ML20151N701
| ML20151N701 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/29/1988 |
| From: | Woodward N PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | |
| References | |
| CON-#388-6864 OL-1, NUDOCS 8808090071 | |
| Download: ML20151N701 (8) | |
Text
un 00CKETED USHRC July 29,1988
'88 AUG -4 M1 :46 UNITED STATES OF Ah1 ERICA
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f NUCLEAR REGULATORY COhihilSSION ERM L" before the ATOhflC SAFETY AND LICENSING BOARD
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In the statter of
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PUBLIC SERVICE COh1PANY )
Docket Nos. 50 443 OL-1 OF NEW H Ah1PSHIRE, gl.at )
50 444-OL 1
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(Scabrook Station, Units 1
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(Onsite Emergency r 12)
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Planning and Safety
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Issues)
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FURTIIER AFFIDAVIT OF NEWELL K. WOODWARD 1.
I am the same Newell K. Woodward that submitted the Newell K. Woodward Affidavit of July 21., 1988.
2.
From a review of NECNP's response to the affidavits made by me (Woodward Affidavit) and hiessrs. Walker and Gill, it is very clear that there is N.a "confusion over what constitutes the actual performance criteria for cable included in Equipment Qualification File No. 113-19 01"1 but rather a misinterpretation by NECNP. There is no basis for not concluding that the information and data in EQ File 11319 01 is found to demonstrate that the RG-58 and RG 59 coaxhl cables wi!! perform their functions when required, or not fail in a manner detrimental to plant safety, when exposed to postulated plant environmental conditions. NECNP implies that because the Applicants and the NRC do not persist in using the same language, and because EQ File No. I13-19-01 (NECNP Fxh. 4) does not contain a page entitled "Performance 1
NECNP "Reply to NRC Staff Res9onse to Board Request of July 20,1988 and Affidavit of Newell K. Woodward," dated July 27,1988.
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Specifications," that we cennot define performance specifications for cable and reach consistent conclusions regarding the RG-58 and RG-59 cable qualification.
As previously stated in the Woodward Affidavit (Items 6, 7 and 8), the performance specifications for the cable in question are given in the documentation contained in the EQ File (NECNP Exh. 4) and the criteria used to assess the acceptability of these specifications for both safety and non-safety related applications is also so stated. Further, NECNP's statement that "the file contains at best, some partial and unexplained criteria for limited non-safety applicaricns, and other partial criteria based on the tester's best guess. This is not adequate to meet the regulations." is completely invalid and again reflects NECNP's inability to evaluate all the data contained in the file and reach a satisfactory conclusion, but rather to continue to misunderstand the evaluation process and misinterpret the technical results.
3.
The issues raised in regard to, and the interpretation of, my affidavit, ;Ne affidavits of Messrs. Walker and Gill, and the EQ File No. 113-19-01 qualificati.:n documentation are invalid and incorrect, respectively, as follows.
a.
The performance characterisics of the RG-58 and RG-59 cable, "which define what constitutes remaining intact," are its ability to "c'irry current and load" during environmental exposure. These characteristics are proved by the fact that the total leaking / charging current rate during tne test (NECNP Exh. 4) did not exceed I amp. During the 1,0CA test, a voltage and current were continually applied to the cable test specimens such that they were continuously energized. The test circuit that allowed this current and voltage to energize the test specimens included a 1 amp circuit breaker to monitor the current, such that if it exceeded I amp, the breaker would open and the cables would be dcenergized. During the test, if the cable insulation degrades *o the point of failure (does not remain intact), the current will increase above 1 amp as it flows through the insulation and shorts to ground, and the breaker will open. Because the cable was continuously energized (carried current and load) throughout the test and the I amp breaker did not open, the leakage / charging 2
h_e 4
1 current rate did not exceed approximately I amp and the cable remained intact. (NECNP Exh. 4 Ref. 2, p.13) (Woodward Affidavit, item 5; Walter and Gill Affidavit, Item A10). Therefore, NECNP's statement that the "Applicants and the NRC staff have offered two different descriptions of what the n-formance specification for the cable are" is wrong because the applicants
..d the NRC staff are describing the same cable performance characteristic.
b.
As previously stated, and continuously misinterpreted by NECNP, the test program performed by Franklin Research Center (NECNP Exh. 4, Ref. 2) was not donc so at the request of the Applicacts but rather completed for ITT Surprenant, the cable vendor.
There is no requirement that testing be performed on the same piece of equipment for each utility that purchases it, but rather that any test or other qualification document used in support of quailfication be evaluated by the end user (Applicant) to determine if it adequately supports the environmental qualification of purchased equipment.
The Assessment Report (checklist) in NECNP Exh. 4 provides the basis for the Applicant's evaluation and acceptance of NECNP Exh. 4 Ref. 2 as documentation in support of the environmental qualification of the RG 58, RG-59, and RG-ll cable.
c.
Contrary to NECNP's assertion on page 4 that "the test report did not demonstrate the acceptance criteria" stated therein, the fact that the cable maintained an electrical load throughout the test and the breaker installed in the test circuit did not open is proof that acceptance criteria (a) (NECNP Exh.
Ref. 2, Section 2.2) was met.
The breaker exists to indicate cable failure during the test, if the cable insulation fails (does not remain intact) then the current surge to ground will open the breaker.
Fu rther, this failure is permanent. Any arguments concerning the use of an uncalibrated breaker by Franklin Research Center, a nationally recognized laboratory with a quality assurance program, are without fact.
3
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4 d.
The high potential voltage withstand test, although not performed under accident environmental conditions, does provide a basis to assess the overall performance of the cable as installed in the plant (Woodward Affidavit, items 6 and 7).
This test was performed after all other sequential (i.e., thermal and radiation aging and LOCA) testing was complete (NECNP Exh. 4, Ref. 2). This is a potentially destructive test where these cables were charged with voltages as high as 9500 volts (NECNP Exh. 4, Ref. 2, p. 15) after they had been exposed to 40 years of simulated thermal and radiation aging, one year of simulated accident radiation and 100 days of LOCA and high humidity simulation. The fact that the cables did not fail (short to ground) during this test demonstrates that no insulation failure occurred during the environmental testing and this is further proof that the performance specification "remain intact" was met, and that the cable will not fail when exposed to the Applicant's environmental conditions, c.
A significant number does not have to. be defined as acceptable or unacceptable for measured insulation resistance (IR). The circuit design and the unique characteristics of the instrumentation included in the circuit determine its insulation resistance tolerance during exposure to environmental events. Therefore, the IR's measured during the test were found acceptable for use in their specific applications at Seabrook. The evaluation of these IR's with respect to the Scabrook design and effects they may have on instrumentation was performed by the Applicant and the results~ were found acceptable (NECNP Exh. 4 Ref. 9) such that the cable test (NECNP Exh. 4 Ref.
- 2) provides adequate documentation in support of cable environmental qualification at Scabrook. Moreover, these evaluations were performed for the i
safety related cable in NECNP Exh. 4 as stated in my previous Affidavit, Item 8.
l L
l 4.
In conclusion, my Affidavit, the NRC Staff's filing (Affidavits of Walker and Gill) and EQ File No. 11319-01 (NECNP Exh. 4) demonstrate that the RG 58 and RG-4
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i 59 cable arc environmentally qualified for use in Scabrook Station, will perform their function as required, and will not fail in a manner detrimental to plant safety when exposed to the harsh environmental conditions occurring subsequent to design basis
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jdr o Newell K. Woodward STATE OF NEW YORK Suffolk, ss.
July 29,1988 The above named Newell K. Woodward appeared before me and made oath that he had read the foregoing affidavit and that the statements set forth therein are true to the best of his knowledge.
Before me, s
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-ck Notary Pu,blic WINititED d. 'di R Hotei Pubite,$ tate of +a er'<
N. M%9:2 Qualified in Suf fo't 3: 41'2
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DOLKETED CERTIFICATE OF SERVICE UMPC I, Thomas G.
Dignan, Jr., one of the attorneygo ggt 46 Applicants herein, hereby certify that on July 29, W9W, gp g)j f
f made service of the withh, document by depositing copies thereof with Federal Express, prepaid, for deliverypto.:(or: *Mt where indicated,. by depositing in the United Stateschaig,gf FM first class, postage paid, addressed 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 East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 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 East West Towers Building Boston, MA 02109 4350 East West Highway Bethesda, MD 20814 Administrative Judge Sheldon J.
Robert Carrigg, Chairman Wolfe, Esquire, Chairman Board of Selectmen Atomic Safety and Licensing Town Office Board Panel Atlantic Avenue U.S.
Nuclear Regulatory North Hampton, NH 03862 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Emmeth A.
Diane Curran, Esquire Luebke Andrea C.
Ferster, 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, 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 East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814
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A 1
4 Adjudicatory File Atomic Safety and Licensing Sherwin E.
Turk, Esquire Board Panel Docket (2 copies)
Office of General Counsel U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission East West Towers Building One White Flint North, 15th Fl.
4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852
- 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 Or.e Ashburton Place, 19th Fir.
Portsmouth, NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin 2.
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 Gordor. J.
Humphrey R.
Scott Hill-Whilton, Esquire U.S.
Senate Lagoulis, Clark, Hill-Washington, DC 20510 Whilton & McGuire (Attn:
Tom Burack) 79 State Street Newburyport, 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 W
L c
H. Joseph Flynn, 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 P1 chard A.
Hampe, Esquire Ho?mes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 Judith H. Mizner, Esquire 79 State Street, 2nd Floor Newburyport, MA 01050
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bl5as'Gi g an, Jr.
(*=U.S. First Class Mail.)
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