ML20023A795
| ML20023A795 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/13/1982 |
| From: | Curran D, Jordan W HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| Shared Package | |
| ML20023A796 | List: |
| References | |
| NUDOCS 8210200026 | |
| Download: ML20023A795 (14) | |
Text
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UNITED STATES OF AMEP.ICA 00CMETED' NC NUCLEAR REGULATORY COMMISSION BEFORE Tile ATOMIC SAFETY AND LICENSING BOlthp g jg g g C"RCI r gre.:n c 71. :,;,,-
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In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443 NEW HAMPSHIRE, et al.
)
50-444
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(Seabrook Station, Units 1
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and 2)
)
)
NECNP FIRST SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS TO APPLICANTS ON CONTENTIONS I.A.2.,
I.B.l.,
I.B.2.
AND I.C.
INSTRUCTIONS FOR USE The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the Applicants with personal knowledge of the facts or information requested in each interrogatory.
The following definitions shall apply to these interrogatories:
i 1.
" Document" shall mean any written or graphic matter of l
communication, however produced or reproduced, and is intended to l
be comprehensive and include without limitation any and all corres-pondence, letters, telegrams, agreements, notes, contracts, instruc-tions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer print-outs, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists,.
publications, drafts, telephone minutes, minutes of meetings, state-l ments, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.
W 82102000.% 6 T)SO3
2 2.
" Identify" shall mean with respec't to any document, to state the following respecting the document:
its title, its date, the author of the document, the person to whom che document was sent, all persons who received or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any and all copies of the document.
j 3.
" Identify" with respect to any action or conduct shall mean state the following regarding any such action or conduct:
the i
person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; any document recording or documenting such action.
I 4.
" Describe" with respect to any action or matter shall mean state the following regarding such action or matter:
the substance or nature of such action or matter; the persons participating in or having knowledge of such action or matter; the current and past business positions and addresses of such persons; the existence and location of any and all documents relating to such action or matter.
Contention I.A.2.
1.
What is the Applicants' position with respect to NECNP Contention I.A.2.?
State all facts and opinions and identify and provide access to all documents on which that position is based.
2.
Identify all individuals whom Applicants expect to call as witnesses with respect to NECNP Contention I.A.2., and identify all documents on which the Applicants expect to rely at
)
the hearing with respect to this contention.
3 3.
Describe the location, function, and purpose of all electric valve operators installed inside the containment.
a.
For each electric valve operator, state its function in the event of a loss of ecolant accident (LOCA).
b.
For each such electric valve operator, state its purpose or function, if any, in preventing a LOCA.
c.
For each such electric valve operator, describe the degree, if any, and the manner in which it contributes to the safety of the facility.
d.
Identify those electric valve operators installed inside the containment that Applicants consider to be " safety related."1/
e.
Identify those electric valve operators installed inside the containment that Applicants do not consider to be
" safety related."
Of those, state which ones Applicants consider to be "important to safety."2/
In each case, explain why Applicants do not consider the electric valve operator to be " safety related" or "important to safety" if they do not.
4.
Identify all electric valve operators installed inside the containment that Applicants believe are required to comply with Criterion 4 of 10 CFR part 50, Appendix A.
a.
Identify those electric valve operators installed inside the containment that Applicants believe are not required to comply with GDC 4.
In each case, explain why compliance is not required.
1/ The term " safety-related" has the same meaning throughout these nterrogatories as it does in the Introduction to Appendix B to 10 CFR Part 50.
Ifs the meaning of the term as used by Applicants in the FSAR is differenttfrom Applicants' understanding of the meaning of the term as used in Ahpendix B, please explain the difference, and whenever the term " safety lrelated" is used in these interrogatories, please respond separately for each meaning.
2/ The term "importar# to safety" has the same meaning throughout these fnterrogatories as it does in the Introduction to Appendix A to 10 CFR Part 50.
4 5.
Identify all electric valve operators installed inside the containment that Applicants classify as Class IE equipment, as the term is used in the preamble to the propos'd rule on environ-mental qualification, 47 Fed. Reg. 2876, 2877 (January 20, 1982).
a.
Identify any additional electric valve operators installed inside the containment that Applicants believe would be governed by PR 10 CFR 50.49(c), Id. at 2878.
b.
If Applicants have prepared the list that would be required by PR 10 CFR 50. 49 (d), or if Applicants have developed a similar list of electrical equipment that must be environmentally qualified, identify and provide a copy of all documents in the possession or control of Applicants or their agents, contractors, or employees, that analyze or discuss the scope of the require-ments of GDC 4 with respect to environmental qualification or that in any way discuss the issue of environmental qualification, 6.
Is it Applicants' position that all safety related electric valve operators installed inside the containment comply with GDC 4?
a.
It is Applicants' position that all safety related electric valve operators installed inside the containment comply with the Division of Operating Reactors' " Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactors"
(" DOR Guidelines")?
b.
Is it Applicants' position that all safety related electric valve operators installed inside the containment comply with NUREG-0588?
l l
7.
Identify each safet3 related electric valve operator i
l installed inside the containment that does not comply with the l
DOR Guidelines or NUREG-0588.
5 a.
For each such electric valve operator, state whether Applicants believe it complies with GDC 4 and justify that position in light of the noncomplionae with the DOR Guidelines and NUREG-0588.
8.
Answer Questions 6 and 7 with respect to electric valve operators installed inside the containment that Appiscants consider to be "important to safety."
3 9.
Is it Applicants' position that compliance with IEEE i
Standards 382-1972 and 323-1974 constitutes compliance with GDC 4?
10.
Identify the suppliers from which Applicants have obtained or will obtain the electric valve operators installed inside the containment that Applicants believe assert comply with IEEE 323-1974.
Explain how such commercially available equipment can comply with IEEE 332-1974 when the Commission stated in CLI-80-21 that there was at that time no commercially available equipment that complies l
with IEEE 323-1974.
11.
Have Applicants undertaken any examination of the Three l
Mile Island accident in order to determine how the knowledge gained from that accident affects actions that may be required to comply with GDC 4 or otherwise to assure that equipment is adequately qualified to withstand the effects of an accident?
If so, identify and provide access to all documents related to any such examination or study.
In addition, identify all actions of any sort taken by Applicants as a result of the TMI accident with respect to the issue T
of environmental qualification.
12.
Identify the parameters of the accident environment for which the electric valve operators installed inside the containment I
have been qualified.
I l
l i
6 a.
Explain the basis for that choice of accident environment parameters.
For each parameter, explain how it differs from the accident environment that existed during and after the accident at Three Mile Island Unit 2.
13.
Describe specifically how it was determined that the electric valve operators in question could survive the accident environment identified in response to Question 12.
a.
Identify and provide access to all documents reflecting testing or calculations done for the purpose of making this determination or otherwise relied upon or referred to in connection with making this determination.
Identify and describe any actual environmental conditions that were created for test purposes and to which electric valve operators were subjected.
In each case, identify the length of time that the electric valve operators were subjected to the simulated accident environment.
Where and when were these tests performed?
In each case, how many electric valve operators were tested?
Of those, how many'were of the same design as those to be used at Seabrook?
14.
State the length of time that Applicants contend the electric valve operators installed inside the containment will remain environmentally qualified and capable of withstanding the effects of an accident should one occur.
a.
Explain the basis for this statement.
b.
Identify all documents on which Applicants rely or to which they have referred in making this statement.
c.
Identify all tests or studies of any sort of which the 4
Applicants are aware in which any electrical equipment has been ys,-
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7 examined after more than one year of use to determine whether it is still environmentally qualified.
15.
State the length of time after an accident has occurred that Applicants contend the electric valve operators installed inside the containment will continue to withstand the effects of an accident and perform effectively after an accident has occurred and they have been subjected to the accident environment.
a.
Explain the basis for this statement.
b.
Identify all documents on which Applicants rely or to which they have referred in making this statement.
16.
Describe specifically how the effects of aging of the equip-ment and cumulative radiation exposure have been considered in determining both whether the electric valve operators installed inside the containment are environmentally qualified and whether they will remain environmentally qualified for the life of the plant.
17.
Have the Applicants prepared the analysis that would be called for by PR 10 CFR 50.49 (k) to assure safe reactor operation pending full compliance with all environmental qualification requirements?
If so, please identify and provide access to that document and all documents on which it is based, to which it refers, or that are otherwise related to it.
l Contention I.B.l.
18.
What is the Applicants' position with respect to NECNP Contention I.B.1?
State all facts and opinions and identify'and provide access to all documents on which that position is based.
a.
Identify all individuals whom Applicants expect to call as witnesses with respect to NECNP Contention I.B.l.,
and identify _
all documents on which Applicants expect to rely at the hearing with respect to this contention.
8 19.
Identify all systems that perform the function or are
+
r required in order to perform the function of residual heat removal under any circumstances.
For each system, explain how and under what circumstances it performs or contributes to the function of residual heat removal.
20.
Is it the Applicants' position that a system that performs the function of residual heat removal or that is required in order to perform that function is not, by virture of that fact, safety related?
21.
Is it the Applicants' position that a system that performs the function of residual heat. removal or that is required in order to perform that function, is not, by virtue of that fact, important to safety?
22.
If it is Applicants' position that the fact that a system performs the function of residual heat removal or is required in order to perform that function does.not, by itself, render the system either safety related or important to safety such that it must be environmentally qualified pursuant to GDC 4, do Applicants believe that there is any system or situation in which the function of heat removal by itself renders the system subject to GDC 4 and requires that it be environmentally qualified?
a.
Identify all such systems.
b.
Explain the principle that distinguishes some heat removal i
functions from others for the purpose of environmental qualifica-tion.
23.
For each system identified pursuant to Question 18, state whether the Applicants believe all or part of the system is safety l
related.
i
9 a.
Where the Applicants believe all or part of a system to be safety related, identify those parts of the system the Applicants believe to be safety related.
b.
Where the Applicants believe all or part of a system is not safety related, identify those parts that Applicants believe are not safety related and state the justification for that position.
Identify and provide access to all documents relied upon by Applicants in reaching that position or other-wise related to the issue of environmental qualification of the equipment in question.
24.
For each system identified pursuant to Question 17 and not identified pursuant to Question 22(a), state whether Applicants believe all or part of the system is important to safety.
a.
Where the Applicants believe all or part of a system 8
to be important to safety, identify those parts of the system that Applicants believe to be important to safety.
s b.
Where the Applicants believe all or part of a system is not important to safety, identify those parts that Applicants believe are not important to safety and state the justification for that position.
Identify and provide access to all documents relied upon by Applicants in reaching that position or otherwise related to the issue of environmental qualification of the equipment in question.
25.
Have the Applicants undertaken any examination of the accident at Three Mile Island in order to determine which systems i
that perform or contribute to the function of residual heat removal should be-environmentally qualified in order to comply with GDC 4 i
?
l I
10 or for any other reason?
If so, please identify all individuals involved and identify and provide access to all documents related to such examination.
26.
Identify the parameters of the accident environment for which systems that perform or contr to the residual heat removal function have been qualified.
a.
Explain the basis for that choice of accident environment parameters.
For each parameter, explain how it differs from the accident environment that existed during and after the accident at Three Mile Island Unit 2.
27.
Describe specifically how it was determined that systems that perform or contribute to the residual heat removal function in question could survive the accident environment identified in response to Question 26.
a.
Identify and provide access to all documents reflecting testing or calculations done for the purpose of making this determination or otherwise relied upon or referred to in connection with making this determination.
Identify and describe any actual environmental conditions that were created for test purposes and to which systems that perform or contribute to the residual heal removal function were subjected.
In each case, identify the length of t.ime that the systems that perform or contribute to the residual heat removal function were subjected to the simulated accident environment.
Where and when were these tests performed?
In each case, how many heat removal systems were tested?
Of these, l
how many were of the same design as those to be used at Seabrook?
i f
I
11 28.
State the length of time that Applicants contend the systems that perform or contribute to the residual heat removal function will remain environmentally qualified and capable of withstanding the effects of an accident should one occur.
a.
Explain the basis for ths statement.
b.
Identify all documents on which Applicants rely or to which they have referred in making this statement.
c.
Identify all tests or studies of any sort of which the Applicants are aware in which any electrical equipment has been examined after more than one year of use to determine whether it is still environmentally qualified.
29.
State the length of time that after an accident has occurred, 4
Applicants contend the systems that perform or contribute to the residual heat removal function will continue to withstand the effects of an accident and perform effectively after an accident has occurred and they have been subjected to the accident environment.
a.
Explain the basis for this statement.
b.
Identify all documents on which Applicants rely or to 1
which they have referred in making this statement.
i Contention I.B.2.
30.
What is the Applicants' position with respect to NECNP Contention I.B.2?
State all facts and opinions and identify and provide access to all documents on which that position is based.
a.
Identify all individuals whom Applicants expect to call as witnesses with respect to NECNP Contention I.B.2., and identify all documents on which Applicants expect to rely at the hearing with respect to this contention.
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12 31.
Is it the Applicants' position that structures, systems, and components governed by GDC 4 must be able to accommodate the effects of and be compatible with the environmental conditions associated with loss of coolant accidents'throughout the operating lifetime of the plant?
a.
If not, state how long the Applicants believe that structures, systems, and components governed by GDC 4 must be able to accommodate the effects of and be compatible with the environmental conditions associated with loss of coolant accidents.
If the response is different depending upon the structure, system, or component in question, provide the specific information.
In each case, explain the basis for the Applicants' position and identify and provide access to all documents referred to in reaching that position or otherwise relevant to the issue.
b.
If so, identify all structures, systems, and components governed by GDC 4 that Applicants contend comply with that i
requirement.
In each case, explain the basis for that contention and describe in detail the methodology employed to determine whether the structure, system, or component complies with the requirement that it remain environmentally qualified throughout the operating lifetime of the reactor.
32.
To the extent that Applicants contend that structures, I
systems, or components will remain in compliance with GDC 4 and environmentally qualified for any period of time less than the operating lifetime of the plant, explain the basis for that contention and describe in detail the methodology employed to l
L-
13 determine that the structure, system, or component will remain environmentally qualified for the time period in question.
33.
Have the Applicants made any effort to determine how long after a LOCA begins and an accident environment is created structures, systems, and components governed by GDC 4 will remain capable of accommodating the effects of and continue to be compatible with the environmental conditions associated with a LOCA?
If so, please describe that effort, identify and provide access to all relevant documents, and state the conclusions reached by Applicants concerning this question.
Explain the basis for each such conclusion.
34.
Is it the Applicants' position that they need not establish that structures, systems, or components governed by GDC 4 will remain environmentally qualified for any period of time once an accident begins?
If not, for what period of time do the Applicants contend they must show that structures, systems, and components governed by GDC 4 will remain environmentally qualified once an accident begins?
Contention I.C.
35.
What is the Applicants' position with respect to NECNP Contention I.C.?
State all facts and opinions and identify and provide copies of all documents on which that position is based.
a.
Identify all individuals whom Applicants expect to call as witnesses with respect to NECNP Contention I.C.,
and identify all documents on which Applicants expect to rely at the hearir g with respect to this contention.
e
14 36.
Identify all components of the llVAC system for the emergency feedwater pumphouse, a.
Describe the function of each component in the event of a LOCA.
b.
Identify and describe all components that Applicants believe must be environmentally qualified pursuant to GDC 4.
In each case, state whether the Applicants contend that the component is environmentally qualified and the basis for that conclusion.
1 c.
Identify and describe all components that Applicants believe are not required to be environmentally qualified pursuant to GDC 4.
In each case, provide the justification for this conclusion.
Identify and provide access to all documents that support this conclusion, or that otherwise related to the issue of whether the component in question should be environmentally qualified.
Respectfully submitted,
.L J / Q J"ig:
William S# Jordan, III i
S-D Diane Curran HARMON & WEISS 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006 (202) 833-9070
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