ML20148S981
| ML20148S981 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/08/1988 |
| From: | Steenland D PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#288-6070 OL-1, NUDOCS 8804200102 | |
| Download: ML20148S981 (27) | |
Text
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Dated:
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UNITED STATES OF L' ERICA UNITED STATES NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of
)-
)
PUBLIC SERVICE COMPANY
) Docket Nos. 50-443 OL-1 NEW HAMPSHIRE, et al.
)
50-444 OL-1
)
(Seabrook Station, Units 1
)
(On-site Emergency and 2)
)
Planning Issues)
)
APPLICANTS' SUPPLEMENTAL RESPONSE ON ENVIRONMENTAL QUALIFICATION OF RG-58 COAXIAL CABLE In ALAB-882, 27 NRC (1988) the Appeal Board requested that the Licensing Board examine Applicants' claim that RG-58 cable does not perform an accident mitigating function and therefore, the high-potential withstand test is all that need be satisfied to demonstrate that the cable is environmentally qualified.1 On March 2, 1988 the Licensing Board, responding to the Appeal Board's remand, issued a memorandum providing support for its determination that the 1
The Appeal Board also provided a summary of the procedural history regarding the issue of the environmental qualification of RG-58 coaxial cable.
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Applicants' claim is meritorious.
Memorandum to Acceal Board on Environmental Oualification of Coaxial Cable RG-58 (March 2,
1988) ("Board Memorandum").
Relying only on the established record, the Licensing Board found that "there is an adequate evidentiary record to show that full environmental qualification of coaxial cable RG-58 is not required, that requirements of the high potential withstand test are all that is needed to demonstrate its environmental qualification, and that the successful environmental qualification of coaxial cable RG-59 can serve to qualify the untested RG-58 cable by comparison."
Board Memorandum at 9.
Pursuant to the Appeal Board's scheduling order of March 3, 1988 New England Coalition on Nuclear Pollution ("NECNP")
filed a supplemental memorandum in which it disagrees with the conclusions of the Licensing Board.
("NECNP Memorandum")
Applicants herein respond.
ARGUMEHI The simple issue which has been before the Licensing Board and the Appeal Board is whether or not, on the basis of the record produced during the on-site hearings, the Licensing Board correctly determined that the RG-58 coaxial i
cable is environmentally qualified.
As the RG-58 cable has i
itself not been tested, the question is whether it was proper I.,,
to establish the environmental qualification of the RG-58 cable on the basis of the tests of the similar RG-59 cable.
See 10 CFR $ 50.49(f)(2)
In support of this proposition, the Applicants, arguing on the basis of the Environmental Qualification File ("E.Q.F."),2 stated that because the RG-58 cable does not perform an accident mitigating function, acceptable performance of the RG-58 cable when exposed to harsh conditions is measured only by the cable's ability to remain intact, i.e. the insulation system will not fail.
ERA, Aeolicants' Resoonse Recardina Environmental Qualification of RG-58 Coaxial Cable (November 25, 1987) at 3; 10 CFR 5 50.49 (b) (2).
The Licensing Board found the Applicants' argument was correct:
The answer to the question can be found j
in the record as to whether cable RG-58 must be ' fully' qualified or whether meeting the requirements of only the high potential withstand test (by comparison with the successfully testod RG-59 cable) is sufficient.
As Applicants point out, and as we indicate above, the information is contained in EQF 113-19-01 (NECNP Exh.
4, References 1, 2,
6, and 7).
References 1 and 7 indicate that cable RG-58 is color coded black with a red trace, and Reference 6 indicates the requirement that cables marked other than with the single color red, white, blue or yellow must only remain intact (e.g. no shorting to ground).
That the high 2
The E.Q.F. was introduced without limitation as NECNP Exhibit 4.
6q potential withstand test does measure leakage / charging current between the main conductor and the shield (i.e., shorting to ground) is indicated in Reference 2 (Table 3, at 15, n.
"d" in regard to test results of cable A5550-2C (RG-59)).
Board Memorandum at 8.
NECMP argues that the Licensing Board erred because it "has done nothing to enhance the record."
NECNP Memorandum at 3.
However, the task of the Licensing Board was not to "enhance" the record, but as the primary fact finder, to review the existina record to determine if there was sufficient support for the Applicants' claim that the RG-58 cable was environmentally qualified.
After such a review, the Licensing Board made appropriate findings.
NECNP further argues that the record is not sufficient to support the Applicants' argument that RG-58 cable has a very limited post accident function since the argument is based solely on a telephone memorandum, Reference 6 of Exhibit 4.
That memorandum notes that color coding is designed to indicate which cables must perform a safety function subsequent to accident events.
Contrary to the view taken by NECNP, this is not novel information.
Cables at Seabrook Station such as the RG-58 and RG-59 cables are color coded in accordance with the scheme described in the phone l
}
memorandum and fully detailed in the F.S.A.R.3 See F.S.A.R.
55 8.3.1.3 and d.3.1.4.k.
(attached).4 Moreover, the issue of the performance requirements of equipment which does not perform an accident mitigating function is again not open to question.
The uncontradicted statement in Reference 6 that such equipment need only remain intact is entirely supported by the affidavit of Harold Walker submitted on behalf of the NRC Staff.
In his affidavit, Mr. Walker stated, "I agree that the different operating requirements of the cables, specifically the differing requirements for insulation renintance are important in determining similarity of performance of the two cables.
However the functional requirements of the cables and the potential failure modes must also be considered.
In this case, these are important considerations because the RG-58 cable only has to remain intact, and is not required to 3
This information is further confirmed by United Engineers & Constructors, Inc., Conduit and Cable Schedule, CASP Design Guide at Table 3, 6-2 -- 6-4 (attached).
This Design Guide is the separation document referred to in NECNP Exhibit 4, Reference 6.
We are informed that the entire Guide, which contains proprietary information of United Engineers & Constructors, Inc., if necessary, can and will be made available for review to the Board and the parties.
4 It should be noted that F.S.A.R.
5 8.3.1.4.k indicates that certain cables are not identified by this color code scheme.
In the case of the RG-58 cable, however, the specification clearly demonstrates that the cable purchased is subject to the color coding scheme.
See NECNP Exhibit 4, Reference 1 at A1.
l 3
i
' l
mitigate an accident."
Affidavit of Harold Walker at A6, HRG Staff ResDonse to Memorandum of Licensina Board and New England Coalition on Nuclear Pollution Recardina Environmental Oualification of RG-58 Coaxial Cable (December i
11, 1987) (attached).
In addition, there is ample support in the record to demonstrate, as the Licensing Board found, that the color code of the RG-58 cable demonstrates that it does not perform i
an accident mitigating function.
ERA NECNP Exhibit 4, References 1, 6 and 7.
Therefore, the RG-58 cable is environmentally qualified on the basis of the acceptable e
tests results of the high potential withstand test for the RG-59 cable which had been subjected to the full test regime
-- e.g. thermal aging, irradiation, LOCA environment, etc. --
as detailed in NECNP Exhibit 4, Reference 2.
1 l
Finally, it should be noted that while NECNP repeatedly suggests that Applicants' position on the RG-58 cable is "new" and therefore somehow suspicious, in fact Applicants' position on this matter is not inconsistent with any previous l
position.
Applicants' witness at the hearing testified that the purpose of the E.Q.
files is to keep a verifiable record l
l that the equipment is qualified for the environment to which it may be subjected in an accident.
(Ltm 360).
As NECNP, on cross-examination, did not challenge the appropriateness of the environmental qualification testing of RG-58 cable to i
projected accident conditions, it was appropriate for Applicants to rely on the record (NECNP Exhibit 4) in this i
regard.
When on appeal, however, it became necessary to make
[
I explicit the argument why RG-58 was environmentally qualified, Applicants put forward their position -- a i
position based entirely on the record created during the on-site proceedings.
j CONCLUSION For the foregoing reasons, the decision of the Licensing Board is correct and NECNP's request to reopen the record should be denied.
Respectfully submitted, b
Thomas G.
Dignan, Jr.
Deborah S. Steenland Ropes & Gra) 225 Franklin
- reet Boston, Massachusetts 02110 (617) 423-6100 Counsel for Applicants t
L s
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SB 1 & 2 Amendment 55 FSAR July 1985 8.3.1.3 Physical Identification of Safety-Related Equipment All cables, raceways and safety-related equipment are assigned to a particular channel or train. There are two redundant trains of power and controls, and four redundant channels of instrumentation.
Each channel or train is assigned a particular color, as shown below:
Equipment Raceway Separation Group Nameplate Tag Cable Color A.
Channel I and Train A Red Red Red Train A AI.sociated Black Black w/ Red Tracer l
B.
Channel II and Train B White White White Train 5 Associated Black Black w/ White Tracer l9 C.
Channel III Blue Blue Blue D.
Channel IV Yellow Yellow Yellow it Each piece of electrical equipment is marked with the node number indicated on the design drawings, in the particular color corresponding to the channel or train to which that equipment is assigned.
Similarly, trays and exposed conduits are marked with color-coded markers.
The cable jacket color code serves as its identification. The operator or maintenance craftsman needs only to observe the color of the nameplate of any piece of equipment or the cable jacket color to determine which channel or train it serves. For exceptions to the above cable and raceway identification criteria, see Subsection 8.3.1.4.k.
Si 8.3.1.4 Independence of Redundant Systems a.
General The Seabrook Station complies with the requirements of FSAR Appendix 8A, IEEE 384-1974 and Regulatory Culde 1.75, Rev. 2.
These documents describe acceptable methods of complying with IEEE 279-1971 and Criteria 3, 17 and 21 of Appendix A to 10 CFR Part 50 with respect to the physical independence of the circuits and electrical equipment comprising or associated with the Class 1E power system, the protection system, systems actuated or controlled by the protection system, and auxiliary or supporting systems that must be operable for the protection system and the systems it actuates to perform their safety-related functions.
Preservation of independence of redundant systems within the control boards and all other field mounted racks is discussed in Subsection 7.1.2.2.
St.
8.3-39
o SB 1 & 2 Anandrant 56 FSAR November 1985 Penetrations for 600 volt service and below are modular type with a header plate welded to the outside of a 12 inch containment sleeve.
Because of the concern regarding leakage currents of terminal blocks during accident conditions, low level instrumentation circuit con-ductors inside containment are connected to the penetration conductors with qualified splices.
Safety-related 480 volt power,120 voit ac and 125 volt de control circuit conductors inside containment required to function for LOCA and main steam line break conditions are also connected to the penetration conductcts with qualified splices. The balance of medium power 480 volt conductors, and control and instrumentation conductors are terminated on terminal Se blocks inside terminal boxes both inside and outside containment.
480 volt heavy power conductors are terminated with lugs on special termination plates inside terminal boxes both inside and outside containment. Nuclear instrumentation detector circuits are termi-nated with connectors inside terminal boxes both inside and outside containment.
Penetrations for medium voltage have header plates welded to the outside of an 18 inch containment sleeve.
Each pene-tration consists of three 1000 MCM conductors terminated with premolded stress cones inside terminal boxes both inside and outside containment.
The capability of the electrical penetrations to withstand the total range of time versus fault current without loss of containment integrity under worst case environmental conditions was demonstrated by test.
These test results are summarized in the response to RAI 430.56.
51 The penetrations are arranged in two levels, with one power train and two channele entering above the intermediate floor of the con-tainment building, and the redundant train and two channels entering below the intermediate floor. Once inside the containment, this floor provides the necessary physical separation and protection between the redundant trains; outside the containment, this separa-tion is continued by separate tunnels connecting the penetration area to the switchgear and cable spreading areas of the control building.
Penetration conductors are sized using ICEA guidelines with an additional restriction of a 650c ambient temperature.
51 The design, construction, and installation of the penetration assemblies are in accordance with IEEE 317 and Regulatory Guide 1.63.
(See Subsections 8.1.5.3, 8.3.1.1, and 8.3.1.2 for further details on compliance to Regulatory Guide 1.63).
k.
Cable and Raceway Identification 41 #I The computerized conduit and cable schedule provides a permanent record of the routing and termination of cables. Circuit level coding identifies the individual channel or train assigned to each raceway and cable.
These data are entered into the conduit and cable program, which in turn produces ceports designating the unique number with origin, destination, channel or train, and specific path for every cable. Every cable is identified by a tag affixed at each end, bearing the unique cable number.
8.3-52
SB 1 & 2 Amsnd cnt 56 i
FSAR November 1985 r
Each channel or train is assigned a particular color, as described in Subsection 8.3.1.3.
4 f
All safety-related cables have jackets of the color assigned to the particular channel and train so there is no dif ficulty in dis-tinguishing between cables of redundant channels. Non-safety related cables are associated with either Train A or B and have black jackets with a red trace for cables associated with Train A and a white trace for cables associated with Train B.
It is immediately evident to the operator or maintenance man, by observing the color of the cable jacket, that a given cable is safety-related $2 and that it is a particular channel or train.
This system also prevents placing a cable of one channel or train with cables of another, by the obvious dissimilarity of jacket color.
Each cable is further identified by a footage and cable code on the jacket of the cable at intervals of approximately five feet.
Reference to pulling records reveals the cable number, routing, separation, circuit type, and use of any cable at any accessible point in the raceway system where the footage marker and cable code can be identified, s
r Exceptions to the above cable identification criteria exist for i
vendor supplied speciality cables for radiation monitoring system and portions of various other systems (for example telephone system, lighting and fire protection / detection). For these exceptions, the necessary information to ensure adequate control of separation, installation, inspection, etc. is provided in the construction documents.
>S r
3 Raceways which are part of the computerized cable and conduit schedule are marked to identify their number and circuit level.
1; Conduit raceways are identified at each end where conduit t e rmina te s and at both sides of wal19, floors and in-line boxes.
Tray raceway markers are spaced at 15 foot or less intervals.
These markings t
are in the same colors assigned to the channels and trains. For example, a raceway with a red seccion marking is utilized only by cables with red (or black with red tracer) jackets.
Hence, it is readily apparent that a given cable is routed with its respective channel.
Raceways which are not part of the computerized conduit and cable schedule may not be marked with a unique identification number, but their function is obvious by tracing the raceway to its end device.
These raceways may be used to carry vendor supplied l
speciality cables for radiation monitoring system and portions of various other systems such as telephone system, lighting and fire l'
mation to ensure adequate controls of separation, installation, protection / detection. For these raceways, the necessary infor-inspection, etc. is provided in the construction documents.
a 95 Since, in general. there is no sharing of safety-related systems 4
between the two units (see discussion of compliance to GDC 5, l
Subsection 8.3.1.2), there is no need to distinguish the safety-i related cables of one unit from the safety-related cables of the
(
8.3-53
)
SB 1 & 2 Amsnd22nt 55 Y
FSAR July 1985 other unit. As such, the cable and raceway coloring scheme is identical for the two units.
In the coninon arcar, the unit to which a cable belongs is not appares from the raceway or cable snarkings.
If it is required to know the unit to which a cable belongs, it can be obtained by observing the equipment designation number, which has the unit number as a prefix. The basis for cable and raceway identification is to distinguish between redundant channels, indicate which channel is involved, and which cables are safety-related.
1.
Administrative Responsibility and Control Administrative responsibility for assuring compliance with sppli-cable design criteria and bases relative to independence of redundant systems rests with the A/E's Project Electrical Engineer. He is responsible for coordination with the A/E's field electcical super-visor to verify that the independence, separation and availability of Class IE equipment is preserved during installation of the electric power system.
The following control procedures are established by the A/E's Project Electrical Engineer to assure compliance of the electric power system with the design criteria and basest i.
Periodic design reviews with the cognizant engineer, the design supe: visor, and the reviewing engineer to assure the criteria are being interpreted and followed, 2.
Issuance of periodic administrative and design directives covering procedures, and 3.
Periodic field reviews at the job site by the Project Electrical Engineer and/or the cognizant engineer to check field installation procedures, to provide interpretation of design drawings and guidance for solution of field installation problems, and to verify compliance with criteria.
The design of the conduit and raceway system is guided by the recoaumendations of applicable IEEE, ICEA and NEC standards.
For l
SL instance, the limiting percentages of fill of internal area of the various sise conduits or cable trays are fixed in one of the input forms of the computer conduit and cable schedule and these limits are automatically applied to all corduits and cable trays by the computer.
Ii the conduit or cable tray is one which the computer is free to size, it designates the size which acconunodates the cables to be enclosed.
If the conduit or cable tray size is designer-designated and tne fill exceeds the limiting percentage, the computer indicates an error message so that either the conduit an be made a larger size, or the cables routed by another path. 3r *,hese methods, all raceways are assured af being of adequate e nacity.
Correct installation practice assures that the design criteria by which the equipment was selected are not violated during construc-tion.
Installation bases are prescribed, where necessary, by the 8.3-54
e q "
TABLE 3 CABLE CODE CHARACTER SIGNIFICANCE 4 CHARACTER CODE = CCIE Voltage, Conductor and Cable Conscruction Number of Conductors or Pairs outer Jacket Color-Conductor Size ise CHARACTER (CONSTRUCTION)
A 600 V Multi-Conductor Control Cable B
600 V Multi-Conductor Power Cable C
600 V. Triplex Power Cable D
600 V Single conductor Cable E
600 V Multi-Conductor Shielded Cable G
TP&L Power & Control Cable H
15 XV Loxarmor Power Cable J
5 KV Loxarmor Power Cable K
5KV Triplex Power Cable i
M 300 V Shielded Twisted ? air Cable N
300 V Twisted Pair Cable Q
Specialty Multi-Conductor S
1000 V Shielded Huiti-Conductor Control Cable T
Coaxial Cable d
Trissial Cable V
Ihree Condescer Twisted R.telded Cable W
Westinghouse Supplied Cable X
300 V Copper-Constantan Thermocouple Cable Y
300 V Chromel-Alumel Ihermoccuple Cable 300 V Chromel-Constantan Thermocouple Cab 1'e Z
PAGE 6-2
u o
Table 3 (Cont'd) 2nd CRARACTER (NO. of CONDUCTORS or PAIRS)
A One V
Nineteen or Two-hundred B
Two W
Twe nty-s even C
Three X
Thirty-seven or Thirty D
Four Y
Forty-two or Forty-eight E
Five Z
Forty-seven or Six-hundred F
Six G
Seven J
Nii" K
Thirty-four L
Eleven M
Twelve N
Thirteen or One-Hundred P
Fourteen Q
Fifteen R
Sixteen S
Eighteen or four-hundred T
Twenty U
Twenty-four 3rd CHARACTER (JACKET COLOR)
COLOR VITAL CIRCUITS 1.
Red Train A and Channel I 2.
White Train B and Channel II 3.
Blue Channel III 4.
Ye;;ow Channel IV Page 6-3
Table 3 (Cont'd)
ASSOCIATED CIRCUITS - Non-Vital 6.
Black w/ Red Tracer Train A, Channel I snd BOP 7.
Black w/ White Tracer Train B and Channel II 8.
Black w/ Blue Tracer Channel III 9.
Black w/ Yellow Tracer Channel IV 0.
Bla ck Temp Power, Fire P'w;-
- ss e I
Page 6-3 A
,-,..,-,v.,
.. ~...... _, -..
TABLE 3 (Cont'd) 4th CHARACTER (CONDUCTOR SI..'
A - 750 MCM J - 4 AWG S - # 4/0 AWG AL B - 500 MCM K - 6 AWG T - 18 AWG C - 350 MCM L - 8 AWG U - 17 AUG D - 250 McM M - 10 AWG V - Not Used (19/22)
E - 4/0 AWG W - 20 AVG F - 2/0 AWG N - 12 AWG X - 22 AWG (19/25)
G - 1/0 AWG P - 14 AWG Y - Undefined H - 2 AWG R - 16 AWG 3
Plug cable (various sizes)
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..w UM!T30 STAT 9S OF AMERICA e
t'UCLEAR R:CUI.ATORY CCVMiSSION
- i2 ATCMIC If.:ETY AMD LICENSING BOARD E EFC.~. _
In the Motter of
).
)
Docket Nos. 50-443 OL-01 FU?L:C 5'IP.V:C3 COf;')AN'/ OF
)
50-444 OL-01 MT'! !!ATiPSMiRE, et ;11.
1 On-site Emergency Planning
)
and Safety issues (Seabrook Station, Units 1 and 2)
)
A. FIDAVIT OF HAROLD WALVER i, !'c ecif '.'la"<e r, being first dely s vorn, hereby affirm that the
- 3 /2 s t' '* : 2 quest' ns 33; for s.1 herein are true to the best of my
.3".'! d;c :
l*r.
l:!': t, :y w'acm and in what capacity are you employed?
cr,;r.yad by t', e 11. S. Muclear Psegulatory Commission as a
?
-ter Er.ginc?r in 50ct!cn E cf the Plant Systems Brarch, Division In !: ering and Systons Techno!?gy, Office of Nticlear Reactor nr P.rgi.:e tto.s.
01-
-.,:u p r ?,r?
.: a s ta ',e m r r t of your professional qualification?
v
'* 2s,. r st1'.3. ant :f m nr ": ri 7a! qua!!fications is attached as an m
'?-
exhibit to th!s aff:dsv!t.
Q:: Mr. Via!!:se, t.lat is the pur,,0se of your affidavit?
mmerandum submitted to the Appeal
(
l J ':
'*y
. ' ' :c,!!
- Irc.ds a-.d the Maw England Coalition on fic:rd ';y t'.9 L!c ns!rn
'4 c a a
- - its rmmercrdum, the Licensing Board l
?'u-! ar Pollut!cn (NHCN.'t.
i :
y
b
. 2ap'ained lts err:n3
'r c:7.c ud!ng thct "ths pertinent EQF r y:v!renmental quclification f!!c j shows that the dimensional c!.'.~:rences b:'wcen the T.058 and the RG59 cables are of such little
~
imp:rt:ne: tS:t the ust r>2 suits for th? RO59 cable can serve to
<- : !'fy 'he untest ed RO53 cable."
In its memorandum to the Appeal L.: d, NHCNP cha!S.ag 3d tS!s conclus!cn on a number of gr ounds, L!censine Emed's Memorandum Q":..;. "?aih e r, do y:u egre2 v Ith the st?tement at page 2 of the L:: ins!ng Soard's memcrendum that:
[TF.c d!?' nsMns of the coppar conductors (#21 AWG strr.nded '.~!rt in ceble RC5 3, and #2 4 AWG stranded wire in cabie RC57) have ilttle, if any, significance to environ-mental qua lf cation of the cables, except that the dimen-s!cns refh:t the dlf f arer t cpplicattens for which the cables are intended.
M: Yes ! agree.
CE: **.
Cla! h:r,
the Ll:ensing B oard s ta *.s at paces 2-3 of its rittr:rt.ndura that it "c vid find no requiremants in the environmental que!!fication cccept::nco criter!a, or in the envircnmental qualification tests themselves, t'iet d: pended upcn the diameter or cross-sectional tres of the conductors."
Do you agree with the Licensing Board?
AS: ! cm uncware of any requirome.! in the environmental qualification 3 csptance criteria or in the environmental qualification test themselves that depends upon tha d!ameter or cross-sectional area of the conductors.
QG:
" r'ker, at page 3 of its mamcrandum the Licensing Scard states
..ti st "different eperating requirements of the cables, specifically the dlfferir.g rcT f r mente i r !rsu!rtion resistance (IR), provide a basis for Ju s t!.'ying the s!:r.". rit / cf the two cables whose primary lasu!st!:n th!ct<r. ass diff:rs by a factor of approximately 1.5."
Do you agree with this statement?
s i
i
. l
.: I agree th:t W.
c" f f:r :-
- c?eraUng reqHrtments of the cables, s; acif!ct!!y the di'.':rirr 2;u!rc. ants for insulation resistance are
~
imp:-tant in d:te m:ning simil:rity of per'ormance of the two cables.
!:c.reva, the functional requirenents of the c bles and the potential f:"u r
- r.od 23.Tu s t c:s > be cencidered.
la this case, these are important e.onsideratiens becausa the RG38 cable only has to remain intcct, and is not requirca to mitigate an accident.
It is also freporttnt to note that the mr;tarlais used in construction, type of c:!:!c (singla conductor vs multiconductor) and whether the cables were mcde by tha same r.ianufacturer also are important.
The Staff b2!!cves that cl' th:r7 fa ters ce!!ectively, proelde a basis for just!fyir.g the sim!'arity of the two cables whose ' primary insulation t:;!:': ness c'iffers by a fc.cter of approximately 1.5.
07:
..r. Walker, in l'gSt of your previous answer, do you agree or ch: gree w!!h th a t.icensing Board s statement at page 3 of its
- .ieme. :r.d em thet "the p. edicted per formance of the smaller RG58 c ?'.:'
va. der cenditlcns of environmental qualification testing would be proportional to the lower required operating resistance of its in c v!a '.!cn" ?
A7-
'1 C. ':. R. 5 50.3?(f)(2) p rovic'es,
in pertinent
- part, that an eculpment !ttm may be cua!ified by testing a similar item with a suphrting ana:ysis to show that the equipment to be qualified is acceptable, in this c e n t.1x t, the Staff believes that the term
" s!: Fic r". m:ans to be alike in substance er in essential respects.
On "2
ct;.-
o r :', tN ! 2. n "preprotional" implias a more exact comp:..':en or a rr!!.
'n
'*.2 MMext of la CFR 50.f49 the Staff C.:t r.a t b !'?ve tF t sl-C!:- r.n d prcportional are synonymous.
<~%
J g,,
Mcvorth2!:sc, "O :n o.
cen F.'dsrs the !:ncv n attributes of cables RG53 and ftG59 such as the functionc! requirements under accident cond!!!:ac, the difference in ir.sula'.!cn thichn2ss of only 20 mils, the same r.7ter'c!- of const-uct!cn end type of construction and that P.G 5 0 did nt fa!' rs a r?sult of th e env!ronmental qualification in:t!ng, 'hn cbifity of RG53 te perform its function by remaining intret is e ecacoasbly cons 2rvailve pre. diction.
N o t"rit' s tanding tSt abeve described attributes, proportional parformance under th 3 conditions of environmental qualification tes tirg r1y be a ressencble expectction but it is not assured.
H e."<! v e r,,nrepert!cnc! perforr.anca is ne!ther required or necessary
!r c-d:t for RG'3 to perform I'.s required function under accident
- vU:
3, n-- is it r ic2sstr'r 'n order to d2monstrate similarity.
': !;.3 cr d::- cf l3remb:r 3, 1937 the Appeal Board
' ' '. l '. r. ".'ai:u r,
cr'ad :.1: NRC St ff t: discus: "" h2ther in v!aw of the specification thet cSexh! cab!e must pass an 'AC Voltage V'Ithstand' test at 5000 cc:ts,
t'.? L!cens!ng Board :rremecusly re!!ed upon the value of 80 mil of insu:stion' as the applicab!3 accaptance criteria.
v.0! t ?
~-
Pins: cocress the Ap? al Ecccc".: ccncarn, l
A': Tha Ve:tegs v!i'.s ta r.d test of 5333 Vol ts,
identified in the spadfication for coaxial
- ctbia, is in accord::nc2 with Military specif!cetion MI L-C-17 E, r: ':h !s id2ntifiad by Applicants as the in order to acceptanca crit.cria tht! th!s partics;'ar ccble must meet be accepted for use at Secbrco!<.
The NRC acceptance criteria is 80 V..I t s AC per mil of 1.1suir. tion, as set fcrth by the institute of Electrical and E!?ctronics 2ng!ne2rs (!EEE) in th? "lEEE Standard for l
Typa Test of C! css 13
'i!::tric
- Cobles, Field
- Splices, and
b-
. C:nnedt'm 3 f:r *!uclear Pn".'er Gen: rating Stations" ("lEEE Standard 3 '! 3 ' 0 7'? ).
"h's stand rd !! endorsed by NUREG-0588 Revision I, "l ate rim S it 'f Posit!on en Environmental Quallfication of
'?:f 2ty.77!cted Ehetrical Equ!pment ".
t ' E C N ~ 's.'/.n.nc e ? ;.c'u m QO:
.' r. '"r : h s r, "3Ci:P arg*ns (-t pages 3 !I of its memorandum) that the Licen:ing 3 card's conciusion that "the predicted performance of the smc!!:..7.C50 cab l urc'er conditions of envi.onmental qualification testing wouid be proportbnal to the lower required operating res!s tar.ca of its insulatten" is contradicted by information in the scmo equlpt.cr.t c,ualificat on fila relating to the environmental qualificat!:n cf P.G!1 cable.
Do you agree with NECNP, and if so, is this point s!gnificant?
A9: I egree with NECN? but as 1 ::g!ained above (A7), this point is not s!gni fice r.t.
QiO:.'#. Waihr, NECNP states at page ti of its riomorandum:
C! vin the fact that n'!ther the insulation
-a ris tar.c c operating requirement r.c r the measured i:.:uiction r :Istanco after testing of the RG11 and R C.O cabios is proportional to the cables' insutztbn t hic!<r.e s s,
the Board's Memorandum raises questiens as to what other factors might influence the qualification of these cables.
Ared,ther2 other fccters rhich might !nfluence the qualification of these cables?
A 0: Yes, see my reconse to Question 6.
Q': 1: M. "c:her, at pag? 5 of !!s r.eTer:ndum, ??.CNP argues that it is n,1 possibla to infer wlth an dar,.; ate degree of conservatism that an
4, untested cc':!c can Lc q. ;-l!.~:cd by comr rlsan to a tested cable Scv!ng th!cher is.::at!On cnd si;;!!ar or h!gher insulation resistance requirements.
Do you agree?
A*1: Tha concept of demonstr t!ng sir. !!cr!!y is somewhat complex, but I da not egree that it is impos s!ble.
The Staff believes that the c'am:ns t r.tico of s!m?hrity !ncrer.scs in complexity as differences bctsveen the items in auestion becom2 greater (i. e., the more they ara diff: rent the loss they ere similar). In the case of the RG58 and RC59 ceWs, the Staff believes c";atification has been demonstrated in eccerc'ence with t o C. F. R. ?50.49(f}(2) because the materials of co n s t.- : tion and typa of construct!on is the same for both cables, t'i c insu!: tion thickncis for RC59 is 1.5 times greater but the s! 7c!fhd ecorat!ng resi.etarce is 10 times grerter.
Finally, there is ac'ded c nservatism !n that RC5? !s only required to remain intact (I. 2., r ; S Sc r ; to ;,n 0.m. -;) es ind!cated !n NECNP Ex.
4, reference S.
- 2 : ' '.. "' 3 ; a r, p hc:0 add: ers.9'ICh'F's comment (at page 6) that "the test :rct' cds used to que!!fy th3 RG59 cable provide a questionable t?s's either fo. qualifying the RI.59 cable or qualifying the RG58 crb': by comparison."
' l2: 19 C.F.R.
550.03 sets fe r (1 th requi. e-ents for environmental cuabf! cation of elect.-!cci equ'pment important to scfety for nuclear poe/ar p'cnts.
The NRC ac:ntance criteria for cables is described In 12iE standard 303-19T4.
I be!; eve that environmental qualification of '.CSI and RC ? !s in cc-.p:!t. ce v.dth the requirements of 10 CFR TO. :3.
f I
4 l
1 g.
7 TDa_ fc!iowing ls th rotaticnshh of Ir.su!at'en resistance to cab!: !:ngth:
. Ormu:e :: c:!culete the insu!zt!cn Resistance of a given langth cf Cable:
.. L. _ lim X CTSL p.
~
,w P., r Measurec' resistance of tested cable in Megohms C.;.g, = Cable test s, cfr.1cn length in feet 0
Ins'. :ation res! stance for cable of L feet R L =In m:gehms L = leng, !n fast R:Ter nce Mi.
.'-17?, Jcnuary 1992.
Q 2: Ocss this c:mp :ta your alfic'avit?
A;1: '/ s !! dc as.
/
!hb/&V Wif* d f.
~
Harold Walker 7
St bscrlhed and sworn be.' ora me 1;1:s //;#c:r.y of Dacem'>tr 1067:
12-% i S
b_.S. CJ.nY./
1 Vff 4'
My ecmm!ss!cn expires July 1,1991 0
t
a MC?35 3 ?O".' '. GU '.LIFICAT ON OF HA.:O' D WALKER I am c Iteacter Eng!nter in Sacticn B of the ?lant Systems Branch, O!v'slon of Engicier!ng and Syste s Technology, O ffice of Nuclear fierctor ' eg dction, Un!ted States Nuclear Regulatory Commission.
My Cutlas inclu:*2 serv'r.g as a principal reviewer in the area of nuclear plant prctection to assure ageinct var!cus hazards and certain aspects of centcinment, radio-act!v1 waste pecces.3 and other support systems csc'gned to the Branch. Prior to this assignment I was a Mechanical Engineer in the E!ectrical, Instrumentation and Control Systems Branch where I reviewed the integrity, operabliity and functional capability of mechanicci and electrical equipm1nt, mechanical components, and their cupports needed for safe ope:: tion and sa fe shutdown of nuclear faci itlac.
Prior to being assigned to the Electrical Instrumentation and Control Systeris Eran:h, I
was a
Mechanical Eng!neer in the Equipment Quc!!ficatien 3rrnch whera my duti:s included per forming technical revie."s, analyses and evaluctions of the adequacy of the environmental qualificatidn of electr!c-! and mac. anica! equipment whose fallure, due to such environmental conditiers as terapara ture, humidity, pressure and re dir.tlon, could adverseiy affect the performance of safety systems.
I we,s provicu:!y a Mcterials Engineer in the Materials Engineering Branch where my duties arm res. cons!b!!! ties i'volved the review and evaluation of natoric s perferran:2 from th n stand 0 int of operab!!!!y and functional
?
c:p:S!!:ty e-d integr'ty under rerm:f, abnormct, and accident loading
J r
~ '
f
- en !!t!cas; and analyz!ng fracture toughness cf reactor vessel materials,
-l
!ncluding specific data to assure that th a materials w!!! behave in a O
non-brittle manner.
Pr!ar to my position in t'n Maaria!s Engineering Branch, I was a Materic s Engineer in th e Enginaaring 3 ranch, Division of Operating P.uctors. IAv dutics and responsibilities included the review of operating p:c5lems to determ'ne wh3thar safety requirerrents were being satisfied r.nd to assure that operating problems were corrected, and met with due regcrd for safety and envircnmental protection.
Pr!cr to my position in the Engineering Branch, I was a ACRS Fellow at the Advisory Committee on Reactor Safeguards.
My duties included cai:: t!ng cnf conso!!detirg information pertaining to non-destructive testing methods.
'u d a R.2. d2grea 1.1 machtn!:al engineering from the City College City Uc.! ersity of,'3w Ye-k and I have taken graduate courses at N
o~ "l a t:
Uni"3rs!!y of Pittsbargh.
' ' :- '. ; j:In8ng the N F. C, i v>3s an enc!neer at Westinghouse i
rie ear-S Co. pora tien in Pittsburgh,
Pennsylvania where my duties incF;dsd t".3 r splicatien of the state cf the art fracture mechanics as well as the study of structure! intag 'ty cf c.3:teriais in various environments
^
t end under;various lord!ng c:ndit!cns.
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i 00LKETED usNRC CERTIFICATE OF SERVICE
.gg gg j$ pj ;74 I,
Deborah S.
Steenland, one of the attorneys for the Applicants herein, hereby certify that on April 8, 19&A6tcI GF ILCulh Y made service of the within document by mailing copies 00CKEimG t 'Dvict BRANCH thereof, postage prepaid to:
Alan S.
Rosenthal, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeal Panel U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Thomas S. Moore Mr. Ed Thomas Atomic Safety and Licensing FEMA, Region I Appeal Panel 442 John W. McCormack Post U.S. Nuclear Regulatory Office and Court House Commission Post Office Square Washington, DC 20555 Boston, MA 02109 Administrative Judge Sheldon J.
Robert Carrigg, Chairman Wolfe, Esq., Chairman Board of Selectmen Atomic Safety and Licensing Town Office Board Panel Atlantic Avenue U.S.
Nuclear Regulatory North Hampton, NH 03861 Commission Washington, DC 20555 Judge Emmeth A.
Luebke Diane Curran, Esquire Atomic Safety and Licensing Andrea C.
Ferster, Esquire Board Panel Harmon & Weiss 5500 Friendship Boulevard Suite 430 Apartment 1923N 2001 S Street, N.W.
Chevy Chase, MD 20815 Washington, DC 20009 Dr. Jerry Harbour Stephen E. Merrill, Esquire Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee, Esquire U.S.
Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General Washington, DC 20555 25 Capitol Street Concord, NH 03301-6397 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of the Executive Legal l
l Board Panel Docket (2 copies)
Director U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory l
Commission Commission Washington, DC 20555 Washington, DC 20555 I
{
- Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O.
Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Mr.
J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S.
Sneider, Esquire Matthew T.
Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney 25 Maplewood Avenue General P.O.
Box 360 One Ashburton Place, 19th Flr.
Portsmouth, NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A.
Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Kensington, NH 03827 126 Daniel Street Portsmouth, NH 03801 Senator Gordon J.
Humphrey Mr. Angie Machiros U.S.
Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn:
Tom Burack)
Town of Newbury Newbury, MA 01950 Senator Gordon J.
Humphrey Mr. Peter S. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn:
Herb Boynton)
Newburyport, MA 01950 Mr. Thomas F.
Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.
Washington, DC 20472 l i
/
8 Gary W.
Holmes, Esquire Richard A..Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant' Street Hampton, NH 03841 Concord, NH 03301 Judith H. Mizner, Esquire Charles P.
Graham, Esquire Silverglate, Gertner, Baker McKay, Murphy and Graham Fine, Good & Mizner 100 Main Street 88 Broad Street Amesbury, MA 01913 Boston, MA 02110 t
^
(
Deborah S.
Steenland
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