ML20151G861
| ML20151G861 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/27/1988 |
| From: | Walker H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20151G858 | List: |
| References | |
| OL-1, NUDOCS 8807290273 | |
| Download: ML20151G861 (11) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COPMISSION i
BEFORE THE ATOMIC SAFETY ALD LICENSING BOARD In the Matter of
)
Docket Nos. 50-443 OL-01 ruBLIC SERVICE COMPANY OF 50-444 OL-01 NEW HAPPSHIRE, et al.
On-site Emergency Planning i
and Safety Issues (Seabrook Station, Units I err' ')
AFFIDAVIT OF HAROLD WALKER I, Harc1d Walker, being first duly sworn, hereby affirne that the respenses to the questions set forth herein are correct to the best of my knowledge and belief:
Q1: !!r. Valker, by whom and in what capacity are you employed?
l A1:
I am errployed by the U.S. Nucicar Regulatory Comissien as a Senior Reacter Systems Engineer in Section B of the Plant Systtn.s Branch, Divisien of Engineering and Systems Technclogy, Office of the Nuclear Reactor Regulation.
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Q2: Have you prepared a statement of your professional qualification?
A2:
Yes, a staterrent o' my professional cualificatict s is attached as an exhibit to this affidavit.
Q3: Mr. Walker, what is the purpose of this affidavit?
I l
A3:
This affidavit addresses the question whether remanded NECNP Centention I.B.2, relating to the environmental qualification of RG-58 coaxial cable raises issues which must be resolved prior to the i
8807290273 880727 PDR ADOCK 05000443 C
2 reauthorization of low power (5% rated power) operations at the Seabrook facility.
Q4: Mr. Walker, the Appeal Board has stated that "10 C.F.R. 6 50.57(c) allows the authorization of low-power operation so long as no safety issues pertaining to such cperation remain unresolved."
Are any e
safety issues pertainirg to low power operations presented by remanded NECNP Contention I.B.2?
A4:
The Staff's position is that the requirements of 10 C.F.R. 5 50.49
("Environment 61 Qualification of Electrical Equipment Itportant To Safety For Nuclear Power Plants") apply during low power as well as full power operation. The basis for this position is that were an accident to occur at low-power (less than 5% rated power),
there is the potential for failure of safety-related and t ensafety-related electrical equipment (as discussed in 10 C.F.R.
! 50.49(b)) if subjected to a harsh environment.
Such equipment is relied upon to remain functional during and following postulated events to er.sure the integrity of the reactor ccolant pressure boundary, to safely shut down the reactor and maintain it a safe shutdown condition, and to prevent or mitigate the consequences of accidents that could result in potential offsite ex psure.
l It should be noted that remanded NECNP Contention 1.E.? focuses not on electrical equipment in general but rather on a single type of electrical equipment:
RG-58 coaxial.
Accordingly, the Staff acknowledges the possibility that a review of the particular applications of RG-58 at the Seabrook Station may result in a determination that the environmental qualification of RG-58 cable is i
not essential for safe operation of the facility at low pcher.
In making this evaluation, the Staff would conduct a review, similar to 1
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. L
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that described in NRC Generic Letter 88-07, to determine whether l
failure of the sub.iect RG-58 cables under accident conditions during l
low-power operation would result in significant degradation of any i
safety function or prcvide misleading information to plant operators.
)
I note that on July 22, 1988, Applicants submitted information intended to demonstrate.that the RG-58 coaxial cables installed at the Seabrook Station are not relevant to low-power operation; the Staff, however, has not reviewed or evaluated this infortation and, in view of the response' to the following question, believes that a ccenprehensive review a r..
evaluation of these materials is not necessary.
05: Mr. Walker, section 50.57(c) of the Comission's regulations provides that where a pending contention is relevant to low power operation, the Licensing Board must find that there is reasonable assurance that the concern raised by the centention will not threaten the public health and safety during low power operation. Do you have an opinion as whether such reasonable assurance exists?
A5:
It is the Staff's position that Applicants have 5 snted sufficient information to demonstrate that both RG-58 and RG-59 coaxial cables are environn;entally qualified for use at the Seabrook Station.
The Staff's conclusions are documented in a letter to i
Applicants dated April 10, 1986, NUREG-0896, Supplement No. 5, which l
was issued July 1986, and in my affidavit of December 'll,1987, which 1
is attached to the "NRC Staff Response To Memorandum Of Licensing Board And New England Coalition On Nur. lear Pollution Regarding Environtrental Qualification Of RG 59 Coaxial Cable."
Further, since Applicants have replaced those RG-58 cables which could be exposed to a harsh environment with RG-59 coaxial cable which previously has m..
that described in NRC Gene *ic Letter 88-07, to determine whether failure of the subject RG-58 cables under accident conditions during low-power operation would result in significant degradation of any safet.y function or provide misleading information to plant operators.
I note t%t on July 22, 1988, Applicants submitted information i
intended to demonstrate that the RG-58 coaxial cables installed at the Seabrook Station are not relevant to low-power operation; the Staff, however, has not reviewed or evaluated this infornation and, in view of the response' to the following question, believes that a comprehensive review and evaluation of these materials is not necessary.
QS: Mr. Walker, section 50.57(c) of the Corraission's regulatforts provides that where a pending contention is relevant to low power operation, the Licensing Board must find that there is reasonable assurance that the concern raised by the centention will not threaten the public health and safety during low power operation.
Do you have an opinion as whether such reasonable assurance exists?
A5:
It is the Staff's position that Applicants have presented sufficient information to derrens trate that both RG-58 and RG-59 coaxial cables are environn;entally qualifie>i for use at the Seabrook Station.
The Staff's conclusions are documented in a letter to Applicants dated April 10, 1986, NUREG-0896, Supplement No. 5, which was issued July 1986, and in my affidavit of December 11, 1987, which is attached to the "NRC Staff Response To l'emorandum Of Licensing Board And New England Coalition On Nuclear Pollution Regarding Environtrental Qualification Of RC-59 Coaxial Cable."
Further, since Applicants have replaced those RG-58 cables which could be exposed to a harsh environment with RG-59 coaxial cable which r eviously has
been demonstrated by test to be environmentally qualified, the Staff concludes that remanded NECNP Contention I.B.2 does not present any unresolved safety issue pertaining to low power or full power operation.
For these reasons, is my opinion that there is sufficient basis for the Licensing Board to find reasonable assurance that the Seabrook Station can be operated at 5% rated power without endangering the health and safety of the public.
Q6: Pr. Walker, please explain in detail why you believe that RG-58 coaxial cable meets the environmentally qualifications requirements of 10 C.F.R. 6 50.49.
A6:
The Staff's initial review of the environmental qualification of RG-58 coaxial cable installed at Seabrook occurred during an audit of the Seabrook environmental qualification program conducted February 24 through 27, 1986.
The purpose of the audit was to determine if the documents in the environmental qualification files supported the quhlification status assigned by Applicants.
This audit included file No. 113-19-01 which is the qualification file for RG-58 coaxial cable.
The audit did not identify any environmental qualification deficiencies related to RG-58 cable.
The results of the audit are documented in an April 10, 1986 letter to Applicants and in Section 3.11.4 of hUREG-0896, Supplement No. 5, which was issued in July l
1986.
The Staff again reviewed environmental qualification file No.
113-19-01 as part of NECNP Exhibit 4 (NECNP Ex. 4 already has been receivedinevidence).
'n this review the Staff concluded that RG-58 coaxial cable is environmentally cualified in accordance with 10 C.F.R. 5 50.49(f)(2) by virtue of its "similarity" to RG-59 coaxial i
i Cable.
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I
. )
The Staff's conclusion that RG-58 cable meets the environmental qualification requirements of 10 C.F.R. 9 50.49 included a review of the test report for RG-59 cable (see NECNP Exhibit 4, Ref. 2). This test report demonstrates that RG-59 cable is environmentally qualified.
See Gill / Walker Affidavit, attached to February 17, 1988 NRC Staff Response To NECNP Motion To Reopen Record.
The Staff concluded that RG-50 cable is sufficiently similar to RG-59 for purposes of section 50.49(f)(2) because tne cables' materials, construction, and manufacturer are the same, as is the cable type (i.e., both are single conductor).
See NECNP Exhibit 4; Walker Affidavit, attached to December 11, 1988 NRC Staff's Response To Memorandum Of Licensing Board And New England Coalition On Nuclear Pollution Regarding Environmental Qualification Of RG Coaxial Cable.
It should be emphasized that "similarity" for purposes of section 50.49(f)(2) docs not require. that components, such as cables, be identical.
Instead, it is the Staff's practice to review the environmental qualification files of components to determine whether there is reasonable assurance that the test results for one component, in this case RG-59 coaxial cable, will be representative of another component, in this case RG-58 coaxial cable.
Consequently, as a result of reviewing Qualification File No.
113-19-01, the Staff concluded tnat RG-59 coaxial cable is environmentally qualified by test in accordance 10 C.F.R. 650.49(f)(1) and that RG-58 coaxial cable is envirorrrentally qualif ted by similarity in accordance with 10 C.F.R. 5 50.49(f)(2).
i
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-6 In addition. Applicants recently conducted a review of its records relating to RG-58 coaxial cable which revealed that 12d RG-58 cables had been installed at the Seabrook Station.
The Staff has reviewed and is satisfied with the methodology used by Applicants to identify these cable installations and thus has reasonable assurance that Applicants have succeeded in identifying and locating all of the installed RG-58 cables.
The Staff has also reviewed and finds acceptable the trethodology by which Applicants assigned each RG-58 cable to one of the five category groupings.
Further, based upon a review of the information submitted by Applicants, the Staf f is persuaded that of the 126 RG-58 coaxial cables, the requirements of 10 C.F.R. ! 50.49 are inapplicable to 114 of them.
See June 17 1988 Applicants' Peply To NDC Staff and NECNP's' Response To Applicants' Suggestion Of Mootness, and Affidavit of Richard Bergeron (May 19 and P6, and June 17,1988).
In this connection, the Staff agreas with Mr. Bergeron, Applicants' expert, that the 19 RG-58 cables used as spares need not be environmentally. qualified because they are not "important. to safety" as that phrase is defined in section 50.49(b).
The Staff also agrees with Mr. Bergeron that the 76 RG-58 cables located in mild environments are not subject to the requirements of 10 C.F.R. G 50.49.
Similarily, the Staff agrees with Mr. Bergeron that the nine RG-58 cable.s in mild environment within the nuclear island and routed with other non-safety related cables outside the nuclear island are not required to be environmentally qualified in accordance with 10 C.F.P.
6 50.49.
Last, the Staff agrees with Mr. Bergeron that the 10
., - ~,
y
, RG-58 cables routed with other non-safety related cables outside the nuclear island are not required to be qualified in accordance with 10 C.F.R. I 50.49.
Applicants' review iridicated that the balance of the installed RG-58 cables (12 in number) were located in a harsh environment and thus subject to the environmental qualification requirements of 10 C.F.R. ! 50.49.
(10 C.F.R. 9 50.49(b)(2).
These cables, however, now have been replaced with. environmentally qualified RG-59 coaxial cables.
The Staff believes that the evaluation conducted by Applicants in determining whether RG-59 is a functionally acceptable I
replacement for RG-58 is adequate.
This "functional acceptability" evaluatien is described and explained in the Affidavit of Gerald A.
1 Kotkowski, attached to Applicants' May 19, 1988 "Suggestion Of Mootness."
It is also the Staff's position that Applicants now have adecuately identified the specific uses of RG-58 coaxial cable at Seahrcok.
This position is based on the Staff's review of Applicants' method of icentifying and tracking cable at Seabrook and a review of the service environmental charts.
Both the method and the service environtrental charts are attached to Applicants' June 17, 1908 Reply To NRC Staff and NECNp's Response To Applicants' Suggestion Of Mootness.
Based on all of the foregoing reasons, the Staff has concluded that Applicants have derronstrated compliance with the requirements for environmental qualification as outlined in 10 C.F.R. S 50.49 and thus have provided reasonable assurance that the health and safety of I
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the public will not be endangered during low-power or full-power operation'of the Seabrook Station.
Q7: Mr. Walker, does this complete your affidavit?
A7:
Yes it does.
J h
Harold /Kal ke'r Sworn to and subscribed before me this 27th day of July 1988:
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@ oi~clssion expires: ~ July 1,1990 l
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Uwc UNITED ST ATES OF AMERIC A NUCLEAR REGUL ATORY COVMISSION
'88 J128 A9 :44 B EFO R E _ T HE ATOMIC S AF ET Y A N D LICENSIN G 'B(dkb $ 6.,jd, E R A tt -
In the Matter of
)
)
Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF 50-444 O L-01 NEW H A MPSHIR E, et al.
On-site Emergency Planning and Safety Issues (Seabrook Station, Units 1 and 2)
)
C E R TIFIC A_T E O F S E R VIC E I
hereby certify that conies of "FRC STAFF
RESPONSE
TO LICENSING BOARD ORDER OF JULY 1,
1988 in the a bove-captioned proceeding have been served cn the following by deposit in the United States mail, first class, er as indicated by an asterisk, by deposit in the Nuclear EE g ulatory Commission's internal trail system or, as indicated this 27th day of July 1988.
Sheldon J. Wolfe, Eso., Chairman
- Atomic Safety and Licensing
/ dministrative Judge Beard
- Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D C 20555 Washington, D C 20555 Dr. Jerry Harbour
- Docketing and Service Section*
l.dministrative Judge Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Pegulatory Commission Washington, D C 20555 Washington, D C 20555 Dr. Emmeth A. Luebke T homas G. Dignan, Jr., Esq.
Administrative Judge Robert K. Gad, III. Esq.
4515 Willard Avenue Ropes & Gray C hevy Chase, Maryland 20815 225 Franklin Street Boston, M A 02110 Atomic Safety and Licensing H. J. Fly n n, E s q.
A ppeal Panel
- Assistant General Counsel U.S. Nuclear Regulatory Commission Federal Emergency Management Agency Washington, D C 20555 500 C Street, SW Washington, D C 20472
.2-Philip Ahren, Esq.
Calvin A. Canney Assistant Attorney General City Hall Office of the Attorney General 126 Daniel Street State House Station Portsmouth, NH 03801 A ugusta, ME 04333 Mr. Angie Machiros, Chairman Carol S. Sneider, Esq.
Board of Selectmen Assistant Attorney General 25 High Road Office of the Attorney General Newbury, M A 09150 One Ashburton Place,19th Floor Boston, M A 02108 George Dana Bisbee, Esq.
Allen Lampert Assistant Attorney General Civil Defense Director Office of the Attorney General Town of Brentwood 25 Capitol Street 20 Franklin Concord, N H 03301 Exeter, N H 03833 Ellyn R. Weiss, Esq.
William Armstrong Diane Curran, Esq.
Civil Defense Director Harmon & Weiss Town oF Fxeter 2001 S Street, N W 10 Front Street Suite 430 Exeter, N H 03833 Washington, D C 20009 Robert A. Backes, Esq.
Gary W. Holmes, Esq.
Backus, Meyer & Solomon Holmes & Ellis 116 Lcwell Street 47 Winnacunnet Road Manchester, f:H 03106 Hampton, N H 03842 Paul McEachern, Esq.
J. P. Nadeau Matthew T. Brock, Fsq.
Board of Selectmen Shaines & McEachern 10 Central Street i
25 Maplewood Avenue Rye, N H. 03870 P.O. Box 350 Portsmouth, N H 03801 Judith H. Mizner, Esq.
Charles P. Graham, Esq.
Silverglate, Gertner, Baker, McKay, Murphy & Graham Fine 3 Good j
100 Main Street 88 Board Street Amesbury, M A 01913 Boston, M A 02110 Sandra Gavutis, Chairman Robert Carrigg, Chairman Board of Selectmen Board of Selectmen RFD #1, Box 1154 Town Office Kensington, NH 03827 Atlantic Avenue North Hampton, N H 03870 l
William S. Lord Peter J. Matthews, Mayor Boar d of Selectmen City Hall Tewn Hall - Friend Street flewburyport, M N 09150 A n,es bury, M A 01913 y-
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Mrs. Anne E. Goodman, Chairman Michael Santosuosso, Chairman Board of Selectmen Board of Selectmen 13-15 Newmarket Road South Hampton, NH 03827 Durham, NH 03824 Hon. Gordon J. Humphrey Ashod N. Amirian, Esq.
United States Senate Town Counsel for Merrimac 531 Hart Senate Office Buf1 ding 376 Main Street k'eshington, D C 20510 uaverhill, M A, 08130 l
Wh Ah-Tiregory ala n Bsrry Counsellpr h k C Staff i
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