Text

Supplemental Affidavit of R Bergeron.*
	ML20196H125
Person / Time
Site:	Seabrook
Issue date:	05/26/1988
From:	Bergeron R; NEW HAMPSHIRE, STATE OF, PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	;
Shared Package
ML20196G977	List: ML20196G971; ML20196H024; ML20196H069; ML20196H113; ML20196H125;
References
	OL-1, NUDOCS 8807060092
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{{#Wiki_filter:.. .. . . - - - - - - - - UNITED STATES OF AMERICA UNITED STATES NUCLEAR RECULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

In the Matter of )

PUBLIC SERVICE COMPANY ) Docket Nos. 50-4 43 O L- 1 NEW HAMPSHIRE, et al. ) 50-444 OL-1

(Seabrook Station, Units 1 ) (On-site Eme rge ncy and 2) ) Planning Issues)

SUPPLEMENTAL AFFIDAVIT OF RICHARD BERCERON I, RICHARD BERCERON, being on oath, depose and say as follows:

1. I as the Instrumentation and Controls Engineering Supervisor for New Hampshire Yankee. A statement of my professional qualifications is attached and ma rked "A".

2. In paragraph 9 to my af fidavit of May 19, 1988, I indicated that there were "77 RG-58 cables located in mild environments within the nuclear island". Included in this number is an RG-58 cable which is located in a mild environment and which is a spare cable. As such this cable could have been categorized as "RG-58 cables located in mild environments within the nuclear island" or as "Spare RC-58 cables".

3. Since all oth. spare cables located in mild environments within the nuclear island had been included in the "Spare RG-58 cables" category, the tabulation in paragraph 9 should be revised as follows to be consistent with this categorization.

8807060092 000628 PDR ADOCK O>O0 0 J

Nr., . of Cables ___ Category 19 Spare RG-58 Cables 12 RC-58 cables routed at least pa rtially through a harsh environment within the nuclear island. 76 RC-58 cables located in mild environments within the nuclear island. 10 RC-58 cables routed with other nonsafety-related cables outside the nuclear island. 9 RC-58 cables routed in mild environments within the nuclear island and routed with nonsafety-related cables outside the nuclear island. sb w s. > Richard Bergeron 67 STATE OF NEW HAMPSHIRE Rockingham, ss. Ma y 24, 1988 The above-subscribed Richard Bergeron appeared before me and made oath that he had read the foregoing af fidavit and that che statements et forth therein are true to the best of his knowledge. Be f o re me , BiM u d_. Ndw Beverly E.C1111oway, NotaryJublic

~~

My Commission Expires March 6,1990 l 2

J "A" l l l RICHARD BERGERON Instrumentation & controls Engineering Supervisor Education BS Marine Engineering, Maine Maritime Academy, May 1969 Mr. Bergeron joined Public Service Company of New Hampshire in May 1982 as Senior IEC Engineer in the Engineering Services Department. His areas of responsiblity include coordination of I&C Engineering activities for the Station Staff, construction and Startup interface activities, as well as, various special projects. Mr. Bergeron was recently appointed to the position of Instrumentation & Control Supervisor in the Engineering Department. For the past six years Mr. Bergeron has also been assigned as the Station Staff Representative on the Equipment Qualification Task Force. He has been responsible for the coordination and review of the Equipment Qualification Program, as well as, coordinating the implementation of the Station Equipment Qualification Program. Mr. Bergeron came to Public Service Company of New Hampshire from Stone & Webster Engineering Corporation where he was employed from 1972-1982. He held the position of Principle Instrument Application Engineer responsible, for

specifying, purchasing and design review of electron and pneu=atic~ instrumentation control systems. Mr. Bergeron is also experiencad in the scheduling and preparation of Logic Diagrams and System Cescriptions which define the functional control concepts. He was also assigned as a task member to assist in the development and preparation of the 79-01B equipment qualification submittal for Duquesne Light Company. Between 1969 and 1972 was employed by Gulf oil corporation as an engineer in their Marine Engineering Division. There he was responsible for the operation and maintenance of Marine Power Plants. r -

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06/02/8B ) l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

                                                 )       Occket Nos. 50-443 OL-01 FUELIC SERVICE COMPANY OF                   )                     50-444 OL-01 NEW HAMPSHIRE, et al.                     )       On-site Emergency Planning
                                                 )         and Safety Issues (Seabrook Statf or., Units 1 ard ')         )

NPC STAFF RESP 0 HSE TO APPLICANTS' SUGGESTION OF MCOTNESS INTRODUCTION On May 19, 1988, Applicants filed a "Suggestien Of Nootness" in which they recuest the Licensing Board "to enter an order that the issue regaroing the environmental qualification of RG-58 coaxial cable pending before the Licensing Board is troot." Id. at 1. On May 23: 1988, the Licensing Board directed the Staff and NECNP to respond to Applicants' filing by June 3,1988. See Vay 23, 1988 Order at 1. The Staff's views cercerning Applicants' "Suggestion of Mootness" are set forth below. BACKGROUND In ALAB-891, the Appeal Board reversed the Licensing Board's cer.clusion in the March 25, 1987 Partial Initial Decision (LBP-87-10) that the environmental qualification of RG-58 coaxial cable had been established and remanded the matter to the Licensing Board for "a further evidentiary exploration." Public Service Company of New Panpshire (Seabrook Station, Units 1 and 2), ALAB-891, 27 NRC , slip op. at 22 (April 25, 1988). The next day, April 26, 1988, the Licensing Board r (

2 issued its order soliciting the parties' views as to how best to effectuate the Appeal Board's order. See April 26, 1988 Order at 1.

n its response to the Board's April 26, 1988 order M. the Staff r.o ted that the Licensing Board's finding regarding the environmental qualification of RG-58 coaxial cable was reversed by the Appeal Board for only one reason -- that the evidentiary record contained insufficier.t tvidence to support the conclusion that the cable was enviror. mentally cualifiec to perform its intended function. Fay 6 Staff Response at 3, citing, ALAB-891, slip op, at 22. The Staff pointed out that the Appeal Board cid not rule that RG-58 cable was not environmentally qualified.

M. The Staff advised the Beard that to cure this deficiency it war necessary to receive additional evidence from the parties sufficient to enable the Board to reach a sound decision as to whether RG-58 coaxial cable is qualified for its intenced uses. B . The Staff further advised

+ hat because Applicants bear the burden of proef, see 10 C.F.R. 6 2.732, they should be required to present such evidence in the first instance.

The Staff identified three ways in which Applicants could carry their buroen. 53 May 6 Staff Response at 3-4 First, Applicants can subject the RG-58 cable itself to the tests necessary to establish its envirortrental qualification. _!_d, at 3, citing, ALAS-891, slip op at 26, n.66. Second, Applicants can subtrit additional evidence demonstrating that PG-58 coaxial cable is sufficiently similar to RG-59 coaxial cable such that the acceptable test results of the latter can serve to -1/ NRC Staff Response To Board Order Of April 26, 1988 (May 6, 1988) ("May 6 Staff Response").

3 demonstrate the environmental cualification of the former under 10 C.F.R. I 50.49(f)(2). Id. Third, Applicants can attempt to demonstrate that PG-58 coaxial cable is not intended to be used for any purpose in which it may be required to perforin an accident mitigation functicn and that the cable is qualified to perfonn its intended function function. Id, at 4 A fourth cption available to Applicants which the Staff did not address is to reolace all RG .98 coaxial cables requiring environmental qualification with another type cable that has previously been demonstrated to be environn:entally cualified for its intended use. This course of action is appropriate because it addresses and eliminates the central claim of remar.ded NECNP Cortention I.B.? -- that RG-58 coaxial cable was being utilized in a harsh environment at the Seabrook Station without first being envircnmentally qualified pursuant to 10 C.F.R. I 50.49. Applicants state that remanded NECNP Contentier. I.B.2 should be disrtrissed as moct because they plan to replace the RG-58 coaxial cables with FG-59 coaxial cable in each instance where the requirements of 10 C.F.R. 150.49 are applicable. Suggestion Of Mootness at 5-6. To the extent that Applicants seggest that the Board dismiss remanded NECNP Contentic.i I.B.2 without making the appropriate fir. dings of fact and conclusion cf law, the Staff does not agree that Applicants' submission in itself moots the issue. Rather, as the Staff outlined in its May 6 2/ There is no inconsistency between this position and the one taken by the Staff with respect to remanded NECNP Contentions I.V and IV. See Letter from Gregory Alan Perry, Esq. to Licensing Board at 1 (April 28,1988). Since retarded NECNP Contentiens I.V and IV were abandcned by the irtervenor, they properly were dismissed by the (F0OTNOTE CONTINUED ON NEXT PAGE)

4 response, the affidavits submitted by Applicants in support af their mootness motion should be received into the record as evidence offered to establish that the safety concern alleged in remande6 NECNP Contention I.B.2 has been satisfactorily resolved. See May 6 Staff Response at 3-5. Thus, the Board should follcw the procedure outlired by the Staff and afford fiECNP and the Staff a reasonable opportunity to present evidence in suppert of or in c; position to Applicants' position. I d, . at 4-5. El The Staff may submit a further presentation after reviewing Applicants' evidentiary subrission. It is useful et this juncture, however, for the Staff to provide the following coninents on Applicants' submission based upon a preliminary review of that infortration. CISCUSSION Applicants state that a review cf all installed RG-58 coaxial cable at the Seabrook Station resulted in the identification of 126 RG-58 coaxial cables, grcuped into five categcries. Suggestion of Moctness at (FOOTNOTE CONTINUED FROM PREVIOUS PAGE) Board. See May 12, 1088 Order. In contrast, FECNP has not abandoned or withdrawn remanded NECNP Contention I.B.2. The only thing changed by Applicants' instant filing is the n'anner in which Applicants have elected to address the safety concern raised in remanded NECNP Ccr.tention I.B.2.

-3/

The Staff advised the Scard in its May 6 response that the need for anevidentiaryhearingwouldbeobviated"[il.f.uponreviewofall the materials submitted, +here exists no genuine issue as to any caterial fact and Applicants are entitled to judgment as a matter of law [.)" May 6 Staff Respcnse at 5. In such case, "the Board should close the record and issue an initial decision faverable to Applicants." Id. The Staff advised the Board that if, upon review of all the raterials surrbitted by the parties, there existed genuine issues as to any material facts, the Board should then schedule a ! hearing to resolve those issues. Id.

1, citing, Affidavit of Richard Bergeron at f5 3-6. According to Applicants, only the cables (a total of 12) in one the five categories are required to meet the environmental qualification standards set forth in 10 C.F.R. i 50.49. Bergeron Affidavit at 9 15. Applicants take the position that fer various reasons, the remaining 114 cables in the four other categories need rot satisfy the requirements of section 50.49. See Id. at it 17-14 As explained below, the Staff agrees with Applicants that the requirements of 10 C.F.R. 9 50.49 apply only to RG-55 cables located in harsh environments. E Sectior. 50.49 governs the environmental qualification of electrical equipment important to safety. 10 C.F.R. i 50.49. An item is considered "importent to safety" if it (i) has an accident mitigation function; (ii) Its failure under postulated environmental conditions could prevent satisfactory performance of safety relateo equipment relied upon to remain functional durirg and subsecuent to design basis events; or (iii) involves "certain post-accident monitcring equipment." 10 C.F.R. I 50.49(b)(1-3). However, not every item of tiectrical equipment which is "important to safety" need be environmentally qualified in accordance with 10 C.F.R. 6 50.49. Paragraph (c)(3) provides that "[r2equirements for . . . 4/ It should be noted that Applicants have not submitteo the source uaterial upon which the claim that a total of 126 RG-58 cables have been installed in the Seabrook Station is founded. Similarly, Applicants have not submitted the materials evaluated by them in determining which category grcuping a particular RG-58 cable belonged. Consequently, the Staff is not in a position to confirm or deny the accuracy of Applicants' representations that (11 126 pG-58 cables have been installed at the Seabrook Station and (2) the particular category groupings are appropriate. The Staff after reviewing the nature of this submission may make a further iresentation on its sufficiency.

h 6-(3) environmental qualification of electric equipment important to safety . located in a mild environrent are not included within the scope of this section." 10 C.F.R. I 50.49(b)(3). A "mild" environrent is defined as "an environment that would at no time be significantly more severe than the envirer. ment that would o- vr during nont.al plant operation, including anticipated operational occur.ences." J,d . In view of the foregoing, electrical equipment must tte environmentally qualified in accordance with 10 C . F . P . 6 50.49 if it (1) is "inportant to safety" as that term is defined in section 50.49(b)(1-3) and (2) is located ir a harsh (i.e., no n-n.il d ) environment. Unless both of these conditions exist, the electrical equipnent item need not be environmentally cualified. The Staff has applied these criteria to Applicants' PG-58 coaxial cable , groupirgs. A. Applicants' FG-58 Cable Category Groupings

1. Spare RG-58 Coax 1al Cables Applicants' expert, Mr. Eergeron, states that 10 cf the 126 installec PG-58 coaxial cables are spares. Pergeron Affidavit at ? 9. According to Pr. Bergeron. rone of theu. cables need be environnentally quelified pursuant to 10 C.F.R. f,50.49 because, inter alia, they "are not ,

functioning or energized and therefere do not pese any threat to other cables in the same raceway." Jd. at 1 14 Mr. Eergeron further states j i V

                                                                         ~s         ---        _,.      _ , _ _ _

that before a spare RG-SP cable may be used. "a deugo change has to be initiete ir to its incorporation into che plant design." J_d, . 5,/ e information presented 'oy Applicants to date, the Staff agrees 2 cables need not meet the requirements of 10 C . F . R . 6 50.49. 3

                      .oted above, the Commission's environmental qualification reauirements do not apply to nonsafety related electrical equipment unless the failure of such equipment under postulated environmental conditions could prevent satisfactory performance of safety related equiptrent relied upon to remain functional during and after a design basis event.           See 10 C.F.R.     ! 50.49(b)(2).       An electrical cable that is not energized or functional does not present any threat to the ability of other electrical rebles     or corrponents      to  perform their safety functions during or subsequent to an accident.          Consequently, cuch cables are not "important to safety" as that phrase is defined in 10 C.F.R. 5 50.49(b) and thus need not satisfy the environmental qualification standards even if located in a harshenvironment.5/

Although the Staff possesses no information to dispute this claim, it

~5/

should be noted that no documentary materials are cited or provided in support of this claim. For this reason, the Staff has indicated that the Seabrook Final Safety Analysis Report should be amended to reflect this design comittment. See n.6, infra.

 -6/     It should be noted, however, that should Applicants choose in the future to utilize any spare RG-58 coaxial cable located in a harsh environment, it will be necessary for Applicants to first establish the environcental qualification of the cable in accordance with section 50.49. In the treantime, the Seabrook Final Safety Analysis Report should be amended to reflect that no spare PG-58 coaxial cable tray be utilized in a harsh environment.

2. RG.58 Coaxial Cables Routed Through A Narsh Environment Applicants have identified twelve RG-58 coaxial cables routed through harsh environtrents. Bergeron Affidavit at f 9. Applicants state that these cables must cortply with the environmental qualification reouirements of 10 C.F.R. i 50.49. Jf. at i 15. Although Applicants do not expressly state, it appears that these cables are important to safety (i.e. , their failure under postulated environmental cor.ditions could irrpair the ability cf safety related equipment to perform its sa fety function satisfactorily). See I_d. If this assumption is correct, the Staff agrees that the requirerrents of section 50.49 are applicable to the subject cables since they are located in harsh environments. '

3. pG-58 Coaxial Cables located In A Mild Environment

      /.pplicants' expert, Mr. Bergeron, states that 77 of the 126 installed RG-58 colxia' cables are exempt frem the requirements of 10 C.F.R. t 5C.49 because they Jre located in mild environments.                Bergeron Affidavit at U 9,       12. Section    50.19(c)(3)    expressly provides     that electrical equipment irrportant to safety located in mild environments is not subject to the environtrental qualification requirements set forth in 10 C.F.R.

{ 50.49. See 10 C . F . R . Q 50.49(c)(3). Thus assurring Applicants are e.orrect in stating these 77 RG-58 coaxial cables are loca'nd in "mild" environtrents, they need net be environmentally qualified in accordance withsection50.49.1/ 2/ Again, Applicants have not provided any documentary traterials to substantiate the claim that the environment in which these cables are located is a mild one; and the Staff has no independent inforrration to cenfinn or deny the accuracy of this claim.

                                      -9 4    RG-58  Coaxial   Cables   Routed    With  Other Nonsafety-Related Cables Outside The Nuclear Island Ten RG-58 coaxial cables are routed with other non-safety related cables outside the Seabrock nuclear island according to Mr. Bergeron.

Bergeron Affidavit at ! 9. Among the structures included in the Seabrook nuclear island are the containment, control room, fuel storage, diesel gererator, ar.d primary auxillary buildings. See Seabrook FSAR, Figure 8.3-58. According to Applicants, RG-58 cables routed with other nonsafety related cables outside the nuclear island need not comply with 10 C.F.R.

  ! 50.49 because they are not "important to safety."        M. at 1 13. Mr.

Bergeren opines that failure of the subject RG-58 coaxial cables would not prevent the acccmplishment of safety functions but his affidavit does not reference or contain any factual information against which this conclusion can be evaluated. See M . U The Applicants fails to show that important to Safety RG-58 cable might not be exposed to a harsh environment outside of the f uclear island. As the basis of the Applicant's assertion that these cables will not be exposed to a harsh environment is only that they are not in the nuclear island, the Staff is not able to take a position at this tin e as te whether the RG-58 coaxial cables routed with other nonsafety related cables outside the nuclear island must be environmentally qualified in accordance with 10 C.F.R. 5 50.49. 8/ Non-Safety related eouipment is "important to safety" and subject a l environmental qualific6 tion requirements, if (1) it is lccated in a l harsh environment and (2) its "failure under postulated environmental conditions could prevent satisfactory acccmplishment cf safety functions." Compare 10 C.F.R. 6 50.49(b)(2), with, 10 C.F.R. 950.49(c)(3). If either of these conditions are lacking, the requirements of se: tion 50.49 do not apply. Fr. Bergeron's affidavit does not explain clearly why one or the other of these conditions is l net present with respect to the RG-58 coaxial cables routed with other non-safety related cables outside the nuclear island. L .

5.. PG-58 Coaxial Cables Routed In Mild Environaer.ts Within The Nuclear Island And Routed With Nonsafety-Related Cables Outside The Nuclear Island According to Fr. Bergeron, nine RG-58 coaxial cables are routed in milo environments within the nuclear island and with nensafety related cables outside the nuclear island. Bergeron Affidavit at ! 9. Electrical cables, even ones important to safety, which are located in mild environments withir or outside the nuclear island are not subject to envircreental cualification requirements of section 50.49. See 10 C.F.R.

 % 50.a9(c)(3). Electrical cables routed outside the nuclear island need not be c;ualified wFere it is shcwn that such cables (1) are located in mild    ervironments     or  (2) the    failure  of   such    under   postulated environmental conditions wculd not prevent satisfactory accomplishment of safety functions. As noted in Part A(4) of this response, Mr. Bergeren's afficavit does net clearly explain the besis for the determinatien that the F.G-58 coaxial cables routed with other nonsafety related cable outside the nuclear island is not in a harsh environment as those environments are also present outside of a nuclear island.       Consequently, the Staff has ro current position as to whether the subject cables must be qualified in accordance with 10 C.F.R. 6 50.49.                                                1 B. The Acceptability Of RG-59 Coaxial Cable In Place Of RG-58 Coaxial Cabie i

As discussed in the preceding section of this response, the Staff l agrees with Applicants that only RG-58 cables located in harsh enviror.nents need be environmentally qualified. Rather than establish the environmental qualification of RG-58 coaxial cable, Applicants propese l instead to use RG-59 coaxial cable in lieu of RG-58 coaxial cables in which it recognizes are subject to harsh enviornments. Affidavit of

Gerald A. Kotkowski at f 2; Affidavit of Ted C. Feigenbaum at t 7. The Staff agrees that the substitution of RG-59 coaxial cables for the twelve PG-58 coaxial cables would satisfy the environmental qualification requirements of 10 C.F.R. 9 50.49 for those cables. This is because ',ie environmental quhlification of RG-59 coaxial cable already has been established. See Public Service Company of New Hampshire (Seabrook Staticn, Unit I and 2), L8P-87-10, 25 NRC 177, 210-11, rev'd in part en o_ther grounds , ALAB-875, 26 NRC 251 (1987); NECNP Ex. 4 (Environn, ental Qualification File No. 113-19-01); Affidavit of Amritpal S. Gill and Harold Walker, attached to NRC Staff's Response To NECNP Motion To Reopen The Pecord And Adtnit New Contention (February 17,1988). Although from an environmental qualification standpoint no concern is presented by the propcsed substitution of RG-59 coaxial cable in place of the twelve RG-58 coaxial cables located ir harsh environments, it remains to be considered whether the PG-59 coaxial cable is a technically acceptable replacement for the PG-58 coaxial cable. Applicants' expert on this issue, Fr. Kotkowski, concludes in his affidavit that RG-59 coaxial cables would be acceptable substitutes. See Kotkowski Affidavit at

 ? 3-8. On the basis of this affidavit, providing matters set cut therein are not rebutted, the Licensing Board might find that the RG-59 cable is an acceptable substitute for the subject 12 RG-58 cables.

l CONCLUSION l For the reasons stated in this response, the Board should deny l 1 Applicants' motion for an order dismissing remanded NECNP Contention I.B.2 as root. The Board should reopen the record to receive the affidavits of Messrs. Bergeron, Kotkewski, and Feigenbaum submitted by Applicants and l

l l l l 1 any other relevant and admissible evidence which Applicants may offer to support their position en remanded NECNP Contention I.B.2 or to address the questions raised by the Staff herein. The Board should then afford NECNP and the Staff a reasonable amount of time to submit, if they so elect, relevant and admissible evidence in support of or opposition to Applicants ' position. If, upon review of all the materials submitted, there. uists no genuine issue as to any material fact and Applicants are entitled to judgrrent as a matter of law, the Board should close the record and issue an initial decision favorable to Applicants. If, however, a review of all the traterials submitted by the parties reveals the existence of genuine issues as to material facts, the Board should then schedule a heering to resolve those issues. N F45ketfullysubmitted, i-Gr g ry 1 ry Counse'. f r NRQ Staff Dated at Rockville, Maryland this 1st day of May 1988 9/ On May 31, 1988, the Staff received a May 27, 198f, filing from the Applicants concerning its May 19, 1986 Suggestion of Mootness. In this filing the Applicants change the number of cables in two categories and set out matters which they be.lieve are relevant to their Suggestion of Mootness. This additional filing and the changes reinfcrces the Staff's position that the record should be reopened to receive material proffered by the Applicants and other parties in order to detennine whether this environmental qualification issue tray be disposed of on the bases of those submissinns or whether a ( hearing is needed on the subject issue.

Uh!TED ST ATES OF AMERIC A NU CLE A R REGUL ATOR Y COMMISSION B E F0 P E T H E, A T OMIC S AFET Y A N D LIC EN SIN G B O A R O

 .fn the Patter of                                  )
                                                    )       Docket Nos. 50 443 OL-01 FUBLIC SERVICE COMPANY OF                         )                        50-444 OL-01 N EW H AP PS HIR E, et al.
                                                    )       On-sitti Emergency Planning
                                                    )         and S afety Issues (Seabrook Station, Units 1 and 2                  )

CERTIFIC A TE OF SERVIC E I hereby certify that copies of "N R C STAFF RESPONSE TO APPLIC A N T S' S U G G ES TIO N OF P00 TNESS" in the above-captioned proceeding have been served on the following by deoosit in the U nited States mail, first class, or as indicated by an asteric k , by deposit in the N uclear Reg ulatory Commission's internal mail system, this 2nd day of June 1988. Sheldon U. Wolfe, Esq., Chairman

Atomic Safety and Licensing Administrative Judge Board
Atomic Safety and Licensing Board U.S. Nuclear Regulatcry Commission U.S. Fuclear Pegulatory Commission Washington, D C 20555 Washingten, D C 20555 Dr. Jerry Harbour
Docketing and Service Section*

Administrative Judge Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Corrmissior. U.S. Nuclear Pegulatory Commission Washington , D C 2C505 Washington, D C 20555 Or. Emmeth A. Luebke T homas G. Dignan, Jr. , Esq. Administrative Judge Robert K. Gad, III, Esq. 4515 Willard Avenue Ropes & Gray C hevy Chase, Maryland 20815 225 Franklin Street Boston , P A C2110 l Atomic Safety and Licensing H . J . Fly n n , E s q . l Appeal Panel

Assistant General Counsel l U.S. Nuclear Pegulatory Ccn mission Federal Emergency Management Agency 1 Washington, D C 20555 500 C Street, SW I

Washington, DC 20472 l l 1

2 Philip Ahren, Esq. Calvin A. Canney Assistant Attorney General City Hall Office of the Attorney General 126 Daniel Street State House Station Portsmouth , N H 03801 Augusta, ME 04333 . Mr. A ngie Machiros, C hairman Carol S. Sneider, Esq. Board of Selectmen Assistant Attorney General 25 High Rcad Office of the Attorney General Newbury, M A 09150 One Ashburton Place,19th Floor Boston , M A 02108 George Dana Bisbee, Esq. Allen Lampert Assistant Attorney General Civil Defense Director Office of the Attorney General Town of Brentwood 25 Capitol Street 20 Franklin Concord, NH 03301 Exeter, N H 03833 Elly n R . W eis s , Es q . William Armstrong Diane Curran, Esq. Civil Defense Director Harmon & Weiss Town of Exeter P001 S Street, N W 10 Front Street Suite 430 Exeter, N H 03833 Washington, D C 20009 Rcbert A. Backus, Esq. Gary W. Holmes, Esq. Backus, Meyer & Solomon Holmes & Ellis 116 Levell Street 47 Winnacunnet Road Manchester, N H 03106 Ham pton , N H 03842 Paul McEachern, Esq. J. P. Nadeau Patthew T. Brock, Esq. Board of Selectmen Shaires & McEachern 10 Central Street 25 Maplewooo Avenue Rye, N H 03870 P.O. Box 360 Ports mouth , t. H 03801 Judith H. Mizner, Esq. Charles P. Graham, Esq. Silverglate, Gertner, Baker, McKay, Murphy & Graham Fine & Good 100 Main Street 88 Board Street Amesbury, M A 01913 B oston , M A 02110 Sandra Gavutis, Chairman Robert Carrigg , C hairman Board of Selectmen Board of Selectmen R FD fl, Box 1154 Tow n Office Kensington, N H 03827 Atlantic Avenue North Hampton, N H 03870 William S. Lord Peter J. Matthews, Mayor Board of Selectmen City Hall Town Hall . Friend Street Newburyport, M N 09150 An esbury, M A 01913

Mrs. Anne E. Goodmar., Chairman Michael Santosuosso, Chairman Board of Selectmen Board of Selectmen 13-15 Newmarket Roaa South Hampton, N H 03827

.-                                             Durham, N H 03824 Hon. Gordo'n J. Hurr phrey                                                                                                                 Ashed N. Amirian, Esq.

linited States Senate Town Counsel for Merrimac 531 Hart Senate Office B uilding 376 Main Street Washington, D C 20510 Haverhill, M A 06130 U ! Edwin J.Aeis Deputyf Assistant General Counsel

June 9, 1988 UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

In the Matter of )

Public Service Company of ) New Hampshire, et al. ) Docket No. 50-443 OL-1

(Seabrook Station, Units 1 & 2) ) ONSITE EMERGENCY

                                        )          PLANNING & TECHNICAL
                                        )          ISSUES
                                        )

NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S RESPONSE TO APPLICANTS' SUGGESTION OF MOOTNESS REGARDING ENVIRONMENTAL OUALIFICATION OF RG-58 CABLE The New England Coalition on Nuclear Pollution ("NEONP") hereby responds to Applicants' Suggestion of Mootness with respect to the environmental qualification of RG-58 coaxial cable. Applicants' filing and supporting affidavits show not that the issue is moot, but that a great many questions about the RG-58 cable and substitute RG-59 cable remain unresolved. These questions include the issues raised in NECNP's Response to ASLBP No. 88-558-01-OLR, dated May 19, 1988, and in the attached af fidavit of Robert D. Pollard. They may only be resolved through the process of discovery and through confrontation of Applicants' experts on the witness stand. While it is framed as a "suggestion," Applicants' filing has all the characteristics of a summary disposition motion. For three important reasons, this dispositive pleading must be rejected. First, summary disposition is completely inappropriate where the parties have not had discovery on the entirely new set of facts presented by Applicants regarding the qualification of

                                  ,                               {

4 . RG-58 coaxial cable. Applicants' pleadings continue to generate more questions than answers; the discovery procecc is an impor-tant tool for obtaining those answers, and for delving into the reasons for Applicants' 180 degree changa in position since the 1986 hearings. The discovery process would also include examination of documents supporting Applicants' position. For example, in their suggestion of mootness, Applicants cite a number of documents, including schematic drawings and raceway drawings, as well as a computer progran. Not only have Applicants failed to file these documents, but they are described so vaguely as to shed no light on their bearing on this issue. . A second reason that this dispositive motion must be denied is that NECNP is entitled to test the credibility of Applicants' witnesses in a hoaring. Applicants have dramatically changed their position from claiming in 1986 that RG-58 cable is qualified, to claiming now that most of it does not need to be qualified. For those applications for which Applicants concede qualification is required, they maintain that the RG-58 cable is qualified; yet, they have nevertheless decided to replace some of the RG-58 cable with RG-59 cable. Despite the numerous opportunities available to them, Applicants have failed to pro-vide the Board with any specific information regarding the par-ticular pieces of equipment that are served by the RG-58 cable, or the exact environmental qualification requirements to which

l l 1 I

                                        -3    -

l the substitute cable must conform. The affidavits filed by Applicants in support of their suggestion of mootness are ., exemplars of vagueness on this score. Given Applicants' changing position and the vagueness with which it is set forth, it is imperative that the Board subject Applicants' witnesses to the test of cross-examination. Finally, Applicants' filing fails to resolve material issues of dispute between the parties. As discussed in detail in the attached affidavit of Robert D. Pollard, Applicants' affidavits fail to establish that Applicants have identified all uses and locations of RG-58 cable, that they know what qualification requirements the cable must meet, or that RG-59 cable is an ade-quate substitute. A host of important questions remain, includ-ing but not limited to:

1) What is the basis for Applicants' assertion that all identified uses of RG-58 coaxial cable involve non-Class 1E or non-safety functions or applications, including those instances where Applicants propose to replace the RG-58 coaxial cable with RG-59?

2) Why was RG-58 cable designated Class lE safety equip-ment in the first place?

3) What are the specific uses of RG-58 cable? What par-ticular pieces of equipment does it serve?

4) Have Applicants correctly identified all instances in which RG-58 coaxial cable is used at Seabrook Station? Have

l

                                    -4  -

Applicants identifieo all purchase orders of RG-58 coaxial cables?

5) Have Applicants adequately determined the exact physi-cal locations of all RG-58 cable that has been identified as being used at Seabrook Station?

6) What are the specific environmental qualification requirements for RG-58 coaxial cable?

7) What are the specific environmental qualification requirements for RG-59 coaxial cable when used in place of RG-58?

8) Is RG-59 coaxial cable qualified to replace RG-58 cable? (If so, why was RG-58 purchased in the first place, since it is more expensive than RG-59?) (See NECNP Exh. 4, Ref. 7)

These are all issues that must be addressed in'the context of a hearing on the environmental qualification of RG-58 coaxial cable. NECNP agrees in large part with the position taken by the Staff in its filings of June 2 and June 6, 1988. However, we disagree with the Staff in two important respects. First, as discussed above, we do not consider that additional summary dis- , position proceedings are appropriate in this case. Second, we disagree with the Staff that the environmental qualification of j RG-59 cable is "established." NRC Response to Applicants' Sug- ! gestion of Mootness at 11. The qualification of RG-59 cable was not placed at issue in the 1986 hearings, and subsequent litiga-tion on the admissibility of a late-filed contention on the issue l 1

does not constitute a merits ruling on the qualification of that cable. Most importantly, there is no basis for assuming that RG-59 cable meets RG-58 performance requirements for those applica-tions of RG-58 that RG-59 will serve as a substitute. Once the specific environmental qualification requirements for these applications of RG-58 coaxial cable are known, the parties may examine all relevant testing documentation to determine whether RG-59 cable meets those standards. For the foregoing reasons, NECNP asks the Licensing Board to reject Applicants' Suggestion of Mootness and schedule discovery and a hearing on the issue of the need for and adequacy of Gnvironmental qualification of RG-58 coaxial cable and substitute cable. Respectfully submitted,

                                                    .c
                                                 ~
                                           .b .    ;       y Diana Curran Dean R. Tousley RARMON & WEISS 2001 "S" Street, N.W.

Suite #430 Washington, D.C. 20009 l (202) 328-3500 June 9, 1988 i CERTIFICATE OF SERVICE I certify that on June 9, 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. Diane Curran L f

June 8, 1988 UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

In the Matter of )

Public Service Company of ) New Hampshire, et al. ) Docket No. 50-443 OL-1

(Seabrook Station, Units 1 & 2) ) ONSITE EMERGENCY

                                           )        PLANNING & TECHNICAL
                                           )        ISSUES
                                           )
                     &EEIDAVIT OF ROBERT D. POLLARD I, Robert D. Pollard, being duly sworn, depose and say:

1. My name is Robert D. Pollard. My business address is 1616 P Street, N.W., Washington, D.C. 20036.

2. Since February 1976, I have been employed as a nuclear cafety engineer by the Union of Concerned Scientists. Pre-viously, I was employed by the U.S. Nuclear Regulatory Commission as a licensing project manager for commercial nuclear power plants.

3. The purpose of this affidavit is to describe the unresolved technical issues raised in affidavits filed in support of "Applicants' Suggestion of Mootness," filed May 19, 1988.

4. The technical issues regarding which there remains sig-nificant question fall in four principal categories:

a) the adequacy of Applicants' efforts to identify all instances in which RG-58 coaxial cable is used at Seabrook Station. b) the adequacy of Applicant's efforts to determine kW @N -

l

                                    -2  --

the exact physical location of the RG-58 cable that has been identified as being used at Seabrook Station: c) the validity of Applicants' assertion that all identified uses of RG-58 coaxial cable involve non-Class 1E or non-safety functions or applications, including those instances where Applicants propose to replace the RG-58 coaxial cable with RG-59. d) the adequacy of the environmental qualification of RG-59 coaxial cable in those instances where Applicants propose to replace the RG-58 coaxial cable with RG cable.

5. The means used in an attempt to identify all applica-tions of RG-58 coaxial cable in the Seabrook Station was to use the computerized Conduit and Cable Schedule Programs (CASP)

Design Guide to generate a list of installed cables having the cable code TA6Y. Beraeron Affidavit at paragraphs 4-6,

6. Mr. Bergeron claims that "an independent review was performed and verified that all RG-58 had been identified ...

Id., paragraph 16. However, while this review "was performed by different individuals," it cannot be construed as an independent review because it only "essentially replicated the review described above, using the same information sources." Id.

7. Having two or more individuals query the same computer based listing of cables cannot provide an independent review of the validity of the data base of the computer. There are three

                                 -3  -

. cable designations that differ only in the last character, i.e., TA6T, TA6Y, and TA6U, and the three characters, T, Y, and U, are adjacent on a standard keyboard. NECNP Ex. 4, Encl. 1, App. A. Thus, the possibility of erroneous data entries is not insignificant. Errors in data entry would not be discovered by asking the computer the same questions twice.

8. Similarly, if output from CASP was used as instructions to the workers installing the cable, the possibility of inter-changing cable types TA6T, TA6Y, and TA6U during installation is not insignificant. Again, such errors would not be revealed by making duplicative inquiries to the computer.

9. Applicants further claim that the independent review "included an evaluation of Seabrook Station electrical schematic drawings for RG-58 applications." Berceron Affidavit, paragraph

16. This statement fails to show how the review of the drawings was done or how it centributed to the independence of the review.

Schematic drawings frequently do not include information about the type of cable used. However, even assuming such information is on the schematic drawings, Applicants are silent about what, \ if any, effort was made to determine whether the drawings reflect the as-built plant. Furthermore, if the information in CASP regarding cable type was obtained from the schematic drawings, or vice versa, the drawing review would provide no independence.

10. A genuinely independent review to determine whether all RG-58 applications have been identified would involve not only i

                                   -4    -

different individuals, but a different technique as well. For example, the sum of the cable lengths used during installation of each identified use of RG-58, plus the remaining length of RG-58 on hand, should approximate the total length of RG-58 purchased. While this type of check may not succeed in identifying every RG-58 application, it may disclose gross errors in identification of RG-58 applications.

11. The Applicants also fail to address whether any RG-58 was purchased under purchase orders other than 9763-006-113-19.

Furthermore, the cable designation TA6Y designates any cable that is coaxial, single conductor, color coded black with red tracer, and having an undefined conductor size. FSAR, Table 3, page 6-2. (This portion of the FSAR was filed as Attachment 1 to "NRC Staff Response to NECNP Supplemental Memorandum on Environmental Qualification of RG-58 Coaxial Cable," dated April 8, 1988.)

12. In sum, Applicants have failed to establish that they have identified all applications of RG-58 coaxial cable in Seabrook Station.

13. Applicants claim that the "CASP" system "provides the controls to identify and maintain cable routes and termination locations for each uniquely identified plant cable." Heroeren Aaffidavit, paragraph 5. I disagree. The CASP system may have been intended to accomplish those tasks, but the actual location i

and routing of each cable depends on how accurately the construc-tion work force followed the cable installation instructions pro-t

                                       -5  -

vided by CASP.

14. One method of verifying the actual location of a par-ticular cable is to attach a signal generator to the cable and then physically trace the cable length with a signal detector.

Instead, Applicants have apparently simply assumed that the CASP

data base reflects the configuration of the as-built plant. Tracing the route of each cable using "Seabrook Ste. tion Cable raceway drawinas" (Beraeron Affidavit, paragraph 7 (emphasis added)) is not equivalent to physically tracing the actual rout-ing of each cable. Nor is it clear whether the review "to determine if the other cables routed along with the RG-58 cable (s) were Class 1E (i.e., safety-related) or Non-Class lE (i.e., nonsafety-related)" was conducted by reviewing installa-tion instructions or by actual insoection of cables routed with i RG-58 cables.

15. In sum, the Applicants appear to have made no attempt to verify the actual location of the RG-58 cables or the designa-tion (as Class 1E or Non-Class 1E) of other cables routed with RG-58 cables by physical inspection. Instead, reliance is placed on drawings or the CASP data base with no assurance that such information accurately reflects the as-built plant.

16. Applicants claim that all 126 identified applications of RG-58 cables are nonsafety-related. Berceron Affidavit, para-graph 6. This is a new claim but Applicants present no informa-tion that permits an evaluation of that claim. Without this l

                                  -6  -

information, I am unable to express an opinion as to whether Applicants have correctly classified the cable applications as nonsafety-related.

17. Applicants also fail to provide any meaningful informa-tion that would allow me to evaluate the safety classification of the 12 RG-58 cables that they intend to replace with RG-59 cable.

The general description of the cable applications given in Mr. Kotkowski's affidavit at paragraph 3 lacks sufficient specificity with respect to the identity of the equipment served or its loca-tion in the plant.

18. Applicants also fail to describe what environmental qualification specifications are prescribed for RG-58 cable, and thus must be met by the RG-59 cable that is to be substituted for it. As discussed in my affidavit, filed in support of "NECNP's Motion to Reopen the Record and Admit New Contention," dated Feb-ruary 2, 1988, the RG-59 cable fell below the required insulation resistance of 10,000 Megohms during the environmental qualifica-tion test to which it was subjected by the manufacturer.

19. Applicants have claimed elsewhere that the 10,000 Megohm Insulation Resistance requirement was a purchasing speci-fication rather than an environmental qualification requirement for the RG-59 cable. "Applicants' Opposition to Motion of NECNP to Reopen the Record and Admit Late-filed Contention," dated Feb-ruary 12, 1988, Berceron Affidavit at 2.

20. This explanation is unsatisfactory for two reasons.

                                  -7  -

First, Applicants have never provided any documentation of the actual environmental qualification specifications for RG-59 cable, other than to offer their own unsupported judgment as to the "reasonable" specifications for the cable. Id., Berceron Affidavit at 4.

21. Second, Applicants have provided no information to show that the environmental qualification performance of RG-59 coaxial cable is sufficient for the applications of RG-58 cable for which RG-59 will be substituted.

l.

                                         /           1         .
                                                                          /

Robert D. Pollard Subscribed and sworn to before me on this 8th day of June, 1988. m .

  %     ~    \    , . -}c u Notary Publid i My commission expires:

G_ ic' - R Q }- l l l 1 l l l

SEABROOK SERVICE LIST ~ ONSITE LICENSING BOARD

     'Shcidon J. Wolfe, Chairman  155 Washington Road         Office of General Counsel U.S. NRC                      Rye, New Hampshire OM70     U.S. N RC Washington, D.C. 20555                                    Washington, D.C. 20555 Richard E. Sullivan, Mayor

By hand

    'Dr. Jerry Harbour           City Hall                    R. Scott Hill Whilton U S. NRC                     Newburyport, MA 01950        Lagoulis. C!ard, Hill-Whilton  " By Overnight M.nl Washington D.C. 20555                                     & McGuire Alfred V. Sargent, Chairman  79 State Street
    *Dr. Emmeth A. Luebke        Board of Scicctmen           Newburyport, MA 01950 550) Friendship Blvd.         Town of Salisbury, MA 01950

, Apartment 1923N George Dana Bisbee, Esq. Chevy Chase, MD 20815 Senator Gord3n J. Humphrey Geoffrey M. Huntington, Esq. U.S. Senate Offk c 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. N RC 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 Doard Panel Exeter, NH 03833 U.S. NRC Senator Gordon J. Humphrey Washington, D.C. 20555 1 Eagle Square, Stc 507 Richard A. Hampe, Esq. Concord, NH 03301 Hampe and McNicholas Docketing and Service 35 Pleasant Strc:t U.S. NRC Michael Santosuosso, Concord, NH 03301 Washington, D.C. 20555 Chairman Board of Selectmen Gary W. Holmes, Esq. Mrs. Anne E. Goodman Jewell Street, RFD # 1 Holmes & Ellis Board of Sclectmen South Hampton, NH 03842 47 Winnacunnent Road 1315 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. Pcvear Jane Doughty Drinkwater Road Calvin A. Canney SAPL Hampton, Falls, NH 03844 City Manager 5 Market Street City Hall Portsmouth, NH 03801 Phillip Ahrens, Esq. 126 Daniel Street Assistant Aitorney General Portsmouth, NH Owll Carol S. Sncider, Esquire State House, Station # ri Auistant Attorncy General Augusta, ME 043U Matthew T. Brock, Esq. 1 Ashburton Place,19th Floor Shaines & McEachern BoMon, MA 02108 "Thomas G. Dignan. Esq. P.O. Box VO R.K. Gad 11. Esq. Maplewood Ave. Stanicy W. Knowics Ropes A Gray Portsmouth. NH HV01 Board of Selectmen 225 Franklin 5treet P.O. 80: 710 Boston, M A 02110 Sandra Gavutis North Hampton, NH 03N26 R FD I Bot 1154 RoNrt A. Backus Esq East Kenungton, NH uu27 1 JP NadCJu BJCkus, Meycr & Solomon Town of R,vc ill Luwsll Street ( harlo P Graham. Esq Manchester. NH 01104 MsKas. Murphy and (iraham im M.un sir (si

                                 '(ir4Rory A Ostrs.1 q          \ m o burv. M \ 0l'811

r-UNITED STATES OF AMERICA UNITED STATES NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

In the Matter of )

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

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

AFFIDAVIT OF RICHARD BERGERON I, RICHARD BERGERON, being on oath, depose and say as follows:

1. I am the Instrumentation and Controls Engineering Supervisor for New Hampshire Yankee. A statement of my professional qualifications is attached and marked "A".

2. In my affidavits dated May 19, 1988 and May 26, 1988 (hereinafter referred to as "May 19 affidavit" and "May 26 affidavit"), I described the means used to identify and locate all Seabrook Station RG-58 coaxial cable supplied by ITT Surprenant under Specification 9763-006-113-19.

This affidavit provides further explanation of that process.

3. The statement that 126 nonsafety-related RG-58 coaxial cables were identified (May 19 affidavit at i 6) was based on the materials listed in Attachment B. The identification of the five common groupings of the 126 RG-58 coaxial cables (May 19 affidavit at 1 9; May 26 affidavit at 1 3) was based on the materials listed in Attachment C. The source materials identified in Attachments B and C are voluminous. To assist in the y

understanding of the information provided in this affidavit, the May 19 affidavit and the May 26 affidavit, the pertinent information has been e.stracted f rom these documents and summarized and provided in Attachments D and E.

4. The 126 nonsafety-related ITT Surprenant RC-58 coaxial cable runs were determined by means of a specific sort of the CASP database for Cable Code TA6Y and a review of Seabrook Station electrical schematic drawing packages also for any Cable Code TA6Y applications.

5. The CASP database is an appropriate means to identify ITT Surprenant RG-58 coaxial cable applications for three reasons. Fi rs t , CASP is the primary design document for configuration control for electrical cable at Seabrook Station. Second, CASP has the capability to identify ITT Surprenant RC-58 coaxial cable applications by means of sorting on the Cable Code TA6Y because the RG-58 coaxial cable which was supplied by ITT Surprenant only uses the Design Guide Cable Code TA6Y. Therefore, a sort of the CASP database on the Cable Code TA6Y will identif y ITT Surprenant RG-58 coaxial cable applications. Third, one capability of CASP used at Seabrook Station is to determine the shortest route and length of a cable, given the network of raceways, the origin and destination of cable and taking into consideration applicable design requirements. This information is then used to install, inspect and maintain the cable. Accordingly, CASP is subjected to the comprehensive design verification and updating process used for any installation document subject to :he requirements of 10 CFR 50, Appendix B. This necessarily provides the additional assurances that CASP agrees with the as-built condition of the plant.

1

6. The Seabrook Station electrical schematic drawing package review is also appropriate to identify ITT Surprenant RG-58 coaxial cable runs because these are cesign basis documents whose input is not derived from CASP and beer.use one can determine the cable applications for a given cable circuit from thcse documents. These documents have also been subjected to the comprehensive design verification and up-dating process one used for design basis document under 10 CFR 50, Appendix 3. Thus, these documents can be relied upon to identify what cable was used in what applications.

7. At Seabrook Station the electrical schematic drawings are con-tained in electrical schematic drawing packages. These packages, in addition to the schematic drawings contain other information such as cable block diagrams.

Thus, a review of the schematic drawings in conjunction with other information contained in that drawing package allows one to identify the cable application (e.g., ITT Surprenant RG-58 coaxial cable) for a specific cable circuit. 8. Therefore, all ITT Surprenant RG-58 coaxial cable applications at Seabrook Station can be determined by review of CASP and the Seabrook Station electrical schematic drawing packages since both are design basis documents which, under 10 CFR 50, Appendix B, are subject to quality assurance program requirements governing theie issuance and updating. It should also be noted that the results of the reviews using either method was consistent. 9. Following the identification of a specific ITT Surprenant RG-58 coaxial cable (i.e., specific cable identification number) the route of each cable was traced by using approximately 36 Seabrook Station cable raceway drawings. In the case of the independent reviev 3

discussed in the May 19 affidavit at 1 16, the routes were specifically highlighted on a set of these drawings.

10. In conjunction with tracing the route of an identified RG-58 cable, a review was performed to identify the cable (s) routed with the RC-58 cable (s). This was done by means of using CASP to identify other cables sharing the raceway with the RG-58 cable (s). CASP was also used to determine whether the other cable was safety-related (i.e., Class IE) or nonsafety-related (i.e., Non-Class 1E).

11. After identifying a specific RG-58 coaxial cable route, the

 . environmental zones through which each cable traveled was determined using approximately 45 Environment Zone Maps centained in the Service Environment Chart Design Basis Calculation.            The Service Environment Charts were used to identify the applicable environmental parameters f or each environmental zone. See FS AR Figure 3.11(B)-1, Shts 1-5, provided in Attachment G and Excerpt from Environmental Qualification Report provided in Attachment I.       In the case of the independent review assessment discussed in the May 19 affidavit at 1 16 the harsh environment zones were superimposed upon the raceway drawings used in that review.

12. A review of applicable drawings and documents and reisted docu-mentation was performed. This verified that the drawings and documen*s used in the evaluation reflected the as-built configuration.

- 13. Following the review of environmental zones described above (Ref. 1 11) each RG-58 coaxial cable application was then categorized into five common groupings as summarized in Attachment D. The tabulation provided in Attachment D ider. ites each RG-58 coaxial cable, indicates which category it f alls under (e.g. , spare, harsh, etc.) and specifies its function, classification and the environmental zone (s) for each

cable. In addition, the tabulation refers to a figure which is provided in Attachment E. l

14. The figure provided in Attachment E depicts the routing a given l

i cable follows through the various environmental zones at Seabrook Station and identifies the utiding and specific environmental zone the cable passes through. It also indicates whether the cables are inside or outside the nuclear island, and for those cables within the nuclear island whether the zone is harsh or mild. The process used to develop the information to produce the figures is discussed above at 1 9 and 11.

15. From the tabulation provided in Attachment D, it is apparent that the 126 nonsafety-related ITT Surprenant RC-58 coaxial cables can be categorized as provided in the May 26 affidavit at 13.

16. The RG-58 coaxial cable supplied by ITT Surprenant was specified and purchased with a black with red trace jacket color. See EQF excerpts provided as Attachment F. As discussed in FS AR Section 8.3.1.3, cables which are colored black with a red Acer signify that the cables are Train A associated. As discussed in FS AR Section 8.3.1.4, cables which are identified by a black with a red tracer color jacket are nonsafety-related cables. Further, FSAR Sc; tion 8.3.1.4.a also indicates that associated cables are Non-Class IE circuits. Finally, FS AR Section 8.3.1.4.k when read in conjur.ction with FSAR Section 8.3.1.3 indicates that cables with the single solid color of red, white, blue or yellow signify cables which are safety-related or Class 1E. See Attachment G for excerpts f rom above ref erenced FS AR sections. There fore , it is clear from the FSAR that the RG-58 coaxial cable supplied by IIT Surprenant cannot and does not perform an accident mitigating function (i.e., it is nonsafety-related).

17. To clarify the usage of the EQF operability code and actual plant applications: As testified to previously (Transcript excerpts provided as Attachment H), a conservative assumption was made during the initial phase of the Environmental Qualification Program, namely that a given piece of equipment, cable, etc. was required to perform a safety function. Accordingly, the ITT Surprenant RG-58 coaxial cable was specified, purchased, environmentally qualified and installed (within the nuclear island) to safety-related requirements. However, it is possible that the EQ Tile could indicate that the cable is Operability Code A which designates that it is required to perform a safety function, but in actuality the cable is only required to be evaluated to determine if any failures of the cable due to the environment will af fect the accomplishment of a safety function. This is the esse for the RG-58 coaxial cable supplied by ITT Surprenant in that it does not perform any accident nitigating function. 18. To determine if a given component, cable, etc., is required to be environmentally qualified pursuant to 10 CFR 50.49 one must first determine if the item is within the scope of concern as discussed in 10 CFR 50.49(b) and then determine if the item is not in a mild environment (10 CFR 50.49(c)]. Zf the item is not within the scope of concern as discussed in 10 CFR 50.49(b) then the inquiry into the applicability of 10 CFR 50.49 ends. If the item is within the scope of concern but is in a mild environment then the inquiry into the applicability of 10 CFR 50.49 also ends. In either case 10 CFR 50.49 qualification requirements would not apply. 19. As indicated above none of the 126 RG-58 coaxial cables are safety-related; therefore, none are within the scope of 10 CFR 50.49(b)(1). 20. Since the RG-58 coaxial cable is nonsafety-related, one then needs to evaluate the applicability of 10 CFR 50.49(b)(2) to a given RG-58 coaxial cable application. As described in FSAR Section 8.3.1.3, Train A associated cables, such ai 2TT Surprenant RG-58 coaxial cable. can be routed with Train A safety-relsted cables within the nuclear island. Therefore, all Train A associated cables within the nuclear island are within the scope of concern of 10 CFR 50.49(b)(2). However, as provided above, those cables located in mild environments need not comply with the qualification requirements set forth in 10 CFR 50.49 per 10 CFR 50.49(c). (See also May 19 affidavit at 1 12). 21. For those applications outside the nuclear island none were identifiad where a safety-related cable was being rcuted along with the RG-58 :oaxial cable outside the nuclear island. Thus, the postulated f ailure of an ITT Surprenant RG-58 coaxial cable cannot prevent satisf actory accomplishment of safety functions by safety-related equipment since none of the cables it comes in contact with outside the nuclear island are safety-related (i.e., the failure could enly affect another nonsafety-related cable). Therefore, the RG-58 coaxial cable outside the nuclear island is not "important to safety", the qualification requirements of 10 CFR 50.49 are not applicable and further inquiry is not required. 22. The 12 RG-58 coaxial cables routed within the nuclear island are important ,to safety because their f ailure under postulated environmental conditions could potentially impair the ability of safety-related equipment to perform its safety function satisfactorily. These 12 RG-58 coaxial cables are in the process of being replaced with already qualified RC-59 cable. _7

23. As regards to the acceptability of RG-59 coaxial cable for use as a replacement for the RG-58 coaxial cables located in a harsh ennronment, it should be understood that for purposes of environmental qualification, the RG-59 cable's signal transmission characteristics versus those of the RG-58 cable are immaterial because all applications are nonsafety-related.

Rather, the concern is with the cable's ability to withstand the stresses imposed by accident environments and not fail so as to prevent the satisf actory accomplishment of a safety f unction.

24. The EQF for ITT Surprenant RG-59 coaxial cable (File No. 113-19-01),

the Equipment Lis t, the Summary Evaluation, the QEW, clearly indicate that the RG-59 coaxial cable is qualified for use in all building environmental zones and for all event codes. See Attachment F for EQF excerpts. Accordingly, since there is no environmental qualification related restrictions regarding the usage of RG-59 coaxial cable at Seabrook Station, the cable is qualified for any of the building environmental zones in which the ITT Surprenant cable may be located. s ms Rttihard Bergeron' f STATE OF NEW HAMPSHIRE Rockingham, ss. June lie , 1988 The above-subscribed Richard Bergeron appeared before me and made oath that he had read the foregoing af fidavit and that the statements set forth therein are true to the best of his knowledge. Before me, b u w d a C-. b k w 11 Beverly E Jilloway, Notary Pyblic My Commission Expires: Mar W 6, 1990

              . ~
                                   "A" RICHARD SERGERON Instrumentation & Controls Engineering Supervisor Education BS Marine Engineering, Maine Maritime Academy, May 1969 Mr. Bergeron joined Public Service Company of New Hampshire in May 1982 as Senior I&C Engineer in the Engineering Services Department.       His areas of responsiblity include coordination of I&C Engineering activities for the Station Staff, construction and Startup interf ace activities, as well as, various special projects.       Mr. Bergeron was recently appointed to the position of Instrumentation &

Control Supervisor in the Engineering Department. For the past six years Mr. Eergeron has also been assigned as the Station Staff Representative on the Equipment Qualification Task Force. He has been responsible for the coordination and review of the Equipment Qualification Program, as well as, I coordinating the implementation of the Station Equipment Qualification Program. Mr. Bergeron came to Public Service Company of New Hampshire from Stone & Webster Engineering Corporation where he was employed from 1972-1982. He held the position of Principle Instru=ent Application Engineer responsible, for

specifying, purchasing and design review of electron and pneuestic instrumentation control systems. Mr. Bergeren is also experienced in che scheduling and preparation of L:gt: Diagrsms and System Cescriptiens which define the functional centrol concepts. He was also assigned as a task member to assist in the development and preparatien of the 79-01B equipment qualification submittal for Duquesne Light Ceepany. Between 1969 and 1972 was e= ployed by Gulf oil Corporation as an engineer in their Marine Engineering Division. There he was responsible for the operation and maintenance of Marine power plants. _ - ~ - - - - , _ _ , _ _ , , _ _ ,

ATTACHMENT B SOURCE MATERIALS USED TO IDENTIFY ITT SURPRENANT RC-58 COAXIAL CABLE APPLICATIONS 1. CAS' Data Base; Speciality Sort for TA6Y Cable Codes 2. Seabrook Station Electrical Schematic Drawing Packages (164 packages of approximately 12,000 pages). DRAWING ID NUMBERS 300933 301913 310106 310872 310952 300934 301914 310107 310874 310953 300935 301915 310108 310875 310955 300936 301916 310177 310882 310956 300937 301917 310178 310887 310957 301010 309702 310179 310890 310958 301012 3v9703 310180 310891 310961 301015 309709 310181 310894 310962 301016 309709A 310182 310895 310963 301017 309709B 310841 310897 310965 301107 309711 310842 310898 310966 301115 309711A 310843 310899 311864 301211 309712 310844 310900 311865 301212 309712A 310845 310901 311866 301213 309713 310846 310902 311867 301214 309713A 310847 310903 311868 301215 309714 310848 310919 311869 301216 309714A 310849 31C's 20 311870 301221 309716 310850 310921 312020 301506 309716A 310851 310922 312021 301508 309716B 310852 310924 312062 301619 309718 310853 310926 312066 301900 309718A 310854 310927 312067 301901 309720 310855 310928 370008 301902 309720A 310857 310929 301903 309721 310862 310930 301904 309741 310863 310931 301905 309742 310864 310932 301906 309871 310865 310940 301907 309876 310866 310942 301908 310101 310867 310943 301909 310102 310868 310944 301910 310103 310869 310947 301911 310104 310870 310949 301912 310105 310871 310951

ATTACRMENT C SOURCE MATERI ALS USED FOR CATEGORIZATION OF RG-58 COAXIAL CABLE APPLICATIONS

1. CASP Data Base (approximately 3,500 page hard copy equivalent).

2. CASP Data Base; ?peciality Sort for TA6Y Cable Codes

3. Seabrook Station Ca.ble Raceway Drawings:

Drawing Numbers 301286 - 301293; 309850; 310298; 310335; 310366 - 310371; 310450; 310476; 310478; 310479; 310496 - 310501; 310688; 310796 - 310803.

4. Service Environment Design Basis Calculation, Calculation Set No. 6.01.00.00 (approximately 61 pages), dated February 2,1987.

5. Service Environment Charts; FSAR Figures 3.11(B)-1, Shts. 1-5.

6. PSNH Letter (SBN-886) dated October 31, 1985, "Environmental Qualification of Electrical Equipment; SER Outstanding Issue #6,"

J. DeVincentis to G. W. Knighton (Note letter and enclosure distributed to ASLB Service List including NECNP). i l a

ATTACRMENT D ITT SURPRENANT RG-58 COAXIAL CABLE APPLICATIONS CATEGORY QUANTITY LISTING Spare RG-58 Coaxial Cable 19 Sheet 1 RG-58 cables routed at least partially through a 12 Sheet 2 harsh environment within the nuclear island RG-58 Cables located in mild environment within 76 Sheets 3 the nuclear island thru 8 RC-58 Cables routed only with other nonsafety- 10 sheet 9 related cables outside the nuclear island l RG-58 Cables routed in mild environments within 9 Sheet 10 the nuclear island and routed only with nonsafety-related cables outside the nuclear island Total no. of cables 126

Shut'~1 cf 11

                                                                                                  ~~
                                                                  ,                                  l NO. CABLE NO.                 ENVIRONMENTAL ZONES       CATECORY FICURE FUNCTION  CLASSIFICATION

1. FM4-JXt/2 CB2, CB4, ET2A, ET4A, ET3A, ET3B Spare Al 8 -

Nonsafety-related

2. FM7-JX1/2 CB2, CB4, ET2A, ET4A, ET3A, ET3B Spare Al * -

Nonsafety-related

3. FM3-JW5/2 CB2, CB4, CBIO, ETI, PB25, PBil, PB12 Spare A3 * -

Nonsafety-related

4. FM6-JW5/2 CB2, CB4, CBIO, ETI, PB25, PBil, PB12 Spare A3 * -

Nonsafety-related

5. FM6-J X5/ 2 CB2, CB4, ET2A, ET4A, ET3A Spare B * -

Nonsafety-related

6. FM4-JX5/2 CB2, CB4, ET2A, ET4A, ET3A Spare B * -

Nonsafety-related

7. FM7-CY4/2 CB2, CB4, CB6A Spare B * -

Nonsafety-related

8. FM4-CY4/2 CB2, CB4, CB6A Spare B * -

Nonsafety-related

9. FE7-FMb/2 CBI, CB2 Spare B * -

Nonsafety-related

10. FM6-CY6/2 CB2, CB4, CB6A Spare B * -

Nonsafety-related

11. FM4-CY6/2 CB2, CB4, CB6A Spare B * -

Nonsafety-related

12. FM3-FPl/2 CB2 Spare B * -

Nonsafety-related Spare B * - Nonsafety-related

13. FM7-FPl/2 CB2 CB1, CB2 Spare B * -

Nonsafety-related

14. FE7-FM4/2 CB2, CBSA, CB4, TB Spare C * - Nonsafety-related

15. FM3-CYO/2 Spare C * - Nonsafety-related

16. FM7-CYO/2 CB2, CBSA, CB4, TB Spare C * - Nonsafety-related

17. F86-Cl3 CB1, CB4, TB Spare C * - Nonsafety-related

18. FH3-GY9/2 CB2. CBSA, CB4, TB Space C * - Nonsafety-related

19. FM6-CY9/2 CB2, CBSA, CB4, TB

See Note I

She t 2 cf !! NO. CABLE NO. ENVIRONMENTAL ZONES CATECORY FICURE FUNCTION CLASSIFICATION

1. FM4-JXI CB2, CB4, ET2A, FT4A, ET3A, ET3B Harsh Al Station Computer Nonsafety-related Applications

2. FM7-JXI CB2, CB4, ET2A, ET4A, ET3A, ET3B Ha rsh Al Station Computer Nonsafety-related Applications

3. FM4-JX1/1 CB2, CB4 ET2A, ET4A, ET3A, ET3B Harsh Al Station Computer. Nonsafety-related

                                                                              . Applications

4. FM7-J X1/1 CB2, CB4, ET2A, ET4A, ET3A, ET3B Harsh Al Station Computer Nonsafety-related Applications

5. CU4-Y59/2 PB12, PBil, PBl4, PB14A, PB13, PB15C, PB15A Harsh A2 Degasifier Level Nonsafety-related Control

6. GU4-Y59/4 PB12, PBil, PB14, PB14A, PB13, PB15C, PB15A Harsh A2 Degasifier Level Nonsafety-related Control

7. CU4-Y59/3 PB12, PBil, PBl4, PBl4A, PBl3, PB15C, PB15A Harsh A2 Degasifier Level Nonsafety-related Control

8. CU4-YS9/5 Pal 2, PBil, PBl4, PB14A, PB13, PB15C, PBISA Harsh A2 Degasifier Level Nonsafety-related Control

9. FM3-JW5 CB2, CB4, CB10, ET1, PB25, PBil, PB12 Ha rsh A3 Station Computer Nonsafety-related Applications

10. FM3-JW5/1 CB2, CB4, CBIO, ETI, PB25, PBil, PR12 Harsh A3 Station Computer Nonsafety-related Applications

11. FM6-JW5/1 CB2, CB4, CBIO, ETI, PB25, PBil, PB12 Harsh A3 Station Computer Nonsafety-related Applications

12. FH6-JW5 Cd2, CB4, CB10. ET1, PB25, PBil, PB12 Ha rsh A3 Station Cowpater Nonsafety-related Applications l

She t 3 cf'll NO. CABl.E NO. ENVIRONMENTAL. ZONES CATEGORY FIGURE FUNCTION CLASSIFICATION

1. F:14-JX5 CB2, CB4, ET2A, ET4A, ET3A Mild B Station Computer Nonsafety-related Applications

2. FM6-JX5/1 CB2, CB4, ET2A, ET4A, ET3A Mild B Station Computer Nonsafety-related Applications

3. FM6-JX5 CB2, CB4, ET2A, ET4A, ET3A Mild B Station Computer Nonsafety-re: lated Applications

4. FM4-JX5/1 CB2, CB4, ET2A, ET4A, ET3A Mild B Station Computer Nonsafety-related Applications

5. FE2-FM4/1 CBI, CB2 , Hild B Station Computer Nonsafety-related Applications

o. F52-FNi/3 CBI, CB4, CB2 Mild B Station Computer Nonsafety-related Applications

7. F52-FN5/3 CB1, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

8. F72-FN5/2 CB1, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

9. FH6-CY6/1 CB2, CB4, CB6A Mild B Station Computer Nonsafety-related Applications

10. FE2-Fit 4/2 CB1, CB2 Mild B Station Computer Nonsafety-related Applications CB1, CB4, CB2 Mild B Station Computer Nonsafety-related

11. F52-F:11/4 Applications C81, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related

12. F52-FH5/4 Applications CB2, CB4, CB6A Mild B Station Computer Nonsafety-related

13. FM6-GY6 Applications Mild B Station Computer Nonsafety-related

14. FS2-FN1/5 CBl, CB4, CB2 Applications

                                                                                                                                                                          .a
                   ;40.                     CABLE NO.                 ENVIRONMENTAL ZONES   CATECORY rICURE      FUNCTION                                CLASSIFICATION

15. F52-FN5/5 CB1, CB4, CBSA, CB2 Mild B Station Computer No usfety-relcted Applications

16. FMO-F15 CB2, CBI Mild B Station Computer Nonsafety-related Applications

17. FM4-CY6/1 CB2, CB4, CB6A Mild B Station Computer Nonsafety-related ,

Applications

18. FMO-FT5/l CB2, CBI Mild B Station Computer Nonsafery-related )

Applications

19. F52-FNt/6 CB1, CB4, CB2 Mild B Station Computer Nonsafety-related Applications

20. W411-W4J CBIF, CBID Mild B Station Computer Nonsa f e t y-re lat ed Applications

21. F52-FN5/6 CB1, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications F52-FN1/7 CB1, CB4, CB2 Mild B Station Computer Nonsafety-related 22.

Applications

23. F52-FN5/7 CB1, CB4, CBSA, CB2 Mild B Statica Computer Nonsafety-related Applications CB2, CBSA, CBlF Mild B Station Computer Nonsafety-related

24. FN4-W411/ 3 Applications CB1, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related

25. F81-FN4 Applications Mild B Station computer Nonsafety-related

26. FM3-FPI CB2 Applications Mild B Station Computer. Nonsafety-related

27. FN4-W4ti/2 CB2, CBSA, CBIF Applications Mild B Station Computer Nonsafety-related

23. FH7-FPI CB2 Applications

She:t 5 c.f 11 NO. CABLE NO. ENVIRONMENTAL ZONES CATECORY FICURE FUNCTION CLASSIFICATION

29. FM3-FPl/l CB2 Mild B Station Computer Nonsafety related-Applications 30 FM7-FPl/l CB2 Mild B Station Computer Nonsafety-related Applications

31. F90-FN4/2 CB1, CB4, CB5A, CB2 Mild B Station Computer Nonsafety-related Applications

32. F10-FM0 CB1, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

33. F90-FN4/1 CB1, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

34. FS2-FHS CBl CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

35. F72-FNS CBI, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

36. F52-FN1 CBl. CB4, CB2 Mild B Station Computer Nonsafety-related Applications

37. F31-FN! CBl, CB4, CBSA, CB2 Mild 8 Station Computer Nonsafety-related Applications F31-FN5 CBI, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related 38.

Applications CB1, CB2 Mild B Station Computer Nonsafety-related

39. FE7-FM6 Applications CB2, CB4, CB6A Mild B Station Computer Nonsafety-related

40. FM4-GY4 Applications Mild B Station Computer Nonsafety-related

41. FE2-FM6 CBI, CB2 Applications Mild B Station Computer Nonsafety-related

42. IM7-CY4 CB2, CB4, CB6A Applications

NO. CABLE NO. ENVikONMENTAL ZONES CATECORY FIGURE FUNCTION CLASSIFICATION

43. FE7-FMb/l CBI, CB2 Mild B Stetton Computer Non2Efety-related Applications

44. FC2-FM6/1 CBI, CB2 Mild B Station Computer Nonsafety-related Applications

45. F61-FNl/l CBI, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

46. FM7-CY4/1 CB2, CB4, CB6A Mild B Station Computer Nonsafety-related Applications

47. F61-FN1/3 CB1, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

48. FE2-FM6/2 CB1, CB2 Mild B Station Computer Nonsafety-related Applications

49. F61-FN1/2 CBI, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

50. F40-FN5/1 CBl. CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

51. FN4-W4H CB2, CBSA, CBlF Mild B Station Computer Nonsafety-related Applications

52. F40-FN5/2 CBI, CB4, CB5A, CB2 Mild B Station Computer Nonsafety-related Applications CB2, CB4, CB6A Mild B Station Computer" Nonsafety-related

53. FM4-CY4/1 Applications CB2, CBSA, CBIF Mild B Station Computer Nonsafety-related

54. FH4-W4H/l Applications CB2, CBI Mi l< i B Station Computer Nonsafety-related

55. FMO-FTS/2 Applications Mild B Station Computer Nonsafety-related

56. W411-W4J/2 CBIF, CBID Applications

Sheet 7 (f 11 NO. CABLE NO. ENVIRONMENTAL ZONES CATECORY FIGURE FUNCTION CLASSIFICATION

57. FMO-FT5/3 CB2, CBI Mild B Station Computer Nonsafety-related Applications

58. W4H-W4J/1 CBfF, CBID Mild B Station Computer Nonsafety-related Applications

59. F90-FN4 CBl. CB4, CB5A, CB2 Mild B Station Computer Nonsafety-related Applications

60. W4H-W4J/3 CBIF, CBID Mild B Station Computer Nonsafety-related Applio.. Lions

61. F10-FM0/1 CBl. CB4, CB5A, CB2 Mild B Station Computer honsafety-related Applications

62. F40-FNS CB1, CB4, CB5A, CB2 Mild 5 Station Computer Nonsafety-related Applications

63. FIO-FM0/2 CB1, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications 64 F52-FNt/l CB1, CR4, CB2 Mild B Station Computer Nonsafety-related Applications

65. F52-FN5/1 CB1, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

66. F31-FN1/1 CB1, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

67. F61-FNI Cdl, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

68. FM4-CY6 C32, CB4, CB6A Mild B Station Computer Nonsafety-related Appiications CBI, CB4, CB5A, CB2 Mild E Station Computer Nonsafety-related

69. Flu-FM0/3 Applications CB1, CB2 Mild B Station Computer Nonsafety-related

 /U. FE7-FM4 Applications i

Sheit 8 cf 11 NO. CABLE NO. ENVIRONMENTAL ZONES CATECORY FIGURE FUNCTION CLASSIFICATION

71. F52-FNI/2 CBI, CB4, CB2 Mild B Station Computer Nonsafety-related Applications

72. F52-Fr!5/2 CBl CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications

73. FE2-FM4 CBl. CB2 Mild B Station Computer Nonsafety-related Applications

74. F72-FN5/1 CB1, CB4, CB5A, CB2 Mild B Station Computer Nonsafety-related Applications

75. F31-FN!/2 CB1, CB4, CBSA, CB2 Mild B Station Computer Nonsafety-related Applications i

76. FE7-FM4/1 CBl. CB2 Mild B Station Computer Nonsafety-related Applications

N 1 NO. CABLE NO. ENVIRONMENTAL ZONES CATECORY FICURE FUNCTICU CLASSIFICATION I

1. C7S-F3J/1 WPB Note 2 D Waste Fred Nonscfety-related -{

TK-1988 Level l

                                                      ' Corit rol

2. C7S-R3G WPB Note 2 D Waste Feed Nonsafety-related TK-198A Level Control

3. C7S-R3J WPB Note 2 D Waste Feed Nonsafety-related TK-198B Level Control

4. C7S-R3L/1 WPB Note 2 D Waste Concentrate Nonsafety-related Bottons TK-200 Level Control

5. C67-ZM3/2 WPB Note 2 D Primary Drains Nonsafety-related Tank Degasifier TK-67 Level Control

6. C67-ZM3/3 WPB Hote 2 D Primary Drains Nonsafety-related Tank Degasifier TK-67 Level Control Note 2 D Primary Drains Nonsafety-related

7. C67-ZM3/4 WPB Tank Degasifier TK-67 Level Control Note 2 D Primary Drains Nonsafety-related

8. C67-ZM3/5 WPB Tank Degasifier j TK-67 Level Control Note 2 D Waste Feed Nonsafety-related

9. C7S-R3C/l WPB TK-198A Level Control Note 2 D Waste Conceatrate Nonsafety-related

10. C7S-F3L WPB Bottoms TK-200 Level Control i

NO. CABLE NO. ENVIRONMENTAL ZONES CATECORY FICURE FUNCTICJ CLASSIFICATION

1. FM3-CY9 CB2, CBSA, CB4, TB Note 3 C Staticn Computer Nonsafety-relotsd Applications

2. FM3-GY9/1 CB2, CBSA, CB4, TB Note 3 C Station Computer Nonsafety-related Applications

3. FM6-CY9/1 CB2, CB5A, CB4, TB Note 3 C Station Computer Nonsafety-related Applications

4. FM6-CY9 CB2, CB5A, CB4, TB Note 3 C Station Computer Nonsafety-related Applications

5. FM3-CYO CB2, CB5A, CB4, TB Note 3 C Station Computer Nonsafety-related Applications

6. FM 7--CYO CB2, CBSA, CB4, TB Note 3 C Station Computer Nonsafety-related

                                                                /.pplications

7. FM3-CYo/1 CB2, CBSA, CB4, TB Note 3 C Station Computer Nonsafety-related Applications

8. FM7-CYO/l CB2, CBSA, CB4, TB Note 3 C Station Computer Nonsafety-related Applications

9. F86-S3W CB1, CB4, TB Note 3 C Cenerator Hydro- Nonsa fet y-re lat ed gen Core Cooling Monitor

                                                                                                          'N i

NOTES:

1. Routing of spares through environmental zones is as shown in referenced figure, however, the cable is _not _

connected to any devices as the figure depicts.

2. RC-58 cables routed outside nuclear island only with other nonsafety-related cables.

3. RG-58 cables routed in mild environments within the nuclear island and routed only with nonsafety-related cables outside the nuclear island.

LECEND/ KEY Category Column Spare - Spare RC-58 Cables lia rsh - RC-58 Cables routed at least partially through a harsh environment within the nuclear island Mild - RC-58 Cables located in mild environments within the nuclear island Functions Column Station Computer - All Seabrook Station Plant Computer Applications, i.e., connections between main frame and computer peripheral connections between computer peripherals, etc. Environmental Zones TB - Turbine Building outside nuclear island WPB - Waste Processing Building outside nuclear island j

ATTACHMENT E ITT SURPRENANT RC-58 COAXIAL CABLE APPLICATIONS; ENVIRONMENTAL ZONE ROUTINGS CONTENTS Figure Al Figure A2 Figure A3 Figure P Figure C Figure D

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   ;                      CONTROL BLDG                                                                                                       .

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I ATTACMMENT F EQUIPMENT QUALIFICATION FILE NO. 113-19-01 EXCERPTS 3 CONTENTS Harsh Environment Equipment List L Equipment Suasary Evaluation (p. 1 of 1) [ i Qualification Evaluation Work Sheet, 11/05/86 I Appendix A, Spec. No. 9763-006-113-19, Pg. No. Al .. UE&C Purchase Order, EQF Ref. 7, pgJ. 1 & 2 of 4 s k I e

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Electrical Equipment Qualification File No. 113-19-01 Revision 2

     $                               EQUIPMENT SUMMARf EVALUATION 1.0 CeScriDtiO" ine equicment under evaluation is the Coaxial and Triaxial Instrument Cable manufactured by ITT Surpren. int Division.                        Tnis i

cable is located in all areas of the plant, both inside and outside containment, and will be evaluated for the worst case j postula ted environment conci tions ir. side con tainmen t. The traceability of tne test documentation to the cable supplied by ITT for UE&C reference 4 Spec.fication 9763-006-113-19 is provided in 2.0 Conclusion This equipment is qualified by sequential test for the postulated accident temperature, pressure, humidity, chemical spray and radiation dose and by test supplemented by analysis for the required operating time. This equipment has a cualified life of 40 years a t 167'F (75*C). i Therefore, this equipment is qualified to the requirements of NUREG-0588 Ca tegory I. I 3.0 Limitations None. 4.0 Discussion Two specimens are tested in Reference 2. These specimens are RG-11/U and RG-59/U coaxial. Reference 4 states that these two specimens are representative of the four different types of cables supplied to Seabrook as per Reference 1. The supplied cables are RG-11 triaxial, and RG-11, RG-53 and RG-59 coaxial, TheExane an insulation jacket.in these cables is cross-linked polyethylene with i The limiting Environmental Zones for , radiation are PB-15A, PB-4, PB-18 and PB-19. There is no l4 1 Class 1E Electrical Equipmnt is Zones PB-4 and PB-19 l (Reference 8). The qualified life of the cable in Zones PB-15A and PB-18 (Radiation TID 200 Mrads) is limited to 33.20 years. All margins suggested by IEEE 323-1974 have been meet. A vertical tray flame test nas been conducted in accordance with Section 2.5 of IEEE Standard 383-1974 (Reference 3, p. 2. Item 5). I 516Bm Pace 1 of 1

                                                                    ~~  ~~                                                                                                                                   _

oppany of New flanipshire QUAtIIICAil0N 4T100t JdORK SHEE T

        #                                                                                                                                                                                         4 g       ,           443                                                                                             ,

PriparrJ By: L// h ;/[

     .-                                                                                        [QUIPMEK1 QUALIFICATIOR FILE NO.             113-19-01 hg.j,gg f fquiparnt Destription                          1 Pzstuletrd 1nsIronnent Che(Led 8y:  _

h , [,*< { Parameter i Date: f # i Tc7rease Dider h. . Value_ Reference _ Qualifled InwIronnent I ! I Value Referente QualifIt a1 ion ~ Tstandiiig' 1 91h3-oute- I l 3- 19 ll Opera t ing I Method items 11 line i I I (quipment 10 h(s). Il 1 Year p. I 1 Year 3 , test and l E DI -C 81 - 6 I p. 2 1 i l 1 Analysis l None 5 i I __ l I l Pealt j_ I lempera ture 1 t 315 p. 1 2 . iI (Or) 390 p. 11 I Test Mone l Peak Equipe.ent lysw: I Pressure 11 i lits t s amen t t able 60 p. 1 i 7 ll (Psig) l 133 l P. 11 ll l i Iest Mone

                                                                             ;                                                                            l                         }

11 I l I Manufattunee: ll Relatswe l lli Supseiant I i l 11 Hamadity l 100 1 l l 7 j

p. I [ l Modei Number; 11 (1) 100 l p. 10 i Test I lil l None RG-Il freemaal RG-II. l RG-$8 & RG-59 Comanal Cnemical 8cric Acid 5 pray (pH) 1.21 by wt.

1 Boric Acid i 2 l p. I 1.7% by wt. Au uret y: Spe( : N/A pH4.5 to 10.5 p. 10 i Test il pH 10.5 6 Nonc Dee. n: N/A l l ~40 Tea r Norma l 1 Radiation Dose 2.0 m 108 p. 3 T~ (Rads) 1.66 m 108 2 Note 1 I Year Accident I (Note 1) l p. C-2 lest t sen t ing Invesonment : Radiation Dose --- None

p. 3 to(ation: Con t a a rt nevn t ,

                                                                                                                 '                                                           l (All Jones)         ll Aging          i         167/40 RfA lone: Primary Aua.                      l         ("F/ Years) 3                    16//40                                                                 ,

(1500) 3 Iest and 4 314). (P8-15A P8-18) l p. 2 (750C) l I 4

p. 2 Analysis ! None '

Note l (Note I) Lowest Elevation: Note 2 ,a I Ilood fewel: Note 2 Submergence N/A l l Aborr Flood icwel: Note 2l Note 8 N/A N/A N/A None l ' amneatatson Referentes: l Notes: U(&C Ds awing ( P- 33262- 02 No. 9763-F-300219 Revision 19. Service ferironmental Chart. 87/25/86 l FIRL Report No. F-A5550-8. Qualification Tests o( Electrical Cables 1 The limiting zones for rad ia t iori a re P8-lM ", and P8-18. lones P8-4 and P8-19 are c u luded 3 na a Simulated VU-304S4 $ team lit to Of10, t sne 8reak and loss-of-Coolant-Accident Environment.1/14/R3. 8/23/82. since no electrical equipment is installed l ut &C 5 pet i t it a t ion No. 9763-N)6-Il 3-19. *>e(. for Specialty Cable. 9/20/82. ir these areas. (Reference 7). The qualified 2 Impell t al( uta t ion No. 010-032-002 l Isie of the (able (irradiated to 1.t.6 Mrads) g Scabeook 1.Q. f ile No. Il3-19-01. Assessaent Checklist. Note 11. in these iones is limited to 33.20 years. I

      $80-97t.05. Of &t *s letter to Impell, datc<* 2/11/85.                                                                                            2. Subse9 enc e qua l i t s t a t ico i s not required SBU-96.'b1.            ul&( lettes. "Ilooding Study H.trin."                                                                                          (Reference 9).

lepril lettes No. OS70-O l?-NT-l'sb. da ttd .'/2/86 Susanary of Class 11 ( quipment Sutero ged as a kesult of Desigse 8as es E verats. e

APPEND 11 A i BILL OF MATERIAL SEABROOK STATION UIIITS I & 2 SPECIALTY CAELE (6) (7) (8) (9) (10) [ (1) (2) (3) (4) (5) t SHIELD 2URCHASE OVERALL C00m0CTOR MINIMUN TYPE TYPE ORDER QT!- CABLE [ JACERT SIZJ AWC 3RNtBER CABLE COI61**JCTOR CODE ! ITEM CARLE (STRAND) C00m0CTORS (COVERACE) FEET f (FUNCTION) CORAR COLOR NO. VOLTACE I f Braid 25,000 UAlf Triamial N/A Red #18 (7m) 1

l. 2500 vdc (901 Min.) '

(RC-II, - Braid 25,000 UA2T Triamial N/A White #18 (7x) 1

2. 2500 vde (901 Min.)

(RC-II, Braid 7,00') UA3T ! N/A Blue \' #18 (7x) 1

3. 2500 vde Triaxial (901 Min.)

(RC-II, 7,000 4;A4T . Yellow #18 (7x) 1 Braid

4. 25% voc Triamial N/A (901 Min.)

(RC-II, Braid 60,000 UA47 Triaxial N/A Black With #18 (7x) 1 !

5. 2500 voc Red Trace (901 Min.)

(RG-II, Braid 5,000 TA6T Coaxial N/A Black With #18 (7x) 1

      >             6. 2500 ydc Red Trace                                     (90Z Hin.)

(RC-II, Braid 60,000 TA6Y-- Coaxial N/A Black With 721 (19x) 1 ggg 7. 1000 vac Red Trace (901 Min.) l (RC-58, Braid 5,000 ?*tT i

    g g y                         Coaxial        N/A      Red            #24 (7x)                1 1000 vac                                                                         (95% Hin.)

4 . .x -[ 8. (RC-59, Braid 5,000 TA2Y f~ ? g p Coaxial N/A White #24 (7x) 1

9. 1000 vac (951 Min.)

N3 10 1000 vac (RC-59, Coaxial N/A Black With #24 (7x) 1 Braid (951 Min.) 5,000 TA6U l N, O (RG-59, Red Trace (, & 1' 8 g 4 .. p C b k. y 'N 4 A

W- G Il % -I * -C* 5f. 7 t, PURCHASE CROER I j rorn aas I 1.. ..... .....,...o. ac -_- L- - m a..it.~ed m~ engineers O i,'.,=;*,'.'..frt.'ritan. Sxa.m. l cart October 7,199: P. Q. NC. 9 76 3.006-113- *.

..u.i.; s e ,.ci. G W ANY OF SEW HAMPSB~AI et ai u . $ . u . . . . . . . .. . . . . , . . .

                                                                                                                                                          ...,.u........,......

c/o United Engineers (, Constructors Inc. Agents n ., ,, , i,,c , n . . :,,,, v e . ,, , c . Post Offica Box 700 Post offies Box 700 l Seabrook, New Ha=oshire 0387 pumCH ASER Saabrook. Nov Ma:eshire M8 au :s.ettee.es.ca ..o ::,. :. s...... J.8L,*, of a l ITT-Supranant Divisten u"*$s r"to t ciutes ao "ci ac s s'reu=ws'si a::.s r: it -'.,it.

          .co ao 13819                 172 Scarling Street                                                                                             ,o.nois:::            ..n....          i,i3,
          ,o o                         Clinton, Massachusetts 01510                                                                  SELLER             '"" 8 " casa. wa .ca. nee .iwi.

G.LMorris ssip v'A CONSIGN TO Puolic Servs.cs co=pany of New Ha=;s..:.: Motor Traight c/o United Engineers r, Constructors :: 8**D*k 8C'"i** 1" ten (10)/ Seabrook, New Hampshire 03874 TE"S not thirty (30) dava. e.'t o 9/21/82 . . . . . ..... . . .. ,.....,

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i summsei a o s. .Tob Site. SPECT.A1,TT CABI,E f Design, furnish, fabricate, test and deliver 1 Lot of Special Cable in accordance with the following documents: A. Specification No. 9763.006-113-19, dated Septenbar 20, ' 982 consisting . of Cover Page. Table of Contents, nisecoon (19) reproduced typewritten pages, Tigura 1, three (3) pages of Appendix A, and three (3) pagas of Appendix B, attached hereto and nada a part hereof. t

  ,            5. j Specification No. 9 763-QAS-3, Quality Assurance Adninistrative and i     System Requirements, For Safety Ralated Electrical Equipment, Revision 7, l dated April 11, 1979, consisting of Cover, Table of Contents, current Page
                   ' Listing, Identification of Changes, and thirty-nine (39) reproduced type-
                   ' writtan pages, already in your possession and nada a par hereof.

C. l Soecification No. 9763-EQ-1, Class II Equipment Qualification Require = ants , Revi.sion 7 dated Tabruary 19, 1976, consisting of Cover, Table of l Contants, can (10) reproduced typewritten pages and Data to be sub=itted i with Proposal, consisting of tvo (2) reproduced typewrittaa pages. l nu=bered D1 and D2, airsady in your possession and nada a part hereof. j

                    , PRIC*NG :                                                                                                                                                       !
                                                                                                                                                                                  . . S*.30,365.:
                                                                                                  "'OTAL T13M DE:.17DED ? RICE .                                 . . . .

I

                         !*IM Q UAS""'T                               D ES L"t!P*!ON                                       PRICE /M3""                    EI*INSION                   l

1. 25,000 ft. CAi! Triax RG-11 Rsd $310.00 $ 20,250.:0

2. 25,000 it. CA2T Triax Pf,-11 **hita $810.00 $ 20,250.00 I 3. 7,000 ft. CA3T Triax M-11 Blue S810.00 $ 5,670.00 j 4 7,000 ft. UA4; Tr14x M-11 Tel;ov $810.00 $ 5,670.00 :

) i 5. 60,000 ft. CA6T Triax M-11 Black / Rad $810.00

                                                                                                       ...e. ..an               .. - * " ' -       ..n-e.
                                                                                                                                                          $ 48,600.00 .IC:stinued I                   .. ...... .... .. ......... . ...
                                                                                                                                                                                     ..        )-

y --- - e PURCHASE CRDER I rom au - v . ..... . .... . .. ... ac-. . ;o m,it,_ed._

                                                                     ,                    engineers                                         a .~. ...~a.'        = c.".
                                                                                                                                                                         " ~
                                                                                                                                                                    ".3, "m". .~. u Art Oe:oder 7, 198:                                        P.* C. NO.9h[$06-il:

P';3:.:: Sav:ct C MPANY OF NDi HAMPSHIM et al . ". [2, . '.* l**..* '. . .*l *.l ". . '.'.* * " c/o Uni:ad Engineers & Construe: cts Inc. Agents umf ta t.ca.uss 6 cc stsuctees ..c AURCHASER Page 2 of 4 I; -Supranas: Division ws mt.::: u.ts o=ci.ct ..o a :: u: it

    ~                                                                                                                                     9 it0 t.ao      eu. &.cCC ciattes      tars        uwst.s c .

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SELLER " 8 " ".Asa m.c t a uce..t1911 , 4

    .t: et ssip vlA                                         CONSIGN To TERMS
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                                                                                                                                                                . . . . . . ....s ... .
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     "                   - =n.-3 I5 QUANT!*Y                                 DES CRI?*!0N                                     PRICI/MFT                   EXTENSION 6,     10.000 ft.                TA6T Coax                 RG-il Black / Rad $755.00                                 $ 7,550.00

7. 60,000 f t. TA6Y Coax RG-58 Black / Rad $250.00 $ 15,000.00

8. 5,000 ft. *A1Y Coax RG-59 Rad $225.00 $ 1,125.00

9. 5,000 ft. TA2T Coax RG-59 Whits $225.00 $ 1.125.00

10. 5,000 ft. TA6U Coax RG-59 Black / Rad $225.00 $ 1,125.00 i Premium Prica - 7endor to expedits deliverv ts October 8, 1982.

I' i DES CRI?* ION FRDCM j !!Ei QUAN"I"'T $ 4,000.00

5. 25,000 ft. CA6T Triax RG-ll Black / Rad Prices are firm for delivery through January 14, 1983.

i

                     *I3MS OF PAT TC:

L* :en (10)/ na: thir:7 (30) days. SPECIAI, CONDI*:0NS - Torn So. 9763-4224 Revised May 20, 1981 coisisting

of Cover Page, *able of Contents and eventy (20) reproduced typewri::en

                     ;agna is attached harste and sada a part hereof.                                                                                                      ,

O A'.*RA.YT!!:

                   , .s accordance with Article 9 of Special Conditicas Fors 9763-4224 for a
                   ! Period of one (1) year f rom data of conmaarcial opera:Lon.

k

                   . No (2) unpriced copias of outside Purchase Orders are to be sub 1::ed
                   , Oc tha attentics of Mr. D. E. McCaig, Manager - T.xpediting.

Monthly progress charts outlining engineering, purchasing, produe:1on ; and dalivery status vill be submitted starting Augus 23, 1962. 1

                                                                                                                                                                                 .    -J

ATTACHMENT G EXCERPTS FROM FSAR CONTENTS FSAR Pg. 8.3-39 8.3-40 8.3-40a 8.3-41 8.3-52 8.3-53 8.3-54 FSAR Fig. 3.11(B)-1, Sh. 1

SB 1& 2 Amendment 55 FSAR July 1985 8.3.1.3 Physical Identification of Safety-Related Equipment All cables. riceways and safety-related equipment are assigned to a particular chennel or train. There are two redundant trains of power and controls, and four redundant channels of instrumentation. Each channel or train is assigned a particular color. as shown below: Equipment Raceway Separation Group Nameplate Tag Cable Color A. Channel I and Train A Red Red Red Train A Associated Black Black w/ Red Tracer l G. Channel II and Train B White White White Train B Associated Black Black w/ White Tracer l 1 C. Channel III Blue Blue Blue D. Channel IV Yellow Yellow Yellow it Each piece of electrical equi .nent F is marked with the node number indicated on the design drawings, in the particular color corresponding to the channel or train to which that equipment is assigned. Similarly, trays and exposed conduits are marked with color-coded markers. The cable jacket color code serves as its identification. The operator or maintenance crattsman needs only to observe the color of the nameplate of any piece of equipment or the cable jacket color to determine which channel or train it serves. For exceptions to the above cable and raceway identification criteria, see Subsection 8.3.1.4.k. ff 8.3.1.4 Independence of Redundant Systems

a. General The Seabrook Station complies with the requirement s of TSAR Appendix 8A, IEEE 384-1974 and Regulatory Guide 1.75, Rev. 2.

These documents describe acceptable methods of complying with IEEE 279-1971 and Criteria 3, 17 and 21 of Appendix A to 10 CFR Part 50 with respect to the physical independence of the circuits and electrical equipment comprising or associated with the Class IE power system, the protection system, systems actuated or controlled by the protection system, and auxiliary or supporting systems that must be operable for the protection system and the systems it actuates to perform their safety-related functions. Preservation of independence of redundant systems within the control boards and all other field mounted racks is discussed in Subsection 7.1.2.2. ft 8.3- 39

SB 1 & 2 Am:ndacnc 59 FSAR May 1986 8.3.1.4 Independence of Redundant Systems

a. General The Seabrook Station complies with the requirements of FSAR Appendix 8A, IEEE 384-1974 and Regulatory Guide 1.75, Rev. 2.

These documents describe acceptable methods of complying with IEEE 279-1971 and Criteria 3, 17 and 21 of Appendix A to 10 CFR Part 50 with respect to the physir.al independence of the circuits and electrical equipment comrerising or associated with the Class IE power system, the protection system, systems actuated or controlled by the protection system, and auxiliary or supporting syst.ms that must be operable for ene protection system and the systems it actuates to perform their safety-related functions. Preservation of independence of redundant systems within the control boards and all other field mounted racks is discussed in Subsection 7.1.2.2. In accordance with the provisions of Section 4.5a and 4.6.2 uf FSAR Appendix 8A, Sections 4.5(1) and 4.6.1 of IEEE 384-1974, and Position C4 of Regulatory Guide 1.75, Revision 2, we have elected to associate all of the Non-Class 1E circuits with Class 1E circuits. This application of associated circuits allows the plant to be designed with one less separation group; that is, instead of having five separation groups consisting of four safety-related separation groups and one non-safety-related separation group, Seabrook has only four separation groups. The major advantages of this approach are the ability to provide greater separation distances between the groups, as well as to reduce the raceway system's exposure to fire. As a result of this design, all plant circuits are specifically assigned to one of the following four separation groups as noted in Figure 8.3-57: Group A - Train A, Channel I and Train A Associated Circuits Group B - Train B, Channel II and Train B Associated Circuits Group C - Channel III Group D - Channel IV I The great majority of associated circuits are with Group A, a very limited number are with Group 5, and none are with Groups C and D. The circuits that are associated with Train A onsist of:

1) Son-Class 1E power, control, instrument circuits contained within the Nuclear Island.

2) Non-Class 1E power, control, and instrumentation circuits that traverse the Nuclear Island boundary.

3) Non-Cla s s 1E power, control, and instrument circuits outside the Nuclear Island.

47 6 8.3-40

Br3 ' 4 SB 1 & 2 Amendment 59 FSAR May l986 The circuits that are associated with Train 8 consist of:

1) Non-Class IE power, control, and instrument circuits contained within the Nuclear Island.

2) Non-Class 1E power, control, and instrumentation circuits that traverse the Nuclear Island boundary.

47 The Nuclear Island boundary is shown in Figure 8.3-58. This figure denotes the buildings, structures, duct banks, etc., which are part of the Nuclear Island. All other buildings, structures, etc., are considered to be outside the Nuclear Island. , 61 The four separation groups are routed through four separate raceway systems per the separation criteria given in Table 8.3-10. This separation criteria are based on a combination of the following:

1) Standard separation criteria given in Sections 5.1.3, 5.1.4, and 5.6 of FSAR Appendix 8A and IEEE 384-1974 and

2) Separation criteria established by analysis and testing as permitted aby Sections 5.1.1.2 and 5.6 of FSAR Appendix 8A and IEEE 384-1974. This analysis and testing are documented in References (a) and (2) (see FSAR Sociton 8.3.4).

59

8. 3 -40 a

I b '$l V SB 1 & 2 Amandmant 52 FSAR December 1983 The following analysis examines the design features and modes of failure of associated circuits of each separation group to determine any interaction and challenges with other separation groups. The overall objective is to assure that the ability to achieve a safe plant shutdown under design basis event (DBE) conditions is not compromised.

b. Train A Associated Circuit Analysis

1. Associated Circuits Contained within the Nuclear Island Non -C la s s IE circuits that remain within the Nuclear Island are permitted to share the same raceway as Train A Class IE circuits. These circuits are classified as Train A Associated Circuits and are designed and installed to meet all the require-ments placed on associated circuits as required by the compli-ance documents listed earlier.

Challenges to Class 1E circuits, because of failure in an associated circuit, have been examined and determined to have no detrimental ef fect because: (a) When Class 1E power supplies are utilized, failure of a Non-Class lE motor, load, <;c device connected to this power supply will be p :spely isclated by operation of Class IE protecti,e devices. Non-Class lE loads connected to Class IE buses are in all cases protected by Class lE devices. The breakers protecting Non-Class lE loads are coordinated such that failure of all Non-Class lE loads, with proper operation of their own breakers, will not result in tripping of - the incoming breaker to the bus. Further, in the few cases where credit is taken for the incoming bus feeder breaker to provide backup protection to meet Regulatory Cuide 1.63, the associated bus is dedicated to Non-Class 1E loads only and, therefore, will not degrade a Class 1E bus. (b) In cases where Non-Class lE power supplies, such as switchgear, motor control centers, and distribution panels are utilized, these are of identical design of the Class lE counterparts and have been purchased to the same specification requirements inclusive of quality control. Mounting of the Non-Class lE power supplies within the Nuclear Island is identical to the mounting of their Class IE counterparts; therefore, credit can be taken for this equipment to function under DBE conditions. 51 8.3-41

SD 1 & 2 Amendmsnt 56 FSAR November 1985 Penetrations for 600 volt service and below are modular type with a header plate welded to the outside of a 12 inch containment sleeve. Because of the concern regarding leakage currents of terminal blocks during accident conditions, low level instrumentation circuit con-ductors inside containment are connected to the penetration conductors with qualified splices. Safety-related 480 volt power, 120 volt ac and 125 volt de control circuit conductors inside containment required to function for LOCA and main steam line break conditions are also connected to the penetration conductors with qualified splices. The balance of medium power 480 volt conductors, and control and instrumentation conductors are terminated on terminal Ee blocks inside terminal boxes both inside and outside containment. 480 volt heavy power conductors are terminated with lugs on special termination plates inside terminal boxes both inside and outside ce9tainment. Nuclear instrumentation detector circuits are termi-nated with connectors inside terminal boxes both inside and outside containment. Penetrations for medium voltage have header plates welded to the outside of an 18 inch containment sleeve. Each pene-tration consists of three 1000 MCM conductors terminated with premolded stress cones inside terminal boxes both inside and outside containment. The capability of the electrical penetrations to withstand the total range of time versus fault current without loss of containment integrity under worst case environmental conditions was demonstrated by test. , These test results are summarized in the response to RAI 430.56. 51 - The penetrations are arranged in two levels, with one power train and two channels entering above the intermediate floor of the con-tainment building, and the redundant train and two channels entering below the intermediate floor. Once inside the containment, this floor provides the necessary physical separation and protitction between the redundant trains; outside the containment, this separa-tion is continued by separate tunnels connecting the penetration area to the switchgear and cable spreading areas of the control building. Penetration conductors are sized using ICEA guidelines with an additional restriction of a 650C ambient temperature.

                                                                              !L The design, construction, and installation of the penetration assemblies are in accordance with IEEE 317 and Regulatory Guide l    1.63.    (See subsections 8.1.5.3, 8.3.1.1, and 8.3.1.2 for further details on compliance to Regulatory Guide 1.63).

! k. Cable and Raceway Identification The computer.?ed conduit and cable schedule provides a permanent 41 #3 record of the reuting and termination of cables. Circuit level coding identifies the individual channel or train assigned to each raceway and cable. These data are entered into the conduit and cable program, which in turn produces reports designating the unique number with origin, destination, channel or train, and specific path for every cable. Every cable is identified by a tag affixed at each end, bearing the unique cable number. 8.3-52

SB 1 & 2 Amendment 56 FSAR November 1985 Each channel or train is assigned a particular color, as described in Subsection 8.3.1.3. All safety-related cables have jackets of the color assigned to the particular channel and train so there is no dif ficulty in dis-tinguishiag between cables of redundant channels. Non-safety related cables are associated with either Train A or B and have black jackets with a red trace for cables associated with Train A and a white trace for cables associated with Train B. It is immediately evident to the operator or maintenance man, by observing the color of the cable jacket, that a given cable is safety-related 32 and that it is a particular channel or train. This system also prevents placing a cable of one channel or train with cables of another, by the obvious dissimilarity of jacket color. Each cable is further identified by a footage and cable code on the jacket of the cable at intervals of approximately five feet. Reference to pulling records reveals the cable number, routing, separation, circuit type, and use of any cable at any accessible point in the raceway system where the footage marker and cable code can be identified, s Exceptions to the above cable identification criteria exist for vendor supplied speciality cables for radiation monitoring system and portions of various other systems (for example telephone system, lighting and fire protection / detection). For these exceptions, the necessary information to ensure adequate control of separation, installation, inspection, etc. is provided in the construction I documents. M Raceways which are part of the computerized cable and conduit schedule are marked to identify their number and circuit level. Conduit raceways are identified at each end where conduit t e rmina t e s and at both sides of walls, floors and in-line boxes. Tray raceway markers are spaced at 15 foot or less intervals. These markings are in the same colors assigned to the channels and trains. For example, a raceway with a red section marking is utilized only by cables with red (or black with ed tracer) jackets. Hence, it is readily apparent that a given cable is routed with its respective channel. l Raceways which are not part of the computerized conduit and cable schedule may not be marked with a unique identification number, but their function is obvious by tracing the raceway to its end device. These raceways may be used to carry vendor supplied speciality cables for radiation monitoring system and portions of various other systems such as telephone system, lighting and fire protection / detection. For these raceways, the necessary infor-mation to ensure adequate controls of separation, installation, inspection, etc. is provided in the construction documents. e Since, in general, there is no sharing of safety-related systems between the two units (see discussion of compliance to CDC 5 Subsection 8.3.1.2), there is no need to distinguish the safety-related cables of one unit from the safety-related cables of the 8.3-53

SB 1& 2 Amendment 55 FSAR July 1985 other unit. As such, the cable and raceway coloring scheme is identical for the two units. In the common areas, the unit to which a cable belongs is not apparent from the raceway or cable markings. If it is required to know the unit to which a cable belongs, it can be obtained by observing the equipment designation number, which has the unit number as a prefix. The basis for cable and raceway identification is to distinguish between redundant channels, indicate which channel is involved, and which cables are safety-related.

1. Administrative Responsibility and Control 4 4

Administrative responsibility for assuring compliance with appli-cable design criteria and bases relative to independence of redundant systems rests with the A/E's Project Electrical Engineer. He is responsible for coordination with the A/E's field electrical super-visor to verify that the independence, separation and availability os Class IE equipment is preserved during installation of the electric power system. The following control procedures are established by the A/E's Project Electrical Engineer to assure compliance of the electric power system with the design criteria and bases:

1. Periodic design reviews with the cognizant engineer, the design supervisor, and the reviewing engineer to assure the criteria are being interpreted and followed,

2. Issuance of periodic administrative and design directives covering procedures, and

3. Periodic field reviews at the job site by the Project Electrical Engineer and/or the cognizant engineer to check field installation l

procedures, to provide interpretation of design drawings and guidance for solution of field installation problems, and to verify compliance with criteria. The design of the conduit and raceway system is guided by the recommendations of applicable IEEE, ICEA and NEC standards. For I SL instance, the limiting percentages of fill of internal area of the various size conduits or cable trays are fixed in one of the input forms of the computer conduit and cable schedule and these limits are automatically applied to all conduits and cable trays by the computer. If the conduit or cable tray is one which the computer is free to size, it designates the size which accommodates the cables to be enclosed. If the conduit or cable tray size is designer-designated and the fill exceeds the limiting percentage, the computer indicates an error message so that either the conduit can be made a larger size, or the cables routed by another path. By these methods, all raceways are assured of being of adequate capacity. Correct installation practice assures that the design criteria by which the equipment was selectad are not violated during construc-tion. Installation bases are prescribed, where necessary, by the 8.3-54

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                                                                                                                                                                                                                                                                       -     ,ard 98070(o00 % -05 PUBLIC 5ERVICE COMPANY OF NEW HAMPSHIRE                                                                                                             SERVICE ENVIRONMENT CHART SEA 8 ROOK STATION. UNITS 1 & 2 FINAL SAFETY ANALYSIS REPORT 9763.F-300219                                 l       FIGURE 3.11(B)-1. 5H.1
                                                                                                                    ,         , -.-       , - - ~ _ ,

ATTACHMENT H EXCERPT FROM ASLB HEARING TRANSCRIPT TUESDAY, SEPTEMBER 30, 1986 CONTENTS Transcript pgs. 384-389 (

 ' '=                  _ _ _ _ _

154 Sim 7-6 i MS. CURARN : I would like to turn now to 1# l el ipme..: qualifiesti n fi'.e No. 113-20-01, which I weald 2! ask the reporter to mark for identification purposes as 3 Exhibit 5. l 4 1

              !                                   (The document referred to was 5
              !                                   markedMECMP Exhibit 5 for 6 I l                                   identification.)                                          t 7 ;

i

NDEX i MS. CURRAN: Do you have a copy of that, 8 ,

i Mr. Woodward? WIT. NESS WOODWARD: Yes, I do. l 10 l BY MS. CURRAN: ' 11 Q According to Applicant's testimony at page ', this is one of the pieces of equipment that is not ; qualified fer 100 days. Am T correct? i A (Witness Salvo) That is correct. I 15

=~

l C This piece of equipment is qualified fo -- 16 j least not for all parameters -- this piece of equipment I 17 is qualified for 30 submergence, am I correct? j 18 l A (Witness Woodward) Yes, that is correct. l 19 Q Would you please describe the location and the { use of this cable at the Seabrook plant? 21 A This cable is 300 volt instrument cable that 22 can be found anywhere in the plant. With respect to all , 23 specific applications, I couldn't answer that question. , 24 ,

              "         Q     But it is pcssible, is it not, that this cab'e                       _

25 i I

335 Sim 7-7 1 supplies electricity to instruments that would say show 2 l the conditions cf accidents at the plant and monitor the i I 3 various parameters associated with accidents at the plant? 4 A It is'possible, yes. End S m 5 Sue fois 6 i 7 8 . 9 i 10 11 i 12 1 13

                                                                                                                           .                                    I 14 15                                                                                                                                                     ,

f l 16 k I 17 q 18 3 I I S s 19 I 20 i s 21 22 23 24 1

               't 25 l

386 I O Now, according to Page 7 of the qualification 5.- S u eW 2 report review checklist, this test program doesn't include i 3 submergence tests. And, their checklist refers to Note 9 I dI for an explanation of that. I I would like to turn to Note 9 which is en Page 11 5h' I I 6 of the assessreent checklist. And, in particular I would like I ' to discuss the statement in Note 9 that this particular 7[

                 'l 8J          table supplies instrument rack MM-IR-12.

9 Now, as I understand it, the cable that supplies 10 l MM-IR-12 may be submerged during an accidents is that

                  't I

correct? A (Witness Woodward) That's correct. 12 ] I3 ' O However, the note explains that instrument rack Id MM-IR-12 is denoted operability Code C. Now, would you 15 explain what operability Code C means? l 16 ' A In accordance with the regulations and criteria 17 set forth in NUREG 0588 and Regulatory Guide 1.89, all the i I8 d equipment in Seabrook for which qualification is addressed is assigned operability codes. I 20 Operability Code C represents equipment which may 7I f see what we call harsh environment of which submergence may be 22 ' one subsequent to design basis events. 23 However, it performs no safety function relative to mitigating the accident or putting the plant in a safe cwe n ewrws.onel24l 25 condition after these events. And, also it has been evaluated I i 0

337 l l

 *3-2-SueW      1     to see if any failures of this equipment due to the erviren-2     ment will effect anything else in the plant, the safety of 3     the plant.

4 Q Okay. I would like to turn to Reference 12 which ! l I f I 5' is the letter from the Impell Corporation to Yankee Atomic, I i 61 dated February 2nd, 1986. Now, on February 2nd, do I under-I 7 stand it that at that time the Impell Corporation considered s 8 that instrument rack MM-IR-12 was Class lE equipment which 9 would have been operability Code A? e i (Mr. Woodward and Mr. Salvo are conferring.) 10 l 11 f A Yes. As of the date of this letter, the equipment ! 1 12 on, and parts of instrument rack of MM-IR-12, were considered i i 13 to be essential to the plant 5t that time. la Q And, am I correct that Impell suggested that 15 rack MM-IR-12 should either be relocated above flood level le I or it should be shown that operability for a moderate energy I 17 l line break is not required? i 18 Is that correct? - I 19I (The witness is looking at the document.) 20 A Yes, as stated on Page 4 of that letter. 21 I O Now, did New Hampshire Yankee relocate this i 22 ! instrument rack? 23 l A (Witness Salvo) During the initial phase of the 24 EQ program, an assumption was made that -- a conservative co .i a,an.. iat - 25 , assumption was made -- many pieces of equipment were assumed _ f 1

333 . 8-3-SueW i to have an operability Code A, which meant that they were 2 required to perform a safety function. When the specific , 3l files were reviewed and we encountered problems that did not l < 4l envelope all accident assumptions, conservative action assump-I 5; tiens, that we made we went back and did a specific review of I 6l each piece of equipment's operability requirements. ; 7l .his is what was done for this part..cular instrument rack. It was originally assumed an operability Code A as a l 8l , 9 conservative assumption. And, after problems were encountered 10 , due to submergence, we then performed a specific review for 11 l that piece of equipment. And, it was determined that no 12 piece of equipment in that rack was required to perform any 13 " safety function during a mild energy break. ja And, that was performed by United engineers. 15 0 And, was a report and an evaluation prepared for 16 that piece of equipment? l 17 A I believe so. i Q But, you are not sure? 13 q

                        !          A                                        Well, United has done a document of review.          I 19 i

20 haven't seen a report. But, United did perform a review and i I have not specifically seen the report. 21 , l q l 22 1 Q Now, turning back to the Note 9 in the assessment 23 checklist, Note 9 refers to Reference 16 as an explanation 24 e for the downgrading of the instrument rack, MM-IR-12, from cm., a.mneri. in ' 25 operability Code A to operability Code C; is that correct? i

389 OC-4-SueW 1q (Mr. Woodward and Mr. Salvo are conferrirg.) 2 A (Witness Woodward) Reference 16 reports that the 3 Operability code will be changed in the program from either A 4i or 3 to C. t

                  $                  Q      And, Reference 16 -- correct me if I'm wrong, but 6           Roterence 16 is the only reference in this file to the change b

7 i in the operability code for that instrument rack, from A to

                      !                                                                            {

I 8l C. It's the only explanation that's given of how this 9 Operability code has changed. t 10 , Is that right?

                ') l i (Mr. Woodward and Mr. Salvo are conferring.)

12 ' A Yss, this is the official United engineer's I

                                                                .                                    I 13 i ' documentation that notifies people that the change will i

14 occur. Ultimately, the equipment list or that harsh environ-15 . ment list we have previously talked about will show chat i change. l 16 ' I 17 0 okay. I would just like to review this reference { t with you since it is a kind of unusual looking document. 18 [ 19 l The first page is an engineering change authoriza-l 20 tion; is that right? I 21 : A That's correct. 22 !ll 0 Basically, this lists the equipment, the specific il 23 d pieces of equipment, for which the company is requesting 24 , the authori:ation to downgrade the safety code? e,v snon.n. sac. ; 25 4 (Mr. Woodward and Mr. Salvo are conferring.)

ATTACHMENT I EXCERPT FROM ENVIRONMENTAL QUALIFICATION REPORT (EQR) 4 CONTENTS

1. SBN-886, Letter transmitting EQR

2. EQR, Section 2.1

                    'Q                                                            SE43R00K $TA!!CN cngineering office October 31, 1985 P@ec SeMee of New HampeNro l                                                       SBN- 886 l     Now Hornpshire Yank e o Divialen                  T.F. 37.1.2 Uni:ed States Nuclear Regulatory Commission Washington, DC 20555 Attention:        Mr. George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing

References:

(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) PSNH Letter (SBN-549), dated August 12,1983, "Respor.se to Safety Evaluation Report Outstanding Issue #6 (SER 3.11, - Equipment Qualification Branch)," J. DeVincentis to G. W. Knighton

Subject:

Environmental Qualification of Electrical Equipment; SER Outstanding Issue #6

Dear Sir:

As discussed at the June 13, 1985 meeting regarding Seabrook's Environmental Qualification Program, the report entitled, "Environmental Qualification of Electrical Equipment Important to Safety" (hereinafter referred to as EQR), was being updated and would be submitted to the NRC in the late fall. Accordingly, please find enclosed three (3) copies of the revised EQR, which documents our compliance with 10CFR50.49. It is also our understanding, from the above. referenced meeting, that the NRC site audit would be scheduled approximately six to eight (6-8) weeks after submittal of the EQR. We respectively request that you advise us as soon as possible of your plans for conducting this audit, so that we can begin planning for support of your audit activities. If you have any questions or require further clarificar. ions, please do not hesitate to contact us. V y truly yours,

                                                    /JohnDeVincentis, Director Engineering and Licensing Enclosure cc:    Atomic Safety and Licensicj Board Service List P O Sci 300 . Seoorock. NH O3874  Teteohene (6031474 95?1

William S. Jordan, III Donald E. Chick Diane Curran Town Manage r Harmon, Veiss & Jordan Town of Exeter 20001 S. Street, N.W. 10 Front Street Suite 430 Exeter, NH 03833 Washington, D.C. 20009 Ro be rt C. Perlis Brentwood Board of Selectmen RED Dalton Road Of fice of the Executive Legal Director Brentwood, NH 03833 U.S Nuclear Regulatory Commission Washing ton, DC 20555 Richard E. Sullivan, Mayor City Hall Robert A. Backus, Esquire Newburyport, MA 01950 116 Lowell Street P.O. Box 516 Calvin A. Canney Mane be s t e r, NH 03105 City Manager City Hall Philip Ahrens, Esquire 126 Daniel Street Assistant Attorney General Portsmouth, NH 03801 Augusta. ME 04333 Dana Bisbee, Esquire Mr. John B. Tanze r Assistant Attorney Gene ral D;signated Representative of Of fice of the Attorney General th? Town of Hampton 208 State House Annex 5 Morningside Drive Concord, NH 03301 Ha:pton, NH 03842

Anne Verge, Chairperson Roberta C. Pevear Board of Selectmen Designated Representative of Town Hall tha Town of Hampton Falls South Hampton, NH 03827 Drinkvater Road Harpton Falls, NH 03844 Patrick J. McKeon Selectmen's Office Mrs. Sandra Cavutis 10 Central Road Designated Representative of Rye, NH 03870 th2 Town of Kensington RFD 1 Carole F. Kagan Esquire East Kingston, NH 03827 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Jo Ann Shotwell, Esquire Washington, DC 20555 Assistant Attorney General Envi ronment al Protec tion Bureau Mr. Angi Machiros Dapa rtment of the Attorney Gene ral Chairman of the Board of Selectmen One Ashburton Place, 19th Floor Town of Newbury Boston, KA 02108 Newbu ry , MA 01950 Sonator Cordon J. Humphrey Town Manager's Office U.S. Senate Town Hall - Friend Street Washington, DC 20510 Amesbury, MA 01913 (ATTN: Tom Burae k)

Senator Cordon J. Humphrey Diena P. Randall 1 Pillsbury St reet 70 Collins Street Concord, NH 03301 Seabrook, NH 03874 (ATTN: Herb Boynton)

PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE SEABROOK STATION ENVIRONMENTAL OVALIFICATION OF ELECTRICAL EQUIPMENT IMPORTANT TO SAFETY 2.0 DEFINITION OF ELECTRICAL E0VIPMENT IMPORTANT TO SAFETY 2.1 Criteria for Selection of Equipment The Seabrook environmental qualification program addresses all electrical equipment important to safety which is located in a potentially harsh environment. Equipment which would not be exposed to a harsh environment during postulated accident conditions (i.e., mild environment) is not included. A mild environment, as defined in 10 CFR 50.49(c) is, "...an environment that would at no time be significantly more severe than the environment that would occur during normal plant operation, including anticipated operational occurrences." Seabrook Station defines a harsh environment as those areas of the plant where normal or accident environmental temperatures exceed 130*F, pressures exceed 1 psig, humidity is 100% and condensing, or the total integrated radiation dose exceeds 1 x 104 rads. Electrical equipment important to safety which were con-sidered for inclusion within the scope of the Seabrook program includes the following: A. Safety-related (Class 1E) electrical equipment. B. Nonsafety-Related electric equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions. C. Post-accident monitoring equipment. The systems found to contain electric equipment in the above categories are listed in Table 2-1. 2.2 Identification of Eouipment In response to the requirements of 10 CFR 50.49 paragraph (d), a documented review was performed of all applicable design documents to assure that all equipment important to safety [10 CFR 50.49 paragraphs (b)(1), (b)(2), (b)(3)] was identified. The equipment was listed and categorized in accordance with the guidance provided in Appendix E to Regulatory Guide 1.89, Rev. 1. Pevision 2 10/31/85 2-1

Dated: June 17, 1988 UNITED STATES OF AMERICA UNITED STATES NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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

(Seabrook Station, Units 1 ) (On-site Emergency and 2) ) Planning Issues) __) APPLICANTS' REPLY TO NRC STAFF AND NECNP'S RESPONSE TO APPLICANTS' SUGGESTION OF MOOTNESS BACKGROUND Following the Licensing Board's Partial Initial Decision,1 ("PID") NECNP challenged, inter alia, the Licensing Board's finding that the RG-58 coaxial cable was environmentally qualified by comparison with RG-59 coaxial cable. In ALAB-875 the Appeal Board agreed with NECNP and

stated that a letter from the cable vendor to Seabrook's architect-engineer and constructor was an insufficient 1 Public Service conoany of New Hamoshire, (Seabrook Station, Units 1 and 2) LBP-87-10, 25 NRC 177 (1987), rev'd in cart, A LA D- 8 7 5, 26 NRC 251 (1987). 8 i

evidentiary basis for the Licensing Board's finding.2 The Appeal Board requested that the Licensing Board indicate any additional support in the existing record for its finding, or take further evidence.3 Unpersuaded by the submissions from the Licensing Board and the Applicants, the Appeal Board, in ALAB-891, reversed the decision of the Licensing Board in the PID and remanded the issue of whether RG-58 coaxial cable is environmentally qualified.4 In ALAB-891, the Appeal Board stated that new evidence introduced on this issue, following-the remand, "must be sponsored by a competent affiant or witness."5 On May 19, 1988, the Applicants filed a "Suggestion of Mootness" in which they stated, on the basis of affidavits of experts, that they had: 1) identified which RG-58 coaxial cables are required to meet the environmental qualification requirements of 10 CFR 50.49; and 2) directed that those RG-58 coaxial cables be replaced by RG-59 coaxial cables -- an 2 Public Service Comoany of New Hamoshire, (Seabrook Station, Units 1 and 2) ALAB-875, 26 NRC 251, 271 (1987). 3 Id. 4 Public Service Comoany of New Hamoshire, (Seabrook Station, Units 1 and 2) ALAB-891, 27 NRC (April 25, 1988). 5 Id. slip on at 22. environmentally qualified, technically acceptable substitute.6 The NRC Staff responded on June 2, 1988. In its response, the Staff agreed that "(a) fourth option available to Applicants...is to replace all RG-58 coaxial cables requiring environmental qualification with another type cable that has previously been demonstrated to be environmentally qualified for its intended use. This course of action is appropriate because it addresses and eliminates the central claim of remanded NECNP Contention I. B. 2. 7 vurthermore, the Staff agreed that the requirements of 10 CFR 50.49 apply only to RG-58 cables which are important to safety and located in harsh environments,8 agreed that spare cables need not meet the requirements of 10 CFR 50.49,9 and agreed that RG-58 cables located in a mild environmental do not need to be environmentally qualified in accordance with 10 CFR 50.49.10 Finally, the Staff also agreed that the replacement of the RG-58 cable by the RG-59 cable "would satisfy the 6 On May 27, 1988 Applicants filed the Supplemental Affidavit of Richard Bergeron, and in accordance with that affidavit, slightly revised the pleading. 7 "NRC Staff Response to Applicants' Suggestion of Mootness" (June 2, 1988) at 3. 8 Id. at 5-6. 9 Id. at 7. 10 1d. at 8. environmental qualifications of 10 CFR 50.49 for those cables."11 Nevertheless, while seemingly endorsing the Applicants' course of action, the Staff in effect faulted the affidavits of the Applicants' experts based on the alleged failure to supply suf ficient information to substantiate certain claims. While not conceding that such additional information is necessary, the Affidavit of Richard Bergeron (June 16, 1988) responds to the issues raised. On June 9, 1988 NECNP filed its response, together with the affidavit of Robert D. Pollard.12 NECNP argues that the Applicants' Suggestion of Mootness must be rejected for three reasons, all of which are without merit. First, NECNP seeks discovery, specifically the examination of documents supporting Applicants' position.13 Second, NECNP argues that it is entitled to a hearing to test the credibility of Applicants' witnesses.14 Third, NECNP asserts that there are remaining disputes of material facts because Applicants have failed "to 11 Id. at 11. 12 "New England Coalition on Nuclear Pollution's Response to Applicants' Suggestion of Mootness Regarding Environmental Qualification of RG-58 Cable" (June 9, 1988). 13 Id. at 1-2. 14 Id. at 2-3. _4

establish that Applicants have identified all uses and locations of RG-58 cable, that they know what qualification requirements the cable must meet, or that RG-59 is an adequate substitute.:15 NECNP's arguments are without merit. NECNP may not use the Applicants' Suggestion of Mootness as a basis for random inquiry or to raise new contentions. The issue remanded to the Licensing Board concerns only whether the RG-58 cable is environmentally qualified. This is the only issue remanded to this Licensing Board and therefore the sole issue over which the Licensing Board has jurisdiction 16 and the sole issue which NECNP properly may litigate. Applicants have mooted that issue by agreeing to remove all RG-58 coaxial cables presently required to meet the environmental qualification requirements of 10 CFR 50.49. There is no contention in this case, and never has been, that Applicants were not capable of selecting what componente 2 to be environmentally qualified. Indeed, there has never been a contention that the Seabrook organization was not fully technically qualified. 15 l Id. at 3. I 16 Carolina Power & Licht Co. (Shearon Harris Nuclear Power Plant, Units 1, 2, 3 and 4), ALAB-526, 9 NRC 122, 124 and n.3 (1979); Portland General Electric Comoany (Trojan Nuclear Plant), ALAB-534, 9 NRC 287, 289 at n.6 (1979). l

I' Nevertheless, without conceding that NECNP's inquiries are proper, the affidavit of Richard Bergeron (June 16, 1988) responds to the issues raised. Finally, NECNP, in disagreement with the NRC Staff and Applicants, claims that it has not been established that RG-59 coaxial cable is environmentally qualified. This is incorrect; the environmental qualification of RG-59 coaxial cable has been already established.17 Moreover, FECNP's motion 18 to reopen the record and admit a late-filed contention concerning whether RG-59 coaxial cable was environmentally qualified was denied.19 On the basis of the foregoing, Applicants press their motion that the Licensing Board enter an order that the issue regarding the environmental qualification of RG-58 coaxial cable as moot. Any possible remaining matters of concern are fully capable of resolution by a purely objective 17 See LBP-87-10, suora n.1, 25 NRC 177 at 210-211, rev'd in cart on other arounds, ALAB-875, 26 NRC 251 (1987); NECNP Ex. 4 (Environmental Qualification File No. 113-19-01); see also May 19 affidavit at 119. Of course, the initial issue on appeal was whether it was proper to conclude that uhe RG-58 coaxial cable supplied by ITT Surprenant was environmentally qualified based on its similarity with RG-59 coaxial cable. 18 Motion to Reopen the Record and Admit Late-Filed Contention (February 2, 1988). 19 Public Service conoany of New Hampshire (Seabr" Sk Station, Units 1 and 2), ALAB 886, 27 NRC __ (February 22, 1988).

determination, and will be appropriate for ministerial resolution by the NRC Staff. See e.c., Louisiana Power and Licht Comoany (Waterford Steam Electric Station, Unit 3), ALAB-732, 17 NRC 1076, 1104-1105 (1983) (Details of installation and testing of siren system is proper matter for Staf f to oversee) ; Carolina Power & Licht Co. (Shearon Harris Nuclear Power Plant, Units 1,2,3 and 4) CLI-74-22, 7 AEC 939, 951-952, (1974). A license condition to this effect is acceptable to the Applicants. Respectfully submitted, A Thomas G. Dignan, Jr. ' Deborah S. Steenland Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 Counsel for Applicants l l l

CEBTIFICATE OF SERVICE I, Deborah S. Steenland, one of the attorneys for he Applicants herein, hereby certify that on June 17, 1988, I made service of the within documents by depositing copies thereof with Federal Express, prepaid, for delivery to (or where indicated, by depositing in the United States mail first class, postage paid, addressed to): Administrative Judge Sheldon J. Robert Carrigg, Chairman Wolfe, Esq., Chairman, Atomic Board of Selectmen Safety and Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Emmeth A. Diana Curran, Esquire Luebke Andrea C. Ferster, Esquire 4515 Willard Avenue Harmon & Weiss =p--md4 Chevy Chase, MD 20815 Suite 430 2001 S Street, N.W. Washington, DC 20009 Dr. Jerry Harbour Stephen Ev Merrill Atomic Safety and Licensing Attorney Genaral Board Panel George Dana B.'sbee U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North, 15th Fl. East West Towers Building 11555 Rockville Pike 4350 East West Highway Rockville, MD 20852 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

bE Philip Ahrens, Esquire Mr. J. P. Nadeau 'j . Ass'.stant Attorney General Selectmen's Office 10 Central Road F Department of the Attorney General Rye, NH 03870 7 04333 g Augusta, ME Paul McEachern, Esquire Carol S. Sneider, % quire E Matthew T. Brock, Esquire Assistant Attorney General 1 Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue one Ashburton Place, 19th Floor - 1 P.O. Box 360 Boston, MA 02108 :fi in / ~~ .k. Portsmouth, NH 03801 ?. Q.)

                                                                                                        .w n:..

l.'

    !       Mrs. Sandra Gavutis              Mr. Calvin A. Canney E E=eE" W"

Chairman, Board of Selectmen City Manager l l City Hall E WME i f RFD 1 - Box 1154

   -!       Route 107                         126 Daniel Street                                               ,i Kensington, NH    03827           Portsmouth, NH 03801

Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire fg U.S. Senate Lagoulis, Clark, Hill-Whilton &

i Washington, DC 20510 McQuire NL 1 (Attn: Tom Burack) 79 State Street Newburyport, MA 01950 $

Senator Gordon J. Humphrey Mr. Peter J. Matthews g

_ - One Eagle Square, Suite 507 Mayor E Concord, NH 03301 City Hall Newburyport, MA 01950 L (Attn: Herb Boynton) h

g. Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street -4'"

10 Front Street Amesbury, MA 01913 - ; g < .g . J J m Exeter, NH 03833 c ; M. Y

                                                                                                     '~ , i H. Joseph Flynn, Esquire           Brentwood Board of Selectmen       ,   <,                     .

Office of General Counsel RFD Dalton Road ,; ' ^-M .

                                                                                  '(, ,03 .",1j                  []

Federal Emergency Management Brentwood, NH 03833 h E Agency 3.24. Je4 ; J.Q 500 C Street, S.W. 2 20472 'lg s c.1, y

Washington, DC . , ..

E Gary W. Holmes, Esquire Richard A. Hampe, Esquire Hampe and McNicholas f[9..i.

                                                                                     # - x, ' .1 h' .

_. Holmes & Ells (j, i( . ' 47 Winnacunnet Road 35 Pleasant Street . gi, Haupton, NH 03841 Concord, NH 03301

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Mr. Ed Thomas Juctith H. Hizner, Esquire FEMA, Region I 79 State Street 442 John W. McCormack Post Second Floor Office and Court House Newburyport, MA 01950 Post Office Square Boston, MA 02109 Charles P. Graham, Esquire Murphy and Graham 33 Low Street Newburyport, MA 01950 I Deborah S. Steenland (*= Ordinary U.S. First Class Mail.)

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ML20196H125

Text

References:

Subject:

Dear Sir:

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