ML20196B075
| ML20196B075 | |
| Person / Time | |
|---|---|
| Site: | Seabrook, Comanche Peak  |
| Issue date: | 02/01/1988 |
| From: | Pollard R UNION OF CONCERNED SCIENTISTS |
| To: | |
| Shared Package | |
| ML20196B067 | List: |
| References | |
| OL-1, NUDOCS 8802080025 | |
| Download: ML20196B075 (5) | |
Text
AFFIDAVIT OF ROBERT D.
POLLARD The above being duly sworn, deposes and says:
I, Robert D.
Pollard, state as follows:
1.
My name is Robert D.
Pollard.
Since February 1976, I have been employed as a nuclear safety engineer by the Union of Concerned Scientists.
My business address is 1616 P Street, N.W.,
Suite 310, Washington, D.C.
20036.
Previously, I was employed by the U.S. Nuclear Regulatory Commission as a licensing project manager for commercial nuclear power plants 2.
I have carefully reviewed Equipment Qualification File (EQF) # 113-19-01 for the Seabrook Station, NECNP Ex.
4.
3.
My review of EQF 113-19-01 reveals the following:
a)
RG-59 coaxial cable is used in the Seabrook plant for functions important to safety.
Specifically, the file indicates this cable is used for radia-tien monitoring, NECNP Ex. 4, Ref.
1, p.
6, which is class 1E electrical equipment as defined in 10 CFR 50.49 (b) (1).
b) 15,000 feet of RG-59 cable was purchased for use 4
at Seabrook.
NEONP Ex.
4, Ref.
1,
- p. A1.
c)
The insulation resistance requirement for RG-59 cable is 10,000 megohms @ 1000 feet, NECNP Ex.
4, Ref.
1, p.6.
d)
The samples of RG-59 used in the environmental qualification tests were approximately 30 feet 8802000025 880202 DR ADOCK 05000443 PDR
-2 long, of which a minimum of 15 feet was contained within the test vessel and exposed to the simu-lated accident environment, NECNP Ex.
4, Ref.
2, p.
3.
The two RG-59 test specimens were desig-nated A5550-2C (aged) and A5550-2D (unaged).
Id.
e)
The measured insulation resistance of the RG-59 test specimens fell below the required insulation resistance during the environmental qualification tests.
The measured insulation resistance of both RG-59 test specimens fell below the required insulation resistance of 10,000 megohms by 1.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> into the test and remained below the o
required insulation resistance for between 7.5 and 14.5 days, NECNP Ex.
4, Ref.
2, Table 2, p.
14.
In the case of test specimen A5550-2C, the measured insulation resistance of the RG-59 reached a low of 300 megohms, more than an order of magnitude below the required insulation resistance.
Id.
4.
The measured insulation resistance of the RG-59 must be corrected for the length of the test specimen in order to compare it to the required insulation resistance.
As noted above, only a minimum of 15 feet of the RG-59 test specimens were exposed to the simulated accident environment, but the required insulation resistance for RG-59 of 10,000 megohms is based on 1000 feet.
I l
5
. The NRC staff has stated that the measured insulation resistance must be multiplied by the length of the test specimen and divided by the length of cable whose insulation resistance is to be determined.
NRC Staff Response to Memorandum of Licensing Board and New England Coalition on Nuclear Pollution Regarding Environ-mental Qualification of RG-58 Coaxial Cable, December 11, 1987, Affidavit of Harold Walker, p.
7.
5.
Thus, in this specific instance, and assuming that the NRC staff's affidavit is correct, the measured insulation resistance of RG-59 must be multiplied by 0.015 (15 feet exposed to accident environment divided by 1000 feet) to compare the measurement to the required insulation resistance of 10,000 megohms at 1000 feet.
6.
Applying this correction factor to the measurements of RG-59 insulation resistance presented in NECNP Ex.
4, Ref.
2, Table 2, p. 14, reveals that both RG-59 test specimens, A5550-2C and A5550-2D, fell below the required insulation resistance at the beginning of the test (even before being exposed to the steam / chemical-spray, high-humidity environment) and never recovered throughout the entire test, which lasted about 100 i
i days.
7.
This evidence reveals a serious safety deficiency in the l
Seabrook plant.
The RG-59 cable clearly is not environmentally f
qualified.
The test data indicate that the RG-59 radiation monitoring cable will fail to meet its insulation resistance pre-cisely when it is most needed - during an accident.
l i
l t
s
- 8.
It appears that the failure to correct the measured insulation resistance for the length of the test sample of cable may be a widespread deficiency in the Seabrook plant's environ-mental qualification program.
Examination of the data in NECNP Ex. 4 also reveals that RG-11 coaxial cable is not environmen-tally qualified, for reasons similar to those discussed above for RG-59.
RG-11 coaxial cable is used in the Seabrook plant for the Radiation Data Management Data Link, NECNP Ex.
4, Ref.
1, p.
7.
/
/
Y Robert D.
Pollard Subscribed and sworn to me on this 1st day of February, 1988.
Ct-wC A
\\.
G-W Notary Public My Commission Expires:
My Co nmbsion Expires April 30, 1992 h
.o "l
SEABROOK SERVICE LIST - ONSITE APPEAL BOARD Sheldon J. Wolfe, Chairman North Hampton, NH 03826 111 LowellStreet Charles P. Graham, Esq.
NRC Manchester, NH 03105 McKay, Murphy and Graham 4350 East West Highway J.P. Nadeau 100 Main Street West Tower - 3rd Floor Town of Rye
- Greg Bery Amesbury,MA 01913 Bethesda,MD 20814 155 Washington Road NRC Rye, New Hampshire 03870 1155 Rockville Pike
' Alan S. Rosenthal, Chairman Dr. Jerry Harbour 1 White Mint North NRC NRC Richard E. Sullivan, Mayor Rockville,MD 20852
' 4350 East West Highs y 4350 East West Highway City Hall West Tower - 3rd Floor West Tower - 3rd Floor Newburyport,MA 01950 Mr. Angie Michiros, Bethesda, MD 20814 Bethesda,MD 20814 Chairman Alfred V. Sargent, Chairman Town of Newbury
- Howard A.Wilber Dr. Emmeth A. Luebke Board of Selectmen Town Hall,25 High Road NRC 5500 Friendship Boulevard Town of Salisbury, MA 01950 Newbury,MA 01951 4350 East West Highway Apartment 1923N WestTower 3rd Floor Chevy Chase, MD 20815 Senator Gordon J. Humphrey George Dana Bisbee, Esq.
Bethesda, MD 20814 U.S. Senate Geoffrey M. Huntington, Esq.
Atomic Safety & Licensing Washington, D.C. 20510 Office of the Attorney General Board Panel (Attn. Tom Burack)
State House Annex U.S. NRC C.sncord, NH 03301
- By hand Washington, D.C. 20555 Selectmen of Northampton Northampton, New Hamp-Allen Lampert
" By overnight Atomic Safety & Licensing shire 03S26 Chil Defense Director Apped Board Panel Town of Brentowood U.S. NRC Senator Gordon J. Hun:;- -
Exeter,NH 03833 Washington, D.C. 20555 1 Eagle Square, Ste 507 Concord,NH 03301 Richard A. Hampe, Esq.
Docketing and Sersice Hampe and McNicholas U.S. NRC Michael Santosuosso, 35 Pleasant Street Washington, D.C. 20555 Chairman Concord, NH 03301 Board of Selectmen Mrs. Anne E. Goodman Jewell Street, RFD 12 Gary W. Holmes, Esq.
Board of Selectmen South Hampton, NH 03842 Holmes & Ellis 1315 New Market Road 47 Winnacunnent Road Durham,NH 03842 Judith H. Mizner, Esq.
Hampton,NH 03842 Silverglate, Gertner, et al.
William S. Lord, Selectman 88 Broad Street William Armstrong Town Hall-Friend Street Boston, MA 02110 Chil Defense Director Amesbury,MA 01913 10 Front Street Rep. Roberta C. Pevear Exeter,NH 03833 Jane Doughty Drinkwater Road SAPL Hampton Falls,NH 03844 CaMn A. Canney 5 Market Street City Manager, City Hall Portsmouth,NH 03S01 Phillip Ahrens, Esq.
126 Daniel Street Assistant Attorney General Portsmouth,NH 03801 Carol S. Sneider, Esquire State House, Station #6 Assistant Attorney General Augusta,ME 04333 Matthew T. Brock, Esq.
1 Ashburton Place,19th Moor Shaines & McEachern Boston, MA 02108 "Thomas G. Dignan, Esq.
P.O. Box 360 R.K. Gad 11, Esq.
Maplewood Avenue Stanley W. Knowles Ropes & Gray Portsmouth, NH 03801 Board of Selectmen 225 Franklin Street P.O. Box 710
- - Boston, MA 02110 -
Sandra Gavutis RFD 1, Box 1154 Robert A. Backus, Esq.
East Kensington,NH 03827 Backus, Meyer & Solomon
_-