ML20236V048

Applicant Response Re Environ Qualification of RG-58 Coaxial Cable.* Details Forwarded Re Comparison Between RG-58 & RG-59 Cables,In Response to ASLB 871106 Order. Certificate of Svc Encl

ML20236V048
Person / Time
Site:	Seabrook
Issue date:	11/25/1987
From:	Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#487-4945 ALAB-875, OL-1, NUDOCS 8712040055
Download: ML20236V048 (14)

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USHRC idMN30Nj:38 November 25p4Q;8 7, , , ,,,.f p;cgi i n s , r f.

u' i UNITED STATES OF AMERICA UNITED STATES NUCLEAR REGULATORY COMMISSION before the d

ATOMIC SAFETY AND LICENSING APPEAL BOARD

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In the Matter of )

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

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(Seabrook Station, Units 1 ) (On-site Emergency and 2) ) Planning Issues)

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APPLICANTS' RESPONSE REGARDING ENVIRONMENTAL QUALIFICATION OF RG-58 COAXIAL CABLE In ALAB-875, the Appeal Board requested that the Licensing Board indicate the basis in the record for its findings regarding the environmental qualification of RG-58 coaxial cable, or reopen the record on this issue. The Licensing Board responded with a Memorandum to the Appeal Board outlining the basis for its determination that "the dimensional differences between the RG-58 and the RG-59 cables are of such little importance that the test results for the RG-59 cable can serve to qualify the untested RG-58 cable." ALSB Memorandum to Appeal Board, unpublished (October 16, 1987) at 4. Pursuant to the Appeal Board's 9712040055 871125 PDR 4 G

ADOCK 05000443 b0 /

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scheduling order of October 20, 1987, the New England Coalition on Nuclear Pollution ("NECNP") filed a Supplemental Memorandum on November 4, 1987, in which it argues that the Licensing Board failed to demonstrate that RG-58 cable may be qualified by comparison to the RG-59 cable. On November 6, 1987 the Appeal Board issued a further Order, requesting that the NRC Staff and the Applicants specifically respond to the points raised by the NECNP Supplemental Memorandum, provide the mathematical expression describing the relationship of insulation resistance to cable length, and discuss whether the Licensing Board erred in relying on the value of 80 volts per mil of insulation. Applicants herein respond.1 ARGUMENT

1. The Licensing Board's Conclusion Has Sufficient Basis in the Record.

The record produced during the on-site hearings provide a sufficient basis for the Licensing Board to have found that RG-58 coaxial cable is environmentally qualified.

Specifically, the record supports the Licensing Board's reasoning that the differences between RG-58 cable and RG-59 cable are so insignificant that the tests results for RG-59 cable may be used to qualify the RG-58 cable as well.2 1 In addition, the Appeal Board extended the page limitation from ten to fifteen pages.

2 See 10 CFR 5 50.49(f)(2) which provides that an item of electrical equipment may be qualified by "[tjesting a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable."

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The RG-58 coaxial cable does not perform an accident mitigating function but must withstand the environment such that it does not compromise the safety function of other l components. The RG-58 coaxial cable supplied by ITT Surprenant to seabrook is color coded in accordance with  !

Specification No. 9763-006-113-19, and is black with a red trace (Reference 1 at A1; Reference 7 at 2).3 Based on this color coding, acceptable performance of the RG-58 cable when exposed to harsh environmental conditions is measured only by the cable's ability to remain intact such that its insulation system will not catastrophically fail and result in a short to ground (Reference 6). Therefore, the basis for installed (i.e. RG-58) to tested (i.e. RG-59) cable similarity only relates to the overall strength of the insulation system and its resistance to catastrophic failure with respect to environmental effects.

The best test to demonstrate that an insulation system is strong and will not fail as a result of environmental degradation is the high potential voltage test or the 80 volts per mil of insulation thickness test as required by IEEE-383 - Section 2.4.4. This test is an excellent measure of strength and resistance to failure because:

1. The voltages applied are much greater ,

than the cable ratings and many times J I

3 All references given refer to those contained in the Environmental Qualification File ("E.Q.F.") 113-19-01 j unless otherwise stated. This E.Q.F. was introduced as NECNP {

Exhibit 4. I I

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• greater.than the potential the cable will carry when energized to the plant.

(Reference 1 at 2.6.1.2A(a))

2. The test is performed after all environmental testing is complete and the cable has been cumulatively exposed to all environmental effects. (Reference 2 at 1, 9)

The nature of the 80 volt insulation test, combined with the character of the RG-58 cable makes it unnecessary to 1

actually test the RG-58 cable to determine whether it is l environmentally qualified. What is required is that the 80 volt per mil test be performed on a cable of similar construction, allowing one to draw a conclusion regarding what would be the test results on a cable of less insulation thickness. This is the case because the 80 volt per mil rate of application is consistent for all insulation thicknesses; that is, the voltage level varies with the thickness of the insulation. IEEE-383 - Section 2.4.4. Second, the insulation resistance specified for is less in the RG-58 cable than the RG-59 cable. For example, the operating insulation resistance requirements for a 1000 foot length of RG-58 cable is a factor of ten less than that of a RG-59 cable, or 1000 megohms vs. 10,000 megohms. (Reference 1 at 2.6.1.2A(b), and 2.6.1.2B(b)) /

The Licensing Board therefore correctly applied a proportionality analysis. Since it is undisputed that the RG-58 and RG-59 cables are similar in construction and materials (ASLB Memorandum to Appeal Board, unpublished

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(October 16, 1987) at 3) the results of an 80 volt test on l the RG-58 cable could be inferred from the results of the j tests on the RG-59 cable. Moreover, the test results on the RG-59 cable demonstrate that if the 80 volt test had been '

applied to the RG-58 cable, the RG-58 cable would have remained intact.

Furthermore, the Licensing Board did not err in relying upon the value of 80 volts per mil of insulation. The 5000 volt test referred to by the Appeal Board (November 6 Order at 2) is a test required in the normal procurement of the cable but is unrelated to any environmental qualification testing. This is demonstrated by the fact that the 5000 volt test appears in the specifications but is not included in the qualification test report. The 80 volts per mil test, however, is taken from the requirements of IEEE-383, Section 2.4.4. Adherence to this IEEE standard is required by the specification. The cables were in fact tested based on the requirements of this standard. (Reference 2 at 1, 2, 9, 13-15). Moreover, this standard is consistently used throughout the nuclear industry and is endorsed by Regulatory Guide 1.131.

2. NECNP's Arauments Are Without Merit NECNP argues in its Supplemental Memorandum that the Licensing Board " erred in undertaking the role of a witness when it asserted that the cable was qualified based on information in the equipment qualification file that L

1 Applicants' witnesses failed to identify on the stand."'

Supplemental Memorandum at 2. It must be noted, however, that it was NECNP who introduced the equipment qualification file involved into evidence, and did so without limiting its offer. See, Transcript of 9/30/86 at 460. Under these circumstances it was well within the discretion of the Licensing Board to examine the entire exhibit and draw conclusions.

NECNP further asserts that the Licensing Board's inference that "the predicted performance of the smaller RG-58 cable under conditions of environmental qualification testing would be proportional to the lower required operating resistance of its insulation" is contradicted by other information in the same equipment qualification file.  !

NECNP's Supplemental Memorandum at 3. In support of this l

assertion NECNP refers to the RG-11 cable which has the same minimum insulation resistance as specified for the RG-59 cable (i.e. 10,000 megohms 0 1,000 ft) but whose thickness is thicker than that for the RG-59 cable (i.e. 122 mils vs. 61 mils). NECNP's Supplemental Memorandum at 3, 4. From this, NECNP implies that the proportionality argument set forth by the Licensing Board for the RG-58 cable is inappropriate.

For the following reasons NECNP's argument must fail.

In order to apply a proportionality analysis there must be at least a technical basis to conclude that such an analysis would be appropriate. Here the sole basis put forth i

by NECNP to apply the proportionality argument to the RG-11/RG-59 combination appears to be that the RG-11 cable is in the same E.Q.F. as the RG-59 cable.

Applicants are unaware of an assertion in the E.Q.F.

that the RG-11 and RG-59 cables are similar in materials or ,

construction or that one cable would be representative of the other for purposes of environmental qualification. In fact, the only assertions in the E.Q.F. are that RG-58 cable is similar to RG-59 cable and that the RG-11 coaxial test data is appropriate for RG-11 triax. (Reference 3,4)

On the other hand, it is undisputed that RG-58 cable and RG-59 cable are similar in materials and construction. The Board's proportionality analysis, therefore, as applied to RG-58 and RG-59 cables, is reasonable. NECNP's allegation of inconsistency, based on comparing two cables when there is no basis for comparison, is irrelevant.

NECNP also asserts that other factors, such as moisture, may influence the qualification of cables. NECNP supplemental Memorandum at 5. NECNP then proceeds to explain how moisture would alter the proportionate effectiveness of insulation by assuming penetration of moisture of each cable to a distance of 30 mils. This assertion fails for two reasons. First NECNP does not substantiate the basis for such an assumption. In addition there is no basis in this test report or any other test report of the Applicants which would substantiate this unfounded assumption. Because of the i

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lack of basis, it is questionable whether the assumption is I correct. Second, RG-59 cables were tested for the effects of humidity or moisture on cable performance. (Reference 2)

The results of these tests demonstrate that the RG-59 cable was qualified for its intended purpose. (Reference 9)

NECNP also criticizes the Licensing Board's proportionality analysis because "of its lack of conservatism." Supplemental Memorandum at 5. The conservative element of the analysis, which NECNP ignores, is that RG-59 cable is being tested to determine whether it will maintain accuracy requirements. Maintaining accuracy requirements is obviously a more stringent standard than that applied to the RG-58 cable which, as noted above, to serve its intended function, is not required to perform an accident mitigating function, but needs only to remain intact.

The last argument set out in NECNP's Supplemental Memorandum, whether RG-59 cable itself was correctly found to be qualified, is not properly before the Appeal Board. NECNP failed to raise this issue in its original appeal of the Licensing Board's Partial Initial Decision. It should not be allowed to raise it now for the first time. E.c., IYA (Hartsville Nuclear Plant, Units 1A, 2A, 1B and 2B), ALAB-463, 7 NRC 341, 348 (1978) and cases there cited.

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l-In any event, NECNP's assertion is incorrectly premised on the assumption that the insulation resistance of 10,000 megohms is the acceptance criteria or operating requirement for accident conditions. The operating value referred to by NECNP is used for purposes of specifying and procuring cable.

(Reference 1 at 12) In these circumstances the applicable insulation test is performed in ambient conditions (i.e. in air) and is performed on a cable which has not been subjected to radiation, thermal aging, etc. associated with environmental qualification. This testing environment is hardly the accident environment referred to in the E.Q.F.

(Reference 2). Furthermore, the insulation resistance changes that occurred during the various stages of testing were reviewed and a determination was made regarding the cable's suitability for its intended purpose. That review is documented in the E.Q.F. (E.Q.F. at 9 n.7 and Reference 9).

Therefore not only is it inappropriate to use the 10,000 megohm insulation resistance value as an acceptance criteria, it is an incorrect premise that the cable is not qualified for its intended function.

In responding to this assertion of NECNP, the Board requested that the Applicants set forth the mathematical expression describing the relationship of insulation resistance to cable length. November 6 Order at 1. Counsel signing this memorandum are advised that the following can be

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used to describe the relationship of insulation resistance to cable-length:

R R=

L c L

Where:

R:

L Resistance (ohms) for a given length of cable in question.

Re: Resistance constant (ohms - ft)

L: The actual length of the cable in question.

Rc can be determined by means of the following:

Rc =

RTS X LTS Where:

RTS: Measured resistance of'a tested cable specimen.

LTS: Actual length of the tesued cable specimen.

It bears repeating that the insulation resistance changes that occurred during the various stages of testing RG-59 cable were reviewed and a determination was made regarding the cable's suitability for its intended purpose.

The review is documented in E.Q.F. at 9 n.7 and Reference 9.

Finally, NECNP's complaint that the record must be reopened on this issue or its due process rights will be violated is not persuasive. The issue of the environmental qualification of electrical equipment was fully litigated l before the Licensing Board. NECNP was a full participant.

Subsequently, NECNP filed an appellate brief which devoted considerable length to the environmental qualification issue.

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l1 NECNP has been further invited by this Board to respond to the Licensing Board's findings on this matter. Under anystandard, NECNP has been fully involved in the adjudication of the environmental qualification issues.4 Respectfully submitted, Thw 6. % 3< . /353 #

Thomas G. Dignan,'r.

J George H. Lewald Kathryn A. Selleck 1 Ropes & Gray 225 Franklin Street Boston, MA 02110 (617)423-6100 Counsel for Applicants 4 NECNP's due process argument is especially curious in view of the leniency granted to NECNP by the Licensing Board regarding this contention. As Applicants have argued previously (See, Brief of Applicants, On Appeal From A Partial Initial Decision of the Atomic Safety and Licensing Board, dated June 3, 1987 at 19) NECNP's original contention was significantly more narrow, and NECNP was allowed, over Applicants' objection, II. 392 (9/30/86), to explore matters far outside the scope of the contention as it was worded and admitted for litigation. Of course, it is established that an intervenor is bound by the " literal terms" of the contention; i.e., the words of the contention limit the scope of what may be contended during the proceedings, including on appeal. Texas Utilities Electric Co. (Comanche Peak Steam Electric Station), ALAB-868, 25 NRC , Slip Opinion at 37 n.83 (June 30, 1987); Carolina Power and Licht Co. (Shearon Harris Nuclear Power Plant) , ALAB-843, 24 NRC 200, 208 (1986); Philadelphia Electric Co., (Limerick Generating Station, Units 1 and 2) , ALAB-836, 23 NRC 497, 505 (1986).

DOCKETED USNRC 1<

CERTIFICATE OF SERVICE '8*/ )gf 30 jyj M8 I, Thomas G. Dignan, Jr., one of the attorneys for the l Applicants herein, I made cervice hereby of the certify within that onbyNovember document $[ch.L@.

depositing" g ,Q g' yggscq thereof with Federal Express, prepaid, for delivery to (or where indicated, by depositing in the United States mail, ,

first class, postage paid, addressed to): l 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 i Commission Commission l East West Towers Building East West Towers Building l 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Atomic Safety and Licensing Mr. Ed Thomas Appeal Panel FEMA, Region I U.S. Nuclear Regulatory 442 John W. McCormack Post j Commission Office and Court House i East West Towers Building Post Office Square 4350 East West Highway Boston, MA 02109 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 Judge Emmeth A. Luebke Diane Curran, Esquire Atomic Safety and Licensing Andrea C. Ferster, Esquire Board Panel Harmon & Weiss 5500 Friendship Boulevard Suite 430 Apartment 1923N 2001 S Street, N.W. I Chevy Chase, MD 20815 Washington, DC 20009 Dr. Jerry Harbour Stephen E. Merrill, Esquire i Atomic Safety and Licensing Att.orney 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 i 4350 East West Highway Concord, NH 03301-6397 I Bethesda, MD 20814 l

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Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory East West Towers Building Commission 4350 East West Highway Tenth Floor Bethesda, MD 20814 7735 Old Georgetown Road 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 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 One Ashburton Place, 19th Flr.

Portsmouth, NH 03801 Boston, MA 02108 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 Mr. Angie Machiros U.S. Senate Chairman of the Board of Washington, DC 20510 Selectmen (Attn: Tom Burack) Town of Newbury Newbury, MA 01950 I l

• 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 j I

Mr. Thomas F. Powers, III Mr. William S. Lord l Town Manager Board of Selectmen I l

Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 l

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H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel- RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 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 Judith H. Mizner, Esquire Charles P. Graham, Esquire Silverglate, Gertner, Baker, McKay, Murphy and Graham Fine, Good & Mizner 100 Main Street 88 Broad Street Amesbury, MA 01913 Boston, MA 02110

~l'hnwu G.hgvwJr. /tss Thomas G. Dignan, Jr. '

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

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