ML20237B687
| ML20237B687 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/10/1987 |
| From: | Weiss E HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#487-5072 OL-1, NUDOCS 8712170058 | |
| Download: ML20237B687 (5) | |
Text
,[C72L-DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'M E 11 P2 42 Before the Atomic Safety and Licensing Appeal Board 0Fr!CE OF H U r.1Ai >
DOCK [}iNG i %NlCf.
)
b#
In the Matter of
)
)
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 APPLICANTS' RESPONSE REGARDING ENVIRONMENTAL QUALIFICATION OF RG-58 COAXIAL CABLE On December 2, 1987, the Appeal Board sua sponte issued an order granting the Coalition permission to reply to Applicants' November 25, 1987 Response Regarding Environmental Qualification of RG-58 Coaxial Cable.
Applicants' Response states, at p. 3:
The RG-58 coaxial cable supplied by ITT Surprenant to j
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).
Based on this color coding, i
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.
ARGUMENT As a threshold matter, it bears re-emphasizing that the issue on this appeal is whether there is adequate basis in the 8712170059 871210 PDR ADOCK 05000443 G
PDR ND
1 1'
-2 record for the Licensing Board's conclusion that RG-58 cable is environmentally qualified.
Rather than support the Licensing Board's conclusion that there is an adequate basis for finding I
that the RG-58 cable is qualified, Applicants here appear to be i
arguing--for the first time--that because of its color coding, RG-58 cable does not need to be fully environmentally qualified.
In support of this novel proposition, Applicants offer only Reference 6 of Environmental Qualification File (EQF) No. 113 01, New England Coalition Exhibit 4.
That document is I
denominated " Record of Conversation between Chuck Greiman (UE&C) 1 and Mr. N. Woodward (Impell), dated 10/8/85.nl To begin with, a memorandum of a telephone conversation between two contractors is hardly probative authority for estab-lishing the environmental qualification requirements for ten l
1 1
The memo states, in its entirety-l Chuck and I discussed how Impell can identify which of the different cables in P.O.
113-18 and the other cable specifi-J cationn are connected to equipment which must perform a safety function subsequent to accident events.
The color coding of the outer jacket as defined in UE&C separation documents enables this determination.
Specifi-cally, outer jackets with the single solid color of red, white, blue, or yellow designates cables for which per-formance requirements such as I.R. and accuracy must be met during environmental qualification.
Cable of other colors I
or color schemes must only remain intact (e.g. no shorting i
to ground).
However, all Class 1E cables as defined by the Specification must be environmentally qualified.
Chuck will forward a copy of the UE&C separation document which defines these color schemes so that it may be included in the EQFs.
EQF No. 113-19-01, New England Coalition Exhibit 4, Reference 6.
-3
4.
miles of cable inside this plant.
The memo purpsets to describe how cables important to safety can be identified based on their color coding, but it does not explain the authority or basis for j
the unsubstantiated statement that multi-colored cables such as RG-58 "must only remain intact", rather than satisfy the more rigorous environmental qualification requirements.
Nor does it contain any other indicia of reliability.
It is not even clear that the memorandum in question applies j
to the cables of instant interest, as,it refers to "P.O.
113-18 and the other cable specifications", whereas the cables in ques-tion here were part of P.O.
113-19.
We are apparently expected to infer, in the complete absence of any evidence on the point, i
that "the other cable specifications" applies to the one in ques-tion.
Moreover, there is absolutely nothing in the record which j
establishes the qualifications or authority of either of the
)
parties to the conversation to make pronouncements on the subject of environmental qualification requirements.
In sum, this telephone memo--Applicants' only authority for their new argument that RG-58 cable need only satisfy some lower environmental qualification standard--is the worst kind of unsubstantiated, non-probative multiple hearsay.
It provides no objective evidentiary basis for finding either that RG-58 is suf-ficiently similar to RG-59 to justify a conclusion that it is qualified (the original finding of The Licensing Board) or to find that the cable need not be fully qualified, which appears to be the new substitute rationale.
)
4 1
=
- L
I l
-4 At this point, it could not be more clear that the record does not support the Licensing Board's finding that the ten miles of RG-58 cable is environmentally qualified.
This is an issue as to which the Applicant has the burden of proof and has not met it.
Its latest filing only underscores the need for a hearing on this issue.
I I
1 Respectfully submitted,
{
pl bG Dean R. Tousley Ellyn R. Weiss HARMON & WEISS 2001 S Street, N.W.
Suite 430 Washington, D.C.
20009 (202) 328-3500 i
December 10, 1987 I certify that on December 10, 1987, copies of the foregoing pleading were served by first class mail, on the attached service list.
). ML D
s Dean R. Tousley Ellyn R. Weiss
~
LOLnf.IM thNEC SEABROOK SERVICE LIST -- ONSITE LICENSING BOARD N khbesh.
a am, Esq.
Sheldon J. Wolfe, Chairman North Hampton, NH 03826 111 Lowell Street Atomic Safety and Licensing Manchester, NH 03105 McKay, Murphy and Graham Board J.P. Nadeau 0FFIC; 400 Main Street U.S. NRC Town of Rye Sherwin E. Turk, Esq.
DOCKOiAih6sEMry$4 01913 Washington, D.C. 20555 155 Washington Road Office of General Counsel BRAN'h Rye, New Hampshire 03870 U.S. NRC Dr. Jerry Harbour Washington, D.C. 20555 Atomic Safety and Licensing Richard E. Sullivan, Mayor Board City Hall Mr. Angie Machiros, U.S. NRC Newburyport, MA 01950 Chairman Washington, D.C. 20555 Town of Newbury Alfred V. Sargent, Chairman Town Hall,25 High Road Dr. Emmeth A. Luebke Board of Selectmen Newbury,MA 01951 5500 Friendship Blvd.
Town of Salisbury, MA 01950 Apartment 1923N George Dana Bisbee, Esq.
Chevy Chase, MD 20815 Senator Gordon J. Humphrey Geoffrey M. Huntington, Esq.
U.S. Senate Office of the Attorney General Atomic Safety and Licensing Washington, D.C. 20510 State House Annex Board Panel (Attn. Tom Burack)
Concord, NH 03301 U.S. NRC Washington, D.C. 20555 Selectmen of Northampton Allen Lampert Northampton, New Hamp-Civil Defense Director Atomic Safety and Licensing shire 03826 Town of Brentowood Appeal Board Panel Exeter, NH 03833 U.S. NRC Senator Gordon J. Humphrey Washington, D.C 20555 1 Eagle Square, Ste 507 Richard A. Hampe, Esq.
Concord, NH 03301 Hampe and McNicholas Docketing and Service 35 Pleasant Street U.S. N RC Michael Santosuosso, Concord, NH 03301 Washington, D.C. 20555 Chairman Board of Selectmen Gary W. Holmes, Esq.
Mrs. Anne E. Goodman Jewell Street, RFD # 2 Holmes & Ellis Board of Selectmen South Hampton, NH 03842 47 Winnacunnent Road 13-15 New Market Road Hampton, NH 03842 Durham, NH 03842 Judith H. Mizner, Esq.
Silverglate, Gertner, et al.
William Armstrong William S. Lord, Selectman 88 Broad Street Civil Defense Director Town Hall-- Friend Street Boston, MA 02110 10 Front Street Amesbury,MA 01913 Exeter, NH 03833 Rep. Roberta C. Pevear Jane Doughty Drinkwater Road CaMn A. Canney SAPL Hampton, Falls, NH 03844 City Manager 5 Market Street City Hall Portsmouth,NH 03801 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. Ifrock, Esq.
1 Ashburton Place,19th Floor Shaines & h Eachern Boston, MA 02108 Thomas G. Dignan, Esq.
P.O. Box 36' R.K. Gad II, Esq.
Maplewood ve.
Stanley W. Knowles Ropes & Gray Portsmeuth, 4 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 Kersington, NH 03827 Backus, Meyer & Solomon t