ML20151P470
| ML20151P470 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/05/1988 |
| From: | Feigenbaum T, James Smith PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| References | |
| CON-#388-6882 OL-1, NUDOCS 8808100041 | |
| Download: ML20151P470 (37) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the 1
ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al.
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50-444-OL-1
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On-site Emergency (Seabrook Station, Units 1 and 2)
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Planning Issues
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APPLICANTS ' RESPONSE TO "NEW ENGLAND COALITION ON NUCLEAR POLLUTIO.'.4'S THIRD SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO APPLICANTS ON HECNP CONTENTION I.B.2" AND SUPPLEMENTAL ANSWER TO INTERROGATORY Pursuant to 10 C.F.R. 55 2.740b and 2.741, Applicants herein respond to "New England Coalition on Nucinar Pollution's Third Set of Interrogatories and Request for the Production of Documents to Applicants on NECNP Contention I.B.2."
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.QENERAL O.NECTIDNji Applicants object to the p.toposed definitions provided in paragraphs 2-4 of the instructions on the grounds that
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such definitions are overbroad and burdensome.
Applicants will "identify" drawings by number, and other documents by category or by title and date.
Applicants will "identify" an individual by providing the individual's name, title, and business address.
Il{TERROG ATORY NO. 1 For each of the four individuals identified in response to Interrogatory No. 1 of NECNP's first set of interrogatories, please describe the person's area of expertise and the particular substantive contribution.
that the person has made, both to the Applicants' review of the RG-59 coaxial cable issue, and to the answering of NECNP's first, second, and third sets of interrogatories.
RESPONSE
Applicants object to the interrogatory to the extent that it asks for a description of "the particular substantive contribution" by each person, on the ground that such a re. quest is burdensome and seeks privileged information.
Without waiving the foregoing objection, Applicants state:
Attachments 1-1 through 1-4 provide the qualifications of the four named individuals.
Atta.chments 1-5 and 1-6 indicate which individual (s) were responsible for developing the technical response to NECNP's First and Second Set of Interrogatories.
It should I
be understood that the individual (s) who developed a i ;
i technical response may have used information obtained from other individuals.
The individur.i (s) responsible for developing a response to the Third Set of Intarrogatories is noted in the particular responso.
The individual's name, title and business address is provided in Attachment 1-7.
for all three sets of interrogatories Mr. Vargas reviewed and commented on the responses developed.
Finally, as to the review of the RG-58 coaxial cable issue, Mr.
R.
Bergeron and Mr.
P. J. Tutinas generally dealt with issues related to environmental qualification while Mr.
G. A.
Kotkowski generally dealt with issues relating to Electrical Engineering (e.g., technical adequacy of RG-59).
Mr. Vargas provided management supervisica and review to all issues.
(Bergeron)
INTERROGATORY NO. 2 Please identify all witnesses and affiants you intend to use in hearings and summary disposition proceedings on RG-58 coaxial cable, and describe the substance of their affidavits and testimony.
RES PONSE At preaant Applicants intend to use one er all of the following individuals as affiants for summary dispositi.on concerning the RG-58 coaxial cable.
Richard Bergeron Instrumentation and controls Engineering Supervicor (NHY) l
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s Thomas.T. Glowacky Senior Engineer, Seabrook Project Electrical Engineering Group (YAEC,'
Gorald A.
Kotkowski -
Electrical Engineering Supervisor (NHY)
Peter J. Tutinas Project Engineer Instrumentation and Controls (NHY)
Newell K. Woodward Senior Project Manager (Tenera)
The substance of their affidavits will be that RG-58 coaxial is not used in safety-related/ accident mitigating applications; that all RG-58 cable located in a harsh environment that would have been required to be environmentally qualified per 10 C.F.R. 50.49 has been replaced by RG-59 coaxial cable; that RG-59 coaxial cable is a technically acceptable substitute for the twelve (12) RG-58 applications and that RG-58 coaxial cable 10 envircnmentally qualified for use at Seabrook Station.
Applicants presently intend to use the affiants identified above as witnesses for hearings.
(Bergeron/Kotkowski/Vargas)
INTERROGATORY NO. 3 on May 27, 1988, you filed a revised "Suggestion of Mootness" which corrected your May 19, 1988, tabulation regardi'g the categorization of RG-08 cables in the n
Seabrook plant.
How and when was this error discovered?
To what do you attribute the error made in the May 19th filing?
Was the review procedure described in the May 19 Bergeron affidavit inadequate to detect this error?
If so, how?
Was the review procedura described in the Bergeron affidavit improperly carried out?
If I
so, how?
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RESPONSE
The CASP system and electrical schematic drawing packages were used to initially identify the 126 RG-58 coaxial cable applications.
This review is documented in Engineering Evaluation 87-028.
The inconsistency in the number of spare cables referred to above was determined to be the result of a tabulation error by the Applicant:
R.
Bergeron.
While tabulating the quantity of cables for each category he inaGvertently categorized a cable as being mild when,.in fact, the review had identified the cable not only as being in a mild envirorment, but also being a spare.
The review procedures described in the May 19 Bergeron Affidavit were aduquato.
The inconsistentcy was not in the review process used to identify and categorize the 126 RG-58 coaxial cables, but rather in tabulating the results.
(Bergeron/Tutinas)
INTERROGATORY NO. 4 Does the June 16 Bergeron affidavit describe any review procedures for the identification and location of RG-58 cable that are not already described in the May 19 Dergeron affidavit?
If so, please describe them, and explain why they were added.
RES PONSE No.
The June 16 Bergeron Affidavit provides further explanation of the review process.
(Bergeron) l ;
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3 INTERRQM'LQRY NO. 5 In response to interrogatory 5 of NECNP's first set of interrogatories, you state that "subsequent review" has determined that cables No. FE2-FM4/2 and FE2-FM6/2 were spare cables.
Please describe this "review" and state when it took place and by whom it was conducted.
In what respects, if any, does it differ from the review described in the Bergeron affidavits of May 19 and June 16, 1988?
Do you consider the procedures described in those affidavits to be inadequate in any way?
If so, how?
Please describe your reasons for conducting the "su:, sequent review."
RES PONSE The "subsequent review" was performed by Mr. Thomas W.
Glowacky in July, 1988.
His review was an in-depth clicult review and analysis of the electrical schematic drawing packages for all the identified 126 RC-58 coaxial cable applications, including those 12 cables subsequently replaced vith RG-59 coaxial cable.
This review formed the basis of his failure mode and effects analysis documented in Engineering Evaluation 88-017 and in his Affidavit of July, 1988.
There are two differences between the reviews performed.
First, the Glowacky review included only some of the documents that were included in the review described in the Bergeron Affidavits.
Second, the end purpose for reviewing the specific document was markedly different.
The Glowacky review was an in-depth review of each circuit, including the h.
components within each circuit, necessary for a failure mode and effects analysis.
The review described in the Bergeron Affidavits was performed to identify RG-58 cable applications for qualifica. tion and to assist in categorization.
The reviews performed and the procedures used were and still are adequate to reach this conclusion because the Glowacky review did not identify any additional energized cables.
(Bergeron/Tutinas)
INTERROGATORY NO. 6 Do the electrical schematic drawings that you reviewed according to the procedures described in the Bergeron affidavits show that cables No. FE2-FM4/2 and FE2-FM6/2 are spare cablos?
If not, please describe the reason for the error and any efforts you have made to detect other errors in the electrical schematt:
drawings.
RES PONSE Applicants object to the form of this question, on the grounds that it incorporate s an arsumption that has no basis in tha record of these proceedings.
Without waiving the foregoing objection, Applicants state yes.
(Kotkowski)
INTERROGATORY NO. 7 Does the CASP show that cables No. FE2-FM4/2 and FE2-FM6/2 are spare cables?
If not, please describe the reason for the error und any efforts you have made to detect other errors in the CASP. \\
RES PONSE No.
CASP does not identify cable nos. FE2-FM4/2 and FE2-FM6/2 as spares.
This, however, is not considered an error.
CASP has designated these cables for use in the Station Computer System and not for use as a general spare.
Determining which of these cables were spares required a review of the schematic drawing packages, not CASP.
(Kotkowski)
INTERROGATORY NO. 8 Given the fact that you previously erred in calculating that some cables were energized when they were actually spare cables, do you believe it is possible that some cables which you believe are spare are actually energized?
If not, why not?
RESPONSE
Applicants object to this interrogatory on the ground that, insofar as it asks about cables in general, it is overbroad.
Without waiving the foregoing objection, Applicants state that, with regard to the RG-58 coaxial cables at Seabrook Station, no.
See Response to Interrogatory No.
9.
(Kotkowski)
INTERROGATORY NO. 9 Have you physically inspected all spare RG-58 coaxial cables to determine whether they are indeed not connected to any circuits?
If so, when was the inspection performed and what were the results?
If no,,
why not?
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RESPONSE
Yes.
On July 25, 1988 and July 26, 1988 the 21 spare RG-58 coaxial cables were physically inspected and all were four.d to be disconnected.
Also, the 12 RG-58 cables'which were replaced with RG-59 cables were physically verified as disconnected as part of the process of replacing those cables.
(Kotkowaki)
INTERROGATORY NO. 10 Please describe the steps taken to account for the 602 feet of RG-58 cable that have not yet been accounted for.
What are the results of your review to date?
To what do you attribute your previous inability to account for this cable?
RESPONSE
To date the following have been reviewed:
Electrical schematic pickages, CASP, cable pull slips, historical CASP files, the Electrical Status Program and design change documents affecting Specification 9763-006-113-19 and CASP.
This review has not accounted for the remaining 502 feet of RG-58 cable.
We are confident that this cable does not need to be environmentally qualified because all active cables are identified op the electrical schematic packages and/or CASP.
(Kotkowski/Bergeron)
INTERROGATORY NO. 11 In response to interrogatory No. 7 of NECNP's first t
set of interrogataries, you state that 4,000 of the 12,000 pages of electrical schematic drawings contain cable schematics and cable tables.
Did you review only those 4,000 pages, or did you also review the other 1
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8,000 pages?
What information did the 8,000 pages contcin?
If you did not review them, why not?
RESPONSE
All 12,000 pages of the electrical schematic drawing packages were reviewed.
The 8,000 pages contain index sheets, revision lists, general notes, circuit schematics, reference drawings, front views, panel arrangements, auxiliary contact developments, legends, switch developments and three line diagramo.
(Kotkowski)
INTERROGATORY NO. 12 In response to interrogatory No. 12 of NECNP's first set of interrogatories, you state that Applicants physically verified the locations of the end points of each of the 12 replaced RG-58 cable (sic), as part of the process of disconnecting and replacing those cables.
Have Applicants physically traced the route of those cables over their entire lengths?
If so, how and when was this done?
Did the physical review confirm your review of CASP and the plant drawings?
Please identify all cables for which your physical review did not confirm what was in CASP and the drawings, describe the discrepancy, and state why you believe the discrepancy exists.
RESPONSE
No.
(Kotkowski)
INTERROGATORY NO. 13 Have Applicants physically verified the end points of any other of the 126 RG-58 coaxial cables?
If so, which ones have you verified?
How and when was this done?
Did the physical review confirm your review of, -.
CASP and the plant drawings?
Please identify all cables for which your physical review did not confirm what was in CASP and the drawings, describe the discrepancy, and state why you believe the discrepancy exists.
RESPONSE
Yes.
On July 25, 1988 and July 26, 1988 the 21 spare RG-58 coaxial cable endpoints were physically inspected.
That inspection confirmed that each of these cable ends was precisely where CASP indicated it should be.
(Kotkowski)
INTERROGATORY NO. 14
!! ave you physically traced the routes of any of the remaining RG-58 coaxial cables over their entire lengths?
If so, which ones were traced?
Did the physical review confirm your review of CASP and the
, plant drawings?
Please identify all cables for which your physical review did not confirm what was in CASP and the drawings, describe the discrepancy, and state why you believe the discrepancy exists.
RESPONSE
No. The routes of the remaining 114 RG-58 coaxial cable applications were not physically traced over their entire length.
(Kotkowski)
INTERROGATORY NO. 15 Please explain how procedure FEP-504 provided l
physica,1 verification of the location of each RG-58 coaxial cable.
Would that procedure also verify whether cables were energized or not?
If so, why did it not i
show that some of the cables shown to be energized by l
CASP and/or plant drawings were not in fact energized?
RESPONSE
A prerequisite to Procedure FEP-504 provides that: "The latest approved revision of the design documents shall be used for construction and acceptance of all cable installations."
CASP-generated cable pull slips or worksheets were used in the installation of cables.
Upon completion of the cable pull, the slip /worksheet was signed to signify compliance with the design document.
Procedure FEP-504 verified that the cable pull slip /worksheet agreed with the CASP Cable Schedule - Report A.
Physical verification was provided because the installation document was generated by CASP and the installer attested to compliance with the design document by signing the pull slip.
Procedure FEP-504 does not verify whether cables are supposed to be energized or not.
(Kotkowski)
INTERROGATORY NO. 16 What is the source of and basis for the acceptance r
criteria described in Section 5.2 of Procedure No. 2483-38N. At,tachment 1 to NYN-8905?
RES PONSE The functional requirements of the RG-58 cable under accident conditions are very limited.
The only requirement i t
is that the cable must not fail (i.e. short to ground).
The acceptance criteria described in Section E.2 of Procedure 24843-89N was selected only to establish a reference point, as is typically done during baseline functional tests.
(Bergeron/Tutinas)
INTERROGATORY NO. 17 Your response to interrogatory 16 of NECNP's first set of interrogatories appears to indicate that it is your position that the 12 circuits in which RG-59 coaxial cable is used will function properly regardless of how low the insulation resistance drops as long as the cable does not short to ground.
Is that correct?
If so, please explain your answer.
If not, please explain why not.
Is it your position that the circuits would continue to function during a direct short?
If so, please explain your answer.
If not, please explain why not?
RESPONSE
The functional requirement of the RG-59 cable used to replace the twelve RC-58 cables, under accident conditions, is that it not fail (i.e., short to ground).
There are no requirements that these cables be capable of performing anZ signal transmission function during postulated accident conditions.
Therefore, questions regarding circuit functionality are irrelevant.
(Bergeron/Kotkowski/Tutinas)
INTERROGATORY NO. 18 on what basis have you concluded that the functional performance of RG-59 coaxial cable in each of the 12 circuits makes it a technically acceptable substitute for RG-58 coaxial cable? 4
, ~ _.. - _ - -
RESPONSE
As stated in Response to Interrogatory No. 17, the only environmental qualification related functional performance requirement is that the cable not fail (i.e., short to ground) under postulated accident conditions.
The acceptability of the RG-59 cable as a substitute for the RG-58 cable from an environment qualification standpoint was based on a review of RG-59 test results documented in NECNP Exhibit 4, Reference 2.
The test results demonstrated that the cable would not short to ground.
See Response to Interrogatory No. 20 regarding the RG-59's technical acceptability for normal plant operations.
(Bergeron/Tutinas)
INTERROGATORY NO. 19 Is it correct to state that you do not know the minimum insulation resistance necessary for the proper functioning of each circuit where RG-59 coaxial cable has been substituted for RG-58 coaxial cable?
Please explain your answer.
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RESPONSE
Applicants reiterate that the only environmental qualification functional performance requirement is that the cable not fail (i.e.,
short to ground) under postulated accident conditions (see Response to Interrogatory No. 17).
As discussed in the Affidavits of Newell K. Woodward, dated July 27, 1988 and July 29, 1988, the electrical characteristic that demonstrates that a cable remains in tack is its ability to carry current and voltage under postulated environmental conditions and not fail.
Therefore, questions regarding insulation resistance as it relates to circuit functionality are irrelevant.
(Bergeron/Tutinas/Kotkowski)
INTERROGATORY NO. 20 In response to NECNP's interrogatory No. 19, you state that "cable manufacturer data was reviewed and determined to be acceptable" for each substitute application of RG-59 coaxial cable.
Precisely what information in the RG-58 or RG-59 coaxial cable manufacturer data led you to believe that RG-59 cable was an acceptable substitute for RG-58 cable?
Please explain why you considered the data to be sufficient.
RESPONSE
As a preface, it should be understood that the quoted excerpt was in the context of the proper functioning of each.
circuit during normal plant operations.
In this light, the Applicants respond:
The manufacturer's data for characteristic impedence, attenuation and velocity of propagation were evaluated to determine if RG-59 coaxial cable was an acceptable substitute for RG-58 coaxial cable during normal, non-accident plant conditions.
These are the primary specifications that determine the wave propagation characteristics of transmission lines.
(Kotkowski)
INTERROGATORY NO. 21 Is it correct to state that there is D2 minimum insulation resistance required for the s1ccessful functioning of the circuits in which RG-09 coaxial cable have [ sic] been substituted for RG-58 coaxial cable?
Picase explain your answer.
RESPONSE
See Response to Interrogatory No. 19.
(Bergeron/Tutinas/Kotkowski)
INTERROGATORY NO. 22 Do you agree that degradation of signal due to insertion loss (attenuation) and variation in response time due to the change in the velocity of propagation are pertinent parameters for proper functioning of the 12 substitute RG-59 coaxial cables?
RES PONSE For normal plant operation yes.
Regarding operation under postulated accident conditions, see above Response to Interrogatory No. 17.
(Kotkowski/Bergeron) l 1 I
INTERROGATORY NO. 23 Is it your position that decreases in the insulation resistance of the 12 substitute RG-59 coaxial cables would have no effect on the degradation of signal due to insertion loss (attenuation) and variation in response time due to tne change in the velocity of propagation?
RESPONSE
No.
(Kotkowski)
INTERROGATORY NO. 24 Do you agree that the length of cable exposed to the &ccident environment is relevant to 4 determination of its insulation resistance?
If not, why not?
RESPONSE
Applicants object to this interrogatory on the grounds tnat, insofar as it asks about cable in general, it is ovorbroad.
Without waiving the foregoing objection, Applicants state that, with regard to RG-58 coaxial cable in Seabrook, Station, yes.
(Bergeron)
INTERROGATORY NO. 25 For each of the 12 cables exposed to a harsh environment, it is possible to measure the length of cable that is exposed to the harsh environment?
If so, why hav'e you not done so?
If not, why not?
RES PONSE Yes.
The length of the portion of each cable exposed to a harsh environment is not critical to this particular case when the only environmentally related functional performance l
4 requirement is simply that the cable must not fail under accident conditions.
Th'a re fore, cable length was not measured.
(Bergeron/Kotkowski)
REOUEST NO. 1 Please identify all documents rolled on for purposes of answering the foregoing interrogatories or identified in response to the foregoing interrogatories.
RESPONSE
Applicants object to this request on the grounds that it overbroad.
Applicants also object to identifying, and will not identify or produce, documents already filed on the record in these proceedings or otherwise publicly available.
Without waiving the foregoing objection, and with the exception noted above, Applicants state that all documents relied upon were identified in the response to the foregoing interrogatories.
REQUEST NO. 2 Within 14 days, please provide access to all documents identified in response to the immediately preceding request.
No.
1.
RES PONSE Applicants incorporate here their objections to Request No. 1 above.
Without waiving the foregoing objections, and with the exception noted, Applicants will provide access all requested documents which are in their possession or control.
Documents will be accessible at the Seabrook Station and will be made available to NECNP or its representative for inspection and copying at a time between 8:00 a.m. and 4:00 p.m.,
Monday through Friday.
Please contact Mr. William J.
Daley at (603) 474-9521 ext. 2057 to arrange for document inspection.
REQUEST NO. 3 Please provide access to procedure FEP-504.
RES PONSE See Response to Request No.
2.
REOUEST NO. 4 Please identify and provide access to all documentation of the manner in which the procedure FEP-504 provided verification of the location of RG-58 coaxial cable.
RES PONSE To the extent that Applicants have documents responsive to this request, see Response to Request No.
2.
REOUESTf' M Please provide access to the data sheatr described in Attachment 2 to your answers to NECNP's first set of interrogatories, the July 5, 1988, letter from NTS to R.
Bergeron/J. Vargas. t
BESPONSE See Response to Request No.
2.
REQUEST NO. 6 Unless already provided in response to the preceeding (sic) document request, please provide access to all other results of equipment qualification testing of RG-58 coaxial cable, including insulation resistance measurements.
RESPONSE
See Response to Request No.
2.
REOUEST NO. 7 Please provide access to the cable manufacturing data referred to in your answer to intorrogatory 19 of NECNP's first set of interrogatories.
RESPONSE
See Response to Request No.
3.
SUPPLEMENTAL P.ESPONGE TO INTERROGATORY 5 OF NECNP'S FIRST SET OF INTERROGATORIES Attachment C to the June 16, 1988 Bergeron Affidavit should centa,in reference to the Seabrook Station Electrical Schematic Drawing Packages.
This information, which was inadvertantly excluded from Attachment C, is contained in Attachment B thereto.
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As to Answers:
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Ted C.
Feigen a
Vice-Preelds of Engineering, 2.icensing, and quality Programs New Hampshire Yankes Division of Public service company of New Hampshire August 5, 1985 Commonwealth of Massachusetts Essex County, ne, Then appeared before na the @a e subscribed Ted C.
reiganbaun and nade oath that he is the Vice-President of Licensing, and Quality Programs of How Hampshire Engineering, ion, authoritad to execute the foregoing response Yankee Divis to interroq'atories on behalf of the Applicants, that he made inquiry and believes that the foregoing answere scourately set forth.,nformation as is avaliable to the applicants.
Before me, Yt.
j H<tc M.
V\\j My commisabn Expires 113 3, \\49 L, As to objections jm ht a alllr1 b'
Thomas G. Dignan, Jr Deborah 8. steenland Jay Bradford saith Ropes & Gray 225 Franklin Street Boston, MA 02110 (417) 423-6100 gunami fer penlicanta TOTA P.02
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l ATTACHMENT l-1 RICHARD BERGERON Instrumentation & Controls Engineering Supervisor Education BS Marine EngineerAng, Maine Maritime Academy, May 1969 Mr. Bergeron joined Public Service company of New Hampshire in May 1982 as Sen.' '- I&C Engineer in the Engineering Services Department.
His areas of responsiblity include coordination of IEC Engineering activities for the Station Staf f, Construction and Startup interf ace activities, as well as, various special projects.
Mr. Bergeron was recently appointed to the position of Instrumentation &
Cont cl 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 Terce.
He has been responsible for the coordination and review of the Equipment Qualification Program, as well as, coordinating the Laplementation 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 for Principle Instrument Application Engineer responsible,
specifying, purchasing and design review of electron and pneumatic instru.?.entation control systems.
Mr. Bergeron is also experienced in the scheduling and preparation of Logic Diagrams and System Descriptions which define t he functional control concepts.
He was also assigned as a task member to assist in the developnent and preparation of the 79-01B equipment qualification submittal for Duquesne Light company.
Detween 1969 and 1972 was employed by Gulf oil Corporation as an engineer in their Marine Engineering Division.
There he tas responsible for the operation and maintenance of Marine Power Plants.
s ATTACHMENT l-2 GERALD A. KOTK0WSKI ELECTRICAL ENGINEERING SUPERVISOR EDUCATION Bs Electrical Engineering, Northeastern University, June 1974.
Mt. Kotkowski joined PSNM in June 1982 as a Senior Electrical Engineer in the Engineering Services Department.
He was assigned to the Startup and Test Department as the System Test Engineer for the 13.8 KV, 4160 Volt, 125 Volt DC and Diesel Generator Electrical Systems and as the Lead Electrical Distribution Test Engineer.
Specific accomplishments include the preparation and parformance of the pre-operational acceptance tests for the DC Distribution and Diesel Generator systems, specific responsibilities included the review and approval of all design changes to the Distribution Systems and the subsequent implementation and testing of these changes.
i wCRX EXPERIENCE In June 1986, Mr. Kotkowski was appointed to the position of Electrical Engineering Supervisor in the j
Engineering Department.
His current responsibilities include 4
the supervision of Electrical Engineering and Design activities and technical support of field / construction activities.
He has overall responsibility for ensuring that i
o I
the electrical design of the plant complies with the codes and regulations specified in the Seabrook FSAR.
Mr. Kotkowski came to PSNH from Pow 1r Technical Services where he was amployed from June 1981 - April 1982 and was assigned as a Project Engineer to Boston Edison Company.
While in this position he had the overall responsibility for implementing an Emergency Response Facility program for the Pilgrim 1 Nuclear Station.
This program was designed to ensure technical adequacy and licensing compliance to current regulatory requirements including NUREG-0696, NUREG-0700 and Regulatory Guide 1.97, Revision 2.
Between March 1978 and May 1981, Mr. Kotkowski was employed by Stone & Webster Engineering as an engineer in the Electrical control Group.
While at stone & Webster Headquarters in Boston he was assigned to the Electrical Control Group on the Shoreham Nuclear Power Station Project as the engineer responsible for providing post accident instrumentation to meet the requirements of Regulatory Guide 1.97, Revistor. 2.
He also was designated as the cognizant engineer responsible for all controls associated with the Nuclear Steam Supply Systems as well as several other major modifications to Balance of Plant Systems.
While on a field assignment he was the only site representative for the controls Division at the Shoreham Nuclear Power Station.
He assumed complete responsibility l 4
I for the resolution of construction snd startup problems on all instrumentation and controls associated with an 850 MW Boiling water Reactor.
Specific responsibilities included medium and low voltage switchgear, motor control centers, protective relaying, control and relay panels, electronic analog instrumentation, pneumatic control loops and instrumentation tubing.
Also designated as the Interface Engineer between Nuclear Steam Supplier and the Architect Engineer.
Between December 1974 and February 1978, he was employed by General Atomic Engineering company.
While on a field assignment he participated in the rise to power program at the Fort St. Vrain Nuclear Power Station.
Specific accomplishments include:
tuning the major plant controllers, modifying the Plant Protective System and overall Plant control System as required to pass Reactor Scram and Turbine Trip testing, coordinating a task force to resolve the Nuclear Regul,atory Commission's concerns on cable segregation, and eliminating spurious control room alarms.
l While at General Atomic Headquarters in San Diego he was l
assigned to the control and Electrical Department.
He was responsible for the design of instrumentation and controls 1
for systems associated with the operation of a nuclear power l
plant.
He prepared control and instrumentation diagrams, l
3 l
l
schematic diagrams, cable tabulations, and instrument specifications.
Between December 1970 and October 1974 he was employed by stone & Webster on a student co-operative basis where he received various assignments in the Electrical control Department.
In summary, Mr. Kotkowski has fourteen (14) years experience in the electrical design and testing of nuclear power plants.
ce 00esS/1980 11839 FROM 70 l
ATTACHMENT l-3 PETER J. TUTINAS INSTRUMENTATION & CONTROL ENGINEER ENVIRONMENTAL QUALIFICATION ENGIST.ER EXPERIENCE
SUMMARY
Project Engineer with over ten (10) years of experience in the Instru=en-tation Engineering and Environmental Qualification of Nuclear Power Plants.
Re9ponsibilities have included the specifying and procurement of instru-ments, instrument racks and cabinets, related hardware including valves, reviewing vendors' and project drawings, reviewing specifications, interf ace with vendors and client, and interviewing potential employees. Prinary responsibilities hase been in the areas of instrument end tubing supports, and tubing installation criteria.
Extensive knowledge of USNRC Regulatory Cuides, IEEE Standards, AFNZ 111 Code, ANSI B31.1 Power Piping Code, and ASIM/ASME Material Specifications gained through applicstions of codes during development of instrueent installation details and environmental qualification activities.
Construction experience consisting of a one (1) year assignment at Waterford Unit No. 3 providing construction engineering support to the instrument installation contractor, augmented by an assignment as interia ESSE Lead Instrument Engineer.
Served at instrumentation lead engineer on the EMP-3 project in the home office.
Duties included budget, schedule and proposal preparation, along with completion and coordination of technical assignments.
Assignment to the Seabrook Project jobeits as a member of the client's Independent Keview Team. Responsible for reviewing the major A/E's site and home of fice I&C design, engineering and construction activities, and providing recommendations for completing work expeditiously, resolving Particular technical probless, increasing quality and reducing cost.
reviews includad as-constructed verification, calibration f acilities,
design fresse, employee allsgations, installation criteria, details, and Conducted daily meetings to resolve open engineering and een-supports.
struction issues. Tracked and expedited various tasks to assure their completion.
- Responsible for addressing the concerns of outside reviewing agencias (Duke, INF0, NRC, etc.); provided litigation support to the Client; provided recommandations for training.
Af ter completion of the Independent Review Team assignment, assumed duties in the A/E's 16C dite organization. Activities included A5ME IfJ Code Case use program, developing quality assurance and hydrotesting requirements, coordicating "N" stamping activities, establishing ASME KI requirenents and giving training in ASME II.
Af ter completion of the I&C assignment, assuned duties in the station's Corporate Engineering group, responsible for pre-paring the Environmental Equipment Qualification program manual.
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riin to P.J. TUTINAS Page 2 Experience Summary Meer joining New Hampshire Yankee, responsible for various Environnental Qualification (EQ) Program activities, including preparation of EQ file revision, development of maintenance requirements, preparstion and review of design changes, resolution of EQ technical issues. Project representa-tive in the Nuclear Utility Group to Environmental Qualification (NUGEQ).
REPRESENTATIVE'EIPERIENCE Client _
Projecc Size M
Position Plorida Power & Light St. Lucie Unit 890 MWe Nuchar Support Company No. 2 Carolina Power & Light Shearon-Barris 900 MWe Nuclear Support Company NPP Unit 1 & 2 Louisiana Power & Light Waterford SES 1163 MWe Nuclear Support Company Unit No. 3 Washington Public VNP-3 1300 MWe Nuclear Lead Power Supply System Public Service Co. of Seabrook 1190 MWe Nuclear Support New Hampshire Station EMPLOYMENT' HISTORY New Hampshire Yankee
- Project Engineer 1986 - Present Ebasco Services Incorporated 1977 - 1986 EDUCATION Polytechnic Instituto of Brooklyn - BSME - 1976 Brooklyn Technical liigh School - Machanical Technology Diploma Ebasco Courses including QA, Electrical Technology Seminar, Piping Traiaing Seminar, Contruction Practices, and Interviewing Techniques.
l Fisher Control valve Seminar, Fisher Power Seminar l
New Hampshire Tankee trais.ing including valve actuators, electrical f
terminations and EQ splices l
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ATTACHMENT l-4 JOE M. VARGAS MANAGER OF ENGINEERING EDUCATION:
COLUMBIA UNIVERSITY M.S. in Mech / Nuclear Engineering. Majored in Power Plant Engineering and Operations.
NEW YORK UNIVERSITY 3.5. in Nuclear Engineering. Recipient of the American Nuclear Society "Nuclear Engineering Avsed."
BRONX COHiUNITY COLLEGE A.A.S. in Engineering Science. Racipient of the "Phys!.cs Medal" and the "Engineering Science Award" (highest C.P.A. for Physics, Math and Chemistry combined).
PROFESSIONAL LICENSE:
Pegistered Professional Engineer fn the state of New York.
Registered Prof essional Engineer in the state of New Hampahire.
OPERATIONAL EDUCATION:
Completed advance coursa on W-PWR design at V Of fice in Pittsburgh.
Completed operater training course at Westinhouse Situulator Center in Illinois.
Completed Post-Graduate Waste Management Program at Georgia Tech.
11PERIENCE
SUMMARY
,1 1986 - Present PUBLIC SERVICE COMPANY OF NEW RAMPSHIRE Manager of Engineering Seabrook Nue. lear Generating Station Direct the activities of the multi-discipline Engineering Department to ensure that licensing, engineering, design and technical support for Seabrook Station is provided in a superior quality manner consistent with safety, applicable regulations, and good engineering practices.
Responsible for the technical and administrative performance of the Plant Engineering Department (which consists of Electrical, Instrumentation and Control, Structural, and Mechanical Engineering Groups) and the Engineering Services Department (which provides budgets, scheduling and administrative Responsible for the technical adequacy of all plant design f unct ions ).
modifications, safety evalaations, engineering technical procedures and engineering programs.
"seessettee stia6 reen 73 0.43 JOE M. VARGAS Page 2 E5ASCO SERVICES, INCORPORATED 1973 - 1986 Supervising Engineer Seabrook Nuclear Generating Station, Unit 1 Appointed to the Executive Review "eam, as the Engineering Representative, which reported to the Senior Viuc iresident. Responsible for monitoring overall engineering budget and schedule, and ensuring technical coapliance with the applicable codes and standards.
Responsible for all major engi-nearing programs (including Fire Protection, Environmental Qualification, SQRT, etc.), as well as monitoring all day-to-day engineering production activities.
Supervisor Mechanical Engineer St. Lucia 2 Nucisar Power Plant 1978-1984: Lead Mechanical Engineer directly responsible foc supervision of all Mach / Nuclear saf ety-related systema studies that encompassed all areas of engineering and plant operations. Directed the ef forts of many engineers, assistant engineers, and designers in these engineering studies and nade appropriate presentations to the client. Supervised preparation of bidding documents, bid evaluations, and corresponding procurenent recommendations.
Directly responsible for supervising of the Mech /Muclear discipline scope required to engineer and compile the FSAR for St. Lucie 2.
Generated and reviewed all FSAE sections to assure compliance with all applicable KRO Reg. Guides, Codes of Federal Regulation, ASME Codes, and Industry Standards.
POWER AUTHOKin' 0F THF. STATE OF NEW YORK 1976 - 1978 Lead Mechanical / Nuclear Engineer __
indian Point 3 Nuclear Power Plant Responsible for backfit engineering and design modifications of all the Mach and Nuclear systems, and nuclear-related f acilities. Directed the efforts Reviewed and of various architectural engineering firms and NSSS vendors.
approved all engineering requests received from Operations Department and Plant Staf f.
Established project positions and directed the ef forts of various architectural engineering firms to ef fect the above.
1972 - 1976 STONE & WI55 TEE ENGINEERING COLPORATION Machanical Engineer Engineered and designed many Mach saf ety and nonsafety-related systems for the Greene County Nuclear Power Plant. Responsible for sising and selection of all saf ety-related pumps, heat exchangers, valves, filters and associated piping for these systems.
Prepared and issued Systen Flow Reviewed all piping and Diagrams, Logic Diagrams, and Systes Description. Prepared all PSAR sections (tabl equipment diagrams for ISI per ASME XI.
and figures), responses to KRC quastions, and project position in accordance with 10CFR50, ASME 11I and ASME XI.
e eseea isse t6ier reen g
A_TTACMMENT NO. 1-5_
73ptytotALs RESPONS1sLI FOR DEVELOPING TtcM81 CAL RESPONSES TO NECNP'S FIRST $
OF INTERROGATORIES RISPONSIBLE INDIVIDUAL (S)
INTERROGATORY NO.
Bergeron 1
Bergeron 2
Sergeron 3
Sergeron Sergeron/Kotkowski 4
5 Bergeron 6
'Kotkowski/ Bergeron 7
Kotkowski 8
Kotkowski/5ergeron 9
Kotkowski 10 Kotkowski 11 Kotkowski 12 Kotkowski 13 Kotkowski 14 Kotkowski 15 Bergeron/Tutinas 16 Bergeron/Tutinas 17 Se r;...on/Tutinas 18 Kotkowski Sergeron/Kotkowski 19 Bergeron 20 Tutinas/Kotkowski 21 Sergeron/Kockowski 22 Ber5eron/Kotkowski 23 Bergeron/Kotkowski 24 25 Sergeron/Tutinas Berleton/Kotkowski
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16 27 l
. #$ ' he
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to ATTACHMENT NO. 1-6 INDIVIDUALS RESPONSI5LE FOR DEVELOFING TECHNICAL RESPONSES TO NICNP'S SECOND SE OF INTERROGATORIES RESPONSIBLE INDIVIDUAL ($1 INTERROCATORY NO._
Kotkowski 1
Kotkowski 2
Deraeron 3
Berge ron 4
Berge ron S
Feigenhaus 6
Sergeron 7
Bergeron/Kotkowski 8
Teigenbaum 9
i 6
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a ATTACHMENT NO. 1-7 Ted C. Feigenbaum Vice President of Engineering, Licensing and Quality Programs Joe M. Vargas Manager of Engineering Ins tru=entation and Controls Engineering Richard Berge ron Supervisor Electrical Ergineering Supe rvisor Gerald A. Kotkowski Project Engineer, Instrumentation and Controls Pete r J. Tutinas The business address of each of these individuals is Seabrook Station, Seabrook, NH 03874.
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- 0 METED L"M c C_ERTIFICATE OF SERVICE I,
Kathryn A. Selleck, one of the attorneys for Me ALE -8 P4 :58 Applicants herein, hereby certify that on August 5, 1988, I made service of the within document by depositing copjgs.
thereof with Federal Express, prepaid, for delivery 49C10Ew
,, 'h i' where indicated, by depositing in the United States mail,ER AE" first class postage paid, addressed to) the individuals listed below.
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.
Diane Curr&n, Esquire Luebke Andrea C.
Forster, Esquire 4515 Willard Avenue Harmon & Weiss Chevy Chase, MD 20815 Suite 430 2001 S Street, N.W.
Washington, DC 20009 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General Commission Offica 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 i
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2 Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney Generni Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T.
Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O.
Box 360 Boston, MA 02108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 Mi'y Hall Route 107
.~q ianiel Street Kensington, NH 03827 ucrv.smouth, NH 03801
- Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S.
Senate Lagoulis, Clark, Hill-Whilton &
Washington, DC 20510 McQuire (Attn:
Tom Burack) 79 State Street Newbu ryport, MA 0195>
- Senator Gordon J. Humphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn:
Herb Boynton)
Newbu ryport, MA 01950 Mr. Thomas F. Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 i
H. Joseph Flynn, Esquire Office of General Counsel Federal Emergency Management Agency 500 C Street, S.W.
Washington, DC 20472 Gary W.
Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 l i
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't Mr. Ed Thomas Judith H. Mizner, Esquire FEMA, Region I 79 State Street, 2nd Floor 442 John W. McCormack Post Newburyport, MA 01950 Office and Court House Post Office Square Boston, MA 02109 Charles P.
Graham, Esqu!re Murphy and Graham 33 Low Street Newburyport, MA 01950 t
Khghryn A.
Selleck p
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