ML20023D084
| ML20023D084 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/16/1983 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 ISSUANCES-OL, NUDOCS 8305190199 | |
| Download: ML20023D084 (5) | |
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FILED:
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UNITED STATES OF AMERICA og NUCLEAR REGULATORY CDN1 MISSION p BEFORE THE ATOMIC SAFETY AND LICENSINO-BOARD i,
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PUBLIC SERVICE WMPANY OF Docket Nos.
3 ',O L NEW HAMPSHIRE, et al N0 4 4'4 OL (Seabrook Station, Units I and 2)
SAPL'S MOTION TO AMEND PETITION TO INTERVENE Pursuant to 10 C.F.R. 2.714(a)(3), the Seacoast Anti-Pollution League (SAPL), moves to amend its Petition to Intervene by adding Contention SAPL Supp. 7, " Instrumentation for Detection of Inadequate Core Cooli ng"..As discussed inf ra, this filing meets the Commission's standards for amending petitions to intervene found at 10 C.F.R. 62.714(a)(1)(i-v).
SAPL CONTENTION SUPP. 7, " INSTRUMENTATION FOR DETECTION OF INADEQUATE CORE COOLI NG. "
The Applicant has not provided information in response to NUREG-07 37 I tem II.F. 2, " Instrumentation for Detection of Inadequate Core Cooling".
Acceptable documentation detailing compliance with four subject areas indicated in II.F.2 must be provided by the Applicant and approved by the NRC Staff prior to issuance of an operating
- license, l
Basis: On Oc tober 31, 1980, Darrell G. Eisennut, Director, Division of Licensing, Of fice of Nuclear Reactor Regulation of the U.S. Nuclear Regulatory Commission issued a letter to all licensees of operating plants and applicants for operating licenses and holders of construction permits in the form of NUREG-0737.
(Clarification of kh h
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cet ion plan requirements f or all applicents f or en operating Ilcense, i
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including Public Service Company of New llampshire.
Item II.F.2 describes four subject areas in regard to instrumentation for detection of, inadequate core cooling.
The subject areas include
. procedures inst ruments and a subcooling meter, as well as installat ion and descriptions of additional instrumentation.
The Staff's position with respect to this item was straightforward.
NUREG-0737 provides that:
Licensees shall provide a description of any additional instrumentation or controls (primary or backup) proposed for the plant to supplement existing instrumentation (including primary coolant saturat ion moni tors) in order to provide an unambiguous, easy to interpret indication of inadequate core cooling (ICC).
A description of the functional design requirements for the system shall also be included.
A description of the procedures to be used with the proposed equipment, the analysis used in developing these procedures, and a schedule for installing the equipment shall be provided.
(See NUREG-0737, pg. 3-113.)
in addi t ion, the Staf f art iculated ten points of clar i ficat ion, among them the requirement that the evaluat ion must include reactor water-level indication.
(Id., pg. 3-114.)
All the clarification points provided for in the letter are straightforward, mandatory requirments of the Applicant which were i
to have been implemented by January 1, 1982.
Yet, in spite of that requirement, the Applicant still has provided no information whatsoever on this issue.
As stated in the Saf ety Evaluation Repor t issued by the Staff in March,
- 1983, acceptable documentation l
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.L satisfying these requirements must be provided before an operating license can be issued.
Justification for Late Filing Pursuant to 10 C.F.R. 62.714(a).
This contention is filed as the result of SAPL's ongoing review of the Staff's Safety Evaluation Report, issued in March of this year.
The SER clearly indicates that the Applicants are not in compliance with the above stated requirements, and because this information was not previously available to SAPL, good cause exists
'f o r filing this contention at this time.
During the seven' weeks since publication of SER, no prejudice has occurred as a result of SAPL's not having filed this contention any earlier, because the SER has put Applicant's on notice that their ICC instrumentation compliance with NUREG-0737 has yet to be demonstrated.
(SER at 4-32.)
In addi t ion, there are no other means by which SAPL's interest in-this matter can be protected.
- Moreover, litigation of this contention will not cause significant delays in the proceeding. SAPL is merely seeking straightforward compliance.with the Action Plan requirements as articulated and clarified in NUREG-0737.
The Applicants have been on notice since the issuance of that document about what they must comply wi th before issuance of an Operating License.
If any aspect of this particular issue causes delay in the issuance of an Operating
- License, i t will be because l
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L the Applicants have not provided the NRC Staf f with all the information necessary to satisfy the requirements of the Action Plan.
For all these reasons set f or th, SAPL urges that the Board adopt SAPL Content ion Supp. 7 in i ts present form and require the Applicants to meet the applicable requirements concerning i nstrumentation for detection of inadequate core cooling in the course of these hearings.
Respectfully submitted, Seacoast Anti-Pollution League By its attorneys, BACKUS, SHEA & MEYER e
By:
_I/W Rob e r.t A.
Backus
'116 Lowell St.,
Box 516 Manchester, N.H.
03105 Tel:
(603) 668-7272 May 16, 1983
L CERTIFICATE OF SERVICE Helen lloyt, Chm.
Thomas G.
Dignan, Esq.
Admin. Judge Hopes and Gray
~
Atomic Safety & Lic. Ap.
225 Franklin Street Board - U.S. NRC Boston, MA 02110 Washington, DC 20555 Dr. Jerry Harbour Admin. Judge.
Docketing and Service Sec.
Atomic Safety LLic. Ap.
Office of the Secretary U. S. NitC Board - U.S.
NitC Washington, DC 20555 Washington, DC 20555 Roy P. Lessy, Jr., Esq.
Robert L. Chiesa, Esq.
Office of Executive 95 Market Street Legal Director U.S. NilC Manchester, Nil 03101 Washington, DC 20555 Phillip Ahrens, Esq.
Asst. Atty. Genera]
Jane Doughty State House, Station #6 Field Director 33pg Augusta, ME 04333 5 Market Street Portsmouth, NH 03801 Anne Verge Chairperson
,g Board of Selectnrn
'Ib','.u Hall ALIorney General's Office So !!ampt on, Nil 03812 State of New Ilampshire Concord, Nil 03301 Dr. Emmeth A.
Luebke
- David it. Lewis Admin. Judge Atomic Safety & Lic. Brd.
Atomic Safety & Lic. Ap.
U.S. NRC - Ilm. E/W-430 Board - U.S. NRC Washington, DC 20555 Washington, DC 20555 Jo Ann Shotwell, Asst. AG Calvin A. Canney, One Ashburton Place, 19th Ci ty Hgr.-City liall Floor 12G Daniel Street j
Boston, MA 02108 Portsmouth, Nil 03801 l
William S. Jordan, II, Esq.
Ituthanne G. Miller, Esq.
l Ellyn R. Weiss, Esq.
Law Clerk to the Board l
1725 I Street, N.W.
Atomic Safety & Lic. Brd.
Suite 506 USNIIC Washington, DC 20006 Washington, DC 20555 Dr. 4nay Tye, President.
Sun. Valley Assoe.
08 Iherson St reet.
l Itaverhill, MA 01830
..