ML19269D506
| ML19269D506 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/14/1979 |
| From: | Bell N AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML19269D505 | List: |
| References | |
| NUDOCS 7906040168 | |
| Download: ML19269D506 (4) | |
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TED CORRF2; pop,p c:1119 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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I$** \\h$7 4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 2
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a In the Matter of bS
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s FORTLAND GENERAL ELECTHIC
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Docket No. 50-344
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COMPANY, g al.
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(Control Building) 4
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(Trojan Nuclear Plant)
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CONSOLIDATED INTERVSORS ANSWERS TO INTERROGATORIES FP.0M THE LICDSEE - FIRST SET.
1.a.i. A1,1*. cable penetrations in the area of modifications are subject to a higher potential for fire.
1.a.ii.
Contention 2 clearly states that there is inadequate information on this.
PGE 1020 generally states that additional " housekeeping proceedures" will be esta-blished for fire protection. 41(a) Welding and protection against its fire po-tential was discussed in PGE 1020 5 3 11 and the site visit. Work'such as welding, increased accumulation of flammable materials and workers unfamiliar with the necessary precautions all could result in higher fire potential.
1.a.iii.
It is Intervenors understanding that PGE cable penet. cation fire stop tests have not been completed. Furthermore PGE's response to a document request on the fire tests of protective blankets and welding screens was not adequately answered. Thus it remains unclear if such measures will actually improve, rather than degrade, present cable penetration fire stop ability.
1.a.iv.
(i) PGE 1020, site visit, 10 CFR 2.732, 50 40, 50 57, 50 97., and mmmon sense.
(ii) see above, PGE 1012, creative imagination (necessary to anticipate problems)
(iii) general information.
l.c Site visit.
1.d.i.
The specific bases to agree or disagree with the following staements have not been provided: (From PGE 1020) 5 3 15 " Performance of the modification........ emergency function."
".....an access path will be maintained in this area at all times."
page 5-11 Paragraph Two.
1.d.ii.
Information required: 1) present access used by fire brigades including the room necessary and the access routes t.nd the equipment used; 2) the work schedule indicating when and how access routes will be impaired or blocked a 2260 O
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. (1.d.ii) routes available; 3) the sixe of equignent, excavations, storage of construction materials that will be present in these areas during the modifications.
1.d.iii Removal of structures and installation of others, use of large equipment for the modifications all muld block access of fire brigades.
1.d.iv.
(i) see 1.a.iv (i),
(ii) see 1.a.iv (i)
(iii) see 1.a.iv (ii).
2.a Sections 5 2
" Equipment, components......will remain qualified..... modification work."
"If any modifications..... perfomed."
Appendix B*
1 2 "Any modifications.....will. be made."
1 3(b)(c) 3 0 Paragraph 2 3 0 Paragrph 3, " Table 3 7-2 of the FSAR......individaul equipcent."
4.0 Paragraph 2, " Modifications to piping...... modification program."
5.0 Last paragraph 60 2.b Scope of infomation required includes: proof of original qualification of safety related euqipestn, piping, systems and components details on identifying and implementing work schedules such that it is guaranteed that modifications are perfomed and perfomed at the point when stated in Appendix B.
2.c (a) see 1.a.tv (i)
(b) see 1.a.iv (i)
- 3. a see 1.d. i 3.b Licensee is in a psition to better answer this interrogatory. It serves no useful purpose to answer this when the information provided in PCE 1020 does not fully reflect the scope of the modifications.
3.c Removal of structures could impair fire brigade access; destroy safety systems; impair the ability of plant operators to perform emergency functions outside of the Control Room.
3.d See (c) above. More details will be forthcoming when the work plans for modification are made more specific.
Intervenor believes such troubleshooting and planning for possible error should be initially the burden of the Licensee.
3.e Damaging of safety systems, hampering of access with materials and equipment and structural changes could affect the ability of the operators. For instance, certain accidnet scenarios necessitate operators perfocing functions a. local 2260 073 6
(3.e) stations. Should such actions be precluded while modifications are underway?
Intervenor belives not.
If personnel actions are the 1st line of defense, they should not be hampered.
3.f see (e) above.
3.g (a) see 1.a.iv (i)
(b) NA (c) see 1.a.iv (i), (ii), (iii)
(d) see see 3.d and 3.e (e) same'as above (f) same as above 4.a 5.3 11 paragraph 2 " Suitable precuations...... theses arc c" page 5 9 Paragraphs 2 and 3 4.b Design details of 21) steel plate and 2) equipment used for its installation and
- 3) protective devices. More specific analyses of the effect of equipment failure and a p pstulated accident sequence in case of gross failure of equipment.
4.c (a) see 1.a.iv (i)
(b) see 1.a.iv (i)
- 6. a see 1. a.11, 1. a.iii, 1.d.1, 3. a, 3.c, 3.d, 4.a 6.b see 1. a. iii, 1.d. ii, 1.d. iii, 2.b, 3. c, 3.e, 4.b If Licensee provided detailed and labelled drawings of all areas which will be affected by modification work and a list of equipment, piping, and components in the area including their function, location and what kind of work will be done in the vicinity of' all such safety-related equipment, cables, components and piping.
Lienesee should assume an investigative role in this.
6.c Having never alleged an inadequacy of Licensee's ability, Intervenor concludes this is a defensive question. However, Licensee's inability to troubleshoot, identify and resolve problems and to anticipate and correct warly warning signs are docum documented in NRC reports and letters written to PGE from the Oregon Department of Energy.
6.d Intervenor alleged inadequate infor=rion on which to proceed to analyse this' situation.
6.e (a) see answers to 1. a.iv, 1.d.iv, 3.g (b) see 1.a.iv, 1.d.iv, 2.c, 3.g, 4.c (c) none (d) none
7.a Inadequate information to assess the following:
5.3.4 "Other precautions.... steel."
"Further..... co nt acted. "
"When the location
..... capacity."
Furthermore Intervenor questions the advisability of some of the suggested practicles.
7.b Analyses to support enclusory statements in 5 3 4 and design details of the drilling.
7.c (a) see 1.a.iv (i)
(b) see 1.a.iv (i) 8.a &b Licensee has not provided sufficiently detailed design and work plans.
Liensee has not sufficiently analysed the potential safety hazards of modificatin work nor done a complete analysis of the effect of the modifications on the structural integrity of the compler.
9.a & 9.b see answers to 8 above 13 see answers to 8 above.
14 site visit.
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Dated this day the
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14th of April,1979 Nina Bell, pro se '
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Consolidated Intervenors.
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1 PCRfLAUD 1 .ZL CL20f?.IC C' ' ' AhT et 'l.
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Occhet 50-3W+
(Tro..*sn Nuclear Plant)
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Certific1tn of dervice I hereby certify that copies of Intervenors Responses to PGE Interroratories and Intervenors Reponses to NRC Staff Interrogatories have been delivered by U.S. Postal Service or by hand upon te persons listed below.
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Marshall E. Millce, Erq., Chairman Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panci U. S. Nuclear Regulatory Commission U. S. Nuclear Scgulatory Com=ission Washington, D. C.
20555 Washington, D. C.
20555 Dr. Kenneth A. McCollom, Dean Atomic Safety 'and Licensing Appeal Division of Engineering, Board Architecture and Technology U. S. Nuclear Regulatory Commissior Oklahoma State University Washington, D. C.
20555 Stillwater, Oklahoma 74074 Robert M. Johnson, Esq.
Dr. Hugh C. Paxton Assistant Attorney Cencral 1229 - 41st Street 100 State Office Building Los Alamos, New Mexico 97544 Salem, Oregon 97310 Joseph R. Gray, Esq.
Robert Lowenstein, Esq.
Counsel for NRC Staff Lowenstein, Newman, Reis & Axelrad U. S. Nuclear Regulatory Commission Suite 1214 Washington, D. C.
20555 1025 Connce ricut Ave., N. W.
Washington, D. C.
20036 Columbia County Courthouse Law Library Mr. Eugene Rosolie Circuit Court Room Coalition for Safe Power St. Helens, Oregon 97051 215 S. E. 9th Avenue Portland, Oregon 97214
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.QP")5)((3, Mr. John A. Kullberg s
Route 1, Box 250Q
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Sauvic Island, Oregon 97231
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2260 076 Docketing and Service Section William Kinsey, Esq.
Of fice of the Secretary Bonneville Power Administration U. S. Nuclear Regulatory Commission P. O. Box 3621 Washington, D.
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20555 Portland, Oregon 97208 s0
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Dated this day, the 15th c f April,1979.
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