ML20151G729
| ML20151G729 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/22/1988 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20151G732 | List: |
| References | |
| CON-#388-6810 OL-1, NUDOCS 8807290192 | |
| Download: ML20151G729 (8) | |
Text
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1988 UNITED STATES OF AMERICA 30 JL 28 A9:58 NUCLEAR REGULATORY COMMISSION before the OFFICE t
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ATOMIC SAFETY AND LICENSING BOARD"nggei.';:
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In the Matter of
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PUBLIC SERVICE COMPANY
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Docket Nos. 50-443-OL-1 OF NEW RAMPSHIRE, ET AL.
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50-444-OL-1
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(Seabrook Station, Units 1
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(Onsite Emergency and 2)
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Planning nnd Safety
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Issues)
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APPLICANTS' MEMORANDUM IN SUPPORT OF PERMI'I"IING IDW POWER OPERATION PRIOR TO RESOLUTION OF "COAXIAL CABLE" ISSUE Introduction Backaround In an unpublished Order, dated June 29, 1988, the Nuclear Regulatory Commission directed this Licensing Board "to determine whether the remanded ceaxial cable issue need 1
be resolved before low-power operation."
The Licensing Board responded on July 1, 1988 by issuing a scheduling order directing that the parties file briefs addressing the issue posed by the Commission.
Applicants herein respond and demonstrate that the remanded coaxial cable issue does not need to be resolved prior to low-power operation because it j
is not relevant to low power operation.
8807290192 880722 PDR ADOCK 05000443 p$D3 G
1 In addition to this memorandum, there are filed herewith a total of five affidavits, as follows:
1.
Affidavit of Richard Bergeron, 2.
Affidavit of Bruce E.
- Beuchel, 3.
Affidavit of Thomas W. Glowacky, 4.
Affidavit of Randy C. Jamison, 5.
Affidavit of Peter S.
Littlefield.
These affidavits will be referred to in some detail below.
By way of initial background, the affidavits establish that there were originally a total of 126 RG-58 cables in Seabrook Station, and twelve of these, all located in a harsh environment, have been replaced by RG-59 cable.
Glovacky Aff. Paras.
4-5.
The Law Authorization to operate at low power should be granted under 10 CFR 50.57(c) where the pending contention is not relevant to the activity for which authorization is requested.1 Indeed, this standard was addressed by the Appeal Board in this proceeding, and the Appeal Board stated, "it is not every contention that need be heard or decided 1
10 CFR 50.57(c); Pacific Gas & Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 & 2), CLI-83-27, 18 NRC 1146, 1149-50 (1983}; Lona Island Lichtina Co. (Shoreham Nuclear Power Station, Unit 1), CLI-84-21, 20 NRC 1437, 1440 (1984) ("Simple logic and common sense indicate that some regulations should, by their own terms, have no application to fuel loading or some phases of low power operation.").
2
prior to the authorization of a low power licenso.
- Rather, in so many words, (50.57(c)) requires a hearing only on those contentions ' relevant to the activity to be authorized' --
here, operation at levels up to five percent of rateu power."2 Issues to Be Resolved In the present posture of the proceeding, there are two matters which must be resolved within the scope of the coaxial cable issue:
1.
Whether RG-58 cable is, in fact, environmentally qualified?
2.
Whether, in the twelve cases where RG-59 cable has been substituted for RG-58 cable, the RG-59 cable is a technically acceptable substitute for the RG-58?
)
ARGuxzur I,
pesolution of the Technical Compatibility the Twelve RG-59 1
Cables is Unnecessary Before Low Power Operation As set forth in the Beuchel Affidavit,3 there are two systems which contain the instrumentation necessary to provide for the automatic actions necessary for accident mitigation (The Reactor Trip System (RTS) and the Engitieered Safety Features Actuation System (ESFAS)); in addition, 2Eublic Service Company of New Hampshire (Seabrook Station, Units 1 and 2) A LAB-8 9 2, 27 NRC (May 24, 1988)
(slip op. at 10).
3 Beuchel Aff., Paras.
6-9.
3
Category I Accident Monitoring Instrumentation (AMI) is the jnstrumentation necessary to achieve the required manual operator actions required to safely ahut down the plant. The RTS, ESFAS and Category I AMI will hereinafter be referred to as the "Safe Shutdown Instrumentation" or "SSI. "
Assuming the availability of the SSI, then, in the event of the occurrence of the bounding design basis LOCA or Steam Generator Tube Rupturo event during low power operation, no off-site dose requiring off-site protective actions-would result.4 And indeed, the off-site doses which would result to the public would be extremely small percentages of those set forth in 10 CFR 100.5 This being the case, the issue of RG-59 compatibility would not adversely impact upon the public health and safety at 5% power operation and, therefore, need not be resolved before 5% power operation.6 None of the 126 coaxial cables at issue herein, including the 12 RG-59 cables, are connected to any of the devices included within the SSI.7 Inasmach as none of the twelve RG-59 cables is attach ?d to any of the devices included within the SSI, it is of no moment whether they are 4Littlefield Aff., passim.
5 Littlefield Aff., Paras.
6, 17.
6,Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), LBP-88 6, 27 NRC 245, 251 (1988),
affirmed, ALAB-8 9 2, 27 NRC (May 24, 1988).
Egg Alap Commonwealth Edison Co. (Braidwood Nuclear Power Static't.
Units 1 and 2), LBP-86-31 24 NRC 451, 456 (1986).
7Beuchel Aff. Para. 10.
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an acceptable substitute for the RG-58 cable originally used because it is not necessary that they function in order to accomplish a safe shutdown of the reactor.
II.
There is no Need to Resolve the Issue of the Environmental Qualification of RG-58 Cable Prior to Low Power Operation.
There is no need to resolve the issue of environmental qualification of RG-58 cable.
As the Board is aware, the Applicants believe that all of the RG-58 cable which is located in a harsh environment has been replaced with RG-59.
However, there remains the argument that an RG-58 cable wh'.ch would be located in a harsh environment in the event of an accident either has been "missed" by the Applicants or has not been properly classified as being in a harsh environment.
The Applicants have also addresned this problem in the Beuchel Affidavit.8 The analysis contained therein was based upon the assumption that there a hypothetical RG-58 cable I
could exist in any of the raceways of concern throughout the plant.9 It was further assumed that the failure of the cable I
would also result in the failure of all safety-related cables routed in the same raceway.10 Analysis has shown, that such an event would not compromise the SSI because:
(1) some of the instruments are simply not required during low power j
8 Beuchel Aff., Paras. 11-15.
9 Beuchel Aff., Para 11.
10Beuchel Aff., Para, 11, 5
operation 1 11 (2) some of the instruments have no input from the raceways of interest;12 and (3) with respect to all other instruments within the SSI, walkdowns have been performed to verify that the raceways of interest either (a) are in a mild environment, or (b) do not contain RG-58 cable in fact.13 In connection with the latter, it was also physically verified that, for those cables in a mild environment, active RG-58 cable does not cross the boundary from an area which could be subjected to a harsh environment into those areas.14
- Thus, even if there is any remaining RG-58 cable located in a harsh environment and even if it failed, causing the failure of all safety related cable routed with it, the SSI would still be available.15 Finally, as noted earlier, the design basis accident doses to the public are small percentages of the doses set forth in 10 CFR 100 and, therefore, the safety concerns raised do not adversely impact on the public health and safety.16 11 Beuchel Aff., Para. 12.
12 Beuchel Aff., Para. 13.
13 Beuchel Aff., Para. 14.
14 Beuchel Aff., Para. 14.
15Feuchel Aff., Para. 15.
16Suora, page 4, and authorities cited nn.
4-6.
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III. There are Other Factors Which Militate Against the Need to Resolve the Coaxial cable Issue Before Operation at Low Power.
There are a number of other factors which militate against the need for resolution of the coaxial cable issue j
prior to low power operation.
In the first place, the cables involved are all relatively new.17 Further,at the 5% testing levels, the resulting aging and accident environmental factors are much less severe than during full power operation.18 In addition, as the Board is aware from a communication sent to it and the parties on July 12, 1988,19 RG-58 cable has now been tested and found to be environmentally qualified.20 Finally, the largest current which any of the cables will see is 400 milliamps.21 Tests were conducted with new unaged RG-58 cable and new unaged LOCA tested RG-59 cable to ascertain whether shorting to shield of these cables, while carrying currents of one amp and ten amps, would result in degradation of adjacent cables which had been bundled around them to simulate the conditions of an RG-58 cable located in l
17
)
Bercqrgn Aff., Para.
4.
18 Berceron Aff., Paras.
4-6.
19Letter, NYN-88095 to NRC from Ted C.
Feigenbaum with attachment 1.
20Berceron Aff., Paras.
7-9.
21 Glowackv Aff., Para.
7.
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the middle of a cable tray.22 The results of these tests show that a failure cannot generate sufficient heat to cause damage or degradation to adjacent cables.23 l
l CONCLUSION Low power operation should be permitted pending i
resolution of the coaxial cable issue.
Respectfully submitted, f
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/&r
[
Thomas"G. Eighan, Jr.
Deborah S.
Steenland Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Cpunsel for Aeolicants l
l I
1 I
l 22Jamison Aff., Paras.
3-5.
23Jamison Aff., Paras.
6-9.
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