ML20151N528

Applicant Response to New England Coalition on Nuclear Pollution (Necnp) Second Set of Interrogatories & Request for Production of Documents to Applicant on Necnp Contention I.B.2.* W/Certificate of Svc.Related Correspondence

ML20151N528
Person / Time
Site:	Seabrook
Issue date:	07/28/1988
From:	Feigenbaum T, James Smith PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	NEW ENGLAND COALITION ON NUCLEAR POLLUTION
References
CON-#388-6839 OL-1, NUDOCS 8808090028
Download: ML20151N528 (12)

Text

'

1

, [U7 samssee July 28, 1988 Tsr

'83 AUG -1 P3 :03 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

.: rr Luce; ,-

before the ATOMIC SAFETY AND LICENSING BOARD

. )

In the Matter of )

)

PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al. ) 50-444-OL-1

) On ite Emergency (Seabrook Statica, Units 1 and 2) ) Planning Issues

)

)

APPLICANTS' RESPONSE TO I "NEW ENGLAND COALITION ON NUCLEAR i POLLUTION'S SECOND SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION ?F DOCUMENTS TO APPLICANTS ON NECNP CONTENTION I.B.2" Pursuant to 10 C.F.R. 5 2.741, Applicants herein respond to "New Englend Coalition on Nuclear Pollutien's Second Set of Interrogatories and Request for the Production of

! Documents to Applicants on NECNP Contention I.B.2."

GENERAL OIL 7ECTIONS 3

Applicants ,bject to the proposed definitions provided in paragraphs 2-4 of the instructions on the grounds that su7h definitions are overbroad and burdensome. Applicants will "identify" drawings by number, and other documents by category or by title and date. Applicants will "identify" an 8808090028 000728 gDR ADOCK 0 %

4 individual by providing the in't . '2di's name, title, and i business address.

INTERROGATORY NO. 1 Reference 1 of Equipment Qualification File No.

113-19-01 provides the specifications for RG-58 coaxial ,

cable in purchase order no. 9763-006-113-19. Please  ;

identify the individual (s) who developed these specifications. What is the basis for these specifications?

BESPONSE i

UE&C Specification 9763-006-113-19 was prepared by G.W.

Morris and checked by D.W. Knox. Morris held the title of ,

Engineer I, ar.d Knox of Engineer I. Knox's business address is United Engineers & Constructors, Inc., 30 South 17th Street, P.O. Box 8223, Philadelphia, PA 19101. Morris, while employed at the time by United Engineers & Constructors, l i

Inc., is ne longer employed by United Engineers & [

l' Constructors, Inc. His current business address is presently a

unknown. ,

The bases for the specifications for RG-58 coaxial cable I

are the characteristics of the cable applications, the general industry standards included in Section 3.0 of UE&C Specification 9763-006-113-19, and a technical data sheet  !

supplied by ITT Suprenaut, f INTERROGATORY NO. 2 l If RG-59 coaxial cable is an acceptable substitute  !

]

for RG-58 cable, why was RG-58 coaxial cable ordered in i the first place? j t

i b 1 ,

1 1  !

or, i

RESPONSE

f Applicants object to this interrogatory on the graund that it is irrelevant to the issues properly in litigation in these proceedings. j Without waiving the foregoing objection, Applicants  !

state that RC-59 coaxial cable is an acceptable substitute l for some but not all uses of RG-58 cable. The 12 circuits where RG-59 coaxial cable was substituted for RG-58 cable were reviewed on a case-by-case basis and found to be acceptable. RG-58 coaxial cable was initially ordered to meet '/endor requirements for interconnections in the main i pla:t.t computer. f INTERROGATORY NO. 3 [

On what basis was RG-58 coaxial cable originally designated operability code A? Who made the

determination and when?

i i

RESPONSE l During the initial development of the E.Q. program, it was decided to use the very conservative approach of reviewing cable for the mest restrictive potential I  :

l application (32g2, operability Code A) regardless of actual i plant application. This approach simplified programmatic i

controls for cable urage. The results of this evaluation are clearly documented in E.Q. file 113-19-01 (NECNP Exhibit 4).

Equipment identification numbers for cables were i typically assigned only to each type of cable within each purchase order (types of cable being power, control, i

7 4

instrument, or thermocouple). The primary purpose of the equipment identification number in the Harsh Environment Equipment List was to tie the cable type to an EQ file. For each type of cable there may have been numerous cable codes, depicting various constructions, sizes, and colors, all within the same EQ file. The operability code shown in the Harsh Environment Equipment List was for the most demanding application of all of the cables with EQ File 113-19-01. The specific requirements for each cable code were considered within the EQ File and the acceptance criteria established accordingly.

It is clear from EQ File 113-19-01, Reference 6 that cables with a color scheme of black with a red tracer, such as RG-58, need only remain intact during harsh environment conditions and have no performance requirements such as accuracy. This agrees with the definition for operability Code B - "Equipment that will experience conditions of design basis accidents through which it need not function for mitigation of such accidents but through which it must not fail in a manner detrimental to plant safety or accident mitigation". Had the EG-58 cable been the only cable in the EQ File, then the operability Code for equipment identification number EDE-CBL-6 would have been "B".

The design change to replace the RG-58 cables within the scope of 10 C.F.R. 550.49 also revised the Harsh Environment i

(

~4-l l

1

o Equipment List to show the Operability Code as "B" for RG-58 and other completely non-vital cable codes.

There is no record of which individual (r.) made the initial determination that cables would be reviewed for the most restrictive potential application (gtgt, Operability Code A).

INTERROGATORY NO. 4 Please provide the acceptance criteria for environmental qualification of RG-58 coaxial cable.

From what are these acceptance criteria derived?

RESPONSE

The acceptance criteria are based on 10 C.F.R. 550.49, subsection (b)(2) in particular, and the FSAR Section 8.3.

The acceptance criteria are summarized accurately in EQ File 113-19-01, Reference 6 (NECNP Exhibit 4), namely that the cable shall remain intact during harsh environment conditions.

INTERROGATORY NO. 5 Please identify and describe all telephone conversations and meetings with the NRC Staff in which you have discussed RG-58 coaxial cable.

RESPONSE

Applicants object to this interrogatory on the grounds that it is overbroad and not reasonably calculated to lead to the discovery of admissible evidence.

Without waiving the foregoing vojections, Applicants state that a few telephone conversations occurred during 1988 between the NRC Staff (Mr. Harold Walker) and New Hampshire Yankee (Mr. R. Bergeron) during which RG-58 coaxial cable was discussed. These conversations involved providing clarification to the NRC Staff concorning information that was already available contained in previously submitted documents for Seabrook Station. There eire no notes or records of conversation documenting these discussions (i.e.,

none were taken). To the best of Mr. Bergeron's recollection these telephone conversations took place in April and May 1988.

There have been no meetings with the NRC Staff regarding RG-58 coaxial cable.

INTERPOGATORY NO. 6 Please identify any future meetings or conversations you intend to hold with the NRC Staff for the purpose of discussing RG-58 coaxial cable.

i

RESPONSE

Applicants object to this interrogatory on the grounds that it is overbroad and not reasonably calculated to lead to l

the discovery of admissible evidence.

I Without waiving the foregoing objection, Applicants l

state that they have no present intent as to any future meetings or conversatimis with the NRC Staff for the purpore of discussing RG-58 coaxial cable.

I REOUEST NO. 7 Please identify all documentation which demonstrates that RG-59 coaxial cable meets the acceptance criteria for RG-58 coaxial cable.

I l

RESPONSE

Applicants object to this request on the grounds that it is irrelevant to the issues properly in litigation in these proceedings. The Board has clearly and emphatically ruled that the environmental qualification of RG-39 coaxial cable is not to be litigated in these proceedings. Public service Company of New Hamoshire (Seabrook Station, Units 1 and 2),

ASLBP No. 88-558-01-OLR (June 28, 1988) ("we will neither allow nor give consideration to any arguments or to any efforts to contend that the RG-59 cable is not environmentally qualified"); see also Public Service Comoany of New Hamoshire (Seabrook Station, Units 1 and 2), ALAB-886, __ NRC __ (Feb. 22, 1988).

Without vaiving the foregoing objection, Applicants I state that documents in EQ File 113-19-01, and particularly the Franklin Institute Research Laboratory Final 9eport F-A5550-8, demonstrates that the replacement RG-59 cable meets the acceptance criteria for RG-58 coaxial cable (i.e., cable remains intact / does not fail).

i REQUEST NO. c.

Please identify all documents relied on for i

purposes of answering the forngoing interrogatories.

RL'S PONSE Applicants object to this request on the grounds that it 1

is overbroad. Applicants also object to the request to the extent that it is irrelevant to the issues properly in litigation in these proceedings. Applicants object, and will Y

-7

- ---r --m, -c_-m-.7. . . - . .,_ _ _ _ _ _ _ . .

not identify or produce any and all documents previously filed or produced in these proceedings, and any and all documents that otherwise are publicly available.

Without waiving the foregoing objections, and with the exception noted above, Applicants state that they relied upon the documents identified in the above interrogatory responses, as well as:

. Mod Comp Drawing No. 515-A00009

• Mod Technical Manual 225-900006-001, p. 4-8

• Engineering Evaluation Number 88-014, Replacement of Coaxial Cable Type RG-58 by RG-59

• ITT Suprennut Data Sheet.

REOUEST NO. 9 Within 14 days, please provide access to all documents identified in response to the foregoing requests.

RESPONS8 Applicants incorporate here their objections to Request No. 8.

Without waiving the foregoing objections, and with the exception noted, Applicants will produce all requested documents which are in their possession or control.

Documents will be transmitted to NECNP under separate cover, pursuant to arrangements between counsel for NECNP and Mr.

William J. Daley.

1 l

l l

1 -g-l

l As to Answers: l h *F Ted C. Felsenbaum Vice President of Engineering, Licensing, and Quality Programs New Hampshire Yankee Division of Public Service Compan/ of New Hampshire July 28, 1988 State of New Hampshire Rockingham County, as.

Then appeared before me the above subscribed Ted. c.

Feigunbaum and made oath that he is the Vice President of Engineering, Licensing, and Quality Programs of Mew Hampshire Yankee Division, authorized to execute the foregoing responses to interrogatories on behalf of the Applicants' that he made inquiry and believes that the foregoing answers accurately set forth information as is available to the Applicants.

Before me,,

'ShA E. Shu My Commission Expires J 3 - L, 30 As to ob'jectionst

, /; , i;2 e -a f . . ' . - ~

Thomas G. Dignan, Jr.

Deborah S. Steenland Jeffrey P. Trout Jay Bradford Smith Ropes & Gray 225 Franklin Street Boston, MassLchusetts 0211C (617) 423-6100 pounsel for Amelicants

O 00NiiT u3N-C ,

CERTIFICATE OF SERVICE es ME -1 P 3 :03 l I, Jay Bradford Smith, onc of the attorneys for the Applicants herein, hereby certify that on July 28, 1988,il- . n: i' made service of the within document by depositing coKHk h i;? ;'

thereof with Federal Express, prepaid, for delivery to (or where indicated, by depositing in tha United States mail, first class postage paid, addressed to) the individuals ,

listed below.

Administrative Sodge Sheldon J. Robert Carrigg, Chairman Wolfe, Esq., Chairman, Atomic Board of Selectmen Safety and Licensing Board panel Town Office U.S. Nuclear Regulatory Atlantic Avenue ,

Commission North Hampton, NH 03862 +

East West Towers Building  !

4350 East West Highway i Bethesda, MD 20814 Administrative Judge Emmeth A. Diane Curran, Esquire Luebke Andrea C. Perster, Esquire '

4515 Willard Avenue Harmon & Weiss Chevy Chase, MD 20815 Suite 430 2001 S Street, N.W.

Washington, DC 20009 '

Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway concord, NH 03301-6397 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire i Atomic Safety and Licensing Office of General Counsel l Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commissior '

Commission One White Flint North, 15th Fl.

East West Towers Building 11555 Rockville Pike  ;

4350 East West Highway Rockville, MD 20852 Bethesda, MD 20814

• 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

a Tailip Ahrens, Esquire Mr. J. P. Nadeau l Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road l Rye, NH 03870 i

General Augusta, ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02308 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801

• Senator Gordon J. Humphrey h. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Clark, Hill-Whilton &

Washington, DC 20510 McQuire (Attn Tom Burack) 79 State Street Newburyport, MA 01950

• Senator Gordon J. Humphrey Mr. Peter J. 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 Flyna, Esquire Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.

Washington, DC 20472 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

. - . m

9 Mr. Ed Thomas Judith H. Mizner, Esquire FEMA, Region I 79 State Street 442 John W. McCormack Post Second Floor Office and Court House Newburyport, MA 01950 Post Office Square Boston, MA 02109

~

Jay Bradford Smith

(*= Ordinary U.S. First Class Mail.)

a e

4 a

4

,1 J

a

)

i l

,_ - - .