ML20205J007
| ML20205J007 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/27/1986 |
| From: | Churchill B GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#186-872 OL, NUDOCS 8601300074 | |
| Download: ML20205J007 (6) | |
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UNITED STATES OF AMERICA
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BEFORE THE ATOMIC SAFETY AND LICENSING BOA $tD(
In the Matter of
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GEORGIA POWER COMPANY, et al.
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Docket Nos. 50-424
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50-425 (Vogtle Electric Generating Plant, )
Units 1 and 2)
)
APPLICANTS' MOTION FOR PARTIAL RECONSIDERATION OF MEMORANDUM AND ORDER RULING ON MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 10.1 By Memorandum and Order dated January 23, 1986, the Li-censing Board denied Applicants' motion for summary disposition of Contention 10.1 and designated six issues for hearing.
Applicants request reconsideration of the designation of the fourth of these issues for hearing -- that Applicants have not explicitly addressed the polymer applications other than cable jackets and insulation identified by Intervenors.
Contention 10.1 pertains to the significance of dose rate effects in the artificial aging of four specific polymers-dur-ing environmental qualification.
The contention is based on a Sandia Study (NUREG/CR-2157), and the four polymers addressed in that study are chlorosulfonated polyethylene (Hypalon), eth-ylene propylene rubber (EPR),'chloroprene.(Neoprene), and 9601300074 860127 PDR ADOCK 05000424 9s03
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cross-linked' polyolefin (XLPO).
In their motion for summary disposition, Applicants specifically addressed all four polymers in terms of the various polymer applications put forth by Joint Intervenors and the bases for the Intervenors' allega-tions, to wit, the Sandia Study.
For'three of these polymers -- Hypalon, EPR, and Neoprene
-- Applicants demonstrated that the dose-rate effects that had been observed in these polymers.were insignificant at and below the maximum total dose that equipment important to safety at VEGP might incur over forty years of normal plant operation.
In the case of Hypalon and EPR, Applicants demonstrated that the reduction in properties addressed by the Sandia study is virtually the same for all dose rates up to a total integrated dose of 20 megarads.
In the case of Neoprene, the reduction is virtually the same up to a total integrated dose of 10 megarads.
At VEGP, no equipment important'to safety will re-ceive a total integrated dose for forty year normal operation greater than 10 megarads, and'most such equipment will receive less than one megarad.
Thus, only XLPO exhibited discernible dose-rate effects within the range of relevant total doses.
Affidavit of Joel Kitchens, Victor L. Gonzalez, and Mark L.
Mayer (July 30, 1985)', 11 28-29 (Affidavit of Kitchens et.
al.); Applicants' Statement of Material Facts As to Which There is No Genuine Issue To Be Heard Regarding Joint Intervenors' Contention 10.1 (Dose Rate Effects) (July 31, 1985), 11 7-9.
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L Applicants cross-checked the four polymers against their uses at VEGP, including all applications put forth'by Joint In-tervenors.
Affidavit of Kitchens et. al., 1 18.
XLPO was found only in cable insulation.
Id., 1 30.
For XLPO, Appli-cants proceeded with an application-specific analysis to demon-strate that the dose-rate effects observed in XLPO did not com-promise the environmental qualification of safety-related applications of XLPO.
XLPO was not found in the other applications identified by Joint Intervenors -- 0-rings, gaskets, and elastic diaphragms.
See id., 1 30 Since dose rate effects were not discernible in Hypalon, EPR, and Neoprene at and below the maximum total dose that equipment important to safety might incur over forty years of-normal plant operation, the applications of these three polymers were irrelevant.
Irrespective of the polymer applica-tion, artificial aging of safety-related equipment with these three polymers reasonably simulates normal life degradation, and hence the environmental qualification tests of such equip-ment are valid.
As a legal matter, the fourth issue designated for hearing is not material.
Intervenors have presented no bases for even suggesting that there are significant dose-rate effects for any application of Hypalon, EPR, or Neoprene.
To the contrary, the only information put forth by Joint Intervenors (the Sandia
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6 Study) demonstrates that the effects are insignificant regard-less of application.
As a practical matter, presenting an analysis of each ap-plication of Hypalon, EPR, and Neoprene is a considerable and burdensome task which will not contribute to the resolution of the contention.
Accordingly, Applicants ask that the Board reconsider and eliminate the fourth issue as an unresolved issue of material fact.
Respectfullyrsubm tted, b
' Av Brucs N'.
Churchill, P.C.
David R.
Lewis SHAW, PITTMAN, POTTS & TROWBRIDGE James E. Joiner, P.C.
Charles W. Whitney Kevin C.
Greene Hugh M.
Davenport TROU__iN SANDERS, LOCKERMAN
& ASHMORE Counsel for Applicants Dated:
January 27, 1986
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January 27, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
~
GEORGIA FOWER COMPANY, et al.
)
Docket Nos. 50-424 (OL)
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)
50-425 (OL)
(Vogtle Electric Generating Plant, )
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion for Partial Reconsideration of Memorandum and Order Ruling on Mo-tion for Summary Disposition of Con.tention 10.1," dated January 27, 1986, were served upon those persons on the attached Ser-vice List by deposit in the~ United States mail, postage pre-paid, this 27th day of January, 1986.
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~Brude WT Churchill Dated: January 27, 1986
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
GEORGIA POWER COMPANY, et al.
)
Docket No. 50-424
)
50-425 (Vogtle Electric Generating Plant,
)
Units 1 and 2)
)
SERVICE LIST Morton B. Margulies, Chairman Douglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle U.S.
Nuclear Regulatory Commission Atlanta, GA 30306 Washington, D.C.
20555 Mr. Gustave A.
Linenberger Laurie Fowler Atomic Safety and Licensing Board 218 Flora Avenue, N.E.
U.S. Nuclear Regulatory Commission Atlanta, GA 30307 Washington, D.C.
20555 Dr. Oscar H.-Paris Tim Johnson Atomic Safety and Licensing Board Campaign for a Prosperous U.S. Nuclear Regulatory Commission Georgia Washington, D.C.
20555 1083 Austin Avenue, N.E.
Atlanta, GA 30307 Bernard M.
Bordenick, Esq.
Office of Executive Legal. Director Docketing and Service Section U.S. Nuclear Regulatory Commission Office of the Secretary Washington, D.C.
20555 U!.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel U.S.
Nuclear Regulatory Commission Bradley Jones, Esquire Washington, D.C.
20555 Regional Counsel U.S.
Nuclear Regulatory Atomic Safety and Licensing Commission Appeal Board Panel Suite 3100 U.S. Nuclear Regulatory Commission 101 Marietta Street Washington, D.C.
20555 Atlanta, GA 30303 j
.