ML20028E353
| ML20028E353 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/17/1983 |
| From: | Bisbee G, Fan S, Kinder E NEW HAMPSHIRE, STATE OF, NEW HAMPSHIRE, UNIV. OF, DURHAM, NH |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| NUDOCS 8301210256 | |
| Download: ML20028E353 (48) | |
Text
RELA,TED CORRESPONDMtBN ,
s -
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- - DOCKETED pp;c r .
Before the *S3 #!!20 f.'0 28 ATOMIC SAFETY AND L1 CENSING BOARD
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In the matter of: ' )
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PUBLIC SERVICE COMPANY OF NEW EAMPSHIRE) Docket Nos.: 50-443 ET AL. ) and
) 50-444
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(Seabrook Station, Units 1 and 2) ) January 17, 1983 THE STATE OF NEW HAMPSHIRE'S RESPONSE TO THE APPLICANT'S INTERROGATORIES AND REQUESTS FOR THE PRODUCTION OF DOCUMENTS FILED DECEMBER 8, 1982 ,
INTRODUCTION The following constitutes the State of New Hampshire's Response to the Interrogatories and Requests for the Production of Documents by the Applicant. As is indicated at several points in the Interrogatories, New Hampshire has not yet finalized its position with regard to certain of the contentions admitted in this proceeding., New Hampshire's l inability to finalize its position is often due to the fact I that the Applicant and NRC Staff have not completed reviews and preparations of documents which New Hampshire feels are essential to be reviewed before our position on the contention can be finalized. Therefore, in those instances, New Hampshire ,
reserves its right to supplement these snswers as additional information becomes available from the Applicant and Staff.
New Hampshire is mindful of its obligation to supplement the enswers when appropriate under 10 C.F.R. 52.740(e).
The Applicant ha9 set forth general Interrogatories, G1 l
through G3. We interpret these to be in the nature of directions for answering the specific interrogatories and, therefore, we have included in the answers to the specific interrogatories the information requestad by the general l interrogatories.
9301210256 830117 PDR ADOCK 05000443 C PDR d
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ANSUERS TO EPECIPIC INTERROGATORIES -
Contention NH-9 Radioactivity Monitoring I-l Yes.
I-2 With regard to General Design Criteria 63, New l Hampshire has not yet completed its review of the system's ability to detect conditions that may result in loss of tesidual heat removal capability. As soon as this review is completed, this answer will be supplemented. .
With regard to General Design Criteria 64, New Hampshire has not received complete information concerning compliance of the post-accident monitoring instrumentation with Regulatory Guide 1.97(2). Thus, we are not in a position to identify in detail the aspects of the monitoring program which fail to meet the requirements of General Design Criteria 64.
With regard to NUREG-0737, the Applicant has not produced a completed submission demonstrating comp]iance with SSII.B.2, II.B.3, II.F.1, III.D.1, III.D.3, and III.D.4. Thus, we are unable at thi6 time, as is the NRC Staff, to identify instances of non-compliance with the requireroents of NUREG-0737.
With regard to NUREG-0800, New Hampshire has not yet evaluated compliance with NUREG-0000.- This answer will be supplemented when the review of this regulatory document is complete.
I-3 Because we do not have complete information at this "'
time, we cannot identify all changes, additions, or deletions which would satisfy applicable regulatory requirements.
I-4 New Hampshire has not yet identified which, if any, witnesses it will offer with respect to this contention.
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s G-1 Since New Hampshire has not yet finalized its position with regard to Contention NH-9, we cannot provide a complete list of documents which may provide the basis for our position. However, we can provide a partial list which is set forth below:
NUREG-0737 Sections II.B.2, II.B.3, II.F.1, III.D.l.1, III.D.3.3, III.D.3.4, NUREG-0800 GDC-63 GDC-64 Regulatory Guide 1.97 FSAR Ch. 6.4, 7, 9.4, 11, 12, 15 All documents provided by the A.pplicant in response to New Hampshire's Interrogatories on Contention NH-9 W.W. Weaver, Aging Techniques and Qualified Life for Safety System Components, Nuclear Safety, Vol. 21, p.51, January 1980, Report of the President's Commission on the Accident at Three Mile Island.
G-2 At this time, the State's' answers are not based on any type of study, calculation, or analysis other than a review of the information contained in the above-mentioned documents. The review has been performed to date by Dr. Stephen S. T. Fan and Mr. William Dotchin. The curriculum vitae of Dr. Fan and Mr. Dotchin are attached to these Interrogatories as Attachments A and E. Also working with Dr. Fan on these matters generally are D . Filson H. Glanz and Mr. William Mosberg, whosr curriculum vitae are attached as Attacuments C and D.
G-3 The above answers have been developed through conversations among Dr. Fan, Mr. Dotchin, and Assistant Attorney General E. Tupper Kinder, in various meetings between August 1982 and the date of these answers. The answers are not based upon any communications with other individuals.
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N,-
Establishing Priorities in Control Room Design -
Review, E.L. Zebroski, M.E. Maddox, P.E. Dietz, Nuclear Engineering International, July 1982, pp. 30-34 II-8 New Hampshire believes that changes to control room design and procedures should result from a thorough V Control Room Design Review, including human factors N and task analysis. New Hampshire has not performed
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such an analysis since this is the responsibility of a the Applicant under 0737, I.C.1, I.D.1, and I.D.2.
Once a Control Room Design Review is produced and New Hampshire has an opportunity to review it, New Hampshire will comment on the proposed upgrading of control room design and procedures.
II-9 As far as is known to New Hampshire, every nuclear m power plant in the United States is required to dO. perform'a Control Room Design Review and/or Assessment.
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.II-10 When specific changes in control room design are proposed as a result of a Control Room Design Review and of the development of procedures for transients and accidents as required by NUREG-0737, I.C.1, New Hampshire will be in a position to review such changes for possible off-setting negative effect on control room efficiency or operator performance, as well as the significance of such changes in enhancing the safe operation of the plant. .
II-ll New Hampshire began reviewing the Seabrook FSAR when it was received in November of 1981. Initial review of the FSAR was on a non-technical basis by the staff of the Attorney General's Office, E. Tupper Kinder, Esquire and George Dana Bisbee, Esquire. Technical '
review was begun by Dr. Stephen S. T. Fan in August of 1982.
II-3 2 - Review of the Seabrook control room design is a continuing process and continues to be reviewed by Dr. Stephen S.T. Fan.
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Contention NH-10 Control Room Design II-l Yes.
II-2 through II-7 For the purposes of clarity, these Interrogatories can be answered together. A detailed Control Room Design Review or preliminary Control Room Design Assessment is required under NUREG-0737, I.D.1 and Supplement thereto. Equally important to this review requirement is the requirement under 1.D.2 that safety parameters be displayed as a system. Evaluation of control room design problems since the accident at Three Mile Island has indicated that ic.provement of Control Room Design and procedures is essential to safe operation of a nuclear power facility. It is noted that review of emergency procedures is required Dy NUREG-0737, I.C.l. .
The focus of New Hampshire's contention is to assure that an assessment of the Control Room Design and emergency procedures is performed and results in appropriate modifications. The Applicant's answers to Interrogatories NH-10.13 and NH-10.14 reflect that such a review or assessment has not been performed and that human factors and task analyses have not been performed. Similarly, the Applicant has not developed a proposal for SPDS. ,
The State of New Hampshire has not performed a technical a sessment of the Applicant's compliance with General Design Criteri.a 19, 20, 21, and 22 and at this time, we do not intend to offer direct testimony on thase specific issues. HowcVer, the absence of the required review and assessment process required by :-
NUREG-0737 indicates that compliance with the General Design Criteria has not been demonstrated. Since we have not had an opportunity to review the DCRDR or preliminary assessment, as neither is yet available, we cannot be more specific on areas in which the.
Applicant has failed to improve Control Room Design and procedures as required by NUREG-0700 and 0737.
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4 New Hampshire bases its position that a detailed
- Control Room Design review is required on the following regulatory requirements and documen^s.
These documents, in general, indicate the importance of timely review and upgrading of Control Kuom Design and procedures. Because the Applicant has not completed its Control Room Design Review, this is a partial list which may be supplemented.
GDC 13, 19, 20, 21, 22 NUREG-0700 NUREG-0737, I.C.1, I.D.1, I.D.2, II.B.1, II.D.3, II.F.1, II.F.2, and Supplement 1 NUREG-0800 NUREG-0696 Regulatory-Guide 1.97 Documents produced by the Applicant in response
{ to the New Hampshire's interrogatories on Contention NH-10 Technical Note: The Control Room Design Review, E.W. Hagen (Ed.), Nuclear Safety, 23 (291-299),
1982 Survey of Control Room Lesign Practices with Respect to Human Factors Engineering, J.L.
1 Seminara, S.W. Parsons, Nuclear Safety, 21 (603-617), 1980 Human Factors Engineering Enhancement of Nuclear Power Plant Control Rooms, J.L. Seminbra, R.W.
Pack, S. Seidenstein, S.K. Eckert, Nuclear Safety, 21 (351-363), 1980 Human Factors Engineering in the U.S. Nuclear Arena, E.W. Hagen, G.T. Mays, N'arlear Safety, 22 (337-346), 1981 4
Some Possible Ways to Improve Nuclear Power Plant Instrumentation, Y.Y. Hsu, A.L.M. Hon., Nuclear Safety, 22 (728-737), 1981 4
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Establishing Priorities in Control Room Design .
Review, E.L. Zebroski, M.E. Maddox, P.E. Dietz, Nuclear Engineering International, July 1982, pp. 30-34 II-8 New Hampshire believes that changes to control room design and procedures should result from a thorough Control Room Design Review, including human factors and task analysis. New Hampshire has not performed such an analysis since this is the responsibility of the Applicant under 0737, I.C.1, I.D.1, and I.D.2.
Once a Control Room Design Review is produced and New Hampshire has an opportunity to review it, New Hampshire will comment on the proposed upgrading of control room design and procedures.
II-9 As far as is known to New Hampshire, every nuclear power plant in the United States is required to perform a Control Room Design Review and/or Assessment.
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II-10 When specific changes in control room design are -
proposed as a result of a Control Room Design Review .
and of the development of procedures for transients and accidents as required by NUREG-0737, I.C.1, New Hampshire will oe in a position to reviaw such changes for possible off-setting negative effect on control room efficiency or operator performance, as well as the significance of such changes in enhancing the safe operation of the plant, .
II-11 New Hampshire began reviewing the Seabrook FSAR when it was received in November of 1981. Initial review of the FSAR was on a non-technical basis by the staff of the Attorney General's Offica, E. Tupper Kinder, d
Esquire and George Dana Bisbee, Esquire. Technical review was begun by Dr. Stephen S. T. Fan in August of 1962.
II-12 Review of the Seabrook control room design is a continuing process and continues to be reviewed by Dr. Stephen S.T. Fan.
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o, II-13 New Hampshire has not yet determined which witnesses -
it will offer with respect to this contention.
G-1 The documents upon which the above answers are based are listed in the above Interrogatories.
G-2 The answers are not based upon any type of study, calculation, or analysis other than a review of the F3AR, RAI, and the above-mentioned documents by Dr. Fan. -
! G-3 The above answers were developed as a result of a number of discussions between Dr. Fan and Assistant Attorney General E. Tupper Kinder since August of 1982 and are not based on communications with any other individuals.
Contention NH-13 Operations Personnel Qualifications III-l Yes.
III-2 Item I.A.l.1 does not apply to the position of station manager.
III-3 New Hampshire does not assert non-compliance with Item I.A.2.1 with regard to the position of station aar.ager.
III-4 New Hampshire does not assert non-compliance with Item I.A.2.3 with regard to the position of station manager.
III-5 Chapter 13 of the FSAR doer not provide sufficient detail to ensure that the atation manager has the proper qualifigations and training to respond properly in controlling or mitigating an accident in which the core is severely damaged. New Hampshire's concern focuses on the ability of the station manager to deter?.ine the extent of core damage, understand instrumentalon response in an accident environment, understand the expected chemistry ;esults and ramifications of severe core damage, and properly determine the level of radiation inside ti.c containment.
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III-6 NUREG-0737, Item I.C.1 requires the Applicant to perform analyses of transients and accidents, prepare emergency procedure guidelines, upgrade emergency procedures, including procedures for operating with ,
natural circulation conditions, and to conduct operator retraining. According to this guidance, the f analyses of transients and accidents should consider the occurrence of multiple and consequential failures and operator errors or omissions. ,Because the Applicant has not performed such analyses (see ,
Applicant's answer to NH Interrogatory No. SAPL Supp. i 3.6), the training of the cration msnager does not ;
include the necessary elements contemplated by ;
NUREG-0737, Item I.C.l. r III-7 New Hampshire does not assert non-compliance with Appendix C as to the position of station manager. I t
III-8 Item I.A.1.1 does not apply to the position of assistant station manager. -
III-9 New Hampshire does not assert non-compliance with Item I.A.2.1 with regard to the position of assistant station manager.
III-10 New Hampshire does not assert non-compliance with Item I.A.2.3 with regard to the position of assistant station manager.
III-ll Chapter 13 of the FSAR does not provide sufficient detail to ensure that the assistant station manager has the proper qualifications and training to respond properly in controlling or mitigating an accident in "
which the core is severely damaged. New Hampshire's concerns focuses on the ability of the assistant station manager to determine the extent of core damage, understand instrumentaion response in an accident environment, understand the expected chemistry results and ramifications of severe core damage, and properly determine the level of radiation l inside the containment.
s III-12 NUREG-0737, Iter I.C.1 requires the Applicant to perform analyses of transienus and accidents, prepare Emergency procedure guidelines, upgrade emergency procedures, including procedures for operating with natural circulation conditions, and to conduct operator retraining.
According to this guidance, the analyses of transients and accidents should consider the occurrence of multiple and consequential failures and operator errors or omissions. *Because the Applicant has not performed such analyses (see Applicant's 3.6), answer to NE Interrogatory No. SAPL Supp.
the training of the assistant station manager does by not include the NUREG-0737, Itemnecessary I.C.1. elements contemplated III-13 New Hampshire does not assert non-compliance with Appendix C as to the position of station manager.
III-14 Item I.A.1.1 does not apply to the position of senior reactor operator.
III-15 New Hampshire does not assert non-compliance with Item I.A.2.1 with regard to the position of senior reactor operator.
III-16 New Hampshire does not assert non-compliance with Item I. A. 2.3 with regard to the-position of senior reactor operator.
III-17
- Chapter 13 of the FSAR does not provide sufficient detail to ensura that senior reactor operators have I
the proper qualifications and training to respond properly in controlling or mitigating an accident in which the case is severely' damaged. New Hampshire's concern focu.es on the ability of senior reactor operators to determine the extent of core damage, understand environrent, instrumentaion response in an accident understand the expected chemistry results and ramifications of severe core damage, i
- deter.T.ine the level of radiation inside theand properly containment.
1 I III-18 NUREG-0737, Item I.C.1 requires the Applicant to perform analyses of transients and accidents, prepare emergency procedure guidelines, upgrade emergency procedures, including procedures for operating with natural circulation conditions, and to conduct operator retraining. According to this guidance, the analyses of transients and accidents should consider the occurrence of multiple and consequential failures and operator errors or omissions. Because the Applicant has not performed such analyses (see Applicant's answer to NH Interrogatory No. SAPL Supp.
3.6), the training of the senior reactor operators does not include the by NUREG-0737, necessary Item I.C.l. elements contemplated III-19 New Hampshire does not assert non-compliance with the requirements of Appendix C, as tc the position of reactor operator or senior reactor operator.
III-20 Iter I.A.1.1 does not apply to the position of reactor operator.
III-21 New Hampshire does not assert non-compliance with Item I.A.2.1 with regard to the position of roactor operator.
III-22 New Hampshire does not assert non -compliance with Item I.A.2.3 with regard to the position'of reactor operator.
III-23 Chapter 13 of the FSAR does not provide sufficient detail to ensure that reactor _perators have the e proper qualifications and training to respond properly in controlling or mitigating an accident in which the case is sevcrely damaged. New Hampshire's concern focuses on the ability of reactor operators to determine the extent of core damage, understand instrumentaion response in an accident navironment, understand the expected chemistry resultt, and ramifications cf severe core damage, and properly containment.the level of radiation inside the determine
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III-24 UUREG-0737, Item I.C.1 requires the Applicant to .
perform analyses of transients and accidents, prepare l*
emergency procedure guidelines, upgrade emergency '
procedures, including procedures for operating with natural circulation conditions, and to conduct operator retraining. According to this guidance, the analyses of transients and accidents should consider the occurrence of multiple and consequential failures and operator errors or omissions. Because the Applicant has not performed such. analyses (see Applicant's answer to NH Interrogatory No. SAPL Supp.
3.6), the training of the reactor operators does not include the necessary elements contemplated by NUREG-0737, Item I,C.1.
III-25 New Hampshire does not assert non-compliance with Appendix C as to the position of reactor operator.
III-26 Chapter 13 of the FSAR does not adequately detail the scope of training of Shift Technical Advisors, and therefore, does not ensure that Shift Technical Advisors will receive proper training in the response and analysis of the plant for transients and accidents. New Hampshire asserts in particular that the Shift Technical Advisors will not be able to provide the proper assistance to operations personnel in mitigating accidents. (See New Hampshire's answer to Interrogatory III-29 below.) Furthermore, the FSAR does not adequately demonstrate how the Shift 4 Technical Advisors will be trained to assess accident l
conditions, notify the appropriate off-site authorities of an accident, and recommend appropriate protective actions to off-site authorities.
III-27 New Hampshire does not assert non-compliance with i Item I.A.2.1 with regard to the position of shift l technical advisor.
l III-28 New Hampshire does not assert non-compliance with Item I.A.2.3 uith regard to the position of' shift technical advisor.
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Chapter 13 of the FSAR does not provide sufficient
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III-29 .
detail to ensure that the shift technical advisor has the proper qualifications and training to respond properly in controlling or mitigating an accident in which the case is severely damaged. Heu Hampshire's concern focuses on the ability of the shift technical advisor to determine the extent of core damage, understand instrumentaion response in an accident environment, understand the expected chemistry results and ramifications of severe core. damage, and properly determine the level of radiation inside the containraent, r
III-30 NUREG-0737, Item I.C.1 requires the Applicant to perform analyses of transients and accidents, prepare ,
i emergency procedure guidelines, upgrade emergency procedures, including procedures for operating with natural circulation conditions, and to conduct i operator retraining. According to this guidance, the analyses of transients and accidents should consider the occurrence of multiple and consequen' tal failures and operator errors or omissions. Because the Applicant has not performed such analyses (see Applicant's answer to NH Interrogstory No. SAPL Supp. .
3.6), the training of the shift technical advisors does not include the necessary elements contemplated by NUREG-0737, Item I.C.l.
III-31 Neu Hampshire does not assert non-compliance with Appendix C as to the position of shift technical advisor.
III-31 through III-36 New Hampshire has stated above that its primary concerns about operations personnel qualifications and
training focus on the capability of these personnel to control or mitigate accidents, and to properly implement emergency response measures.
Further detail concerning the required experience and the training program for the listed personnel must be provided by the Applicant. In addition, it may be necessary to expand the scope of the training program to provide more thorough training in the areas of accident mitigation and emergency response.
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III-37 New Hampshire has not yet determined which, if any, witnesses it will offer with respect to this contention.
G-1 The answers to the above interrogatories are based on the information provided in the PSAR, Chapter 13 arid the requirements of NUREG-0737 and 10 C.F.R. Part 50.
G-2 The answers to these interrogatories are based only on a review of the cited documents.
G-3 No.
Contention NH-20 Emergency Assessment, Classification and Notification IV-1 Yes.
IV-2 Although New Hampshire has not yet finalized its position on this aspect of its Contention 20, New Hampshire asserts at this time that the following aspects of the Seabrook Emergency Plan do not comply l with 10 C.E.R. 550.47 (b)(4):
l (a) The Applicant has not submitted emergency action levels; (b) The Applicant has not discussed emergency action levels with State and local governmental authorities; l
(c) The Applicant has not sought the j approval of State and local -
l governmental authorities of the emergency action levels; New Hampshire reserves the right to raise i
concerns about the Emergency Action Levels when they are finally submitted.
I"-3 The Emergency Plan does not comply with NUREG-0654 Appendix I for the same reasons stated in New Hampshire's answer to Interrogatory IV-2 above, to the extent that Appendix I is referenced in NUREG-0654, Item 2, D.
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IV-4 The Emergency Plan must contain Emergency Action -
Levels which have been discussed with and approved by State and local governmental authorities. New Hampshire reserves the right to raise its specific concerns about the Emergency Action Levels when they are completed.
IV-5 New Hampshire has not yet determined whether it will offer testimony of any expert witness with respect to l
Contention NH-20.
G-1 The answers to the above interrogatories are based on the information contained in the PSAR and Emergency Plan, and the requirements of 10 C.F.R. Part 50 and NUREG-0654.
G-2 The answers are based only on a review of these documents.
G-3 The answers are based in part on a discussion j with Mr. Michael Nawoj of the New Hampshire Civil Defense Agency (see copy of his resume attached as Attachment E). This discussion, which took place on December 6, 1982, concerned the status of the Emergency Action Levels.
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Contention NH-21 Protective Action (On-site)
- V-1 Yes. .
I The following responses to the Applicant's Interrogatories on Contention NH-21 are limited to concerns regarding on-site protective measures, in conformance with the Board's September 13, 1982 Memorandum and Order, at page 32. To the extent that "
the Applicant's Interrogatories raise broad issues involving on-site and off-site protective actions, New Hampshire will respond only as to on-site issues, reserving the right to raise off-site protective action issues at the appropriate time.
V-2 New Hampshire contends at this time that the following protective measures, as described in the Seabrook Emergency Plan, fail to meet the requirements of 10 C.F.R. S50.47(b) and 10 C.F.R. Part 50, Appendix E:
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(a.) subsection 10.3 of the Emergency Plan .
is inadequate in that it does not set forth in any detail how plant personnel will be protected from exposure to radiation, and (b) Subsection 10.4 of the-Emergency Plan (as supplemented by the Applicant's Answer to Interrogatory NH-21.2) provides no detail on how contaminated injured personnel will receive proper medical treatment. Until the Emergency Plan adequately demonstrates that arrangements have been made for the transportation and treatment of contaminated individuals, and that those responsible for these duties are capable of handling them, the Applicant will not be in compliance with the above-stated requirements.
I V-3 New Hampshire does not contend at this time that any
" additional protective actions" are needed in the Seabrook Emergency Plan. New Hampshire does maintain, however, that those deficiencies noted in the answer t to Interrogatory V-2 above must be rectified.
l V-4 New Hampshire has not yet determined whether it will I
offer the testimony of any expert witness with respect to Contention NH-21. ,
G-1 The answers to the above interrogatories are based on the information contained in the FSAR l
and Emergency Plan, and the requirements of 10 C.F.R. Part 50 and NUREG-0654.
G-2 The answers are based only on a review of these documents: -
G-3 The answers to these interrogatories are based in part on an October 29, 1982 meeting of E. Tupper Kinder and George Dana Bisbee with Dr. Donald Herzberg, head of the Radiation Safety Committee at Mary Hitchcock Hospital in Hanover, New H6mpshire. One of the topics discussed at this meeting was the capability of hospitals to provide proper services for contaminated, injured persons.
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- - Contention NECNP I.A.2 Electric Valve Operators VI-l New Hampshire does not intend to offer direct testimony relating to this contention. However, the State reserves the right to cross-examine or offer proposed findings and rulings on the contention, based on the testimony presented.
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VI-2 through VI-9 See answer to VI-1.
Contention NECNP I.B.1 Classification Safety Grade Residual Heat Removal VII-l Yes.
VII-2 Please refer to Applicant's response to RAI 440.133 and 440.134.
VII-3 New Hampshire will focus its testimony en steam generators as a part of the residual heat removal system. The steam generators are not environmentally qualified.
VII-4 and 5 New Hampshire has not completed its review of the environmental qualification of steam generators.
However, o ar review to date has indicated that since the steam generator serves as the heat sink for residual heat remova! in the natural circulation mode, .,
it is important to mine sure that the steam generator can provide an adequate heat siuk. The tube rupture problems with Westinghouse steam generators are well known. Many operating steam generators in PUR facilities have lost the effective use of a substantial portion of the tubes. It must be demonstrated that the steam generators are capable of functioning as an adequate heat sink in the natural circulation mode if there is to be a reliable heat removal system.
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. i VII-6 New Hampshire has not yet determined which expert witnesses it will offer with respect to this contention.
G-1 The above answers are based on the fcllowing documents:
GDC 4 GDC 34
- NUREG-0578 NUREG-0705 Nuclear Reactor Safety, David Okrent, U. of l
Wisconsin Press, 1981
- Nuclear Reactor Safety, R.R. Farmer (Ed.),
Academic Press, 1977 Nuclear Power Reactor Safety, E.E. Lewis, John Wiley, 1977 Physical Phenomena of a Small-Break ,
Loss-of-Coolant Accident in a PWR, W.E.
Burchill, Nuclear Safety, 23 (525-536),
1982 Steam Generator Problems, Nucl. News, 25 (70-71), 1982 New Type of Steam Generator Fails in First Year of Operation, F. Reisch, 23 (355-358) 1981 Steam Generator Replacement at Surry Power Station, H.S. McKay, Nuclear Safety, 23 (72-84), 1982.
G-2 The above answers are not based upon any type of study, calculation, or analysis other than the review performed by Dr. Fan of the FSAR, RAI, and the above-mentioned documents.
G-3 The above answers are not based upon any communications with other individuals.
Contention NECNP I.B.2.' Time Duration of Environmental Qualification VIII-l New Hampshire does not intend to offer direct testimony relating to this contention. However, it reserves the right to cross-examine or offer proposed findings and rulings on the contention, depending upon the testimony presented.
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'VIII-2 through 6 See answer to VIII-1.
Contention NECNP I.C. Pumphouse HVAC IX-1 New Hampshire does not intend to offer direct testimony relating to this contention. However, the State reserves the right to cross-examine or offer ,
proposed findings and rulings on the contention, depending upon the testimony presented.
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IX-2 through 7 See answer to IX-1.
Contention NECNP I.D.1 Reactor Welds -
X-1 New Hampshire does not intend to offer direct testimony relating to this contention. However, it reserves the right to cross-examine or offer proposed findings and rulings on the contention, depending upon the testimony presented.
X-2 through 9 See answer to X-1.
Contention NECNP I.D.2 Protection System Test at Power XI-l Yes.
XI-2 through 6 New Hampshire has not yet finalized its position on this contention. Therefore, it is unable to answer these Interrogatories at this time. These answers will be supplemented as required by Nt.C regulations.
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VIII-2 through 6 See answer to VIII-1.
Contention NECNP I.C. Pumphouse HVAC IX-1 New Hampshire does not intend to offer direct testimony relating to this contention. However, the
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State reserves the right to cross-examine or offer proposed findings and rulings on the contention, depending upon the testimony presented.
IX-2 through 7 See answer to IX-1.
Contention NECNP I.D.1 Reactor Welds -
X-1 New Hampshire does not intend to offer direct
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testimony relating to this contention. However, it reserves the right to cross-examine or offer proposed findings and rulings on the contention, depending upon the testimony presented.
X-2 through 9 See ar,3wer to X-l.
Contention NECNP I.D.2 Protection System Test at Power XI-l Yes.
XI-2 through 6 New m .npshire has not yet finalized its position on this contention. Therefore, it is unable to answer these Interrogatories at this time. These answers will be supplemented as required by NRC regulations.
XI-7 New Hampshire has not yet determined which experts, if any, it will offer with respect to this contention.
Contention NECNP I.D.3 Leakage Detection Testing Required XII-l New Hampshire does not intend to offer direct testimony relating to this contention. However, it reserves the right to cross-examine or offer proposed findings and rulings on the contention, depending upon the testimony presented.
XII-2 through 15 See answer to XII-1.
Contention NECNP I.D.4 IEEE . Standards XIII-l New Hampshire does not intend to offer direct testimony relating to this contention. However, the State reserves the right to cross-examine or offer proposed findings and rulings on the contention, depending upon the testimony presented.
XIII-2 through 32 See answer to XIII-1. .
Contention I.F. Diesel Generator Quali.'ication
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XIV-1 Yes.
XIV-2 New Hampshire has not yet finalized its position on this contention. Therefore, it is unable to answer these Interrogatories at this time. These anewers will be supplemented as required by NRC regulations.
XIV-3 through 8 See answer to XIV-2.
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, t XIV-9 New Hampshire has not yet determined which experts, if any, it will offer with respect to this contention.
Contention NECNP I.G. Pressure Instrument Reliability XV-1 New Hampshire does not intend to offer direct testimony relating to this contention. However, we reserve the right to cross-examine or offer proposed findings and rulings on the contention depending upon the testimony presented.
XV-2 through 10 See answer to XV-1.
Contention NECNP I.I Cold Shutdown XVI-l Yes.
XVI-2 New Hampshire has not finalized its position on this contention. Therefore it is unable to answer these Interrogatories at this time. These answers will be supplemented as required by NRC regulations.
XVI-3 through 7 -
See answer to XVI-2.
XVI-8 New Hampshire has not yet determined which experts it will offer with respect to this contention. .,
Conter. tion NECNP I.L PORV Plow Detection Monitoring XVII-l New Hampshire does not intend to offer direct testimony relating to this contention. However, we reserve the right to cross-examine or offer proposed findings and rulings on the contention depending upon the testimony presented.
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XVII-2 through 5 -
See answer to XVII-1.
Contention NECNP I.M Fire Protection
^
XVIII-l New Hampshire does not intend to offer direct testimony relating to this contention. However, we reserve the right to cross-examine or offer proposed findings and rulings on the contention depending upon the testimony presented.
XVIII-2 through 5 See answer to XVIII-1.
Contention NECNP I.N. Solid Waste Disposal l .
XIX-1 New Hampshire does not intend to offer direct testimony relating to this contention. However, we reserve the right to cross-examine or offer proposed findings and rulings on the contention depending upon j the testimony presented.
l XIX-2 through 5 l See ar.swer to XIX-l.
I Contention NECNP I.U Turbine Missile l
l XX-1 Yes. ,
XX-2 New Hampshire has not yet finalized its position on this contention. Therefcre, it is unable to answer these Interrogatories at this time. These answers will be supplemented as required by NRC regulations.
XX-3 through 4 See answer to XX-2.
9 XX-5 New Hampshire has not yet determined which experts, if
, any, it will offer with respect to this contention.
Contention NECNP II.B.1 QA Operation: FSAR S17.2 Fails to Address App. B Criteria XXI-l Yes. ,
XXI-2 New Hampshire has not yet finalized its position on this contention. Therefore, it is unable to answer these Interrogatories at this time. These answers will be sapplemented as required by NRC regulations.
XXI-3 through 6 See answer to XXI-2.
XXI-7 New Hampshire has not yet determined which experts, if any, it vill offer with respect to this contention.
Contention NECNP II.B.3 QA Organization Not Independent XXII-l New Hampshire does not intend to offer direct testimony relating to this contention. However, we reserve the right to cross-examine or offer proposed findings and rulings on the contention, depending upon the testimony presented.
XXII-2 and 3 See answer to XXII-1.
Contention NECNP II.B.4 QA Program for Replacement After Operations Begin XXIII-l New Hampshire does not intend to offer direct testimony relating to this contention. However, the state reserves the right to cross-examine or offer t.roposed findings and rulings on the contention, depending upon the testimony presented.
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XXIII-2 and 3 .
See answer to XXIII-1.
Contention NECNP II.B.5 QA Presence of Qualified Personnel XXIV-1 New Hampshire does not intend to offer direct testimony relating to this contention. However, we reserve the right to cross-examine or offer proposed findings and rulings on the contention, depending upon the testimony presented.
XXIV-2 and 3 See answer to XXIV-1.
Contention S APL Supp. 3 - Class 9 XXV-1 Yes.
XXV-2 The NRC policy statment of June 13, 1980 anticipates that implementation of the policy will result in efforts to identify additional features or other actions which would prevent or mitigate the consequences of serious accidents (45 F.R. 40103).
Neither the Applicant nor the NRC staff has addressed implementation of the policy in this manner. As stated in its answers to New Hampshire Interrogatories l SAPL Supp. 3.9 through 3.11, the Applicant has no documented proces2 for the consideration of additional features or actions which would improve the original design of the facility for preventing or mitigating the consequences of serious accidents. In the FES the NRC staff c6ncludes that no additonal fertures or other actions are necessary without discussion of whether upgrading of systems was considered.
New Hampshire asserts that in order to comply with the policy statement the staff and Applicant should review the following areas to identify additional features or other actions which would prevent or mitigate the consequences of serious accidents.
'* w
- 1. Anticipated transients without scram.
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!!o review is provided in the FSAR except for reliance on a Westinghouse report prepared in 1974.
- 2. Steam Geaerator The Applicant and staff should review the extent to which failure of the steam generator tubes may affect the occurrence and severity of accidents.
- 3. Emergency Procedures NUREG-0737 1.C.1 requires that an evaluation of procedures for dealing with transients and accidents should be conducted including the potential for multiple and consequential failures and human error. Neither the Staff nor the l Applicant has considcrad these factors in !
implementing the policy statement of i June 13, 1980 for Emergency Planning.
- 4. Emergency Planning. -
Although Emergency Planning is mentioned frequently in the Staff's discussions in the FES, the Staff acknowledges that Emergency Response docum2nts are not yet prepared, but makes no effort to identify critical areas of mitigation which should be addressed by Emergency Planning documents.
XXV-3 New Hampshire has not yet finaIized its. position on initiating sequences and source terms which must be discussed by the Applicants. However, we can say at this time that the problem of steam generator tube ,
blockage should be discussed. Although Applicant has !
presented certain scenarios of accidents, New I Hampshire believes the Applicant has placed an /
inappropriate measare of reliance on out of date data (i.e., for ATWS a Westinghouse Report prepared in 4 1974). New Hampshire has not developed at this time an additional scenario which must be looked at by Applicant. f XXV-4 At this time New Hampshire has not performed an I analysis of consequences which will result from i accidents. l 1
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1
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.. XXV-5 New Hampshire has not performed the probability ,
calculation requested in this Interrogatory. -
XXV-6 See answer to XXV-5.
XXV-7 New Hampshire has not formed a position on additional design or related features which may be required as a condition of granting the operating license. As indicated in the answer to Interrogatory XXV-2 the focus of this contention is that it is the Applicant and Staff's responsibility to evaluate such additional designs and actions. Neither the Applicant nor staff has demonstrated that such an evaluation has been performed.
XXV-8 As indicated in the preceding Interrogatory New Hampshire has not evaluated additonal features that may be required as a condition of licensing. However, experience indicates that failure tc consider additonal designs, related features or other actions may lead ts extensive repair and replacement costs which exceed the costs of reviewing and implementing such features. Neither the Applicant not the staff has documented that additional features h' ave been considered and that the cost of implementing such features aas been balanced against the value of such feature to prevent or mitigate the consequences of serious accident including future repair and replacement costs.
XXV-9 New Hampshire has not yet determined which exper t witnesses it will offer with respect to this contention. .
G-1 NRC Policy Statement June 13, 1980 (45 FR 40101)
NUREG-0737 I.C.1 NUREG-0460 R.S. Denning & P. Cybulskis, Reduction in Reactor Risk,by the Mitigation of Accident Consequences, Nuclear Safety, 22(165-172),
1981 E.W. Hagen, Anticipated Transients Without Scram ,
for Light-Water Reactor: Unresolved Safety Issue TAP A-9, Nuclear Safety, 22(191-201),
1981 NRC, Officelof Nuclear Reactor Regulation, Antici-pated Transients Without scram for Light-Water Reactors: Resolution of Unresolved Saf ety Issue TAP A-9, NRC Report NUREG-0460, Vol.4, NTIS, March 1980
E.W. Hagen, Anticipated Transients Without Scram, Nuclear Safety, 21(731 -732), 1980 -
D. Okrent, Nuclear Reactor Safety, The University of Wisconsin Press, 1901 FSAR, Ch. 15 Environmental Report, Ch. 7 All documents produced by the Applicant in response to New Hampshire's Interrogatories on this contention.
Such other documenta as may be pertinent when the required review is performed by the Applicant and Staff.
Documents referred to in New Hampshire's answers to Interrogatory VII. ,
G-2 The answer is not based on any calculation, review or study, otaer than a review of the ,
aforementioned documents by Dr. Fan, j G-3 No. ,
Contention CCCNH 4 Accident Classificayion and Notification X XVI-l Yes. To the extent that Contention CCNH 4 overlaps with Contention NH-20, the State does intend to litigate this Contention. The Applicant may wish to refer to New Hampshire's answers to the Applicant's Interrogatories IV-1 through ' -5.
XXVI-2 New Hampshire relies on the facts as they are presented in the Emergency Plan to supp, its concerns relative to this Contention, which Contention parallels Contention NH 20. New Hampshire contends that the following sections of the Applicant's Emergency Plan are inadeqc ate as they relate to "
on-site emergency planning:
Emergency Plan 55 The Applicant has not submitted Emergency Action Levels and has not discussed them with, nor sought the approval of, State and local governmental authorities. Therefore, New Hampshire asserts that the Emergency Plan does not comply with 10 C.F.R. S50.47tb)(4)), and 10 C.F.R. Part 50, Appendix E, SIV,L, and NUREG-0654, Item II(D).
4
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Emergency Plan S6 & 57 ,
The Emergency Plan does not assure that adequate emergency facilities and equipment are provided and mLintained, in that the location of the various emergency response centers has not yet been selected, or if selected, may not be appropriate. For example, as the Applicant indicates in its January 5, 1983 response to New Hampshire Interrogatory 20.14,.the location of the EOF is still under review, and also New Hampshire believes the Media Center's proposed location in Seabrook is too close to the plant.
In addition, there is insufficient assurance that the facilities will be properly equipped with communications eqtipment, and will be capable of coordinating with State emergency response personnel. New Hampshire is particularly concerned that the commercial telephone lines for use between the Technical Support Center and the Emergency Operations Facility, the TSC and the Incident Field Office, and each of th'ese facilities and the Emergency Operations Center in Concord are inadequate. The Applicant has, then, not demonstrated compliance with 10 C.F.R. 50.47(b)(8); 10 C.F.R. Part 50, Appendix E, SIV,E; and NUREG-0654, Item II, F.)
Emergency Plan S9 The Emergency Plan does not assure that those personnel responsible for classifying an accident and notifying state officials, should a classifiable + vent occur at Seabrook station, will be adequately experienced or trained for th!d responsibility. Thus, the Emergency Plan does not demonstrate compliance with 10 C.F.R. 550.47(b)(5, 15); (10 C.F.R. Part 50, Appendix E, SIV,D; NUREG-0654, Item II, 0.) (See also, New Hampshire's answer relative to 55 of the Emergency Plan in this Interrogatory.)
Emergency Plan 510.2 The Emergency Plan does not demonstrate that persons responsible for recommending protective actions to off-site authorities have the proper training and experience for this responsibility.
For example, this section does not provide
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sufficient information on the training staff and .
program, evaluation of the training program, and the maintenance of emergency preparedness.
Therefore, New Hampshire maintains that the Emergency Plan is not in compliance with 10 C.F.R. S50.47 (b)(5 and 15); 10 C.F.R. P;rt 50, Appendix E, SIV, D.
Emergency Plan 511 The public notification (warning) system for the Seabrook site has not yet been developed. (See
- p. 11-1 of the Emergency Plan.) Also, since the Emergency Plan does not indicate that a brochure, or other means of public information has been developed, there is no assurance that the public will know how to respond to an emergency warnir" The Emergency Plan does not adequately .
deta12 ..ow the public is to be informed during an acciaent, or how the various emergency centers, including the Media Center, will coordinate public information functions. The Emergency Plan, therefore, is not in compliance with 10 C.F.R. Part 50, Appendix Es SIV, D, 1; and 10 4 C.F.R. S5 0.47 (b) (5, 7). (S.4 also New Hampshire's answers above regarding SS 3 and 7 of the Emergency Plan.)
Emergency Plan S12 This section of the Emergency Plan does not adequately demonstrate that communications, medical, radiological monitoring, and health physics drills will be impler;.ted. For instance, the medical drill is to be conducted annually with one simulated, contaminated person. New Hampshire asserts that this is insufficient to evaluate medical personnel and facilities. Also, the content and frequency of
" scenarios," as described in 12-3 of the Emergency Plan, is insufficient. New Hampshire contends then, that the Emergency Plan is not in compliance with 10 C.F.R. 550.47(b)(15); 10 C.F.R. Part 50, Appendix E, SIV, D; NUREG-0654 Item II, O.
XXVI-3 New Hampshire has not yet determined whether it will offer the testimony of any expert witness with respect to this Contention.
~
G-1 The answers to the above interrogatories are based on the information contained in the FSAR and Emergency Plan, and the requirements of 10 C.F.R. Part 50, NUREG-0654, and NUREG-0737.
G-2 The answers are based only on a review of these documents.
G-3 These answers are based in part on a December 6, 1982 discussion with Mr. Michael Nawoj and Mr. Norman Hobbs of the New Hampshire Civil Defense Agency (see resumes attached as Attachments E and F).
Contention CCCNH 5 On-site Protective Measures XXVII-1 Yes. To the extent that Contention CCNH 5 overlaps with Contention NH 21, we intend to litigate this contention. The Applicant may wish to refer to New Hampshire's answers to Applicant's Interrogatories V-1 through V-4.
I axVII-2 New Hampshire relies on the facts as they are presented in the Emergency Plan to support the concerns it has raised relative to Contention CCCNH-5, which Contention parallels Contention NH 21. New Hampshire contends that the following sections of the Emergency Plan are inadequate:
Emergency Plan SS5 and 9 See answer to Applicant's Interrogatory IV.2.
Emergency Plan S10 ,
See New Hampshire'a Answer to the Applicant's Interrogatory V.2.
XXVII-3 New Hampshire has not yet determined whether it will l offer the testimony of any expert witness with respect l
to this Contention.
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G-1 The answers to the above interrogatories are .
based on the information contained in the FSAR and Emergency Plan, and the requirements of 10 C.F.R. Part 50, NUREG-0654, and NUREG-0737.
G-2 The answers are based on a review of these documents.
G-3 The answers to these interrogatories are based in
. part on an October 29, 1982 meeting of E. Tupper
, Kinder and George Dana Bisbee with Dr. Donald
! Herzberg, head of the Radiation Safety Committee at Mary Hitchcock Hospita3 in Hanover, New l
Hampshire. One of the topics discussed at this meeting was the capability of hospitals to provide proper services for contaminated, injured persons.
Contention CCCNH-7 Radioactive Monitoring XXVIII-l Yes.
XXVIII-2 and 3 1 See New Hampshire's answers to Interrogatories I-2 through I-4 above.
Contention NECNP III.1 Emergency Classification XXIX-1 Yes. This Contention overlaps with Contentions CCNH 4 and NH 20 and New Hampshire does intend to litigate these Contentions.
XXIX-2 See New Hampshire's answer to Interrogatory IV-2 and 3 above.
XXIX-3 See New Hamphire's answer to Interrogatory IV-4 above.
XXIX-4 New Hampshire has not finalized its position on this aspect of Contention NECNP III-1.
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XXIX-5 through XXIX-8 -
New Hampshire has not finalized its position relative to the question of whether the classification scheme minimizes the potential significance of transients, and therefore is unable to respond to these Interrogatories at this time.
XX I 3 through XXIX-21 New Hampshire has not finalized its position on whether "the classification scheme fails to provide a reasonable assurance at Seabrook on-site and off-site emergency response apparatus and personnel can be brought to an adequate state of readiness quickly enough to respond to an accident," so that it is unable at this time to respond to these Interrogatories.
XXIX-22 through XXIX-25 New Hampshire has not finalized its position on whether the classification scheme properly considers
" symptoms of transients and other indicators that transients may occur," and therefore is unable to respond to these Interrogatories at this time.
XXIX-26 No.
XXIX-28 Neu Hampshire has not finally deternined whether or how it will " rely" upon any estimatu of Seabrook evaluation times.
XXIX-29 New Hampshire has not yet determined whether it will offer the testimony of any expert witnesses with respect to this Contention.
G-1 The answers to the above interrogatories are based on the information contained in the FSAR and Emergency Plan, and the requirements of 10 C.F.R. Part 50, HUREG-0654, and NUREG-0737.
G-2 The answers are based on a review of these documents.
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G-3 No. -
Contention NECNP III.2 Simultaneous Emergencies -
XXX-1 New Hampshire does not intend to offer direct testimony relating to this contention. However, we
~
reserve the right to cross-examine or offer proposed findings and rulings on the contention, depending upon the testimony presented.
XXX-2 through XXX-26 See answer to XXX-1.
Contention NECNP III.3 Compliance of Emergency Plan with Appendix E XXXI-l Yes.
XXXI-2 See New Hampshire's answers to Interrogatory III-;
through III-36 above. ,
XXXI-3 New Hampshire has not yet determined whether it will offer the testimony of any expert witnesses with respect to this Contention.
G-1 The answers to the above interrogatory are based on the information provided in the FSAR and the requirements of NUREG-0737 and 10 C.F.R. Part 50.
G-2 The answers to these interrogatories are based on a review of the cited documents.
l G-3 No.
l Contention NECNP III.12 Evacuation' Time Estimates XXXII-l Yes.
i i
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t XXXII-2 through XXXII-13 New Hampshire has not finalized its posit'.on on issues relating to the Applicant's evacuation time estimate, and is, therefore, unable to respond to these Interrogatories at this time. New Hampshire maintains, in any event, that the issue of the adequacy of the evacuation time estimates is relevant to the adequacy of the off-site emergency plans, and, therefore, issues relating to the evacuation time estimates will become ripe when the off-site plans are submitted.
Contention NECNP III 13 Worst Case Estimates XXXIII-l Yes.
XXXIII-2 through XXXIII-21 New Hampshire has not finalized its position on issues relating to the Applicant's evacuation time estimate, and is, therefore, unable to respond to these Interrogatories at this time. New Hampshire maintains, in event, that the issue of the adequacy of i the evacuation time estimates is relevant to the l
adequacy of the off-site emergency plans, and, l therefore, concerns relating to the evacuation time estimates will become right when the off-site plans are submitted. -
As to the answers, we the undersigned, being first duly sworn, do depose and say that the foregoing answers are true except insofar as they are based on information that is available to the State of New Hampshire and the New Hampshire l- -. - . - . - _ - - - _ _ _ ._. . _ .
Attorney General, but not within my personal knowledge as to which we, based on such information, believe them to be true.
3 Dr. St% phen S. T. Fan Chairman and Professor College of Engineering and Physical Sciences Department of Chemical Engineering Kingsbury Hall University of New Hampshire Durham, New Hampshire 03824
. Lt- %
E. Tupper 'Kihder Assistant Attorney General Office of the Attorney General Environmental Protection Div.
State House Annex Concord, New Hampshire 03301
( Tel. 603/271-3678 George D'ana Bisbalf Attorney Office of the Attorney General Environmental Protection Div.
State House Annex Concord, New Hampshire 03301 Tel. 603/271-3678 THE STATE OF NEW HAMPSHIRE STRAFFORD, SS.
Personally appeared this // day of January, 1983, Dr.
Stephen S. T. Fan, before me, the undersigned officer, and made oath that the foregoing statements are true to the best of his knowledge and belief.
Csd .
Notary Public/ Justice of the CAROL FR3"M:. IJo: ey PutEc My Cem.rdes!cn Exp;rts hac 6, G:4
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THE STATE OF NEW HAMPSHIRE .
MERRIMACK, SS.
Personally appeared this // Mday of January, 1983, E.
Tupper Kinder, before me, the undersigned officer, and made oath that the foregoing statements are true to the best of his knowledge and belief.
TERRY L RUSSELL, Notary Pub!!c tNA ///f/f# M '
My Commission Expires April 22,1986 Notar blfc/ Justice' of the Peace i l .
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THE STATE OF NEW HAMPSHIRE MERRIMACK, SS.
Personally appeared this /7 ay of January, 1983, George Dana Bisbee, before me, the dndersigned officer, and made oath that the foregoing statements are true to the best of his knowledge and belief. ,
//M/ j TERRY L RUSSELL, Notary Public My Commissbon Expires April 22,1986 Notary c/ Justice of the s Peace CERTIFICATE OF SERVICE I, E. Tupper Kinder, Esquire, hereby certify that a copy of the foregoing State of New Hampshire's Response to the Applicant's Interrogatories and Requests for the Production of Documents Filed December 8, 1982 has been mailed this 17th day of January, 1983, by first class mail, postage prepaid, to:
i Helen F. Hoyt, Chm. -
Dr. Emmeth A. Luebke Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. NRC U.S. NRC Washington, D.C. 20555 Washington, D.C. 20555
a i
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Dr. Jerry Harbor Jo Ann Shotwell, Asst. AG -
Administrative Judge Office of the Attorney General Atomic Safety and Licensing One Ashburton Place, 19th Floor Board Panel Boston, MA 02108 U.S. NRC Washington, D.C. 20555 Mrs. Beverly Hollingsworth 822 Lafayette Road Roy P. Lessy, Jr., Esquire P.O. Box 596
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Robert Perliss, Esquire Hampton, New Hampshire 03842 Office of Executive Legal Dir. -
U.S. NRC William S. Jordan, II, Esquire Washington, D.C. 20555 Ellyn R. Weiss, Esquire Harmon and Weiss Robert A. Backus, Esquire 1725 I Street, N.W.
116 Lowell Street Suite 506 P.O. Box 516 Washington, D.C. 20006 ,
Manchester, N.H. 03105 Edward J. McDermott, Esquire Phillip Ahrens, Esquire Sanders and McDermott Assistant Attorney General 408 Lafayette Road State House, Station (6 Hampton, N.H. 03842 Augusta, Maine 04333 .
Atomic Safety and Licensing Robert K. Gad, Esquire Board Panel Thomas G. Dignan, Jr., Esquire U.S. NRC Ropes and Gray Washington, D.C. 20555 225 Franklin Street Boston, Massachusetts 02110 David R. Lewis, Esquire l
Atomic Safety and Licensing Board U.S. NRC - Room E/W - 439 ,
Washington, D.C. 20555
/ v;M E. Tupper' Kinder Dated: January 17, 1983 l
A_TTACIniENT A STEPHEN S. T. FAN Department of Cnemical Engineering University of New Hampshire .
Durham, New Hampshire (603) 862-3654 Date of Birth: January 2, 1934 Education: ,
-Stanford University, B.S., Chemical Engineering 1957 Stanford University, Ph.D., Chemical Engineering.1962 Academic Experience:
1962-1967 Assistant Professor, Department of Chemical Engineering University of New Hampshire 1967-1971 Associate Professor, Department of Chemical Engineering University of New Hampshire 1971-1976 Associate Professor and Chairman, Department of Chemical Engineering, University of New Hampshire 1976-present Professor and Chairman, Department of Chimical Engineering University of New Hampshire Industrial Experience:
Summer 1957 Research Engineer, Wolff Process Co., Huntington Park, California Summer 1963 Research Engineer, Gulf Oil Co., Pittsburg, Pennsylvania Summer 1964 Expert, U.S. Army Cold Regions Research Laboratory, Hanover, New Hampshire Courses Taught:
Applied mathematics, thermodynamics, kinetics, transport phenomena, nuclear engineering, energy and pollution Research Interests:
Waste heat utilization, heat and mass transfer, multicompnent diffusion Publications:
- 1. Regan, T. and Fan, S.S.T., " Waste Heat Utilization from Electric Power Generation", presented at the 5th National Conference on Energy and Environment, Cincinnati, Nov. 1977.
- 2. S.P. Ho, Fan, S.S.T., "Effect of Clothing on the Temperature Distribu-tion of Human Thermal System," Computers in Biology and Medicine, Dec. 1975.
>s -+i~- - + - A A R -
@ :1 L 2,, sm. m -+n , ,-+.
FAN - (Continued)
I
- 3. Foss, S.D. and Fan, S.S.T., " Approximate. Solution Lto the Freezing of :
the Ice-Uater System with a Constant Heat Flux in the Water Phase,"
i Water Resources Research, 10, 511-513, 1974.
t
- 4. Fan, S.S.T. and Slater, S.M., "The Classification of Refineries and -
Steady State Oper3tions, Chapter III," in The Impacts of an Oil Refinery j
~ Located in Southeastern New Hampshire: A Preliminary Study. University of New Hampshire, 1974.
. 5 ~.
Foss, S.D. and Fan, S.S.T., " Approximate Solution to the Freezing of
]
the Ice , Water System," Water Resources Research, 3_, 1083-1086, 1972.
- 6. Fan, S.S.T. and Dillman, W., " Measurement of Multicomponent Gaseous
., s . .g. Diffusion Coefficients with Chemically Reacting Systems," presented at the 21st Canadian Chemical Engineering Conference, Montreal, Canada Oct. 1971. '
- 7. Fan, S.S.T. and Yen, Yin-Chao, "Nonsteady Compressible Flow Through Anisotropic Porous Media with Particular Reference to Snow," Water Resources Research, 4, 597-606, 1968. *
- 8. Fan, S.S.T. and Yen, Y.C., " Pressure Wave Propagatied in Porous Media 1
with Non-Uniform Permeability," Research Report, 210, CRREL, U.S..
- Army, 1966.
i j 9. Fan, S.S.T. , Rosza, R.B. , and Mason, D.M. , " Heat Tr,ansfer in Reacting j Systems: Effect of Chemical Kinetics on the Thermal Conductivity of Gases," Chem. Eng. Sci., 18,, 737-752, 1963.
- 10. Fan, S.S.T. and Mason, D.M., " Effects of Chemical Reaction on Gas l Properties and Lewis Number," ARS Journal, 32,, 899-906, 1962.
l '
- 11. Fan, S.S.T. and Mason, D.M., " Properties of the System N24 0 :2N0 2 2N0 + 02 ," J. Chem. Eng. Data, 7_, 182-186, 1962.
1 12. Fan, S.S.T. and Mason, D.M. .. "Effect of. Chemical Dissociation on Gas i
' Properties," Preprint A, Presented at the Fifty-Fourth Annual Meeting of American Institute of Chemical Engineers, New York, N.Y., December,-
i 1961.
} Professional Affiliations:
- American Institute of Chemical Engineers #
American Association of University Professors Tau Beta Pi j Sigma Xi h
., Consulting:
4 i
Environmental Protection Division, Office of N.H. Attorney General.
U.S. Army Cold Regions Research Lab, Hanover, N.H.
Private Firms.
f I
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FAN (Continusd) .
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M.S. Theses Supervised:
Kaseri Dandh -
Studies on Effective Thermal Conductivity in Packed Bed - June, 1965.
Stephen Foss .
Heat Transfer.in a Heterogeneous Catalytically Reacting System - June, 1965.
Eino Lilback -
Adsorption Isotherms for Freon 11 on Activated Carbon Silica Gel, and Mixed Adsorbents -
June, 1966.
Raul Acosta -
Unsteady Heat Conduction.in Chemically Reacting Systems with Local . Equilibrium - June,1967.
George T. S. Chen - Heat Conduction in Chemically Reacting Systems-with Catalytic Surfaces - June,1967 Warren Dillman - The Heasurements of Effective Multicomponent Diffusion Coefficients with Chemically Reacting Systems - June, 1967.
Yue-Kwang Yang - Heat Transfer in Chemically Reacting Flow Systems with Local Chemical Equilibrium: Film Model and the Relating Numerical Methods - June,1968.
Shi-Ping Ho' - Mathematical Modelling for' the Human Thermal Regulation System - September, 1971.
Mohan Rao -
Adsorption Isotherms for Freon 21 on Activated I
~
Carbon, Silica Gel, and Mixed Absorbents -
June, 1971.
William Fifty - A Mathematical Model for the Steady State Thermo-regulation of the Human Leg - June,1973.
Mahendre. Shah - Utilization of' Waste Heat From Power Generation, August, 1973.
Thomas Regan -
Utilization of Waste Heat from Nuclear Power Plants, 1976.
Shashi Lalvani - Transport of Water Through Artificial Membranes -
August,- 1979.
Ph.D. Thesis Supervised:
Stephen D. Foss, An Approximate Solution to the Moving Boundary Problem Associated with the Freezing and Melting of Lake Ice, 1974.
l I
RESUME ATTACHMENT B L. William Dotchin 306 Upper Sixth Street
.. Dover, New Hampshire 03820 Telephone: (603) 742-7524 home (603) 862-2790 office EDUCATION Graduate Education University of New Hampshire Durham, New Hampshire Master of Science degree in Physics was awarded in June,1965.
Recipient of Teaching Assistantship in 1962 and Research 1962 Assistantship 1963 through 1965. Thesis emphasis was on to measurements of lifetimes of atomic states using the Beam-1965 foil method. Results of this work were included in the initial proposal to NASA in 3954 for funding of the atomic and molecular beam research on the University of New Hampshire Physics Department accelerator.
Undergraduate Education.
Bates College Lewiston, Maine 1958 Awarded Bachelor of Science degree in Physics and Mathematics, to June, 1962. Laboratory assistant junior and senior years.
1962 Member of science honor. society. Thesis emphasis on transistor circuit design.
PROFESSIONAL EXPERIENCE Hired as Director of the University Instrumentation Center in October, 1978, a 70s-time appolatment, and as Coordinator of 1978 Research Safety, a 30%-tine appointment. The responsibilities as Director of the University Instrumentation Center include present teaching a senior / graduate student course in Experimental Physics.
1973 Hired as Radiation Safety Officer at the University of New to Hampshire in July, 1973. Responsibilities include teaching a 1978 senior / graduate student course in Experimental Physics.
1965 Hired as Research Physicist at the University of New Hampshire to in February, 1965, to continue the atomic and molecular beam ,,
1973 research begun as a graduate student. Also hired by Physics Department as part-time instructor and placed in charge of Department accelerator installation.
PROFESSION AI.
SOCIETIES New Hampshire Safety Council New England Chapter of the Health Physics Society University Laboratory Managers Association
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- 1 DOTCHIH (Ccntinued) 2 COMMUNITY ACTIVITIES Member of the St. Thomas Episcopal Church vestry for the past eight years. Currently Treasurer of the church.
PERSONAL BACKGROUND Born in August, 1940, in Hartford, Connecticut. Raised in West Hartford and Wethersfield, Connecticut. Attended Wethersfield Junior and Senior High Schools. Married with two children, aged five and seven. Hobbies include: flying an,d gardening.
1 REFERENCES References available on request.
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l-.-.._-..-_.
ATTACHMENT C e,
Filson H. Glanz Associate Professor Electrical Engineering Department
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A. EDUCATION .
B.S. Math Stanford University 1956 M.S. Engineering Mechanics Stanford University 1957 Extension Course in Space Technology Digital Computers UCLA 1957-1959 Ph.D. Electrical Engineering Stanford University 1965 BB&N Underwater Acoustics - one day a month for 9 months 1965-1966 IEEE Short Course on Digital Signal Processing B. EXPERIENCE University of New Hampshire Associate Professor 1972-present University of New Hampshire Assistant Professor 1965-1972 Stanford Electronics Laboratory Research Assistant 1963-1965 EDAL Project-Sea Lab Summer 1966 Meteor Trails December 1966 Stanford Research Institute Research Assistant 1962-1963 Lockheed Aircraft Corporation Bio Behavioral Group Palo Alto, California Programmer Summer 1961 Librascope, Incorptrated, Analysis of land Glendale, California navigation system 1957-1960 Douglas Aircraft, ~
El Segundo, California Math Analysis 1955-1956 C. PROFESSIONAL HONOR SOCIETIES AND HONORS
- 1. Sigma Xi
- 2. IEEE (2 prof. groups)
- 3. Recipient of one of two UNH Alumni Distinguished Teaching Awards, May 1980 D. TEACHING RESPONSIBILITIES - Various undergraduate & graduate courses including Digital Signal Processing, Communication Systems and Digital Systems.
E. RESEARCH ACTIVITIES - in Digital Signal Processing, Meteor Trails Radar, Ecological Modelling.
F. PAPERS AND REPORTS (Partial List)
"An Azimuth Measuring System for a Meteor Trails Radar", IEEE Transactions on Geoscience Electronics, Vol. GE-9, Nc. 1, Jan. 1971, p. 56-62.
-t "Models for Human Operators Based on Non-uniformly Sampled Systems",14th Annual Manual Control Conference, May 1970 Dayton, Ohio, with George D. Kontopidis and David E. Limbert.
"Models of Man-Machine Tasks Based on Non-uniformly Sampled Systems", 2nd Inter-national Conference on Information Sciences and Systems, July 1979, Patras, Greece with G.D. Kontopidis and David E. Limbert.
"A Study on Non-uniformly Sampled Systems", International Conference on Cybernetics and Society, October 1979, Denver, Colorado, with G.D. Kontopidis and David E. Limbert.
" Computer Controlled Systems Using Multiplexed I/0", giver it the Spring Conference on Industeial, Control and Instrumentation Applications c. ini and Microcomputers, March 1980 with G.D. Kontopidis and D.E. Limbert.
, ATTACHMENT D William Mosberg Associate Professor
._ Mechanical Engineering Department University of New Hampshire -
Durham, NH 03824 EDUCATION B.S. Columbia University 1956 M.S. Yale University 1960 EXPERIENCE Academic:
1981 - Pressnt Associate Prof essor, Mechanical Engineering Department University of New Hampshire l'972 - 1981 Associate Professor 6 Chairman, Mechanical Engineering Department, University of New Hampshire 1965 - 1972 Associate Professor Mechanical Engineering, University of New Hampshire 1963 - 1965 Faculty Fellow (N.S.F.) Columbia University -
1958 - 1963 Assistant Professor of Mechanical Engineering, University of New Hampshire 1956 - 1958 Teaching Assistant, Yale University INDUSTRIAL AND MILITARY
. Cities Service Research 6 D,evelopment Laboratory, Granberry, New Jersey, ~
Engineer, Summer 1965.
Griest Manufacturing Company, New Itaven, Connecticut, Engineer, Summer, 1957.
Bechtel Company, New York City, Designer, Summer, 1955.
M.W. Kellogg Company, New York, City, Piping, Designer 6 Engineer, 1948-1954.
Roy M. llenwood Assoc., New York City, Oil Storage Plant Designer, 1946.
U.S. Army, 1942-1946 M.E. Student A.S.T.P. at M.I.T., 1942-1943; Completed Geodetic Computing Course - 1944; Math Instructor 657 Topographic Battalion - 1944 The Lummus Company, New York City, Draftsman, 1941-1942.
~ .
William Mosb rg - Resume P' age 2 Recent Consulting Activities:
- - Howell Laboratories, Inc., Bridgton, Maine ~
Kalwall Corporation, Manchester, New Hampshire Sylvania Corporation, Exeter, New Hampshire COURSES TAUCHT Macro Thermodynamic:, (graduate and undergraduate)
Microscopic Thermodynamics Fluid Dynamics '
Analytical Fluid Dynamics Gas Dynamics Heat Transfer Continuum Mechanics Theoretical Hydrodynamics Engineering Mechanics Graphics and Descriptive Geometry C0hMITTEES Chairman of Faculty and Faculty Caucus, 1973-1974 University Senator most years 1958-1974 -
Blue and White Concerts Committee Allied Arts Committee Faculty Welfare Committee Chairman Allied Arts Committee Council on Educational Innovation M.E. Thermal Science Committee Secretary, Ph.D. Transport Phenomena Committee
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SOCIETY MEMBERSHIP .
AAUP - University of New Hampshire Chapter President, 1967-1968.
l ASEE NYSPE
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, ATTACHMENT E o ,
MICHAEL M. NAWOJ RFD # 1 Normand Road Goffstown, New Hampshire 03045 Home Telephone 603-497-3249 Buisness Telephone 603-271-2231
SUMMARY
OF QUALIFICATIONS: ,
Nearly fifteen years of progressive emergency managment and technical experience at state and local levels of government.
Extensive project development, implementation and management experience of state and local emergency managment systems for radiological and other technical hazards. Experienced in the formulation of emergency response operations procedures, and rescource management systems. Also experienced in the management of Radiation Safety / Health- Physics, and radiological monitoring programs.
PROFESSIONAL AFFILIATIONS:
State of New Hampshire Civil Defense Agency Town of Goffstown New Hampshire Civil Defense Director Town of Goffstown New Hampshire Police Department United States Army SPECIFIC EXPERIENCE:
As the state Radiological Emergency Response Planning coordinator is responsible for the development and coordination of the Radiological Emergency Response Planning Project for the State of New Hampshire.
This includes coordination of radiological emergency response preparedness activities for two nuclear power plant sites, Vermont Yankee, and Seabrook, as well as two Department of Defense / Department of Energy facilities, Pease Air Force Base, and the Portsmouth Naval Ship Yard. Designed and implemented the current program for the development of the State and local radiological emergency response plans for these sites. Responsible for supervising the activities of agency staff and consultant personnel in the preperation implamentation and maintainence of state and local plans.
Developed the Radiological Defense Officer Program for the State.
Supervise the Radiological Systems Maintenance Program as well as the Radiation Safety and Training program.
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MICHAEL M. NAWOJ (continued)
Served as a member of the Governors Hazardous Materials Advisory
. - Board. _
Was Director of Civil Defense for the Town of Goffstown, New Hampshire, with responsibilities for the development and coordination of the towns Comprehensive Emergency Managment plan for all town agencies.
PROFESSIONAL ASSOCIATIONS:
Member Health Physics Society Radiological Defense Officer Radiological Defense Officer Instructor Trainer Member Hazardous Materials Managers Training Course University of ,
New Hampshire Durham, New Hampshire Guest Lecturer Franklin Pierce Law School Concord, New Hampshire Guest Lecturer St Anselms College School of Nursing Manchester, New Hampshire EDUCATION:
St. Anselms College, BA Biology .
University of Lowell, Graduate work Radiological Health Numerous Federal Emergency Management Agency Nuclear Regulatory
? Comission, Department of Defense, and Department of Energy Training Programs New Hampshire State Police Academy SECURITY CLERANCE:
SECRET i
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ATTACHMENT F
< _a NORMAN A. HOBBS, JR 6 1/2 Holmes Street Nashua, New Hampshire 03060 ,
Home Telephone: 603/883-2008 Office Telephone: 603/271-2231
SUMMARY
OF QUALIFICATION 5 Fifteen years of communications and communications management experience in the private sector as well as in state government and the military.
Extensive project management experience in the planning, design and implementation of complex, multi-user, and multi-channel communications and information systems. Experienced in providing technical assistance to units of state and local governments. Also experienced in microwave system planning and design. Experienced in data telecommunications information entry and retrieval for state and federal law enforcement agencies.
PROFESSIONAL AFFILIATIONS New Hampshire State Civil Defense Agency New Hampshire State Police l U.S. Armed Forces
-U.S. Naval Reserve l
-U.S. Army Reserve
-N.H. National Guard SPECIFIC PROJECT EXPERIENCE With New Hampshire Civil Defense Agency, engaged in communications system i
requirements analysis, design and implementation. Microwave system l design, implementation and management in support of a statewide emergency l network was a recent project involvment. Responsible for all facets of emergency planning for ,the Vernon V,ermont Nuclear Power Plant. Managed New Hampshire's Emergency Response Planning to involve all appropriate
, state government agencies. Developed a management program in support of l nuclear plants. Provided consultive assistance to state and local governments in the analysis and design of emergency communications systems. Specified and purchased communications and computer hardware for the agency. Had direct centrol of the New Hampshire National Warning System (NAWAS) and various Federal communications networks. Acted as staff technical advisor to the Director on matters of telecommunications
- and equipment / hardware purchases as well as funding and budgetary matters.
1
n,e NORMAN A HOBBS, JR (continued)
(2)
While with New Hampshire State Police, managed the states participation in a national telecommunications law enforcement informational exchange network, (NCIC). Trained local and state users, and provided technical assistance to members of the law enforcement community. Served as instructor at the Police Academy on matters of communications and computer usage. Operated various data entry / retrieval equipment as well as varied two-way radio and teletype equipment.'
PROFESSIONAL ASSOCIATIONS Past President N.H. Police Dispatchers Association Past Member N.H. Police Association Past member of the instructional team, University of New Hampshire Hazardous Materials CETA Program Past Member of the Executive Board of the State Employees Association Nominated to be member Federal Communications Commission Public Safety Services Subcommittee. -
Member Concord Police Department Oral Board Communications Selection Committee Member Hazardous Waste Council, University of New Hampshire Member New Hampshire State Library Microwave Committee EDUCATION
- Manchester Technical College, Courses in Electronics U.S. Army Communications School, Fort Belvoir, VA U.S. Army Engineer School Training Programs NRC/ FEMA Technical Operations Course FEMA / DOE Radilogical Emergency Response Organization Decision Making Course Analytical Reports Course .g Office Information Management Course SECURITY CLEARANCE Top Secret LENGTH OF EXPERIENCE 15 years l
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