ML20151G806
| ML20151G806 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/20/1988 |
| From: | Berry G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| Shared Package | |
| ML20151G808 | List: |
| References | |
| CON-#388-6814 OL-1, NUDOCS 8807290226 | |
| Download: ML20151G806 (12) | |
Text
6f/Y 07/20/,88 00CKETE0 SELATED CORHf.SPVNDENpj UNITEn STATES OF AMERICA NUCLEAR REGULATORY COMMISSI0n 88 Jd. 28 A9 :36 BEFORE THE ATONIC SAFETY AND LICENSING BOARD
- t. "
In the Matter of
)
Docket No. 50-443 OL-1 e/</( 4d'/
Public Service Company of New Harpshire, et al.
ONSITE EMERGENCY PLANNING
)
& TECHNICAL ISSUES (Seabrook Station, Units 1 & 2)
)
NRC STAFF RESPONSE TO NECNP FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUf'ENTS T0 hRC, STAFF ON NECNP CONTENTION I.B.?
If1 TERR 0GATORY I f c.r each separate interrogatory below, identify each person who participated in any way in the development or preparation of answers thereto, end cescribe the inforraation or ideas contributed by that person.
RESPONSE
For eech interrogatory, the identities of the person (s) participating in the preparation of the answer thereto is listed in parentheses.
It.TERP0GATOPY 2 What is your position with respect to NECNP Contention I.B.2?
l
RESPONSE
The Staff's position is that Applicants' environmental program, qualificatien as it relates to the use of RG-58 and RG-59 coaxial cable, complies with the requirements set forth 10 C.F.R. 6 50.49.
(Staff Counsel) 8807290226 880720 DR ADDCK 050 3
a 0/
INTERP0GATORY 3 Please identify all individuals whom you intend to call as witnesses to support your position during the proceedings regarding Contention I.B.2, and describe the substance of their testimony.
RESPONSE
As of this writing, the Staff plans to call Harold Walker and Amritpal Gill as witnesses in the event a hearing is held on remanded NECNP Contention I.B.2.
The Staff, of course, reserves the right to call other or additfor,al witness if deemed necessary.
The testimony of any witness offered by Staff will support the St a f f's position that Applicants' environmental qualification program, insofar as RG-58 and FG-59 coaxial cable is concerned, corrplies with the requirements set forth in 10 C.F.R. i 50.49.
(Nerses)
INTEPP0GATORY 4 Please identify all individuals whose affidavits you intend to submit in sumary disposition proceedings regarding Contention I.B.2, and describe the substance of their affidavits.
P;ESPONSE See Pesponse to Interrogatory 3.
(Nerses)
INTERR0GATORY 5 At pages 6-7 of the NRC Staff's Response to Applicants' Suggestion of Mootness, dated June 2, you state that spare cables need not rnect the requirements of 10 CFR 5 50.49.
What measures, if any, do you intend to require of or recomtrend to Applicants to ensure that at no tine during plant life will the spare RG-58 cables inadvertently becorre energized, for exarrple, by techr.ician error or equipn.ent rnalfunction?
Please state the reason for your answer, describe any such treasures, and state whether they would be required or recorrrnended.
RESPONSE
As noted in the interrogatory, the spare cables need not meet the requirements of 10 C.F.R. E 50.49.
In regards to the reconnection of
t these spare cables, there already are procedures in place at the Seabrook Station (Bergeron affidavit dated May 19,1988atpp5-6)thatensurethat at no tirte during plant life will the spare RG-58 cables inadvertently become energized.
Therefore, at this time, the Staff believes that adequate measures exist to control inadvertent energization of spare RG-58 cables.
(Nerses)
INTERROGATORY 6 In ycur opiniori, are Applicants correct in asserting that 76 (See affidivit of Mr. Richard Bergeron datav May 26, 1968 for correction from 77 to 76 cables) of the RG-58 coaxial cables are located in a mild envirentrent?
Is your opinion based on a review of the Service Environtrental Charts attached to Applicants' Reply to NRC Staff and NEChP's Response tc Applicants' Suggestion of Mootr.ess, filed June 17, 198S?
k'ba t other documents or information is your opinion based on?
RESPONSE
11 is the Staff's positiori that Applicants are correct in asserting that the 76 RG-56 ceaxial cables are located in a mild environment.
This l
position is based on a review of the methods the Applicants used to ic'entify and track cable at Seabrook; a
review of the service environrental charts attached to the Applicants' filing of June 17, 1988; and on the Staff's familiarity sith Applicants' EQ Program.
The Staff's familiarity of the EQ program is based on the review of the Seabrook EQ l
prograr, transmitted to the Staff by letters from Applicant dated August 12, 19F3, Septerrber 7,1984, October 31,1905, April 3, 1986, and FSAR Section 3.11, at well as an audit of similar information conducted at the plant in February 1986.
The Staff's position is not based on any other infomation or decurrents.
(Walker)
4 INTERROGATORY 7 For the ten RG-58 coaxial cables that Applicants state are routed with other non-safety related cables outside the Seabrook nuclear island, you state on page 9 of the ARC Staff's Response to Applicants' Suggestion of Mootness that Applicants have not provided sufficient information to evaluate Mr. Bergeron's claim that failure of the RG-58 coaxial cable wculd not prevent the accomplishment of safety functions.
Has this concern been resolvec?
If so, please identify and describe the specific documents or statements that have resolved your co'1cern.
RESPONSE
Yes, this concern has been resolved. Fesolution is based on the Staff's review and ecceptance of the Applicants' environmental quelification progran which demonstrates compliance with 10 C.F.R. 6 50.49(b)(2) concerning ncnsafety-related electric equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishnent of safety functicrs by safety-related equipment.
This is covered in Applicants' demonstration of compliance with Regulatory Guide 1.75, "Physical Independence of Electric Systems."
It is discussed in the Applicants' letters to the NF.C dated June 10 and 13,1986. A Staff review fourd the Applicant in compliance with the guidelines of RG 1.75.
This review is occumented in section 8.3.3.3 of NUREG-0896, Supplement No. 5, issued in July 1986.
The Staff has also reviewed and found acceptat'le, the /pplicants' rrethod of identifying and tracking cable usage at Seabrook, and the service environmental charts.
Poth the method and the service er,vironmental charts are included as part of the Applicants' June 17, 1988 Peply to NRC Staff and NECNP's response to Applicant's Suggestion of Mcotness.
In addition, the Staff has reviewed NECNP's Exhibit 4 and the affidavit of Harold k'al ker in the Decerrber 11, 1987 "NRC Staff Response to Memorandum on Licensing Board and New England Coalition on Nuclear pollution Regarding Environmental Cualification of RG-58 Coaxial
~_
. Cable,"
in which it was concluded that RG-58 coaxial cable is environmentally qualified by "similarity" in accordance with 10 C.F.P. 9 50.49(f)(2).
These documents provide the Staff with confidence that the 1
RG-58 cable will not fail as a result of being exposed to the environment (s) defined in the aforementioned service environmental charts.
(Walker)
!!iTERR0GATORY 8 for the same ten cables, vou also state, on page 9 of the NRC Staff's Response to Applicants' Suggestion of Mootness, that "the Staff is not able to take a position at this time as to whether the RG-58 coaxial cables routed with other nonsafety related cables outside the nuclear island must be environmentally qualified in accordance with 10 CFR
! 50.4g. "
Is this staterrent still correct? If you are new able to take a position, please describe that position and identify ano oescribe the srecific occur:ents or statements that have enabled you to take that position.
RESPONSE
f;o, the statement no longer is correct.
The Staff's position has been and continues to be that nonsafety-related cables, such as RG-58, routed with cther nonsafety-related cables need not be environmentally qualified unless they fall within the scope of 10 C.F.R. 6 50.49(b)(2) See fiFC Staff Respense To Applicants' Suggestion Of Footness.
The affidavits of Mr. Bergeren filed on June 17, 1988, in conjunction with Applicants' earlier subrission, previde reasonable assurance that the RG-58 cables routed viith other non-safety related cables outside the nuclear island are in ccmpliance with 10 C.F.R. ! 50.49(b)(2).
(Walker)
If:TERROG,A,T_0RY 9 f;o, the statement quoted no longer is correct.
In Fart A(5) of the f!RC Staff's Response to Applicants' Suggestion of Mootness, you state that the Staff has ro current position as to whether the nine cables alleged to be routed with nonsafety cables through a mild environinent must be
environmentally qualified.
Is this statement still correct?
If you now ha',e a position, please describe that position and identify and describe the specific documents or statements that you rely on to support that position.
RESPONSE
In accordance with 10 C.F.R. 0 50.49(c)(iii),
environmental qualificatien of electric equipment important to safety located in a mild environment are not included within the scope of this section" (i.e., not within the scope of 10 C.F.R. ! 50.49).
Therefore the staff position is that equiptrent located in a mild environment is not required *;o be environmentally qualified in accordsnce with 10 C.F.R. 50.49.
The affiduits of Mr. Bergeron subtritted on June 17, 1988 and May 19, 1988 derronstrate to the Staff's satisfaction that the subject RG-58 cables are not located in a harsh environnent.
(Walker)
INTERFOGATORY 10 In deciding whether a cable is environmentally qualified, do you agree that ycu must take into consideration the functional performance requirerr.ents of that cable in its particular functional application?
Fcr example, do you agree that the tragnitude of leakage current permissible for a cable used in a pcher circuit could be significantly larger than the leokage current permissible for a cable used in an instrumentation circuit?
.R.E_Sp0NS E The environtrental qualification of a cable does not depend on the functional performance, as defined in a purchase specification.
The characteristics which relate to environmental qualification are outlined in IEFE Standards 323-1974 and 323-1974 and may vary depending on the specific application.
(IEEE Standards 373-1974 and 383-1974 have been endorsed by the Staff as being acceptable to meet the requirerrent of 10 C.F.R. 6 50.49).
For instrumentation cable, such as RG-58 and PG-59
coaxial cable, one of the more imprrtant criteria during environmental qualification testing is insulation resistance (IR).
This is important becarse it provides an indication of the ability of a cable to maintain its integrity under accident conditions.
IR is an indication of leakage current.
The Staff agrees that the magnitude of acceptable leakage current permissible for a cable use in a power circuit could be significantly larger than the leakage current permissible for cable used in an instruaentation curcuit.
However. tne leakage current of cables used in power circuits is rot related to the environmental qualification of RG-58 or RG-59.
(Walker)
JNTEPRCGATORY11 Have >cu evaluated the adequacy of RG-59 coaxial cable to meet functicnil performance requirenents in the circuits that presently use RG-58 coaxici cable?
If so, what was the result of your evaluaticn?
If not, why not?
RESPCNSE Based on Appl icants ' affidavits before the Licensing -Ecard (see Applicants' Suggestion Of Mootness, dated Fay 19, 1988), the RG-58 coaxial cables are used in nonsafety-related circuits. Applicants have identified 12 RG-58 coaxial cables from the installed RG-58 coaxial cables at the Seabrook plant that must neet the environmental qualifications set forth 10 C.F.R. 50.49.
Applicant have also represented that the 12 RG-58 coaxial cables have been repit.ced with RG-59 coaxial cables.
The staff's review of the ncnsafety-related circuits is limited to review of conforciance to 10 C.F.R. 6 50.49 for those circuits that are i
ir.stelled in a harsh environment.
The Staff reviewed the RG-58 and RG-59
o l
coaxial cables for compliance with 10 C.F.R. 6 50.49 and accepted both cables as being environmentally qualified.
The RG-59 cable was qualified by test and RG-58 was cualif: J on the basis of its similarity" to RG-59 (see NRC Staff Pesponse to Memorandum of Licensing Board and New England Coalition of Nuclear Pollution Regarding Environmental Qualification of RG-58 Coaxial Cable).
The functional adequacy of RG-59 coaxial cable as replacen.ent of RG-55 coaxial cable is not germane to the environmental qualification isst:e.
It is the responsibility of the Applicants to conduct adequate evaluations c.f all nonsafety applications for functional requirements and compatability.
In the case of RG-58 and RG-59 ceaxial cables, Applicants evaluated the 12 RG-58 circuits in question to assess whether RG-59 coaxial cable is functionally corrpatible with RG-58 coaxial cable (see Gerald A. Kotkcwski affidavit, dated May 19, 1988).
In determining the functionel acceptability of RG-59 coaxial cable for the 12 P.G-58 circuits, the Applicant evcluated the attenuation characteristics, velocity of propagation and corrpatibility of connecting devices / instruments and found thcm ecceptable.
In addition, the Applicant contacted the vendors of the connected equiprent and confirmed the use of RG-59 coaxial was acceptable.
The Staff has no concern regarding the aceouacy of Applicents' review or the conclusions reached.
(Gill)
INTERROGATORY 12 What is the Staff's position regarding whether RG-59 coaxial cable is a technically 6cceptable replacenent for the RG-58 coaxial cable? Please identify a rid c'escribe the staternents and/or dccuments on which your position is ba nd.
~
RESPONSE ~
The Staff's position is that the RG-59 coaxial cable is technically acceptable replacement for RG-58 coaxial cable.
The Staff's position is based upon the results of Applicants' functional evaluation of the RG-59 coaxial cable with respect to functional requirements of RG-58 coaxial cable and as documented in the response to Interrcgatory No. 11.
The documents forming the basis of the Staff's position are also described in the respense to Interrogatory Fo. 11.
(Gill)
INTERROGATORY 13 Do you centinue to take the position described to the Licensing Board in a telephone conference call dated June 23, 1988, that "the record certains all the information necessary for the Board to issue a deternination faverable tc applicants on the remanded contention." Tr. at 1160. Please state the reason (s) for your answer.
RESPONSE
Yes.
The Sta f f's Pcply to Applicants' Suggestion Of Mootness describes the shtving necesstwy for Applicants to prevail on remanded NECNP Centention I.B.2.
The testimonial and docurentary evidence suttitted by Applicants' on May 19, 1988 and June 17, 1988 demens tra tes that there is reasonable assurance that there no longer are any RG-5E cables irstalled in harsh en ironments and that RG-fc cable (the environmental qualification of which is nct subject to dispute in this proceecing} is an acceptable replacentent for RG-58 cables which previously were located in harsh environrnents.
(StaffCounsel)
INTERROGATORY 14 Please identify and cescribe all telephone conversations and nectings with Applicants in which you have discussed RG-5E coaxial cable.
RESPONSE
The Staff (Harold Walker) has hcd two or three telephone conversations with the Applicant (Mr. Richard Bergeron) to discuss RG-58 cable. The conversation took place in April and or May 1988. However, no records of the conversation and no notes were taken.
The conversation were all quite short and restricted to clarifying information contained in -
the public record.
(Walker)
INTERROATORY 15 Please identify any future meetings cr conversations you intend to hold with Applicants for the purgese of discussing RG-58 ccaxial cable.
l
RESPONSE
There are no scheduled future discussions concerning PG-58 coaxial cable.
(Kalker)
INTERRCGATORY 16 Pittse describe any investigations or evaluations you have corducted regarding RG-58 ceaxial cab?e at Seabrook, and identify any future investigations or evaluatier.s you intend to undertake.
RESPONSE
On February ?5, 26, 27, 1986, the Staff, with assistance fr-EGG Idaho, Inc., an NRC contractor, conducted an audit of the Applicant's qualification files ar.d equipment installed at the plant.
Twelve files were audited to deterniine if the docun:ents in the qualification files supported the qualification status determined by Applicants. A file (File
- 113-19-01) docunenting the qu6lification of RG-58 was included in the twelve files audited.
The results of that audit were transmitted to
'pplicants by letter dated April 10, 1986.
The Staff has reviewed NECNP
Exhibit 4 which also included File #113-09-01.
The Staff has also reviewed the affidavits of Mr. Richard Bergeron dated May 19, May 26 and June 16, 1988 and the affidavits of Mr. Gerald A. Kotkowski and Mr. Ted C.
Feigenbaum dated Pay 19, 1938, these reviews constitute all aspects of the Staff investigation regarding RG-58 coaxial cable.
The Staff recently -
(July 14, 1988) received a test plan and results of the environrrental qualification testing rectly completed by National Technical Systems / Action Division en RG-58 coaxial cable n:anufactured by ITT Suprenant.
The Staff may review this data and the completed test report when it becomes available sorretime in the future.
(b'al ker)
INTERR0GATORY 17 Plecse identify any retbers of the NRC Staff who disegree with the answers to thu e interrocatories, ar.d describe their position (s), the reason (s) for their position (s), and the reason (s) that you disagree with theirposition(s).
RESPONSE
The Staff is ur. aware of any trember who disagrees with any of tbc.
ar.swers to these interrogatories.
(Nerses)
FECUEST FOR IDENTIFICATION AND PRODUCTION OF DOCUMENTS:
REQUEST,1 Ple?.se identify all docurrents on which you rely to support your position with respect to Contention J.R.2.
FESPONSE The documents upon which the Staff relies are identified in the foregoing responses to these interrogatories.
REQUEST 2-Please identify all documents in your possession which discuss or refer to whether environmental oualification is required for RG-58 ca m ;
why it is or is not environmentally qualified; why it does or does not need to be environmentally qualified; what environtrental qualification specificatier.., if any, have been recuired or considered for RG-58 cable; whether RG-59 cable meets qualification specifications or other specifica-tions for RG-SS cable; the locations of RG-58 cable in the Seabrook plant; the functicr.s served by RG-58 cable; and whether or not those functions are considered important to safety.
RESPONSE
All documents in the Staff's possession which are responsive to Document Request 2 are identified in the Staff responses to these Interrogatories.
REQUEST 3 Please identify all dccuments relied on for purposes of answering the foregeing interrogatories.
RESPONSE
See response to Document Request I above.
PEOUEST 4 Within 14 cays, please produce the documents identified in response to the preceding requests for the identification of documents.
i l
RESPCESE Objection.
The docunents sought by this docurrent request readily are obtain:W frce the Applicants or NPC Public Document Rocrr.
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