ML20205K617

Testimony of a Masciantonio on Joint Intervenors Contention 10.1 Re Dose Rate Effects.Related Correspondence

ML20205K617
Person / Time
Site:	Vogtle
Issue date:	02/24/1986
From:	Masciantonio A Office of Nuclear Reactor Regulation
To:
Shared Package
ML20205K591	List: ML20205K587 ML20205K598 ML20205K610 ML20205K617
References
OL, NUDOCS 8602270593
Download: ML20205K617 (7)

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DOCKETED UNITED STATES OF AMERICA NUCLEAR DEGULATORY COMMISSION

'86 FEB 26 #0:14 BEFORE Ti!E ATOMIC SAFETY AND LICENSING BOAPD

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In the f. fatter of )

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GEORGIA poi!ER COMPANY ) Docket Nos. 50-424 et al. ) 50-425

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(Vogtle Electric Generating Plant, )

Units 1 and 2) )

I'RC STAFF TESTIMONY OF ARMANDO MASCIANTONIO ON JOINT INTERVENORS' CONTENTION 10.1 (DOSE RATE EFFECTS)

Q.1 Please state your name and position with the NRC and summarize your professional qualifications.

A.1 My name is Armando f.fasciantonio. I am presently employed by the U.S. Nucleer Regulatory Commission as a mechanical engineer in the Engineering Branch of PWR-A Division of Licensing, Office of Nuclear Reactor Regulation (NRR). Before November, 1985, I was employed as an equipment qualification engineer in the Equipment Qualification B ranch , Division of Engineering, Office of Nuclear Reactor Regulation. I was responsible for the technical reviews, analyses and evaluations of the adequacy of the environmental quali-fication of electric equipment important to cafety and safety-related mechanical equipment whose failure under postulated environmental conditions could adversely affect the performance of safety systems in nuclear power plants. Before joining the NRC I was employed as 9602270593 0224 PDR ADOCK 05000424 T M PM

an engineer by Vitro Laboratories Division of Automation Industries, Inc. , . from February, 1981 until May, 1982. I was responsible for the environmental and seismic qualification of the safety-related electronic control' equipment supplied by Vitro Laboratories Division.

Specifically, my duties were to develop and write the environmental 1

and seismic qualification test plans, procedures and reports and oversee the test and procurement activities in support of qualification.

Prior to that, I was employed at the U.S. Naval Surface Weapons Center as a mechanical engineer from August,1972 until January,1981.

My duties involved support of the development, test and evaluation of advanced naval weapons, i

I have a B.S. degree in Mechanical Engineering (1972) from Drexel University, Philadelphia, Pennsylvania, a Masters degree in Mechanical Engineering (1976) from the Catholic University of America, Washington, D.C., and a Masters degree in Administrative Science (1980) from the Johns Hopkins University , B altimore ,

! Maryland.

Q.2 What is the purpose of this testimony?

! A.2 The purpose of this testimony is .to address Joint Intervenors' Contention 10.1. The contention challenges the appropriateness of the rate of application of radiation during qualification tests for four l

specific materials used at Vogtle Electric Generating Plant (VEGP);

l Ethylene Propylene Rubber (EPR), Cross-linked Polyolefin (XLPO),

6-chlorosolfonated polyethylene ( Hypalon) , and chloroprene (Neoprene).

Q.3 Why are materials exposed to radiation during qualification tests?

A.3 Equipment and materials are exposed to radiation from the normal operation of the plant. The long term degradation which results 4

from normal operation must be accounted for. Radiation is applied as part of the environmental qualification aging program to place equipment in an aged state equivalent to its end of installed life so that the effects of a design basis accident on the ability of the equipment to perform its intended function can be determined.

Q.4 Ilow is radiation applied during the qualification progran?

A.4 Because of the prohibitively long time it would take to expose equipment to real time radiation dose rates, the Commission in 10 C.F.R. 50.49, allows accelerated aging of equipment during a qualification program. A higher dose rate may be applied during qualification tests than would be received by the equipment during its installed life. Radiation doses of approximately 1 megarad per

hour are used during tests.

Q.5 Is this an adequate simulation of the radiation effects?

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' A.5 Research tests have shown that most materials exhibit a " dose rate effect!' to some degree. This means that the amount of degradation experienced by~ the material depends not only on the total dose received but also on the rate at which the radiation is applied.

Industry qualification standards and the NRC recognize that aging offects which cannot be adequately accelerated must be accounted for. This includes any effects of dose rate differences between actual and test conditions.

Q.6 Of the four specific materials identified in this contention, do any exhibit a " dose rate effect"?

A.6 Based on the results of Sandia National Laboratories tests as reported in N UREG / CR-2157, " Occurrence and Implications of Radiation Dose-Rate Effects for Material Aging Studies", of the four materials listed , XLPO is the only one which would exhibit any significant degree of " dose rate effect" at the expected total doses of the VEGP.

Q.7 Is XLPO the only mnterial whose electrical insulation property was evaluated subsequent to radiation exposure?

A.7 No. In typical cable qualification tests the electrical insulation property is evaluated for all insulation materials tested.

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0.8 How is XLPO used at VEGP?

A.8 The Applicants state that the only application of XLPO at VEGP is in cable insulation.

4 Q.9 liow does the staff assure that the known " dose rate effects" for XLPO uill not become a safety concern for cable insulation at VEGP?

A .9 h' hen " dose rate effects" are known to exist , material aging data generated at high dose rates are treated cautiously if a low dose rate application is intended. In order to account for dose rate effects , the staff requires applicants for an operating license to develop and implement surveillance / maintenance procedures which will detect age-related degradation and take corrective action before a safety problem develops.

Q.10 What is the standard by which the staff determines the acceptable quality of such a maintenance / surveillance program?

A .10 The staff requires that a maintenance / surveillance program be implemented to identify and prevent significant age-related degra-dation of electrical and mechanical equipment. In the FSAR, the applicants have committed to follow the recommendations in Regulatory Guide 1.33, Rev. 2, " Quality Assurance Program Requirements (Operation) ," which endorses the more detailed guidance contained in American Nuclear Society /American National

i-Standards Institute Standard ANS-3.2/ ANSI N18.1976,

" Administrative Controls and Ouality Assurance for the Operational Phase of Nuclear Power Plants." This standard defines the scopc and content of a maintenance / surveillance program for safety-related equipment which is acceptable to the staff. The program should assure that provisions for preventing or detecting age-related degradation in safety-grade equipment are specified and include (1) utilizing experience with similar equipment , (2) revising and updating the progran as experience is gained with equipment during the life of the plant , (3) reviewing and evaluating malfunctioning equipment and obtaining adequate replacement components, and (4) establishing surveillance tests and inspections based on reliability analyses , frequency , and type of service or age of the items, as appropriate.

The staff has assessed the applicants' Quality Assurance (QA) program for the operations phase to determine if it complies with the requirements of 10 C.F.R. 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants",

including Regulatory Guide 1.33, Revision 2.

In Section 17.4 of the Vogtle Safety Evaluation Report, NUREG-1137, the staff concludes that the applicants' description of the QA program, if properly implemented, is in compliance with applicable NRC regulations and acceptable for the operations phase of VEGP.

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In order to fulfill its commitment, the applicants must provide a program that incorporates the above guidelines and state that the maintenance / surveillance program will be implemented at the time of fuel load . The applicants must also provide a description of the specific program that will be used to detect unanticipated, age-related degradation of electrical cables inside containment. The staff will verify that an appropriate program is implemented at VEGP.

Q.11 What conclusion have you reached regarding the possible " dose rate effect s" identified for XLPO in NUREG /CR-2157 as it applies to VEGP?

A.11 Based on the possible " dose rate effect" for XLPO as identified in NUREG/CR-2157 and the requirement to implement a surveillance / maintenance program to detect and correct any unanticipated degradation of electrical cables at VEGP, I believe that there is adequate assurance that any increased deterioration of cable insulation due to the expected low radiation dose rate will be discovered, if any exists, and .will not cause an unsafe condition to occur.

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