ML20151N723

New England Coalition on Nuclear Pollution Reply to NRC Staff Response to Board Request of 880720 & Affidavit of Nk Woodward.* Applicant & NRC Filings Contain Unacceptable Partial & Unexplained Criteria.Certificate of Svc Encl

ML20151N723
Person / Time
Site:	Seabrook
Issue date:	07/27/1988
From:	Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20151N709	List: ML20151N705 ML20151N723
References
OL-1, NUDOCS 8808090077
Download: ML20151N723 (8)

Text

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July 27, 1988 00f.XETED USNRC UNITED STATES NUCLEAR REGULATORY COMMISSION

'88 JA. 29 A10 :10 >

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _

) 0FF!E 07 :: > Ic 00CXtiM;s <v M In the Matter of )

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Public Service Company of )

New Hampshire, et al. ) Docket Nos. 50-443 OL-1

) 50-444 OL-1 (Seabrook Station, Units 1 & 2) ) ONSITE EMERGENCY

) PLANNING & TECHNICAL

) ISSUES NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S REPLY TO NRC STAFF RESPONSE TO BOARD REQUEST OF JULY 20, 1988. AND AFFIDAVIT OF NEWELL K. WOODWARD On July 20, 1988, the Licensing Board convened a telephone conference in which it directed Applicants and the NRC Staff to respond to two questions: first, whether performance specifica-tions must be included in equipment qualification files pursuant to 10 CFR 5 50.49; and second, whether NECNP Exhibit 4 contains such performance specifications for RG-58 and RG-59 coaxial cable. Both Applicants and the NRC Staff agree with NECNP that the regulations require that equipment qualification files must include performance specifications. They also assert that the equipment qualification file for RG-58 and RG-59 coaxial cable (NECNP Exhibit 4) contains such specifications. As discussed below, the information provided by Applicants and Staff is both contradictory and insufficient; moreover their claims are not supported by the record.

Applicants s. tate that "the only performance specification that RG-58 and RG-59 cable, with a black with red trace jacket, must meet in the Seabrook Plant is to remain intact." Woodward 8008090077 890727 P PDR ADOCK 05000443' O PDR

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Affidavit, par. 5. The NRC Staff states that the performance specification for the RG-58 and RG-59 cable is "a total leakage / charging current rate (not to) exceed approximately 1.0 amp."

At the outset, it should be observed that Applicants and the NRC Staff have offered two different descriptions of what the performance specifications for this cable are. The discrepancy reflects the confusion and lack of information in the equipment qualification file. Moreover, neither party presents an adequate description of the performance specifications for this cable.

The Applicants' characterization of the performance requirements, for example, is incomplete. Even for cable with non-safety apolications, NRC regulations and regulatory guidance require more than a mere showing that the cable remains "intact."1 To say that the cable must remain "intact" is meaningless unless Applicants specify the values of cable characteristics which define what constitutes remaining "intact" (e.g. insulation resistance). No such characteristics have been provided by Applicants, either in the equipment qualification file or Mr.

Woodward's affidavit.

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1 Moreover, the reference given for the specification that cable in non-safety applications remain "intact" is a brief1985, tele-phone memorandum written by Mr. Woodward, dated October 8, Ref. 6 to NECNP Exh. 4. Neither the i amorandum nor any other document in the equipment qualification file contains any expla-

! nation of the basis for this statement.

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Second, the acceptance criterion of 3.0 A leakage / charging current rate, cited by the NRC Staff, was one that was assumed by the tester, Franklin Research Center, because Aeolicants had failed to soecify "potential and current" that were required for

. an acceptable performance.2 Egg NECNP Exh. 4, Ref. 2. The assumption of 1.0 amp leakage-charging current rte was made for each and every application of RG-58, RG-59, and RG-11 cable, regardless of whether the application of the cable was safety-related or non-safety-related. FRC does not say what the basis was for its assumption, nor can it be derived from the equipment qualification file. Thus, neither the recent filings of Applicants and Staff nor the equipment qualification file itself demonstrates that 1 ampere leakage / charging current rate was the actual performance standard for this cable. Rather, it was a generic standard set by the tester in the absence of plant-specific performance criteria.

2 The exact language of the FRC test repcrt was as follows:

The test specimens were considered to have met the requirements of IEEE Std 383-1974, Section 2.4, if they (a) remained energized with client-specified potential and current during the steam, chemical-spray, and high-humidity exposure, and (b) passed a final bend test at a diameter 40 times the cable diameter and an ac high-potential-withstand test at 80 V per mil (3150 V per mm) of insulation thickness. It was asnumed that the first criterion was met if the total leakage / charging current of the specimens connected to an energizing source for potential did not exceed approximately 1.0 A.

NECNP Exh. 4, Ref. 2 at 2 (footnotes omitted)

Motcavor,_ contrary to the NRC's assertion at page 8 of the Gill / Walker affidavit, the test report did n21 demonstrate that the acceptance criteria assumed by the tester "were met through-out the test." The NRC affiants cite the test report, NECNP Exh.

- 4, Ref. 2 at 17, for this proposition. The test report states that the cable met the acceptance criteria by maintcining an electrical load during a 100-day simulated SLB/LOCA exposure, which included two transients to a peak temperature of 390 0 F, and by passing a final 40-times-diameter bend and high-potential withstand test of 80 V/ mil for 5 minutes.

Id. However, due to the nature of the test, the fact that the cable maintained an electrical load during a 100-day simulated LOCA does not demonstrate that the leakage charging current rate did not exceed 1.0 A. As described in the test report, a 600 V potential was applied to the cable conductor with the cable shield at ground potential. The circuit included a circuit breaker that would disconnect if the leakage-charging current 1

i rate exceeded approximately 1.0 A. Ref. 2 at 5. There is no I

indication in the test report that leakage-charging current was measured, nor is there any indication that the circuit breaker l

l was tested to determine what magnitude of current persisting over what period of time would actually cause the circuit breaker to open. Because charging current typically occurs over a brief l

i l period of time, it might not open the circuit breakers even if it exceeded 1.0 A.

The high-pontential test is also inadequate to measure the performance of the cable during an accident because it was not

done under accident conditions, but rather after the simulated LOCA. Ref. 2 at 10, 5 5.5. While leakage-charging current was measured, the measurement told the tester nothing about how the cable would perform under accident conditions.3 Finally, to the extent that Applicants' affidavit and the equipment qualification provide any performance specifications for the cable included in that file, they address only the non-safety uses of the cable (i.e. cable whose jackets are color-coded black with a red tracer) . For the safety applications of the cable (solid color jackets), Mr. Woodward correctly observed in his 1985 memorandum that "performance requirements such as I.R. (insulation resistance] and accuracy must be met during environmental qualification." NECNP Exh. 4, Ref. 6. Een also Woodward Affidavit, par. 5. However, other than the critoria assumed by the tester in the absence of plant-specific criteria from Applicants, acceptance criteria for the safety applications 3 In fact, the insulation resistance measurements taken during the LOCA simulation demonstrate that the cable did degrade under accident conditions. See Ref. 2 at 14, Table 2.

It is worth noting that while Applicants concede in Ref. 6 that insulation resistance is a significant acceptance criterion for safety applications of cable, and while the qualification test performed by FRC measured insulation resistance, neither Applicants nor the NRC Staff identify any acceptance criteria for insulation resistance.

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of RG-59 cable are nowhere described in Mr. Woodward's affidavit 4 or the equipment qualification file. It is also notable that the performance criteria which were assumed by FRC make no distinc-tion between safety and non-safety applications of the cable; nor do they distinguish the applications of RG-59 and RG-11 cable, ,

which were both subjected to the test.

4 In paragraph 6 of his affidavit, Mr. Woodward states that "Once the cable color code was known, NECNP Ex. 4 Reference 6 provided the engineer with the tools to define the electrical characteristics of importance necessary to environmentally qualify the cable." Reference 6 provides no characteristics of safety-related applications, other than a general reference to insulation resistance and accuracy. Paragraph 8 of Mr. Wood-ward's affidavit, which specifically discusses the evaluation of cable in safety-related applications, states only that Applicants' engineers evaluated the environrental qualification test results "for any impact on the attached equipment."

Applicants provide no indication of what standards these impacts were evaluated against.

m CONCLUSION What Applicants' and the NRC Staff's filings show is a state of confusion over what constitute the actual performance criteria for cable included in Equipment Qualification File No. 113-19-01.

In fact, the file contains, at best, some partial and unexplained criteria for limited non-safety applications, and other partial criteria based on the tester's best guess. This is not ;;aquate to meet the regulations.

Respectfully submitted, m_

D ne Curran HARMON & WEISS 2001 "S" Street N.W. Suite 430 Washington, D.C. 20009 (202) 328-3500 July 27, 1988 CERTIFICATE OF SERVICE I certify that on July 27, 1988, copies of the foregoing pleading were served by hand, overnight mail, or first-class mail on all parties to this proceeding, as designated on the attached service list. .

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Diane Curran l

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.a SEABROOK SERVICE LIST Onske Appeal Board NL M ii D William S. lord, Selectman Sandra Gavutis als Alan S. Rosenthat Esq, Chairman Town Hall- Friend Street RFD 1, Box 1154 Atomic S;afety and ucensing Amesbury,MA 01913 - East Kensington, Nil 03827 U C Jane Doughty Senator Gordon J. llumphiev '88 at 29 A10:10 Y!ahington, D.C 20555 SAPL 1 Eagle Square, Ste 507 5 Martet Street Concord,NH 03301 a ,.

Iloward A. Wilber Portsmouth,NH 03801 hphf[{'j G Judith it Mizner, Esq. gg g '4 --

Atomic Safety and Ucensing Appeal Board Carol S. Sneider, Esquire 79 State St. 2nd Floor U.S. NRC Assistant Attorney General Neeuryport,MA 01950 Wuhington, D.C 20$35 1 Ashburton Place,19th licor Doston, MA 02108 "Domas O. Dipan, Esq.

'Sheldon J. Wolfe, Chaittnan R.K. Gad 11. Esq.

Atomic Safety and Ucensing Board Richard A.Ilampe Esq. Ropes & Gray U.S. Nuclear Replatory Commission llampe and McNicholas 225 Franklin Street Washligton, D.C 20555 35 Pleasant Street Bosson,MA 02110 Concord, Nil 03301

'Dr. Emmeth A. Luebke Robert A. Backus, Esq.

Atomic Safety and Uccasing Board Gary W. Holmes, Esq. Backus, Meyer & Solomon 5500 Friendship Boulevard Holmes & Ellis 111 Lowell Street Apartment 1923N 47 Winnacunnent Road Manchester, Nil 03105 Q>evy Chase, MD 20815 llampton, Nil 03842 George Dana Bisbee, Esq.

'Dr. Jerry !! arbour William Armstrong Geoffrey M. Iluntington, Esq.

Atomic Safety and Ucensing Board Civil Defense Director Office of the Attorney General US Nuclear Replatory Commision 10 Front Street State llouse Annes Washington, D.C 20555 Exeter, N1103833 Concord, Nil 03301 Atomic Safety and Ucensing Cama A. Canney R. Scott Ihll Whitton Appe:1 Doard Panel City Manager lagoulis Clark. Ilill Whilton U.S. Nuclear Replatory Commission City 11:11 and McGuire Washington,D.C 20535 126 Daniel Sttsa 79 State Street Portsmouth, Ulf 03801 Nedutyport,MA 01950 Atomic S.fety and Ucensing -

Bzrd Panet Charles P. Graham, Esq. Leonard Koppelman, Esq.

U.S. Nuclear Replatory Comminion Murphy AOraham Barbara J. St. Andre, Esq.

Washington, D.C 20555 33 low Street Koppelman & Paige, PC Neeuryport, MA 01950 77 Franklin Street Docketing and Service Branch Bor?on, MA %110 U.S. Nuclear Regulatory Commission Rep. Roberta C. Pevear Drinkwater Road Diana P, Sidebotham Washington, D.C 20535 llampton Falls, Nil 03844 NECNP Stanley W K. owles R.F.D.#2 i Dettd of Selectaien Phi!!ip Ahrens Esq. P.O. Box #1150 P.O. Don 710 Assistant Attorney GeneN Putney, VF 05 M6 North llampton, N1103826 State llouse, Station #6 Augusta, ME 01333 Ashod N. Amirian, Esq.

Senitor Gordon J. Ilumphrey Town Counsel for Merrimac US Senate "Gregory A. Derry, Esq. 376 Main Street 1

Office of General Counsel llawthill, MA 01:30 Washington, D C 20510 U.S. Nuclear Replatory Commission (Atta. Tom Durack)

Washir>gton, D.C 20555

. J P. Nadeau Tomm of Ryt Allen Lampert

• lland Deintry 155 Washington Road Ciwi Defense Director Rys,N;wIlam; shire 03870 Toms of Drentowood " Ostrnight Deintry Exeter, Nil 03833 Mrs. Anne C Gocdman i Dotrd of Selectmen Matthew T. Drock, Esq.

13-15 New Market Road Shaines & M Eachern Durhsm, N1103&42 P.O. Don 300 j Maplewood Avenue Portsmouth, Nil 03801 I