also monitoring the Tertiary aquifer.
j Crosby et al.,
ff. Tr. 253, Table 1 and Fig. 17.
l 4
i i
I i
is generally 60 feet thich under the power block area, and its minimum thickness is 38 feet under the auxiliary building.
Id.
at 12-13; Heller, ff. Tr. 764, at 11.
40.
The thickness of the merl was determined by over 200 exploratory holes.
These holes include approximately 25 south of the power block area, and a large number to the north (in the direction that ground-water beneath the power block flows
-- the principal area of concern).
Crosby et al.,
ff. Tr. 253, at 8 and Fig. 4; Tr. 267 (Crosby); Tr. 273 (Papadopulos).
This l
number of exploratory holes is unnsually large compared to in-dustry practice and NRC regulatory guidance.
IIeller et al.,
ff. Tr. 764, at 11.
Given that geologic processes are pro-cesses that deposit sediments in a certain, uniform nanner, this large number of holes is more than adequate to define the marl.
Tr. 273-74 (Papadopulos); Tr. 663-64 (Farrell).
41.
The comprehensive exploration and testing that has been conducted demonstrates that the marl is an extensive and persistent Init that significantly inhibits the, percolation of ground-water downward to the underlying Tertiary and Cretaceous aquifers.
In particular, the marl's integrity as a barrier to ground-water movement has been demonstrated by (1) field and laboratory permeability testing; (.2) visual inspection of cored samples, the marl surface exposed during site excavation, and marl outcrops along the Savannah River; and (3) comparison of water levels in observation vells open to the water-table l N
aquifer with those observed in wells open to the confined aquifer immediately below the marl.
Crosby et al.,
ff.
Tr. 253, at 13.
42.
During site exploration, the permeability of the marl was measured in the field at 80 intervals of varying depth in 22 exploratory holes.
Constant-head inflow methods were used.
In 20 of the exploratory holes, inflatable packers were used to isolate a speciiied' test interval.
In two exploratory holes at the intake structure, permeameter tests were conducted.
In nearly all of the intervals tested, no measurable water inflow occurred.
In only three holes was any measurable water intake confirmed, two of which were in near-surface, weathered marl at Water in'lov was measured in three other the intake structure.
f holes, but was due to leakage around the packers.
Id.
43.
During the summer of 1985, the permeability of the marl was again measured.
In-situ permeability testing was con-ducted at 15 intervals in six new holes.
The entire thickness of the marl penetrated in the holes was tested in ten-foot in-tervals te ensure that all of the marl and interbedded lime-stone lenses were tested.
In all of these in-situ tests, the water takes were zero.
The test results confirmed the previous in-situ measurements.
Id. at 14.
44.
Thus, 95 in-situ permeability tests of the marl were performed, almost all of which resulted in no measurable water intake.
For these tests, no intake of water indicates a !
-7 permeability of less than 10 cm/sec.
Tr. 451 (Papa-depulos); Tr. 595 (Farrell).
45.
In addition, during coring of the six new holes.in which in-situ tests were performed in 1985, ten typical marl and limestone core samples were collected for laboratcry testing to pr' ovide an estimate of the range of permeability of various material types (marl and interbedded limestone lenses) within the marl.
The laboratory permeability measurements ranged from 8.5 x.1D-6 to 5.0 x 10 cm/sec.
Crosby et
-9 al.,
ff. Tr. 253, at 14; Heller et al.,
ff. Tr. 764, at 5.
Laboratory mascurements, however, are not as accurate as in-situ tests and tend to overestimate permeability.
Tr. 452-53 (Papadopulos); Tr. 769 (Gonzales).
If in-situ test results were available, the standard practice in the industry would be-to disregard the laboratory data and rely upon the more accurate in-situ results.
Tr. 392 (Papadopulos).
46.
An estimate of marl permeability can also be obtained by examining the rate at which water levels in recently in-stalled piezometers stabilized.
That rate indicates a perne-
-8 ability of about 10 cm/sec.
Tr. 476 (Papadopulos).
See Heller et'al., ff. Tr. 764, at 12, 15-16.
47.
The continuity of this material (i.e.,
the lack of voids, open joints or_ fractures) has also been demonstrated.
Since 1971, there have been over 10,000 feet of marl penetrated at VEGP by drilling, coring, standard penetration testing, and h.
a
~
undisturbed sampling.
At no time throughout this extensive testing was there any unaccountable fluid loss or abnormal tool advance'in the marl.
When coring, the most revealing evidence for the occurrence of voids or fractures is a loss of all or part of the drilling fluid and/or a sudden or rapid advance of the core barrel.
Neither of these conditions occurred during the site exploration.
None of the borings encountered signifi-cantly fractured zon'es; nor was there evidence of leaching (re-moval of calcareous material.)
Crosby et al.,
ff. Tr. 253, at 14-15; Heller et al.,
ff. Tr. 764, at 5, 15.
48.
Visual inspections and detailed logging and photo-graphing of the many extracted samples of marl have likewise produced no indications of voids or extensive fracture zones.
Over 500 feet of the marl. penetrated has been collected either by coring or sampling and closely inspected and' described.
Very few joints or fractures were observed and those identified were consictently found to be tight and without void space.
Marl beneath the plant site, exposed during excavation for the foundation, was directly examined and carefully logged by qual-
\\
ified geologists.
This included inspection and logging of more-than 900,000 square feet of the upper surface of the marl at the base of the power block excavation, more than 20,000 square 3
feet of detailed mapping and photographing of vertical face in the auxiliary building excavation,'and more than 20,000 square feet of inspection and logging of the vertical face in the radwaste solidification building caisson excavations.
Addi-tionally, marl outcrops along the Savannah, River in the vicini-ty of VEGP have also been examined, mapped and photographed.
These extensive and detailed mapping investigations of the marl formation at VEGP have produced an abundance of data indicating the absence of voids, solution cavities, or systematic or ex-tensive fractures or joint sets in the marl.
Crosby et al.,
ff. Tr. 253, at 15-l'6.
49.
Finally, the large and consistent hydraulic head dif-ferential between the water-table aquifer and the confined aquifer immediately below the marl confirms that the marl is a barrier to significant ground-water movement.
The hydraulic head (energy potential) of ground-water in an aquifer is com-monly expressed as feet (elevation) above sea level and is de-termined from measuring the elevation of water in an observa-tion well.
In the vicinity of the plant, the hydraulic head in the water-table aquifer is 45 to 55 feet greater than the hy-draulic head in the aquifer immediately below the marl.
To bring about such a marked difference in hydraulic head, the barrier must be extensive and without significant through-going openings (such as fractures or solution cavities).
Id. at 16-18.
50.
Owing to the extent and very low permeability of the marl, the impact of an accidental spill on the Tertiary and Cretaceous aquifers will be negligible.
A calculation of the possible rate of flow across the marl demonstrates this conclu-sion.
The rate of flow is determined by the hydraulic gradient across the marl, and by the permeability and porosity of the materials.
The relationship between these parameters in de-termining ground-water seepage velocity is expressed as Darcy's LP:t:
v
=
Ki n,
seepage velocity (L/T),
- wnere, v
=
coefficient of hydraulic conductivity K
=
(permeability) (L/T),
i
=
hydraulic gradient (ratio) n, effective porosity (ratio)
=
Id. at 18-19.
51.
The gradient is determined by the hydraulic head dis-sipated (the difference in' piezometric levels of the water table and the Tertiary aquifers) over the travel path (the thickness of the marl).
The difference in head beneath the power block can be determined from a comparisoa of piezometric surfaces of the two aquifers reasured in December 1984.
These indicate a difference of about 50 to 55 feet.
This is similar to the difference observed in a comparison of levels measured j
prior to construction in November.1971.
The minimum thickness of the marl benIeath the power block is 38 feet.
The maximum J
hydraulic gradient, then, is 55 feet of head over a distance of 38 feet, or 1.447.
Id. at 19..
~
52.
The in-situ tests provide a value of 10 cm/sec as an upper bound for the permeability of the marl.
Tr. 473-75 (Papadopulos); Tr. 480, 593 (Farrell).
This value is greater than the harmonic mean of the laboratory measurements of marl permeability.
See Crosby et al.,
ff. Tr. 253, at 20.
53.
Adopting an average vertical permeability of 0.1
-7 ft/yr (10 cm/sec), which is the maximum permeability value indicated by the in-situ tests, is therefore reasonably conservative.
The porosity of the marl has been calculated for 18 samples, and the average value of those samples is 47.5 per-cent.
Id.
54.
Applying the values above for the three controlling parameters -- hydraulic gradient (1.447), permeability (0.1 ft/yr), and porosity (47.5%) -- the average vertical ground-water velocity in the marl is calculated to be 0.31 ft/yr, and the, time required to traverse 38 feet of marl would be 123 years.
Id.
This travel time is a lower bound.
Tr. 484 (Papa-dopulos).
Applicants' experts stressed their confidence with the parameters chosen for this calculation.
Id.
Taking into account retardation due to radionuclide adsorption, the 123-year travel time is sufficient to reduce all radionuclides in a worst case spill below the maximum permissible concentrations set forth in 10 C.F.R. Part 20, Appendix B, Table II, Column 2 (which applies to routine, continuous releases).
Crosby et al.,
ff. Tr. 253, at 21.
Any ground-water that traversed the, -
marl would enter the Tertiary aquifer and would then flow under the site eastward through the Tertiary aquifer to the Savannah River.
Tr. 294 (Farrell); Crosby et el.,
ff. Tr. 253, Fig. 11.
C.
Direction of Ground-water Flow 55.
Because the marl prevents significant vertical move-ment of contaminants across it, migration of contaminants from an accidental spill at VEGF would be predominantly lateral in the direction of decreasing head in the water-table aquifer.
The water table has been monitored by measurements of levels in wells at the VEGP site since 1971.
With these measurements, the direction of ground-water flow can be determined.
Crosby et al.,
ff. Tr. 253, at 21.
56.
The water levels that were measured during site in-vestigation indicated that the direction of ground-water flow beneath the power block area is northward to Mathes Pond.
Sub-sequent excavation and devatering profoundly but temporarily affected the water table level.
The dewatering continued until 1983.
Although water levels were measured periodically during this period, the dewatering operations preclude their use to predict present or future flow direction and flow rate.
Id.;
Heller et al.,
ff. Tr. 764, at 18.
57.
Water levels monitored in observation wells since cessation of dewatering indicate that the water table has re-covered from the dewatering.
Continued construction activity, _
however, still precludes complete. stabilization of the water
' table, particularly in the power-block area.
Backfilling is 4
- still in progress around the structures and requires consider-able application of water to the materials.
This water perco-lates to the water table, where its flow is locally retarded by plant structures.
Thus, the power block is an area in which recharge and hence water levels are temporarily higher than i
will be the case'after construction is complete.
Grading and leveling of the site have-also changed the drainage pattern and
{
reduced topographic relief, and these changes affect the con-figuration of the water table.
Nevertheless, post-dewatering.
water-levels indicate that the configuration of the water table remains a subdued replica of the 1971 levels and that similar j
flow patterns will exist.
Crosby et al.,
ff. Tr. 253, at 22; j
Heller et al.,
ff. Tr. 764, at 19.
58.
The direction of flow from po'ints of potential spill is still north and northwestward to Mathes Pond.
Analysis of past and present water levels demonstrates that an accidental spill will not migrate to the south.
Crosby et al.,
ff. Tr.
253, at 22-23; Heller et al.,
ff. Tr. 764, at 17-19; Tr. 675-77 (Papadopulos); Tr. 774 (Gonzales).
59.
Ground-water moving beneath the power block area will eventually reach Mathes Pond.
Concentrations of any remnant 4
radionuclides from a spill at the plant would be further 1
reduced by dilution as the contaminated ground-water slowly 4 1 1
\\
+ -., ~
,-,.m.
discharged into Mathes Pond (which is completely on-site) and, subsequently, to the Mathes Pond drainage.
Ground-water north of Mathes Pond and stream would not be affected.
The Mathes drainage has cut'down to the marl, as have other streams bor-dering the interfluvial ridge on which VEGP is located, inter-rupting continuity between water-table aquifers.
Ground-water in the water-table aquifers on both sides of the bordering pond and streams discharges into the pond and streams (i.e.,
ground-water flows into and not across the pond and streams).7/
Crosby et al.,
ff. Tr. 253, at 23.
D.
Ground-water Travel Time 60.
The time required for ground-water to migrate through the backfill toward Mathes Pond is determined by the perme-l ability and porosity of the material, and the hydraulic gradi-ent.
The permeability assigned to the backfill is the maximum value measured in situ, 1220 ft/yr.
The average porosity of 7/
Because the water-table aquifer beneath the VEGP site is hydraulically isolated, an accidental spill flowing in any direction could not impair domestic or other wells beyond the streams around the interfluvial ridge.
For the same reason, a spill could not migrate tosan area where the marl is not present or less permeable (potential avenues to reach the lower, confined aquifers).
The only wells that could be affected by an cccidental spill are those on the interfluvial ridge and drawing from the water-table aquifer.
There is only one such well.
This well is located approximately 1.7 miles south of the plant, and an accidental spill would not move in 1
that direction.
Crosby et al.,
ff. Tr. 253, at 23 n.3.
m.-
the backfill material is 34%.
The hydraulic gradient in the
-3 j
backfill along the Mathes Pond flow path is 3.5 X 10
, but
-3 again for conservatism is rounded off'to 4.0 X 10 Id.
at 25-26.
61.
Applying Darcy's Law to the parameter values above, the calculated ground-water velocity in the backfill is 14.4 ft/yr.
The flow path length through the backfill is 550 feet, and the ground-water travel time in the backfill is therefore 38.2 years.
Id.
Taking into account retardation due to radio-nuclide adsorbtion, this travel time is sufficient to reduce the concentration of all radionuclides other than tritium in a postulated worst-case spill to below 10 C.F.R. Part 20 limits.
Id. at 26-29.
62.
Ground-water exiting the backfill would continue its migration through the Barnwell Group to Mathes Pond.
Several high permeability measurements in the Utley limestone raised the possibility that the Utley might permit rapid ground-water flow between the backfill and Mathes pond.
However, even if this hypotheris were correct, contaminated ground-water subse-quently reaching Mathes Pond would be further diluted in the a
pond and in the stream running from the pond to the Savannah River, reducing the concentration of tritium below 10 C.F.R. Part 20 limits before it flows off-site.
Id. at 29-31.
13.
The Board's designation of ground-water travel time 6
as an issue was based on concern that a one-dimensional a
application of Darcy's law might be inadequate for estimating ground-water velocity over long distances where the water table gradient undergoes marked changes (in particular, where the gradient becomes steep at the end of the flow path).
Memoran-dum and Order (Ruling on Motion for Summary Disposition of Con-tention 7 re: Groundwater contamination), dated November 12, 1985, at 28.
This concern in turn was based on differing esti-mates of ground-water velocity at the Savannah River Plant obtained by a one-dimensional application of Dar,cy's law, by a three-dimensional model, and by tracer tests.
Id. at 26-28.
64.
The disparity in the SRP estimates of ground-water velocity, however, was not due to methodology.
Instead, the results varied because the values of the relevant parameters differed from study to study.
Papadopulos, ff. Tr. 253, at 8-9; Tr. 644 (Papadopulos).
If the same values of permeability and porosity had been applied, tha one-dimensional application of Darcy's law would have estimated shorter travel times than 4
those estimated by the three dimensional model or by tracer tests.
Papadopulos, ff. Tr. 253, at 8-12.
The one-dimensional approach is conservative because the one-dimensional (hori-zontal) flow path is shorter than the actual three dimensional, curvilinear flow path (id. at 3-4) and the one-dimensional analysis overestimates average velocity (id. at 5-8).
65.
In addition, the original concern -- that Darcy's law might be inadequate where gradients undergo marked changes and -
become steep at the end of the flow path -- is inapplicable to Applicants' and Staff's analyses.
Applicants' and the NRC Staff's analyses took credit only for the time it took ground-water to travel through the backfill.
Over the power block area, the hydraulic gradient is gentle and does not vary sig-nificantly.
Heller et al.,
ff. Tr. 764, at 21, 24; Tr. 673 (Papadopulos).
E.
Mr. Lawless' Testimony 66.
The findings above are based on the essentially uncontradicted testimony of Applicants' and the NRC Staff wit-nesses.
These witnesses were competent, well-qualified experts in the fields of geology, hydrology, and geotechnical and civil engineering.
The only contradictory testimony in this proceed-ing was that of GANE's witness, William F.
Lawless.
67.
Mr. Lawless, however, is not a geologist or hydrologist.
He has not studied hydrology.
Tr. 721-22 (Law-
]
less).
He, himself, has done no research in these fields.
Tr. 722-28 (Lawless).
Fur-hermore, Mr. Lawless' testimony was vague and speculative.
Mr. Lawless has no personal knowledge J
pertaining specifically to the Vogtle site.
- See, e.g.,
Tr. 722-24, 743, 745-48, 751 (Lawless).
Accordingly, Mr. Law-
]
less' testimony is entitled to little weight.
68.
For example, Mr. Lawless testified that grouted wells 4
are "likely" less compressible in a vertical direction than the -
.o marl, and that plant settlement would therefore punch these grouted wells downward at a rate that "might be different" for the marl.
Mr. Lawless then speculated that "it is possible" that the bottom of the grouted wells "may" separate and core i
out of the bottom of the marl, and "if so" the integrity of the marl would be diminished.
Lawless Attachment, ff. Tr. 720, at 7-8.
69.
Mr. Lawless, however, admitted on cross-examination that he did not know the compressibility either of the marl or of the grout.
Tr. 747-48 (Lawless).
Furthermore, Mr. Lawless admitted he had no information that slippage between grouted wells and the marl has occurred, and had no knowledge of the extent of settlement at VEGP.
Tr. 746-751 (Lawless).
70.
Contrary to Mr. Lawless' unsupported speculation, Applicants' witness, Mr. Crosby, testified that the marl is ac-tually more rigid than the grout columns, not vice versa as Mr.
Lawless had posited.
Tr. 792 (Crosby).
Mr. Crosby further i
testified that there are a number of reasons why there would not be differential movement between the marl and grout col-i umns.
71.
First, there is a very large surface area around the outside of the core hole and more than sufficient friction to prevent differential movement.
Tr. 793 (Crosby).
The overbur-den on the marl produces a constrictive force; and the bond be-tween the marl and the grout is very tight.
In addition, the -
l core hole surface is very irregular, adding to the frictional resistance.
Tr. 793-94 (Crosby).
Finally, the unnamed sands underlying the marl are as dense or denser than the marl, and 1
therefore would not permit a grout column to punch into the lower sands.
Tr. 793 (Crosby).
72.
Applicants also testified that settlement is now es-sentially complete.
Tr. 794 (Crosby).
The consistent. main-tained head difference of 55 feet between the water-table aquifer and the confined aquifer demonstrates that there is no exchange of ground-water between the two aquifers.
Tr. 795 (Crosby).
This testimony belies Mr. Lawless'~ speculative hy-i pothesis that settlement may have created pathways for ground-water. flow across the~ marl.
Finally, Applicants' witnesses 1
testified that even if differential movement between the marl and the grout were to occur, the pressure on the marl due to its overburden would close off any space that might develop.
Tr. 794 (Crosby).
73.
Mr. Lawless also speculated that plant settlement "may" have changed the backfill's hydrologic coefficients, and that "if any fissures occur in the backfill over time" they might.act as conduits.
Lawless, ff. Tr. 720, at 6; Tr. 742 (Lawless).
Mr. Lawless, however, did not know the composition of the backfill; he did not know how it was placed; he was aware of no fissures such as he was hypothesizing; he was aware of no information suggesting-that the backfill's hydrologic i 1 I
coefficients have changed; he was aware of no information sug-gesting any distortion of the backfill; and of course he had no information concerning the extent of settlement at VEGP.
Tr. 742-746.
74.
Applicants, on the other hand, testified concerning the extent of settlement.
The amount of settlement is directly tied to the amount of backfilling that has occurred.
Since the backfilling is about 95 percent complete, the amount of settle-ment is also nearly complete.
The net settlement that has oc-curred throughout the whole backfilling process is less than 1 inch, and any further settlement in the future will be much less.
Moreover, Applicants' measurements of the hydraulic con-ductivity'of the backfill were taken very recently -- in February, 1986.
Crosby et al.,
ff. Tr. 253, at 7; Tr. 653.
See Lawless, ff. 720, References.
These measurements therefore reflect the hydraulic conductivity of the backfill after what-ever effect (if any) settlement might have had on the prop-erties of the backfill.
1 75.
Lastly, Mr. Lawless claimed that the average hydrau-lic conductivity.of the backfill material calculated from the four power block wells has a standard deviation greater than.is customary practice.
Mr. Lawless referred to Bouwer, Groundwa-j ter Hydrology" (1978) at page 132.
Lawless, ff. Tr. 720, at 6.
Dr. Papadopulos, however, testified that Bouwer's statement at
- page 132 merely pointed out that there will be variations in >
r
.a mm
-m
- - m..m.m.
- am m m
- a
- m - -
.m.--
a permeability even in uniform materials.
Tr. 393-95 (Papa-dopulos).
There is no rule as to what is an acceptable stan-dard deviation, since natural materials have large variations in permeability. These natural variations are taken into account by the methodology used to determine the average perme-ability.
In the case where the system is heterogeneous and unlayered, the geometric mean of the permeability measurements is used to determine the average permeability of the system.
Tr. 395-96 (Papadopulos).
76.
The geon.etric mean of the measurements of backfill i
permeability is 850 feet per year.
Applicants, however, did not take the mean, but instead conservatively chose the maximum value measured -- 1220 feet per year.
Tr. 655-56 (Papa-depulos); Crosby et al.,
ff. Tr. 253, at 25.
Mr. Lawless' com-ment concerning the standard deviation of the " average" hydrau-lic conductivity therefore misses the mark.
Morecver, Dr.
Papadopulos computed the confidence level for this maximum value; the confidence level in this value is 84 percent.
Tr. 654-55 (Papadopulos).
F.
Conclusion 77.
Based on the findings above, the Board concludes that Applicants' geological and hydrological exploration has been more than adequate, including their gathering of data per-taining to marl thickness, permeability, and continuity.
Both -
. m
Applicants' and the NRC Staff's expert witnesses so testified as a matter of professional opinion.
Crosby et al.,
ff. Tr.
257, at 36; Tr. 273-74 (Papadopulos); Heller et al.,
ff. Tr.
764, at 4, 6,
11.
The Board further. concludes that Applicants have properly determined the direction of ground-water flow --
i a fact conceded by Mr. Lawless (Tr. 591) -- and that Applicants have conservatively computed the time it would take ground-I water to reach Mathes Pond.
Applicants' analysis demonstrates 1
i f
that a worst case spill would not result in offsite concentra-tions of radionuclides exceeding 10 C.F.R. Part 20 limits.
j Having also found undisputed during summary disposition Appli-j cants' compliance with the stringent standards governing the-2 design and construction of tanks and related piping containing radioactive liquid, the Board concludes that Applicants have i
adequately assured that potable water sources will not be con-i taminated and that operation of Plant Vogtle will not be inimi-d cal to the public health and safety.
j III.
Contention 10.1 78.
In 1981, K. T. Gillen and R.
L. Clough of Sandia Na-tional Laboratories conducted a study addressing dose-rate-ef-e i
fects in ethylene propylene rubber (EPR), cross-linked poly-
{
olefin (XLPO), chloroprene (Neoprene), and chlorosulfonated=
i polyethylene (Hypalon).
This study is entitled NUREG/CR-2157, i
" Occurrence and Implications.of Radiation Dose-Rate Effects for i
)
4 4
Material Aging Studies" (June 1981).
Contention 10.1 asserts j
that VEGP safety-related equipment containing any of the four polymers addressed in NUREG/CR-2157 has not been properly qual-ified because the radiation customarily applied at high~ dose i
rates during accelerated aging produces less degradation in these polymers than the same amount (total integrated dose) of radiation applied at low dose rates.
Kitchens et al.,
ff. Tr.
561, at 4-6; Masciantonio on 10.1, ff. Tr. 576, at 2-4.
79.
In the Sandia Study (NUREG/CR-2157), Gillen and Clough tested EPR and XLPO cable insulation, and Hypalon and Neoprene cable jacketing.
These materials were stripped from the cables and irradiated in air and nitrogen at radiation dose rates ranging from approximately 0.001 to 1.0 megarads/hr.
Degradation of the ultimate tensile properties (elongation and tensile strength) was examined.
Kitchens et al.,
ff. Tr. 561, at 8-9.
Radiation dose-rate effects were found in air environ-ments at high total integrated doses for all of the materials tested.
_I_d.
at 9.
)
80.
The dose-rate effects observed in these four poly-mers, however, are minor.
Moreover, the differences-in the rate of degradation caused by the various dose-rates decrease as the total integrated dose decreases,-and they are indiscern-4 ible at the maximum total integrated doses these polymers could 4
incur over forty years of normal plant operation at VEGP.
Id., -. - -
81.
In the case of ethylene-propylene rubber and Hypalon, the reduction of tensile properties 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 for all dose rates up to a total integrated dose of 10 mega-rads.
At VEGP, no safety-related equipment containing XLPO, EPR, Hypalon, or Neoprene, will receive a total integrated dose for 40 years normal operation greater than 10 megarads; and 1
most such equipment will receive less than two megarads.
- Thus, for EPR, Neoprene, and Hypalon, the dose-rate effects observed by Gillen and Clough are insignificant irrespective of polymer application.
Id. at 9-10.
82.
Of the four polymers addressed in NUREG/CR-2157, only the sample designated as XLPO exhibited dose-rate effects-that
]
were discernible at total doses below 10 megarads.
Id. at 10; Masciantonio on 10.1, ff. Tr. 576,.at 4.
The term "XLPO," how-I
)
ever, does not refer to a cpecific polymer, but instead refers i
to a group of cross-linked polymers that are based on aliphatic alkene monomers.
Kitchens et al.,
ff. Tr. 561, at'7.
Cross-linked polyethylene (XLPE) is the polymer most often referred to generically as XLPO.
Applicants learned from Sandia, how-ever, that the polymer that was designated as XLPO in the Sandia study (NUREG/CR-2157) was a copolymer of ethylene and vinyl acetate (EVA).
Id. at 8. 1
4 83.
EVA is not used-at VEGP in any safety-related equip-ment subject to a harsh environment.
Nor can the results for EVA be used to predict similar effects in other cross-linked polyolefins.
A new study by Sandia, released after Applicants' motion for summary disposition was filed, evaluated dose-rate effects in XLPE.
K. T. Gillen, R. L. Clough, and N. J. Dhogge, NUREG/CR-4358, " Applications of Density Profiling to Equipment Qualification Issues'" (Sept. 1985).
Sandia evaluated among other things the degradation of tensile properties of XLPE in-sulation at various dose-rates.
The results demonstrate.that dose-rate effects in XLPE are insignificant below 20 megarads total integrated dose.
Id. at 10.
84.
Thus, the dose-rate effects observed by Gillen and Clough in XLPO, EPR, Hypalon, and Neoprene are insignificant with respect to safety-related equipment at VEGP. -Moreover, j
the dose-rate effects observed by Gillen and Clough are proba-
{
bly exaggerated when compared to plant conditions.
In the i
Sandia study, pieces of cable insulation were stripped from the wire for the tests.
The insulation material was-thus com-pletely exposed to oxygen in the ambient environment.
In actu-i al application at VEGP, insulation is covered with a jacket ma-terial.
Although the jacket is primarily for mechanical protection (protection from abrasion, cuts, etc.), this cov-j ering significantly reduces the oxygen available for radiation-induced oxidation of the cable insulation.
Since oxygen
)
4 1 1
f I
4
_, _._.1
diffusion into the materials is postulated to be a major con-tribution to the degradation mechanista, the applicability of the Sandia test results to cable installed at VEGP is gunstion-able.
Id. at 10-11.
85.
In the Licensing Board's January 23, 1986 Memorandum and Order (Ruling on Motion for Summary Disposition of Conten-tion 10.1 re Dose-Rate Effects), as amended by Memorandum and Order dated February 13, 1986, the Board designated five issues for hearing.
These five issues relate to (1) the evaluation of electrical. insulation property; (2) the significance of a cable surveillance program being conducted by Duke Power Company; (3) the scope and results of mechanical stress tests on prototype VEGP cable; (4) Applicants' maintenance and surveillance pro-gram; and (5) the significance of Applicants' maintenance and surveillance program.
These issues were addressed fully by Applicants' witnesses and the NRC Staff's witness.
These wit-nesses were well-qualified and knowledgeable experts.
Their testimony was entirely uncontradicted; GANE offered no opposing testimony and conducted no cross-examination.
A.
Evaluation of Electrical Insulation Property 86.
In the affidavit that Applicants submitted in support of their prior motion for suctmary disposition,g/ the affiants g/
Affidavit of Joel Kitchens, Victor L. Gonzales, and Mark L. Mayer (July 30, 1985).
j -
a
assumed for the purpose of their analysis that the dose-rate effects observed in the polymer designated.as XLPO in NUREG/
CR-2157 (which was EVA) were applicable to XLPE.9/
The only safety-related appifcation of XLPE, or of any other type of XLPO, subject to a harsh radiation environment at VEGP is cable insulation.
To demonstrate that the dose-rate effects observed in XLPO did not compromise safety-related cable, affiants de-scribed the results of another Sandia study which demonstrated that degradation of the mechanical properties of XLPO insula-tion does not prevent the cable from performing its required electrical function.
This particular Sandia study is NUREG/
CR-2932, E.
E. Minor and D. T.
Furgal, Sandia National La-boratories, " Equipment Qualification Research Test of Electric Cable With Factory Splices and Insulation Rework Test No. 2" (Sept. 1982).
Id. at 11-12.
87.
In Minor and Furgal's study (NUREG/CR-2932), the XLPO materials that were tested consisted of XLPE.
Electrical cable insulated with these materials was exposed to radiation at a relatively low dose rate (0.062 megarads/hr) for a total inte-grated normal operational dose of 50 megarads.
Then, after el-evated temperature aging, the cable was exposed to an accident dose of 150 megarads at a rate of 0.77 megarads/hr.
Despite 9/
The Sandia study that evaluated dose-rate effects in the tensile properties of XLPE, NUREG/CR-4385,-was not yet in exis-tence. 4 i
.~~
severe degradation of mechanical properties, the cable was able to perform its electrical function at all times.
This series of tests was conducted according to industry standards (IEEE 323-1974 and IEEE 383-1974) and NRC guidelines (NUREG-0588).
Minor and Furgal concluded that the methodology employed by the nuclear industry to qualify electrical equipment (which in-cludes accelerated aging), is adequate despite the dose-rate effect on mechanical properties studied by Gillen and Clough.
Id. at 12.
88.
In the Board's January 23, 198,6 Memorandum and Order, at page 9, the Board stated:
The Board is unaware, from the information submitted, whether XLPO is the only polymer whose electrical insulation property was evaluated subsequent to radiation exposure.
)
89.
In response, Applicants testified that they are not aware of studies that evaluated dose-rate effects in the elec-trical properties of polymers other than XLPE after radiation exposure.
The electrical properties of XLPE and EPR after ra-diation exposure have been evaluated in two additional Sandia studies, but these studies did not assess dose-rate effects.
Id. at 12-13.
Of course, during environmental qualification testing, all safety-related cables undergo an insulation test after LOCA simulation.
Id. at 13; Masciantonio on 10.1, ff.
Tr. 576, at 4. I
6' B.
The Significance of Duke Power Company's Cable Surveillance Program 90.
In Applicants' prior affidavit, Applicants' affiants noted that additional information regarding dose-rate effects may be obtained from a Duke Power Company study.
Duke Power established an informal cable life evaluation program at its Oconee Nuclear Generating Unit 1, which became commercially op-erational in 1973.
Id. at 13.
91.
For this program, representative specimens of con-trol, inctrumentation and power cable were placed in selected locations within the reactor building so that they would be subjected to a normal in-containment environment.
The cables i
were for the most part insulated with EPR and had Neoprene jackets.
Some samples were insulated with cross-linked poly-ethylene and covered with Neoprene jackets.
Id. at 13-14.
92.
For all cable samples, the average radiation exposure rate was 0.65 rads /hr during operation and 0.12 rads /hr when the unit was shut down.
The actual exposure level that each sample received is considered to have varied considerably over the length of the cable dependent upon the exact location of the cable within the reactor building.
These dose rates are quite low in comparison to rates used in the Sandia investiga-tions, but are representative of the dose rates expected to occur at VEGP.
Id. at 14.
]
93.
Samples of these cables were removed after 5 years and again after 10 years of exposure.
Physical and electrical tests were conducted to determine the degree of degradation of the cable components.
In all cases, the cables were in good' condition with no more deterioration observed than would be ex-pected over a similar period in a non-nuclear environment.
In fact, in one instance, the physical properties of the cable sample actually improved during the ten year period.
Id.
94.
With regard to this program, the Board stated at page 9 of its January 23, 1986 Memorandum and Order:
Applicants have not stated what signifi-cance is to be derived from results of the Duke Power Company's cable surveillance program, vis-a-vis a 40 year service life
]
in VEGP.
95.
In response, Applicants testified that the signifi-cance of the Duke Power Company's cable surveillance program is that 10 year exposure to the low dose-rate radiation actually encountered in operating nuclear power plants has not done de-tectable harm thus far to cables of the same general type that are used at VEGP.
Furthermore, the results demonstrate that there will be plenty of time to benefit from. operating experi-i i
ence gained from other plants and to take any necessary correc-
]
l tive action if significant dose-rate-effects are identified.
Id. at 14-15.
l 1
.i
C.
The Scope and Results of the Mechanical Stress Tests on Prototype VEGP Cables 96.
In the prior affidavit, Applicants' affiants noted that with respect to electrical insulation, Gillen and Clough have suggested that mechanical properties are of interest pri-marily when considering the effect of catastrophic failure under the influence of some applied stress.
The affiants re-marked that cable qualification tests at VEGP currently include a mechanical durability test for cable applied following the simulated normal and accidental environmental conditions.
97.
With respect to this assertion, the Board stated at page 9 of its January 23, 1986 Memorandum and Order:
The scope and results of the mechanical stress tests on prototype VEGP cables are not explained.
98.
In response, Applicants testified that the stress test is applied to test samples of all VEGP safety-related ca-bles during environmental qualification.
The test complies with IEEE 383-1974, section 2.4, which states:
Upon completion of the LOCA simulation, the specimens should be straightened and re-coiled around a metal mandrel with a diame-ter of approximately 40 times the overall cable diameter and immersed in tap water at room temperature.
While still immersed, these specimens should again pass a voltage withstand test for 5 minutes at.a potential of 80 V/ mil ac or 240 V/ mil dc.
1 NOTE:
The post LOCA simulation test demonstrates an adequate margin of safety by requiring -
mechanical durability (Mandrel bend) fol-lowing the environmental simulation and is more severe than exposure to two cycles of the environment.
Id.
The samples used to qualify each type of VEGP safety-related cable passed this test.
Id. at 15-16.
See also Tr.
568-70 (Quasny, Kitchens).
D.
Applicants' Maintenance and Surveillance Program 99.
In the NRC Staff's Response to Applicants' Motion for Summary Disposition of Contention 10.1 (Dose-Rate Effects),
dated August 26, 1985, the NRC Staff indicated that Regulatory Guide 1.33, Rev. 2, requires applicants for an operating license to develop and implement surveillance and maintenance procedures for detecting age-related degradation and to take i
corrective action before a safety problem develops.
In the January 23, 1986 Memorandum and Order, at page 10, the Board
. stated:
Regarding the Staff-imposed operational surveillance program, about which Appli-cants are silent, the Board has been unable to identify from the materials before us what it is that Staff will require of Applicants, the nature of Applicants' sub-mittal that has been approved by Staff, what is yet to be developed in satisfaction of Staff's requirement, and how and on what schedule the Staff will want said program to be implemented.
1 100. Responding to this issue in the hearing, Applicants i
described their maintenance and surveillance program.
Prior to.
8 l
f l
fuel loading at Unit 1, Applicants will implement a Maintenance j
and Surveillance Program following tlye guidance of Regulatory Guide 1.33, Rev. 2.
Bockholds et al.,
ff. Tr. 561, at 2.
Reg-ulatory Guide 1.33 endorses the more detailed guidance contained in American Nuclear Society /American National Stan-dards Institute Standard ANS-3.2/ ANSI N18.7-1976, "Administra-tive Controls and Ouality Assurance for the Operational Phase of Nuclear Power Pla'nts."
This standard defines the scope and content of a maintenance / surveillance program for safety-related equipment which is accep' table to the Staff.
..The pro-
]'
gram should assure that provisions for preventing or detecting f
age-related degradation in safety-grade equipment are specified i
{
and include (1) utilizing experience with similar equipment, 1
(2) revising and updating the program as experience is gained J
with equipment during the life of the plant', (3) reviewing and evaluating malfunctioning equipment and obtaining adequate re-1 placement components, and (4) establishing surveillance tests and inspections based on reliability analyses,. frequency and I
type of service or age of the items, as appropriate.
Mascian7 tonio on 10.1, ff..Tr. 576, at 5-6.
a
- ~
101. At VEGP, Planned'Maint6 nance and Surveillance is a
]
program that schedules equipment maintenance, calibration, and surveillance activities.
Its purpose is$to maintain equipment in a condition safe for operation, - minimize unplatined outages due to breakdown, and provide a mechanism by which greater than l
l i
1 i
e s~'
'l.
,,-4,
,},,
,,.a.
,.n.,--w,
anticipated degradation of safety-related equipment can be de-tected and remedied.
Bockhold et al.,
ff..Tr. 561, at 2-3.
102. Under the program, a planned maintenance and surveil-lance checklist is prepared for each piece of safety-related equipment and identifies the maintenance and surveillance tasks to be performed.
The content of the program is derived from the following sources:
Manufacturer / Vendor recommendations Lubrication requirements Calibration requirements Field verification of equipment de-scriptions Industry experience Qualification testing results Id. at 3-4.
103. With respect to Contention 10.1, the qualification testing results have special significance.
All vendors sup-plying safety-related equipment to Plant Vogtle are required to identify critical, age-sensitive, environmentally-degradable organic components and to specify replacement intervals based on test or analysis.
Bechtel, the VEGP Architect-Engineer (AE), reviews and verifies each vendor's test and analysis re-sults.
The information is then used in preparing Environmental Qualification Data Packages (EQDPs) which include maintenance and surveillance requirements specified by vendors.in their test reports.
Id. at 4.
104. These EQDPs are transmitted to Applicants' Environ-mental Qualification Task Force (EQTF), whi.ch reviews the ven-dor's information and the AE's evaluation for completeness and validity.
If satisfactory, the EQTF approves each EQDP and 3
transmits a copy to the VEGP Equipment Qualification (EQ) group.
The EQ group identifies all equipment tag numbers in-cluded in the EQDP and transmits this information along with the maintenance and' surveillance requirements from the EQDP to the Planned Maintenance (PM) group.
The PM group then prepares replacement schedules, planned maintenance and surveillance checklists, and procedures (if necessary).
Id.
105. In addition to that required by the planned mainte-nance and surveillance checklists, surveillance and operability testing are performed under the VEGP Inservice Testing Program-and the Technical Specification Surveillance Program.
The Inservice Testing is conducted in accordance with ASME Section XI.
All safety-related pumps with a Class 1E power source and safety-related active valves required by ASME Section XI are tested on a regular basis.
The pump testing includes determi-nation of flow curves, vibration, bearing temperatures, and differential pressure.
The valve testing _ includes determina-tion of leak rates for isolation valves, stroke times, fail safe verification, and position indication verification.
The Technical Specification Surveillance Program covers all equip -
ment required by the VEGP Technical Specifications.
The VEGP.
N'
Technical Specifications specify requirements for test frequen-cy, acceptability of testing, and measured. parameters.
Id. at 4-5.
106. When required, corrective maintenance will be per-formed to assure that equipment will operate satisfactorily.
Such corrective m,aintenance will become part of an equipment history file.
Proper documentation of corrective maintenance actions will highlight recurring situations in similar equip-ment and will provide data to identify component past-performance trends.
Furthermore, equipment or component fail-ures detected in other nuclear power plants will be available to VEGP through Industry Event Reports, NRC IE Bulletins, In-formation Notices, Letters, and Directives, and Manufacturers' Information Notices.
VEGP will review these reports to deter-mine their applicability and will modify its maintenance and surveillance program accordingly.
Id. at 5-6.
107. With respect'to the surveillance activities that will be performed on safety-related cables, the maintenance and sur-veillance program for safety-related motors includes a provi-sion for the meggering of insulation in accordance with the manufacturers' recommendations, typically every 72 nonths.
This testing is planned to be performed for the motors from th*
associated motor control center or switchgear.
Thus the cables and electrical penetration assemblies will be meggered with the motor windings.
This surveillance is capable of detecting.
s, j
l insulation degradation, and the location of degradation can be j
traced to determine which component is at fault.
Id. at 6.
108. In addition, a program will be implemented to period-ically inspect selected cables inside~the containment.
The ca-1 bles will be selected by type.and material to envelope VEGP instrument and control cables.
The location or locations of the' inspected cables will be selected in areas where higher temperature and radiation fields'are anticipated.
The inspec-tion will be a visual check of the cables to identify signs of degradation, i.e.,
cracking, flaking, discoloration or pow-dering of the exterior of the cable.
The first (baseline) inspection will be conducted prior to commercial operation, and visual inspection will be periodically repeated every five.
l years.
This interval is adequate; since all VEGP safety re-i lated cables have undergone an IEEE-323-1974 qualification pro-gram, which included pre-aging, and all have a qualified life of 40 years, rapid degradation of cables should not occur.
Id.
at 6-7.
109. The NRC Staff has reviewed Applicants' cable surveil-lance program and has found it acceptable.
Formal approval of the program in the SER is forthcoming.
Tr. 578-79 (Mascian-tonio).
4 I
a,
~ -
l E-The Significance of Applicants' Maintenance and Surveillance Program 110. Also with respect to Applicants' maintenance and sur-veillance program, the Board stated:
t
~
The Staff's reliance upon a future opera-tional surveillance program as justifiction for granting Applicants' motion rather than upon the efforts and accomplishments re-ported by the affidavit of Applicants is not satisfactorily explained.
111.
Applicants responded that critical, age-sensitive environmental-degradable components in safety-related equipment located in a harsh environment are environmentally qualified for their service life by test or, analysis, and this qualifica-tion does not depend on maintenance or surveillance.
Mainte-1 I
nance and surveillance does, however, provide a mechanism by-f which greater than anticipated degradation of such components can be detected and remedied.
Hence, the maintenance and sur-veillance program provides additional assurance that safety-related equipment will perform its intended function if needed.
Bockhold et al.,
ff. Tr. 561, at 7.
See Masciantonio on 10.1, ff. Tr. 576, at 5-7; Tr. 578 (Masciantonio).
1 IV.
Contention 10.5 112. Contention 10.5 concerns the environmental qualifica--
tion of solenoid valves manufactured by Automatic Switch Com-i pany ("ASCO") used to perform safety functions at VEGP.
Four I i i
i l
- ~. _ _,,, _. - _ -
types of ASCO solenoid valves are utilized in safety-related applications at VEGP.
ASCO designates those four valve types as models NP 8316, NP 8320, NP 8321, and 206-381-6RF.
Baenteli 1
et al.,
ff. Tr. 517, at 5.
The acceptability of these valves was demonstrated in this proceeding by the comprehensive testi-mony presented by Applicants' and the NRC Staff's witnesses.
These witnesses were well-qualified, knowledgeable experts.
A.
The Use of ASCO Solenoid Valves at VEGP 113. The ASCO solenoid valves used~in safety-related func-tions at VEGP direct the operation of air-operated process valves and dampers in safety-related fluid and HVAC systems by controlling air flow to the air operators on these valves or dampers.
By either venting or providing air to the air opera-tor on the process valve or damper, the ASCO solenoid valve en-ables that valve or damper to close or open.
Id. at 7-8.
Table 10.5-1 of the Applicants' testimony lists each of the safety-related air-operated valves or dampers.at VEGP con-trolled by an ASCO solenoid valve and describes the function performed by that valve or damper.
Id. at 9-10.
114. The safety function of each ASCO solenoid valve is to vent the operator of the air-operated valve or damper with which it is associated to allow that valve or damper to move to its safety-related position.
All of the ASCO solenoid valves employed in safety-related capacities at VEGP are of the i
normally closed design.
This means that when de-energized, which is its safety-related position, the solenoid valve blocks the supply of instrument air and vents the air operator of the process valve or damper.
The process valves and dampers that are controlled by ASCO solenoid valves are arranged so that the process valve or damper will assume its safety-related posi-tion, either open or closed, when the air operator is vented.
~
I_d. at 8-9.
B.
Environmental Qualification Testing Performed on the ASCO Solenoid Valves Used at VEGP 115. Environmental qualification testing has.been per-formed upon ASCO solenoid valves in two separate generic quali-fication testing programs, most recently by ASCO and Westing-house acting jointly and earlier by Isomedix, Inc. on behalf of ASCO.
Id. at 19.
In addition, Franklin Research Center
(" Franklin") has conducted testing on ASCO solenoid valves in a qualification methodology research test sponsored by the Nuclear Regulatory Commission, Office of Nuclear Regulatory Re-search.
Masciantonio on 10.5, ff. Tr. 550, at 3, 11.
1.
The Joint Westinghouse and ASCO Environ-m, ental Qualification Testing Program 116. In 1980 and 1981, Westinghouse and ASCO-jointly con-i ducted an environmental qualification testing program for vari-ous ASCO solenoid valves.
A total of 14 valves were tested, 1
1 including two model NP 8316 valves with ethylene propylene elastomers, two model NP 8320 valves with ethylene propylene and viton elastomers, one model NP 8321 valve with viton elastomers, and one 206 series valve with ethylene propylene elastomers that were representative of the ASCO solenoid valves used at VEGP.
The other test valves, while not representative of valves used at VEGP, had some features in common with those four models of valves.
Baenteli et al.,
ff. Tr. 517, at 19-21.
117. The joint Westinghouse /ASCO qualification program was conducted in accordance with the Institute of Electrical and Electronics Engineers'("IEEE") Standard 323-1974, "IEEE Stan-dard for Qualifying Class IE Equipment for Nuclear Power Generating Stations;" IEEE Standard 344-1975, "IEEE Recommended Practices for Seismic Qualification of Class IE Equipment for Nuclear Power Generating Stations;" and IEEE Standard 382-1972, "IEEE Trial-Use Guide for Type Test of Class 1 Electric Valve Operators for Nuclear Power Generating Stations."
Addition-ally, the qualification program was performed in accordance with the methodology. set forth in WCAP-8587, " Methodology for Qualifying Westinghouse WRD-Supplied NSSS Safety-Related Elec-trical Equipment," which has been accepted by the NRC Staff.
Id. at 21-22.
118. The tests comprising the qualification program con-sisted of initial performance tests; thermal, mechanical, pressurization, and normal environment radiation aging; - -
vibration aging, operating basis earthquake simulation, and resonance search test; safe shutdown earthquake simulation; de-sign basis event environmental radiation exposure; and high en-ergy line break ("HELB") environmental testing.
Id. at 22.
During the course of the tests, vaive performance was observed.
While certain anomalies in performance were observed, evalua-tion of those anomalies demonstrated that they do not affect
{
the qualification of the valves for use at VEGP.
l 119. The model 206-381-6RF valve and the model NP 8320 valve with. ethylene propylene elastomers successfully completed all phases of the qualification testing.
Id. at 23.
120. The solenoid core of the model NP 8320 valve with viton elastomers would not shift when first cyc2<a following the design basic event environmental radiation testing until the operating voltage was increased due to adherence of the viton dynamic seal to t he brass seating surface as a result of degradation caused by radiation exposure.
As a result, ASCO considers model NP 8320 valves with viton elastomers to be qualified to the test levels used in the joint Westinghouse /
ASCO program only for those applications where the valves are not required to shift position following exposure to gamma doses in excess of 20 megarads.
While VEGP does use NP 8320 l
valves with viton elastomers in safety-related applications, i
none of these applications would require the valve to shift po-sition after exposure to radiation in excess of 20 megarads.
Id. at 24..
--g
--e-
k 121. One of the two model NP 8316 valves with ethylene propylene elastomers tested completed a sufficient portion of the HELB environmental testing to simulate operation for more than one year after a design basis accident, which is the length of time that Westinghouse's generic specifications re-quire the valves to be able to operate after such an accident, but then encountered performance problems prior _to the comple-i tion of the full 30 day HELB test period.
In the HELB environ-mental testing, a period of 3.65 days at 265 F following the second transient simulated one year of actual post-accident service.
The model NP 8316 valve would not actuate at the min-imum DC voltage (90 VDC) when energized thirteen days into the test.
When the voltage was increased to 125 VDC, the valve ac-tuated and continued to require at least 110 VDC to actuate for the remainder of the thirty day test period.
Id. at 24-25.
122. Later inspection of the valve revealed that the in-crease in the voltage needed to actuate the valve had resulted from moisture and chemical spray entering the valve solenoid enclosure and over time reducing the coil insulation resis-i I
tance.
This moisture entered the solenoid housing through the conduit nipple opening through which the electrical leads pro-O viding electric power to the solenoid pass.
In the test that opening was not required to be leak tight and thus was not hermetically sealed.
The seal for the conduit opening is not part of the valve, and ASCO does not supply such seals with the l i
i j.
Id. at 25-26.
As discussed in paragraph 165, moisture entering the solenoid _ housing of any of'the ASCO sole -
+
noid valves at VEGP cannot prevent that valve from performing
{
its safety-related function.
Id. at 26-28.
i 123. The other model NP 8316 valve with ethylene propylene elastomers tested performed successfully before, during,.and after the HELB environmental testing.
Upon disassembly subse-
~
quent to the full 3d day HELB testing period and the' final op-l erational check, the diaphragm of the valve was-found to be stuck to the valve body, which caused a tear in the diaphragm.
This sticking of the diaphragm did not represent a test failure i
because it occurred.after successful completion of the HELB j
testing and final operational tests.
Moreover, the thirty day
- i I
testing period to which the valves were. subjected-in'the HELB l
testing simulated approximately eight years of service after a design basis event, which provided a considerable margin over the one year period that Westinghouse generically specifies that the valves be operational following a design basis event.
i Id. at 28.
l 124. In the HELB environmental testing, the model NP 8321 q
valve, which had resilient seats made of viton elastomers, j
would not shift to its de-energized position on the twelfth day i-of the test period.
While the model NP 8321 valve did not suc-cessfully complete fully the full 30-day HELB environmental' testing, the twelve-day period that the valve continued to t
} -
i
operate after exposure to accident conditions represents in ex-cess of a year of post-accident operation at VEGP.
Therefore, those test results do provide a basis for concluding that the NP 8321 valve is qualified for use at VEPG.
Id. at 28-29.
125. For model NP 8321 solenoid valves with viton elastomers, ASCO restricts their qualification to applications where the valves will not be required to shift position follow-ing exposure to gamma doses in excess of 20 megarade.
While some NP 8321 valves with viton elastomers are used in safety-related applications at VEGP, none of those applications re-i quire the valve to shift position after being exposed to gamma-
~
radiation in excess of 20 megarads.
Id. at 29-30.
j 126. The joint Westinghouse /ASCO testing program qualified the ASCO model NP 8316, NP 8320 and 206-381-6RF solenoid valves to the Westinghouse specified generic HELB environmental ex-tremes of (a) a peak temperature of 420*F, (b) pressure of 57 psig, and (c) a chemical spray of 2500 ppm boron buffered with sodium hydroxide to a pH of 10.5.
Id. at 30.
As dis-cussed in paragraph 147, based upon the NRC Staff's evaluation of the Franklin tests, Westinghouse subsequently modified the temperature profile to which it considers the model NP 8316 valve to be qualified to reflect a peak temperature of 400'F.
Id. at 48-49. i
1 l
2.
Environmental Qualification Testing Performed on Behalf of ASCO by Isomedix, Inc.
127. In the late 1970s, Isomedix, Inc. performed qualifi-cation testing for ASCO on several models of ASCO solenoid valves.
The seven test valves included one model NP 8316 valve, one NP 8320 valve, and one NP 8321 valve.
ASCO also tested a model 206-381-6F valve, which differs from the 206-
~
381-6RF valves used at VEGP only in that it has metallic rather than resilient seats.
Id. at 31-32.
128. The Isomedix testing program was based upon IEEE 323-1974, IEEE 382-1972, IEEE 344-1975, and IEEE 382/ ANSI N278.2.?.
4 (Draft 3, Rev. 1 June 1977) " Draft American National Standard for the Qualification of Safety Related Valve Actuators."
Id.
at 32.
129. In this testing program, Isomedix thermally aged the test valves at a temperature of 268*F for twelve days to simu-late a design life of four years.
During that thermal aging, the valves were continuously energized except for five minutes once every six hours when they were cycled by being de-ener-gized.
The valves were then radiation aged and wear aged.
i Next, the valves underwent seismic simulation, vibration endur-ance testing, and design basis event environmental radiation exposure.
Finally, Isomedix exposed the valves to simulated LOCA conditions.
Those conditions included a peak temperature of 346'E and peak pressure of 110 psig that were imposed for i
- s.
m
.m
i approximately three hours.
Id. at 33.
The performance of the valves was observed throughout the tests.
As in the Westing-house /ASCO testing program, certain anomalies occurred in valve performance.
Evaluation of those anomalies has shown that they do not call into question the qualification of the valves test-ed for use at VEGP.
130. The model NP 8316, NP 8320, and 206-381-6F valves performed satisfactorily.
The model NP 8321 valve initially utilized by Isomedix in the test program developed excessive seat leakage (50 SCEH) both in the energized and de-energized states after seven days of the thermal aging portion of the test procedure.
The cause of the excessive leakage was deter-mined to be dirt in the valve originating from pipe attached to the valve as part of the test set up.
Because the cause of the performance problems with the model NP 8321 valve was external-ly introduced contaminants resulting from a deficiency in the test apparatus, ASCO substituted another model NP 8321 valve in the test.
Id. at 33-34.
131. This new model NP 8321 valve was thermally aged at 295*F for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> and was cycled every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Isomedix chose this higher temperature and lower thermal aging period to accelerate the test program.
After approximately 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of this thermal aging, the valve started leaking in the energized state.
The valve shifted properly and had no leakage in the de-energized state.
Id. at 34.
, l
l 132. Isomedix determined that the seat leakage resulted from the softening and resultant degradation of valve slastomer f
material caused by the higher temperature of 295*F used in the thermal aging.
Normal 140 F ambient temperature would not cause noticable softening of this material.
As the valve per-formed its safety function, the thermal aging continued and the 4
other tests were conducted on this valve in the same manner as on the other test valves.
As a result of the ceat leakage en-
)
countered during thermal aging, ASCO reduced the specified max-imum operating pressure differential at which the model NP 8321 valve can operate from 200 psig to 150 psig.
This change re-sulted in a 25% load reduction on the resilient seat. Id.
at 34-35.
1 133. At the end of the LOCA simulation, the coil of the model NP 8321 valve had an insulation resistance of less than one megohm, as a result of spray solution in the solenoid en-closure having degraded the coil insulation.
The spray solu-tion entered the solenoid enclosure as a result of a breakdown of the plastic covering on the flexible electrical conduit through which the electrical leads to the solenoid passed.
I That conduit was qualified for peak temperatures of only 120 F.
3 Isomedix concluded that the coil would have been satisfactory except for the adverse effect of the spray solution, which con-dition resulted from the use of an unqualified conduit and not i
from any problem with the model NP 8321 valve itself.
Id.
l 1
at 35.
As described in paragraph 165, moisture entering thei t
solenoid housing of any of the ASCO solenoid valves used at VEGP cannot prevent that valve from performing its safety-related function.
Id. at 26-28.
134. The environmental extremes to which the ASCO valves tested by Isomedix were qualified include (a) a peak tempera-ture of 346*F, to which temperature the valves were exposed for approximately three' hours; (b) peak pressure of 110 psig; and (c) a chemical spray consisting of 3000 ppm boron buffered with sodium hydroxide to a pH value of 10.
Id. at 36.
3.
The Franklin Research Center Testing Program 135. In 1981 Franklin Research. Center (" Franklin") initi-ated a testing program on ASCO solenoid valves under a contract I
from the NRC.
Id.
That testing program was not intended to be an environmental qualification testing program but to be a re-search program to test qualification methodology.
Masciantonio on 10.5, ff. Tr. 550, at 3-4, 11.
The valves tested by Franklin included two model NP 8316 valves, one model NP 8320, and one model NP 8321, all with ethylene propylene elastomers.
Franklin also tested a model 206-381-6F valve, which is the same as the model 206-381-6RF valves used at VEGP except that it has metallic rather than resilient seats.
Baenteli et al.,
ff. Tr. 517, at 36. 4
. m.m.
l 4
136. Following functional tests, Franklin artificially
-aged one of the model NP 8316 valves and the model NP 8320, NP 8321, and 206-381-6F valves to simulate a four-year life at 140 F.
Those valves were irradiated to a total integrated dose of 50 megarads and then exposed to a temperature of 268*F for t
approximately fifteen days. The valves were cycled 2000 times
~
1 over the thermal aging period while at that elevated tempera-
]
ture.
Id. at 36-37.
1
]
137. Following this artificial aging, the model NP 8321
]
valve was removed from the test program because of seat leak-i age.
Id. at 38.
The seat leakage encountered by Franklin with j
the artificially aged model NP 8321 valve that it tested does i
j not call into question the environmental qualification of that f
model valve for use at VEGP.
f j
138. The severity of the artificial' aging process employed by Franklin was a primary cause of the NP 8321 valve's perfor-j mance in the Franklin tests.
The artificial thermal aging pro-i cess employed by Franklin imposed conditions on.the elastomeric parts of the valves that were far in excess of' normal condi-
+
]
tions or the standards for accelerated aging established by IEEE 323-1974.
Id. at 37.
Cycling at high aging temperatures j
is not a normal condition for the valves and presents a very severe condition for their elastomeric. parts.
Id. at 44.
In.
its test report, Franklin acknowledged that its artificial aging process was overly severe, stating:
4 l
i l
I
~ _.
i l
Cyclical aging during thermal aging presents a different type of over-conserva-tism.
IEEE Std 382-1980 requires that 10%
l of the operational cycles be conducted dur-1 ing thermal aging at the thermal aging tem-perature.
However, when dealing with or-4 l
ganic seats and seals, it should be determined if the cycling of'the valves at the accelerated aging temperature may in-j troduce stresses on the material that might not exist in normal operation."Ihe EPDM discs and seats common to these valves i
raise this possibility.
Since a previous 4
test (the Isomedix test] did indicate soft-ening of the EPDM during thermal aging at 295*F (146*C), the aging at 268*F(131 C) f may have produced softening and the cycling at this temperature may have produced stresses not present in normal operation.
i NUREG/CR-3424 at 2-64.
In a separate Appendix to NUREG/CR-3424 describing the thermal aging analysis, one of the report's authors concludes that "it was inappropriate to cycle a' sole-l noid valve containing elastomeric seals at ambient temperatures in excess of normal rated ambient temperatures (140*F/60*C and j
180*F/82*C for the valves discussed in.this report)."
Id.
at C-1; Baenteli et al.,
ff. Tr. 517, at 37-38.
Because Franklin's test conditions were not representative of condi-i l
tions the NP 8321 valve might experience in a nuclearffacility l
j such as VEGP, Franklin's test results have no applicability to I
and cast no doubt upon the environmental qualification of the i
model NP 8321 valve for use at VEGP.
Id. at 49-50.
1 139. The other model NP 8316 valve had been naturally aged
}
by ASCO at 140*F for three years, without any radiation expo-sure.
That valve had been cycled 2000 times at room
}
temperature.
Id. at 39.
I s
' t 4
I
i.
l 1
l 140. All the valves then underwent pressurization testing, i
vibration aging, resonance search, seismic. testing, design basis event radiation exposure, and a simulated composite LOCA t
i and MSLB exposure.
Id.
t 141. The ASCO model 206-381-6F valve performed satisfacto-rily-through all of the' tests.
The model NP 8320 valve tested f
by Franklin Research Center functioned throughout the tests.
i
^
In the functional testing following the completion of the LOCA/
i MSLB simulation, however, the model NP 8320 valve did experi-l ence seat leakage.
No seat leakage had been observed with the model NP 8320 valve prior to that point, including during the LOCA/MSLB simulation, and the seat leakage did not prevent the valve from being cycled.
Id. at 40, 49.
The results obtained by Franklin do not call into question the qualification of the model NP 8320 valve to the conditions to which it was tested in
]
the Westinghouse /ASCO testing program because of the excessive-ly severe artificial aging process used by Franklin.
Id.
i at 49.
4 142. The model NP 8316 valve that had been artificially 1
)
{
aged could not be cycled properly between the first and second transients of the composite LOCA/MSLB simulation.
Prior to the e
f start of the second transient, Franklin was again able to cycle j
the valve, and it continued to function until four days elapsed k
time in the LOCA/MSLB simulation.
At that time, the test valve
{
cycled to the open position (i.e., process cylinder i
I i
4 i i
i
=
~
pressurized) when energized but did not transfer back when de-
}
energized.
Further attempts to cycle the valve were unsuccessful.
Id. at 41.
143. As with the other test. valves that Franklin artifi-cially aged, the differences in the performance of the artifi-j cially aged NP 8316 valve in the Franklin tests and in the l
prior Westinghouse /ASCO testing program can be attributed to f
differences in test procedure, particularly the overly severe i
artificial aging procedures used.
JJ. at 44.
i 144. The naturally aged model NP 8316 valve stopped I
j cycling between the first and second LOCA/MSLB transients, 1
i began to function again, and continued to operate until 25.6 i
j hours into the second transient.
After that point no further j
cycling could be accomplished. Id. at 42.
145. The Applicants-also attribute the failure of the nat-l urally aged model NP 8316 valve in the Franklin program to dif-ferences in the testing procedures used in the joint Westing-f house /ASCO testing program and the Franklin tests.
The l
targeted peak temperature during the LOCA/MSLB simulations in 1
both testing programs was 420*F.
The actual temperature peaks 1
4
{
reached in the Westinghouse /ASCO tests for the two transients l
were 440*F and 450*F.
For the two transients in the Franklin 1
LOCA/MSLB simulation, the temperature peaked at 450*F and 466*F.
Thermocouple data from the test chamber in the Franklin test indicate that the surface temperature of the naturally a
a
aged model NP 8316 valve, which would lag behind the test cham-ber temperature, reached 410 F, substantially higher than the 350*F to 360*F temperatures reached by any other valve in the test chamber that had a' thermocouple either inside its coil en-closure or taped to its body, including the other model NP 8316 j
valve.
The substantial difference in the temperatures reached by the two NP 8316 valves indicates that the mass flow rate and j
velocity of steam at" each valve was different and that the valves in the test were not exposed to uniform conditions.
When the valve reaches a temperature of 410*F, the elastomers in the valve are well above their damage threshold and would j
degrade rapidly.
Id. at 47-48.
146. With respect to the artificially aged valves in the 1
i Franklin tests, the NRC Staff discounts their failure, i
j concluding that those test results were inconclusive due to the l
severe preconditioning to which those valves were exposed.
With respdet to the naturally aged model NP 8316 valve, the-NRC Staff decided that its failure in the Franklin tests called i
into question the results obtained with that valve during the l
joint Westinghouse /ASCO testing program.
That model ASCO sole-l noid valve, the NRC Staff concluded, was acceptable for use i
only under the environmental conditions to which that valve had 1
2 been tested earlier by Isomedix.
Id. at 42-43.
Masciantonio on 10.5, ff. Tr. 550, at 4, 13-14, 17.
i 1 1 l
o T
147. Although the Applicants believe that the failure of.
the naturally aged model NP 8316 valve in the Franklin tests i
does not call into question the validity of the Westinghouse /
I ASCO test results, in light of the NRC Staff's evaluation of the Franklin test results, Westinghouse has modified the gener-ic composite LOCA/MSLB temperature and pressure profile to-which it considers the model NP 8316 valve to be qualified by reducing the peak teImperature during each transient to 400 F.
l A thermal lag analysis performed by Westinghouse for the model NP 8316 valve, which analysis determines the temperature reached by the valve itself, has shown that upon exposure to 1
the conditions shown in the modified Westinghouse LOCA/MSLB.
t I
profile, the valve itself would reach a maximum temperature of 345 F.
That temperature is below the maximum temperature of 346*F that was reached by the model NP 8316 valve in the quali-fication testing program performed by Isomedix.
Baenteli et al.,
ff. Tr. 517, at 48-49.
The NRC-staff has reviewed the thermal lag analysis and concluded that the approach used to generate the derated Westinghouse generic LOCA/MSLB profile is reasonable and is acceptable as a means of establishing an en-I vironmental qualification level for the model NP 8316 valve.
f Masciantonio on 10.5, ff. Tr. 550, at 14-15.
i 1
4 i !
L l
l-C.
The ASCO Solenoid Valves.Used in Safety-Related l
Applications at VEGP are Environmentally Quali-fied for Use in the Environmental Conditions to Which They Might be Exposed at VEGP i
l 1.
The Environmental Conditions at VEGP (a)
Inside Containment 148. The maximum environmental extremes to which the ASCO solenoid valves located inside containment might be subjected under accident conditions at VEGP are (a) a peak temperature of 400 F, (b), pressure of 50 psig, (c) radiation of 200 megarads total integrated dose, and (d) a chemical' spray of 2000 ppm boron buffered with sodium hydroxide to a short term pH (less than 100 minutes) of 10.5 and a long term pH (more than 100 minutes from the beginning of the LOCA) of 8.5.
Baenteli et al.,
ff. Tr. 517, at 50.
(b)
Outside Containment (Except the MSIV Areas) 149. Most of the rooms outside containment are subject to mild environmental conditions even following postulated design basis accidents.
The harshest environment that would be expe-rienced under accident conditions by ASCO solenoid valves out-side containment, except in the main steam isolation valve
("MSIV") areas, is a peak temperature of 250*F, a peak pressure of 3.5 psig, and radiation of 100 megarads total integrated dose.
Id. at 51..
...a
(c)
MSIV Areas 150. The most severe temperature and pressure conditions to which safety-related ASCO solenoid valves located outside containment might be exposed would occur in the MSIV areas.
The conditions to which the Applicants have required safety-related equipment located in the MSIV areas outside containment to be qualified are a peak temperature of 320 F, a peak pres-sure of 15 psig, and radiation of 50 megarads total integrated dose.
The Applicants have recently determined, however, that the peak temperature in the MSIV areas outside containment could exceed 320 F in the event of a steam line break outside of containment that resulted in a steam generator tube bundle being uncovered, causing superheated steam to be released.
Id.
at 51-52.
151. Two models of ASCO solenoid valves, the NP 8320 and NP 8321 valves, are located in the MSIV areas and would have to function following a main steam line break.
As discussed in paragraph 153, a thermal lag analysis performed by Westinghouse demonstrates that the temperature reached by the NP 8320 and NP 8321 valves in the MSIV areas under superheat conditions will not exceed the Isomedix test envelope of 346*F.
Id.
at 53-54.
2.
The Model NP 8316 Valve is Environ-mentally Qualified for Use at VEGP 152. The model NP 8316 ASCO solenoid valve is used in safety-related applications at VEGP both inside and outside containment.
One NP 8316 valve is located in the MSIV area outside containment.
It, however, performs no safety-related function for any steam line or feed line break in the MSIV area. The model NP 8316 valve has been shown to be environ-mentally qualified for use at VEGP either inside or outside containment by both the Westinghouse /ASCO and Isomedix qualifi-cation testing programs as supplemented by a thermal lag analy-sis performed by Westinghouse.
That thermal lag analysis dem-onstrated that for the modified Westinghouse LOCA/MSLB profile with a peak tem'erature of 400 F, the maximum temperature that p
would be reached by the model NP 8316 valve under LOCA/MSLB conditions woul.d be below the maximum temperature of 346 F that was reached by the model NP 8316 valve under the Isomedix testing program.
The temperature conditions to which the model NP 8316 ASCO solenoid valves located inside and outside con-tainment at VEGP must be environmentally qualified are enve-loped by the conditions profiled in Westinghouse's modified ge-neric LOCA/MSLB profile.
Id. at 54-56; Masciantonio on 10.5, ff. Tr. 550, at 15. -
3.
The Model NP 8321 Valve is Environ-mentally Cualified for Use at VEGP 153. The model NP 8321 ASCO solenoid valve is used in safety-related applications at VEGP only in areas outside con-tainment, including the MSIV areas.
Baenteli et al.,
ff.
Tr. 517, at 56.
For all safety-related applications of the NP 8321 valve, the most extreme pressure and radiation condi-tions to which that' valve might be subjected are enveloped by the conditions to which it was tested in the Isomedix testing program.
The most extreme temperatures to which the NP 8321 valves might be exposed at VEGP would occur in the MSIV areas as a result of superheat conditions following a main steam line j
break.
For those model NP 8321 valves located in the MSIV areas at VEGP, Westinghouse has performed a thermal lag analy-i sis using temperature profiles generated by Bechtel from gener-ic mass and energy release data developed by the Westinghouse Owners Group addressing the superheat issue.
That analysis demonstrates that under the worst case conditions, the tempera-f ture of the model NP 8321 valves located in the MSIV areas i
would not exceed 332*F, which is significantly below the 346 F temperature to which those valves were qualified in the Isomedix tests.
Id. at 56-57.
154. Further evidence of the environmental qualification j
of the NP 8321 valve for use at VEGP was provided by the joint Westinghouse /ASCO testing program.
Although the test valve __
0 representative of the model NP 8321 valve failed during the l
HELB environmental testing in the joint ASCO/ Westinghouse qual-ification program, that failure did not occur until twelve days j
into the test sequence, a period which simulated in excess of a year of post-accident operation at VEGP.
Id. at 57.
I 4.
The Model NP 8320 Valve is Environ-mentally Qualified for Use at VEGP 155. The model NP 8320 ASCO solenoid valve is used to per-
' form safety-related functions both inside and outside contain-ment, including the MSIV areas.
The model NP 8320 solenoid valve has been shown to be qualified for use in the environ-mental conditions to which it might be exposed at VEGP by the joint Westinghouse /ASCO testing program and the Isomedix testing program.
The conditions to which that model valve was tested in the Westinghouse /ASCO program exceeded the most se-l vere conditions to which that valve might be subjected at VEGP l
inside containment or outside containment in areas other than I
the MSIV areas.
For those model NP 8320 valves located in the l
MSIV areas outside containment, the thermal lag analysis per-formed by Westinghouse for model NP 8321 solenoid valves locat-i I
ed in the MSIV areas establishes that the temperature of the i
i ASCO solenoid valves in that area will not exceed 332*F, which is significantly less than the temperature of 346*F reached by those valves in the Isomedix tests.
The model NP 8320 valve is 4 m..
s similar in weight and has less surface area than the model NP 8321 valve.
Therefore, its thermal response would be such that it would not reach a peak temperature greater than the peak temperature.of 332 F that the thermal lag analysis demon-strated might.be reached by the model NP 8321 valve in the MSIV areas upon exposure to main steam line break conditions.
Id.
at 57-58.
5.
The Model 206-381-6RF Valve.is Environ-mentally Qualified for Use at VEGP l
I 156. The environmental qualification of the model 206-381-6RF ASCO solenoid valve has been demonstrated by the joint Westinghouse /ASCO qualification testing program and the Isomedix testing program.
No model 206-381-6RF solenoid valves are used inside containment or in the MSIV areas at VEGP.
All of these valves are located inside.the auxiliary building'and are subject to a peak temperature of less than 250*F.
There-fore, ASCO solenoid valve model 206-381-6RF is qualified for use in its safety-related applications at VEGP.
Id. at 58-59.
e,
[
e
D.
The Applicants Have Adequately Addressed the Five Specific Issues Designated for Hearing in the Licensing Board's January 7, 1986 Memorandum and Order-157. In its January 7, 1986 Memorandum and Order (Ruling on Motion for Summary Disposition of Contention 10.5 re: ASCO Solenoid Valves), the Licensing Board identified the following five issues to be addressed at the hearing on Contention 10.5:
(1)
There is no information offered that permits a determination of_whether any type of failure of any of the valve models considered will result in achieving an unsafe configuration for the valves cad /or dampers that are being controlled.
(2)
No basis is provided for the various statements about how long any of the valve models will be required to oper-ate in VEGP following an accident, nor is there an explanation of how it will be determined that any of the valve models will indeed be capable of the specified length of operating time following an accident.
(3)
It cannot be determined whether the unsealed solenoid housing on one
[NP 8316] valve specimen represents a quality control deficiency that can endanger VEGP operation.
(4)
Since no manufacturer's specifications for the various valve models are given (e.g. acceptable operating voltage ranges, air supply requirements and acceptable leak rates) the anomalous behaviors noted are difficult to eval-unte as to seriousness.
Likewise, the likelihood of valve leakage depending upon the duration of test conditions cannot be evaluated.
~,
(5)
The question of whether production models of the valves discussed may show different performance character-istics than did the specimens tested cannot be evaluated, since Applicants,
have not addressed the subject matter of 10 CFR 50.49(e)(8) in their motion.
Id. at 13.
1.
Can Any Type of Failure of an ASCO Solenoid Valve Result in the Associated Process Valve or Damper _ Reaching an Unsafe Configuration?
158. The first question raised by the Licensing Board con-cerns whether the ASCO solenoid valves used at VEGP could fail in a manner that would cause the process valve or damper being controlled to achieve an unsafe configuration.
159. In response, the Applicants testified that the possi-bility of a failure of an ASCO solenoid valve at VEGP that might result in the associated air-operated valve or damper not assuming its safe position cannot be eliminated completely.
One example of such a failure would be a gross leak of instru-ment air across the solenoid valve seat that exceeded the ex-haust capacity of the valve's exhaust port, which could prevent the associated air-operated valve or damper from attaining its safety-related position.
The testimony of the Applicants dem-onstrated, however, that VEGP systems are designed so that no single failure of an ASCO solenoid valve would jeopardize : safe plant operation, and the environmental qualification testing performed on the NSCO solenoid valves provides assurance that common mode failures of those valves will nct occur.
Baenteli et al.,
ff. Tr. 517, at 60-65.
These tests were properly con-ducted in accordance with accepted standards, and all anomalies in valve performance were adequately addressed.
Masciantonio on 10.5, ff. Tr. 550, at 12.
2.
Operability of ASCO Solenoid Valves Following a Design Basis Event 160. The second issue designated for hearing by the Li-censing Board quest.oned the length of time that the ASCO sole-noid valves used to perform safety functions at VEGP would have to remain operable following an accident and how the capability of the valves to remain operable after an accident had been de-l termined.
I 161. The testimony presented at the hearing demonstrated that for all safety-related equipment, including the ASCO sole-noid valves, the Applicants have specified in their equipment qualification program that equipment operability for a period of one year following a design basis event be demonstrated.
That one year period of post-accident operability, however, greatly exceeds the interval for which safety-related ASCO so-lenoid valves at VEGP would actually have to remain operable following the initiation of a design basis accident.
The safe-ty function performed by all of the ASCO solenoid valves used l
l at VEGP is to de-energize, thereby venting the air operator of
the associated process valve or damper.
Once de-energized, the ASCO solenoid valves are not required to shift position again in response to any accident conditions.
Those ASCO solenoid valves that are de-energized due to automatic safety signals will complete their safety-related function within seconds.
The other ASCC solenoid valves would be de-energized by remote manual plant operator action, which would occur within thirty minutes after suffic'ient alarm or other indication of the oc-currence of the initiating' event or in response to plant emer-gency operating procedures.
The de-energization of the ASCO solenoid valves would thus be complete within a few seconds to hours after the initiation of the design basis event.
Baenteli et al.,
ff. Tr. 517, at 18-19.
162. The environmental qualification testing performed on the ASCO solenoid valves by Westinghouse /ASCO and Isomedix has established the capability of those valves to withstand accie dent conditions and continue to operate properly for the period 1
in which they would have to perform their safety-related func-i tion.
In those testing programs the valves were aged to their j
end-of-lifetime condition for normal environments and then ex-posed to accident conditions.
Following exposure to accident conditions, the valves were required to continue functioning properly for a period that simulated several years of post-i accident operation.
Id. at 31, 33.
This testing established that the valves would remain operable following an accident for i
-m
--v
-r-,-
a period greatly in excess of the few hours in which they might be required to perform their safety-related function at VEGP.
Id. at 18-19.
3.
The Unsealed Solenoid Housing on the Model NP 8316 Valve Tested by Westinghouse /ASCO 163. The third question identified by the Licensing Board was whether the unsealed solenoid housing on one of the model NP 8316 valves tested by Westinghouse /ASCO reflected a quality control deficiency that might endanger safe operation of VEGP.
164. The Applicants testified that moisture entered the solenoid housing of one of the model NP 8316 valves tested by Westinghouse /ASCO through the conduit nipple opening as'a re-sult of the test setup.
ASCO does not supply a seal for the conduit nipple opening with its valves.
Since the moisture problem originated from a test setup deficiency rather than from the model NP 8316 valve itself, that problem does not evi-dence a potential quality control deficiency with ASCO solenoid valves.
Id. at 26.
165. Also, if a similar moisture problem were to occur with any ASCO solenoid valve used at VEGP, it could not affect that valve's ability to perform its safety-related function, which is to vent the air operator of the associated air-operated process valve or damper.
The design of the solenoid housing is such that the intrusion of moisture into the housing - -
does not affect the ability of the solenoid core to shift into its de-energized position.
Because the ASCO solenoid valves utilized at VEGP perform their safety-related function when the coil is de-energized, a valve's inability to shift position 1,
when energized to the minimum DC voltage specified, as occurred l
with the model NP 8316 valve in the joint Westinghouse /ASCO testing program, does not compromise the valve's ability to perform its safety-r' elated function.
Id. at 26-28.
1 l
- 4. -
ASCO's Specifications for Acceptable Oper-i ating Voltage Ranges, Air Supply Require-ments, and Acceptable Leakage Rates 166. The fourth issue identified by the Licensing Board concerned ASCO's specifications of acceptable operating voltage ranges, air supply requirements, and acceptable leakage rates for the various models of ASCO solenoid valves used at VEGP.
{
The Licensing Board also questioned whether the amount of seat leakage shown by the model NP 8321 valve tested by Franklin was dependent upon the length of time that the valve was left in the test program.
(a)
Operating Voltage Ranges 167. The Applicants testified that for its solenoid valves.
i..
operating on direct current, ASCO specifies a nominal applied voltage of 125 volts (125 VDC), with an acceptable operating voltage range of 90 to 140 volts.
For valves operating on i - - -
alternating current, ASCO specifies a nominal voltage of 120 volts of 60 cycle alternating current (120 VAC), with an acceptable operating range of 102 to 132 volts.
At VEGP, the power supplied to ASCO solenoid valves is designed to be either 125 VDC or 120 VAC, and the extreme voltage values expected on the VEGP electrical distribution system are within the accept-able operating voltage ranges specified by ASCO.
Id. at 10-11.
(b)
Air Supply 168. ASCO's specifications require that the air supply to the solenoid valves be instrument quality air.
The VEGP instrument air system provides a continuous supply of filtered, dry, oil-free compressed air that is of the quality recommended in the Instrument Society of America's Quality Standard for Instrument Air, ISA-S7.3.
Id. at 11.
169. The operating pressure differential for the air sup-
\\
ply must range between (a) the maximum differential pressure l
between the inlet and outlet sides of the valve against which the solenoid can safely operate and (b) the minimum operating pressure differential required for dependable operation.
The range of acceptable operating pressure differentials specified by ASCO differs for each model valve.
The operating pressures for the ASCO solenoid valves at VEGP are within the acceptable operating pressure differential range specified by ASCO for each of the models of ASCO solenoid valves used at VEGP.
Id.
at 11-12.
(c)
Seat Leakage 170. After manufacture and assembly, ASCO subjects each valve to a factory acceptance test that verifies the valve's operability and seat integrity.
To pass this test, valves with resilient seats must have no detectable seat leakage.
These manufacturing tolerances set by ASCO, however, are not related to leakage rates that would affect valve performance.
Id.
at 12-13.
171. The amount of seat leakage that would affect an ASCO solenoid valve's ability to perform its safety related function at VEGP, which is to vent the air-operator of the associated process valve or damper, would depend upon several factors, including the size of the vent port in the solenoid valve, the resistance to air flow in the instrument piping between the vent port and the actuator pressure chamber in the air operator of the process valve, and the residual pressure in the actuator i
pressure chamber.
Using a conservative analysis, the Appli-cants have determined the maximum tolerable leakage rates for the ASCO solenoid valves used to perform safety-related func-tions in the containment and MSIV areas at VEGP to be 3000 SCFH for the model NP 8316 valve, 75 SCFH for the NP 8320 valve, and i
555 SCFH for the NP 8321 valve.
Id. at 14-17.
172. ASCO's installation and maintenance instructions for the four types of ASCO solenoid valves used in safety-related i 1
applications at VEGP state that excessive leakage warrants inspection of the valve.
At VEGP excessive leakage in the ASCO solenoid valves would be monitored through operation of and pe-riodic testing of the associated process valve or damper.
If during normal operation or in-service testing the process valve or damper fails to cycle or cycles sluggishly, then the sole-noid valve would be checked.
Id. at 13, 67.
(d)
Leakage Shown by the Model NP 8321 Valve Tested by Franklin 173. The Applicants testified that while the seat leakage exhibited by the NP 8321 valve tested by Franklin could have increased had it been subjected to the remaining aspects of the testing program, any additional test results would have had little meaning in light of the overly severe artificial aging to which the model NP 8321 valve was subjected by Franklin.
The excessive severity of that artificial aging process was a primary cause of the breakdown of the valve's elastomeric mate-rial that produced the gross seat leakage found by Franklin.
Id. at 39.
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a i.
5.
Could Production Models of the Valves Show Different Performance Character-istics Than the Valves Tested)
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174. The Licensing Board's final question asked whether production models' of the ASCO solenoid valves used at VEGP might perform differently from the valve specimens tested and noted that the Applicants had not addressed the subject matter a
of margins, as requi. red by 10 C.F.R. 5 50.49(e)(8), in their motion for summary disposition.
175. In their testimony, the Applicants described the man-1 ner.in which the valve specimens used-in the qualification testing were obtained.
Those valves were procured from ASCO in=
l
.the same manner as any valves supplied to a nuclear plant such 1
as VEGP.
The valves tested were built using the same produc-tion procedures and using the same materials as valves that would be supplied to the field.
ASCO's quality assurance pro-I gram, which has been audited by Westinghouse and other vendors, ensures-that materials are not changed in the valves,'that ma-i terial suppliers remain the same, that identical production procedures are followed for every valve, that drawing changes are not made, and that design changes are not made.
Everything-i that can be done to ensure that the valve tested is identical in design, materials, construction, and testing to the valves supplied to a nuclear facility such as VEGP is done.
Tr. 537-38 (Cesarski).
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e i-i l
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176. The Applicants also discussed the margins present in the qualification testing.
The test conditions to which the test valves were exposed in the joint Westinghouse /ASCO testing program included margins in accordance with requirements of IEEE 323-1974 and 10 CFR S 50.49(e)(8).
The activation energy employed in establishing the length of the thermal aging por-tion of the environmental qualification program was the lowest activation energy for any of the materials in the valves.
The i
test conditions selected for the remaining' aging portions of the program were appropriate for a service life of 40 years even though the qualified life of the valves tested was eight years or less.
The LOCA/MSLB transients were applied twice in the design basis event portion of the testing program to pro-vide margin as suggested by IEEE 323-1974.
The actual peak temperatures reached during the LOCA/MSLB transients were 440 F and 448*F.
The Westinghouse specified generic qualification requirement was only 420 F.
The actual test pressure during the LOCA/MSLB transients reached a peak.of 68 psig, while the Westinghouse specified generic qualification requirement was 57 psig.
The valves were exposed to a total radiation dose of 8
2.05 x 10 rads, whereas the Westinghouse specified generic 8
qualification requirement is 1.82 x 10 rads total inte-grated dose.
Westinghouse specified that the valves be able to operate for one year under post-LOCA conditions.
Under the conditions used in the Westinghouse /ASCO testing, 3.65 days i
simulated that one year of post-accident operation, whereas the test valves were kept under those conditions for 30 days, which simulated approximately eight years of post-accident operation.
Baenteli et al.,
ff. Tr. 517, at 30-31; Tr. 544-45 (Cesarski).
177. The Applicants' testimony also demonstrates that ad-ditional margin exists between the most extreme conditions to which the ASCO solenoid valves might be exposed at VEGP and the conditions to which'they are qualified.
The most extreme con-ditions to which the Applicants require safety-related equip-ment located inside containment to be qualified are enveloped by the conditions to which those model solenoid valves located inside containment, the model NP 8316 and NP 8320 valves, have been exposed in qualification testing.
Included in those ox-treme conditions to which the Applicants require equipment to be qualified are margins of in excess of 40 F for peak tempera-ture, in excess of 15% for peak pressure, and in excess of 20%
for radiation.
Baenteli et al.,
ff. Tr. 517, at 51.
Simi-larly, for those valves potentially exposed to the most extreme environmental conditions outside containment, the model NP 8320 and NP 8321 valves located in the MSIV areas outside contain-ment, the maximum conditions to which those valves might be ex-posed are well below the extreme conditions to which those valves were tested and analyzed.
Id. at 54.
Thus margin ex-ists both in the qualification testing itself and in the dif-ference between the conditions for which the valves are.
environmentally qualified and the conditions to which they might be exposed at VEGP.
E.
The Testimony Presented by the Intervenors Does Not Call Into Question the Environmental Qualification of ASCO Solenoid Valves for Use at VEGP 178. At the hearing, the Intervenors presented testimony on Contention 10.5'from Dr. Howard Deutsch, employed by the Georgia Institute of Technology as a Senior Research Chemist.
While the record shows no reason to question the qualifications of Dr. Deutsch as a chemist, his testimony reflected nothing in his educational background, training, or work experience that even remotely related to the nuclear industry in general or en-vironmental qualification of equipment for use in a nuclear facility in particular.
Deutsch, ff. Tr. 371, at 1; Tr. 360-62 (Deutsch).
Dr. Deutsch has never had any involvement in de-signing, testing, or evaluating the performance of solenoid valves.
Tr. 360-61 (Deutsch).
Because of his lack of prior involvement with subject matters relating to environmental qualification of equipment, Dr. Deutsch's testimony is entitled to little weight in this proceeding.
179. In his testimony, Dr. Deutsch for the most part sim-ply repeated the results of the different tests conducted on ASCO solenoid valves that are discussed earlier in this opinion without adding any additional information.
He did, however, raise two questions that, while outside the scope of the issues -
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4 I
t designated for a hearing by the Licensing Board, were addressed by the Applicants.
180. The first question posed by Dr. Deutsch concerned the testing of the ASCO solenoid valves at VEGP aus part of the Applicants' maintenance and surveillance program..The 7.ppli-cants described generally the procedurc by which the~mainte-nance and surveillance program for safety-related equipment has 4
been developed at VEGP and discussed the preoperational and in-service testing that will be performed on ASCO solenoid i
valves and.the associated process valves.
This testing will 1
verify the functionality of the ASCO solenoid valves and detect i
)
any significant degradation in valve performance.
Baenteli et 1
al.,
ff. Tr. 517, at 65-68; Tr. 540-42, 543-44 (Bockhold).
181. The second question raised by Dr. Deutsch related to the orientation of the ASCO solenoid valves when installed at i
l VEGP.
Dr. Deutsch felt that the orientation of the valves was l
important an(1 expressed concern that it had not been adequately considered by the Applicants.
Deutsch, ff. Tr. 371, at 5.
The Applicants testified that the orientation-of the valves had l
]
been considered, and the only limitation placed by ASCO upon i
l the physical orientation of the models of solenoid valves used j
at VEGP was that the model 206-381'-6RE' valves had to be mounted vertically.
Those valves are in fact mounted vertically.
Tr. 530 (Cereghi-no).
I i,
w F.
Conclusion 182. The evidence before the Licensing Board demonstrates that the model NP 8316, NP 8320, NP 8321, and 206-381-6RF ASCO solenoid valves used in safety-related functions at VEGP are i
i environmentally qualified for use at VEGP.
l V.
Proposed Conclusions of Law I
Based on the entire record in this proceeding, and pur-i suant to 10 C.F.R.
$ 2.760a, the Board concludes as follows:
i 1.
With respect to those matters encompassed by Conten-tions 7, 10.1, and 10.5, there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public and that such activities will be conducted in compliance with the Commission's regulations.
2.
With respect to these matters, issuance of the
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license will not be inimical to the common defense and security or to the health and safety of the public.
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