ML20237E604
| ML20237E604 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/11/1987 |
| From: | Walker H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20237E554 | List: |
| References | |
| OL-1, NUDOCS 8712290081 | |
| Download: ML20237E604 (12) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF
)
50-444 OL-01 NEW HAMPSHIRE, et al.
)
On-site Emergency Planning
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and Safety issues (Seabrook Station, Units 1 and 2)
)
AFFIDAVIT OF HAROLD WALKER 1,
Harold Walker, being first duly sworn, hereby affirm that the answcrs to the questions set forth herein are true to the best of my knowledge:
Q1: Mr. Walker, by whom and in what capacity are you employed?
l A1: I am employed by the U.S.
Nuclear Regulatory Commission as a Reactor Engineer in section B of the Plant Systems Branch, Division of Engineering and Systems Technology, Office of Nuclear Reactor l
Regulations.
Q2: Have you prepared a statement of your professional qualification?
A2: Yes, a statement of my professional qualifications is attached as an exhibit to this affidavit.
1 Q3: Mr. Walker, what is the purpose of your affidavit?
A3: My affidavit responds to the memorandum submitted to the Appeal Board by the Licensino 530ard and the New England Coalition on Nuclear Pollution (NECNP).
In its memorandum, the Licensing Board g22gh p
G
. 1 explained its reasons for concluding that "the pertinent EQF
[ environmental qualification file]
shows that the dimensional differences between the RG58 and the RG59 cables are of such little importance that the test results for the RG59 cable can serve to l
qualify the untested RG58 cable."
in its memorandum to the Appeal Board, NECNP challenged this conclusion on a number of grounds.
Licensing Board's Memorandum Q4: Mr. Walker, do you agree with the statement at page 2 of the Licensing Board's memorandum that:
[T]he dimensions of the copper conductors (#21 AWG stranded wire in cable RG58, and #24 AWG stranded wire in cable RG59) have little, if any, significance to environ-mental qualificatfor, of the cables, except that the dimen-sions reflect the different applications for which the cables are intended.
A4: Yes I agree.
05: Mr.
- Walker, the Licensing Board states at pages 2-3 of its memorandum that it "could find no requirements in the environmental qualification acceptance criteria, or in the environmental qualification tests themselves, that depended upon the diameter or cross-sectional area of the conductors."
Do you agree with the Licensing Board?
A5: I am unaware of any requirement in the environmental qualification acceptance criteria or in the environmental qualification test themselves that depends upon the diameter or cross-sectional area of the conductors.
06: Mr. Walker, at page 3 of its memorandum the Licensing Board states that "different operating requirements of the cables, specifically the differing requirements for insulation resistance (IR), provide a basis for justifying the similarity of the two cables whose primary insulation thickness differs by a factor of approximately 1.5."
Do you agree with this statement?
A6: I agree' that the different operating requirements of the cables, specifically. the differing requirements for insulation. resistance are important in determining similarity of performance of the two cables.
However, the functional requirements of the cables and the potential failure modes must also be considered.
In this case, these are important considerations because the RC58 cable only has to remain intact, and is not required to mitigate an accident.
It is also important to note that the materials used in construction, type of cable (single conductor vs multiconductor) and whether the cables were made by the same manufacturer also are important.
The Staff believes that all these factors collectively, provide a basis for justifying the similarity of the two cables whose primary insulation thickness differs by a factor of approximately 1.5.
07: Mr. Walker, in light of your previous answer, do you agree or disagree with the Licensing Board's statement at page 3 of its memorandum that "the predicted performance of the smaller RG58 cable under conditions of environmental qualification testing would be proportional to the lower required operating resistance of its insulation"?
A7: 10 C.F.R.6 50.49(f)(2)
- provides, in pertinent
- part, that an equipment item may be qualified by testing a similar item with a supporting analysis to show that the equipment to be qualified is acceptable.
In this context, the Staff believes that the term "similar", means to be alike in substance or in essential respects.
On the other hand, the term "proprotional" implies a more exact i
comparison or a ratlo.
In the context of 10 CFR 50.49 the Staff does not believe thet similar and proportional are synonymous.
L_
-n-Nevertheless, when one considers the known attributes of cables RG58 and RG59 such as the functional requirements under accident conditions, the difference in insulation thickness of only 20 mils, the same materials of construction and type of construction and that RG59 did not fall as a result of the environmental qualification testing, the ability of RG58 to perform its function - by remaining intact is a reasonably conservative prediction.
Notwithstanding the above described attributes, proportional performance under the conditions of environmental qualification testing may be a reasonable expectation but it is not assured, j
However, proportional performance is neither required or necessary in order for RG58 to perform its required function under accident conditions, nor is it necessary in order to demonstrate similarity.
Q8: Mr. Walker, in its order of November 6, 1987 the Appeal Board asked the NRC Staff to discuss "whether in view of the specification that coaxial cable must pass an 'AC Voltage Withstand' test at 5000 volts, the Licensing Board erroneously relied upon the value of 80 volts per mil of insulation" as the appilcable acceptance criteria.
l Please address the Appeal Board's concern.
A8: The Voltage withstand test of 5000 Volts,
identified in the j
specification for coaxial
- cable, is in accordance with Military specification M I L-C-17 E, which is identified by Applicants as the acceptance criteria that this particular cable must meet in order to be accepted for use at Seabrook.
The NRC acceptance criteria is 80 Volts AC per mil of insulation, as set forth by the Institute of Electrical and Electronics Engineers (IEEE) in the "iEEE Standard for Type Test of Class 1E Electric
- Cables, Field
- Splices, and
Connections for Nuclear Power Generating Stations" ("iEEE Standard 383-1974").
This standard is endorsed by NUREG-0588 Revision I,
" interim Staff Position on Environmental.
Qualification of Safety-Related Electrical Equipment ".
1 NECNP's Memorandum 1
09: Mr. Walker, NECNP argues (at pages 3-4 of its memorandum) that the Licensing Board's conclusion that "the predicted performance of
.the smaller RG58 cable under conditions of environmental qualification testing would be proportional to the lower required operating resistance of its insulation" is contradicted by informat3n in the same equipment qualification file relating to the en e "onmental qualification of RG11 cable.
Do you agree with NECNP, and if so, is this point significant?
A9: I agree with NECNP but as i explained above (A7), this point is not significant.
1 i
Q10: Mr. Walker, NECNP states at page 4 of its memorandum:
Given the fact that neither the insulation resistance operating requirement nor the measured I
insulation resistance after testing of the RG11 and RG59 cables is proportional to the cables' insulation thickness, the Board's Memorandum raises questions as to what other factors might influence the qualification of these cables.
Are there other factors which might influence the qualification of these cables?
A10: Yes, see my response to Question 6.
Q11: Mr. Walker, at page 5 of its memorandum, NECNP argues that it is not possible to infer with an adequate degree of conservatism that an i
l i
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untested cable can be qualified by comparison to a ' tested ca ble.
having thicker isulation and 'similar or higher insulation resistance requirements. Do you agree?
All': The concept of demonstrating similarity is somewhat complex, but !
do not agree that it is impossible.
The Staff believes that the demonstration of similarity ' increases in complexity as differences between the items in ciuestion become greater (i.e., the more they are different the less they are similar). In the case of the RG58 and RC59 cables, the Staff believes qualification has' been demonstrated in accordance with 10 C.F.R. 650.49(f)(2) because the materials of construction and type of construction is the same for both cables, the insulation thickness for RC59 is 1.5 times greater but.the specified operating resistance is 10 times greater.
Finally, there is added conservatism in that RG58 is only required to remain intact (i.e., no short to ground) as indicated in NECNP Ex. 4, reference i
j i
Q12: Mr. Walker, please address NECNP's comment (at page 6) that "the test methods used to qualify the RG59 cable provide a questionable basis either for qualifying the RG59 cable or qualifying the RG58 cable by comparison."
A12 : 10 C.F.R. 650.49 sets forth the req ?rements for environmental qualification of electrical equipment impcrtant to safety for nuclear power plants.
The NRC acceptance criteria for cables is described in' IEEE standard 383-1974.
I believe that environmental qualification of RG58 and RG59 is in compliance with the requirements of 10 CFR 50.49.
.. _ -.,---..:-=.- - - -
The following is the relationship of insulation resistance to cable length:
Formula to calculate the insulation Resistance of a given length of Cable:
RL Rm X CTSL L
R Measured resistance of tested cable in M = Megohms CTSL = Cable test specimen length in feet insulation resistance for cable of L feet R
L =in megohms L=
length in feet Reference MIL-C-17F, January 1983.
Q13: Does this complete your affidavit?
A13: Yes it does.
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O'Wf
- LY Harold WalkGr '
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Subscribed and sworn before me this _ //CDday of December 1987:
M b.$d&M.)
Vff (f
My commission expires July 1,1991
r PROFESSIONAL' QUALIFICATION OF HAROLD WALKER i
i am a Reactor Engineer in Section B of the Plant Systems Branch, Division of Engineering and Systems Technology, Office of Nuclear l
Reactor Regulation, United States Nuclear Regulatory Commission.
My duties include serving as a principal reviewer in the area of nuclear plant protection to assure against various hazards and certain aspects of containment, radio-active waste processing and other support systems assigned to the B ranch. Prior to this assignment I was a Mechanical Engineer in the Electrical, instrumentation and. Control Systems Branch.
where i reviewed the integrity, operability and functional capability of mechanical and electrical equipment, mechanical components, and their supports needed for safe operation and safe shutdown of nuclear facilities.
Prior to being assigned to the Electrical Instrumentation and Control Systems
- Branch, I
was a
Mechanical Engineer in the Equipment Qualification Branch where my duties included performing technical reviews, analyses and evaluations of the adequacy of the environmental l
qualification of electrical and mechanical equipment whose failure, due to such environmental conditions as temperature, humidity, pressure and radiation, could adversely affect the performance of safety systems.
I was previously a Materials Engineer in the Materials Engineering Branch where my duties and responsibilities involved the review and evaluation of j
i materials performance from the standpoint of operability and functional 1
1 i
capability and integrity under normal, abnormal, and accident loading 1
2 conditions, and analyzing fracture toughness of reactor vessel materials, including specific data to assure that the materials will behave in a non-brittle manner.
Prior to my position in the Materials Engineering Branch, I was a Materials Engineer in the Engineering Branch, Division of Operating Reactors. My duties and responsibilities Inc.luded the review of operating.
problems to determine whether safety requirements were being satisfied and to assure that operating problems were corrected, and met with due regard for safety and environmental protection.
Prior to my position in the Engineering Branch, I was a ACRS Fellow at the Advisory Committee on Reactor Safeguards.
My duties included collecting and consolidating information pertaining to non-destructive testing methods.
I hold a B.E. degree in mechanical engineering from the City College of the City University of New York and I have taken graduate courses at the University of Pittsburgh.
Prior to joining the NRC, I was an engineer at Westinghouse Research Corporation in Pittsburgh,
Pennsylvania where my duties included the application of the state of the art fracture mechanics as well as the study of structural integrity of materials in various environments and under various loading conditions.
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1 DOCKETED USNHC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 87 EC 16 P4:11 bkdb'f[p!f/y*
BEFORE THE ATOMIC SAFETY AND LICENSING APPE dishNvi In the Matter of
)
)
Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF
)
50-444 OL-01 NEW HAMPSHIRE, et al.
)
On-site Emergency Planning
- - ~
)
and Safety issues (Seabrcok Station, Units 1 and 2)
)
CERTIFICATE OP SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO MEMORANDUM OF LICENSING BOARD AND NEW ENGLAND COALITION ON NUCLEAR POLLUTION REGARDING ENVIRONMENTAL QUALIFICATION OF RG-58 COAXI AL CABLE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class cr, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's i
internal mail system, this 11th day of December 1987.
Sheldon J. Wolfe, Esq., Chairman
- Dr. Emmeth A. Luebke Administrative Judge Administrative Judge Atomic Safety and Licensing Appeal 5500 Friendship Boulevard Board Apartment 1923N U.S. Nuclear Regulatory Commission Chevy Chase, Maryland 20815 Washington, DC 20555 Ms. Carol Sneider, Esq.
Dr. Jerry Harbour
- Assistant Attorney General Administrative Judge Office of the Attorney General Atomic Safety and Licensing Appeal One Ashburton Place, 19th Floor Board Boston, MA 02108 j
U.S. Nuclear Regulatory Commission Washington, DC 20555 Richard A. Hampe, Esq.
New Hampshire Civil Defense Agency Beverly Hollingworth 107 Pleasant Street 209 Winnacunnet Road Concord, NH 03301 Hampton, NH 03842 Sandra Gavutis, Chairman Calvin A.
- Canney, City Manager Board of Selectmen City Hall RFD 1 Box 1154 126 Danle! Street Kensington, NH 03827 Portsmouth, NH 03801 Stephen E. Merrill Paul McEachern, Esq.
Attorney General Matthew T. Brock, Esq.
1
Stephen E. Merrill Paul McEachern, Esq.
I Attorney General Matthew T. Brock, Esq.
1 George Dana Bisbee Shaines & McEachern Assistant Attorney General 25 Maplewood Avenue Office of the Attorney General P.O. Box 360 25 Capitol Street Portsmouth, NH 03801 Concord, NH 03301 Roberta C. Pevear l
Angle Machiros, Chairman State Representative l
Board of Selectmen Town of Hampton Falls l
25 High Road Drinkwater Road l
Newbury, MA 09150 Hampton Falls, NH 03844 Allen Lampert Mr. Robert J. Harrison I
Civil Defense Director President and Chief Executive Officer Town of Brentwood
'Public Service Co. of New Hampshire 20 Franklin Street P.O. Box 330 Exeter, NH 03833 Manchester, NH 03105 Charles P. Graham, Esq.
Robert A. Backus, Esq.
McKay, Murphy and Graham Backus, Meyer 6 Solomon 100 Main Street 116 Lowell Street Amesbury, MA 01913 Manchester, NH 03106 Diane Curran, Esq.
Philip Ahren, Esq.
Harmen & Weiss Assistant Attorney General 2001 S Street, NW Office of the Attorney General Suite 430 State House Station #6 Washington, DC 20009 Augusta, ME 04333 1
l Edward A. Thomas Thomas G. Dignan Jr., Esq.
Federal Emergency Management Agency Ropes & Gray 442 J.W. McCormack (POCH) 225 Franklin Street j
Boston, MA 02109 Boston, MA 02110 i
i H.J. Flynn, Esq.
William Armstrong Assistant General Counsel Civil Defense Director Federal Emergency Management Agency Town of Exeter 500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel
- B oa rd*
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 l
1 r
b l
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_ _.i_ Z.i_- - -- R Jane Doughty Docketing and Service Section*
Seacoast Anti-Pollution League Office of the Secretary 5 Market Street U.S. Nuclear Psegulatory Commission Portsmouth, NH 03801 Washington, DC 20555 Miaynard I., Young, Chairman William S. Lord Board of Selectmen Board of Selectmen 10 Central Road Town Hall - Friend Street i
South Hampton, NH 03287 Amesbury, MA 01913 1
Michael Santosuosso, Chairman Peter J. Matthews, Mayor Board of Selectmen City Hall South Hampton, NH 03287 Newburyport, MN 09150 Mr. Robert Carrigg,' Chairman Judith H. Mizner, Esq.
Board of Selectmen Silvergiate, Gertner, Baker Town Office Fine and Good Atlantic Avenue 88 Broad Street North Hampton, NH 03862 Boston, MA 02110 R. K. Gad 111, Esq.
Mrs. Anne E. Goodman, Chairman Ropes & Gray Board of Selectmen 225 Franklin Street 13-15 Newmarket Road Boston, MN 02110 Durham, NH 03824 Gary W. Holmes, Esq.
Holmes S Ellis 47 Winnacunnet Road Hampton, NH 03842 t
t
' Gregory A f irir Be- 'r y g
Counsel fot NRCI Staff
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