ML20065T563

First Set of Interrogatories & Request for Production of Documents.Svc List Encl.Related Correspondence

ML20065T563
Person / Time
Site:	Seabrook
Issue date:	10/28/1982
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20065T557	List: ML20065T554 ML20065T563
References
NUDOCS 8211020578
Download: ML20065T563 (4)

Text

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NUCLEAR REGULATORY COMMISSION

, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD A11:i3 In the Matter of YhTN{ gg A IAR Y

$VICE PUBLIC SERVICE COMPANY OF NEW H AMPSHIRE, et al. Docket Nos. 50-443 50-444 (Seabrook Station, Units 1 and 2)

SAPL FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO APPLICANT PUBLIC SERVICE COMPANY OF NEW H AMPSHIRE Pursuant to 10 C.F.R.,42.740(b), the Intervenor SAPL requests that the attached Interrogatories be answered fully in writing and under oath by any members of the Public Service Company of New Hampshire, Inc. ("PSCO") who have personal knowledge thereof.

L What criteria and standards were used to analyze the probabililty of occurrence ,

of radiation and/or radioactive material releases and the probabililty of occurrence of the environmental consequences of those releases as required in the Interim Policy Statement of the NRC dated June 13, 1980?

2. What weight was given to those probabililties?

3. What computer code or methodology was used?

4. What events or accident sequences were identified and included in the analysis?

5. What was the weight given to such events or accident sequences in the analysis?

6. Identify the inplant accident sequences leading to releases that' were included in the analysis. Identify those inplant sequences which can result in inadequate cooling of reactor fuel and to melting of the reactor core.

7. Identify those inplant sequences which were not included in the analysis.

l 8. Identify those events which arise from causes external to the plant which are l conside, red possible contributors to risk associated with the Seabrook plant.

9. What was the weight accorded to events arising external to the plant?

l

10. What events arising external from the plant were not considered possible l

contributors to risk associated with the Seabrook plant?

11. What is the overall, methodology used in the probabilistic analysis estimate as I required in the Interim Policy Statement of June 13, 1980?

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12.

Whst is the wsight or basis given to environmentel consequ:ncas of re.lrasss

, whos3 proability of occurrence was estimated and included in the analysis?

Specifically what weight was given to potential radiological exposures to individuals, to population groups and to the biota?

13.

Identify those health and safety risks that were analyzed and give the basis or weight which those consequences had in the overall analysis. Also identify the socio-economic impacts that were included in the analysis and identify those socio-economic impacts that might be associated with emergency measures during or following an accident.

1

13. On what basis and what weight was given to the environmental risk of accidents which was compared to and contrasted with radiological risks associated with -

normal and anticipated operational releases?

14. In accordance with the Interim Policy Sta'tement of June 13, 1980, in which the Commission stated that the state-of-the-art of probabilistic risk assessments is sufficiently advanced so that a beginning should now be made in the use of these methodologies in the regulatory process, what is the current state-of-the-art methodology which the Applicant utilized in discussing environmental risks associated with accidents?

15. Identify specifically the significant site features and significant plant specific features of the Seabrook nuclear power plant which were studied in the Applicant's Environmental Risk Assessment as required in the NRC's Interim Policy Statement, June 13,1980.

16. Please state whether PSCO has performed or contracted for the performance of any studies assessing the probability of occurrences for any or allof the following American Nuclear Society Condition IV events:

A. " Steam System Piping Failures" under the classification of " Increase in Heat Removal by the Secondary System" in the Final Safety Analysis Report, Vol 12, page 15.1-13.

B., "Feedwater System Pipe Break" under the classification " Decrease in Heat Removal by the Secondary System" in the Final Safety Analysis Report, Vol 12, page 15.2-16.

C. " Reactor Coolant Pump Shafts Seizure (Cracked Rotor)" under the classification " Decrease in Reactor Coolant System Flow Rate" in the Final Safety Analysis Report, Vol 13, Page 15.3-5.

D. " Reactor Coolant Pump Shaf t Break" under the classification " Decrease in Reactor Coolant System Flow Rate" in the Final Safety Analysis Report.

Vol 13, page 15.3-11.

E. " Spectrum of Rod Cluster Control Assembly Ejection Accidents" under the classification " Reactivity and Power Distribution Anomalies" in the Final l

Safety Analysis Report, Vol.13, page 15.4-27.

l l

F. " Steam Generator Tube Rupture" under the classification of " Decrease in Reactor Coolant Inventory" in the Final Safety Analysis Report", Vol 13, page 15.6-5.

see -

l ._ _. . ,

G.

" Loss of Coolant Accidents Resulting from a Spectrum of Postulated Pip Breaks within the Reactor Coolant Pressure Boundary" under the Analysis Report, Vol.13, page 15.6-12. classification " Decrease in H.

from a system or Component" in the Final 13, page 15.7-10. , Vol Safety An 17.

16. above who performed the studies?If any studies have been done w 18.

16 above, what were the sources of data used in the studie 19.

If any studies have been done with respect to any or all of the items in quest 16 above, were they based on data obtained before or after the Three Mile Islan accident?

20.

If 16anyabove, studies what were have thebeen done costs of with respect to any or all of the items in questi the studies?

21.

question 16 above, have they been updated since the 22.

Please provide copies of any and all studies referred to in question 16 .

Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By its Attorneys, l ' LAW OFFICES OF ROBERT A. BACKUS

/ ,. Y BY: ' .-/ (

/410BERT A. BACKUS ~

P. O. Box 516 Manchester, NH 03105 (603)668-7272 October 28, 1982 m

6g e

, NTED CORRESP, 0NDENC3 SERVICE LIST 000KETED Thomas G. Dignan, Esq. U@C Helcn Hoyt, Chm.

Admin. Judge Ropes and Gray Atomic Safety & Lic. Ap. 225 Franklin Street Board - U.S. NRC Boston, MA 02110 82 NOV'-1 All 13 Washington, DC 20555 bour Docketing and Service Sec. G dmi d g AhC Office of the Secretary Atomic Safety &Lic. Ap.

Washin on, DC 20555 -

h' ash ngt n D 20555 Roy P. Lessy, Jr., Esq.

Robert L. Chiesa, Esq. -

Offica of Executive 95 Market Street Legal Director Manchester, NH 03101 U.S. NRC Washington, DC 20555 Phillip Ahrens, Esq. Jane Doughty Asst. Atty. General Field Director Stato House, Station #6 SAPL Augusta, ME 04333 5 Market Street Portsmouth, NH 03801 -

Wilfred L. Sanders, Esq.

Sanders & McDermott Tupper Kinder, Esq.

408 Lafayette Road Attorney General's Office Hampton, NH 03842 State of New Hampshire Concord, NH 03301 Dr. Emmeth A. Luebke David R. Lewis Admin. Judge Atomic Safety & Lic. Brd.

Atomic Safety ,& Lic. Ap. U. S. NRC - Rm. E/W-439 Board - U.S. NRC Washington, DC 20555 Washington, DC 20555 Jo Ann Shotwell, Asst. AG Ono Ashburton Place, 19th -

Floor Boston, MA 02108 William S. Jordan, II, Esq.

Ellyn R. Weiss, Esq.

1725 I Street, N.W.

Suito 506 Washington, DC 20006 Edward J. McDermott, Esq. ,.

Sandnrs and McDermott 408 Lafayette Road Hampton, NH 03842 -

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