ML20069G450

Answer Opposing Util & NRC Motions for Summary Disposition of Contention NECNP-I.B.1 Re RHR Sys.Factual Dispute Exists Over Adequacy of Steam Generators to Provide RHR Capability. Related Correspondence

ML20069G450
Person / Time
Site:	Seabrook
Issue date:	03/23/1983
From:	Bisbee G NEW HAMPSHIRE, STATE OF
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20069G449	List: ML20069G445 ML20069G450 ML20069G465 ML20069G478 ML20069G492 ML20069G496 ML20069G500 ML20069G502
References
NUDOCS 8303250154
Download: ML20069G450 (3)

Text

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UNITED STATES OF AMERICA ' '

NUCLEAR R'EGULATORY COMMISSION; .,,..

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. , Before th.( ,1f ,-

ATOMICr$AFETS AND.LICENSIMG x -

SOARD '

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l In the matter of: -

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PUBLIC SERVICE COMPANY OF NEU HAMPSHIRE) Docket pos!: 50-443 ET AL. )

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50-444 (Seabrook Station, Units 1 and 2) )

o ) March 23, 1983

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THE ' STATE APPLICANT'S AND OFTHE 'NEU STAFF'S HAMPSHIRE' S %'h0TIONS #'

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SUMMARY

DISPOSITION OF CONTENTION NECNP-I.B.1 Pursuant to 10 C.F.R. S2.749 the State of Neu Hampshire hereby s

answers the Staff's and the-Applicant's Motions for Summary DispositionofContentionNECMP-I.B.handopposes.thesemotionsfor

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the reasons explained belou.

, . Contention NECNP-I.B.1 asserts in broad terms that the residual v.

heat removal system for Seabrook Stat' ion dcEs not satisfy the.

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requirements of GDC 4 and GDC 34. New s Hampshire has raised the i particular question of the reliability of,the steam generator tubes as the heat sink intheresidualYeat removal system.1/ ~

The Applicant and Staff in their respective' motions for summary disposition on this contention do not respond to New Hampshire's l

expressed concerns about this issue. Nev 'idmpshire has questioned the ability of the Westinghouse steam generators to serve as an l

1/ See new Hampshire's January 17, 1993 v.cuere to Applicant's Interregntorier, z. p. 10, cnd _. " - %1ri'-

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.ebruar; 19, 15 43. /;.ncue r to Applica:.

. Motion to Compet, at

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8303250154 830323 '

l PDR ADOCK 05000443 ,

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s l adequate heat sink in light of the repeated occurrences of tube I

ruptures with this type of steam generator. Tube rupture problems

v. have persisted even with Westinghouse's latest Model F steam

} generator. Affidavit of Dr. Stephen S. T. Fan, 12. Given this l evidence of unreliability of the steam generators, it is important to determine how the steam generators will function if their efficiency is impaired due to loss of a portion of the heat transfer surface resulting from-defective tubes.

s In light of the above, the Applicant has complied with neither GDC 34, in failing to provide for an adequate residual heat removal s'ystem, nor GDC 4, in failing to demonstrate that the steam generator is able to " accommodate the effects of and to be

! compatible with the environmental conditions associated with normal

, q.; operation . . . and postulated accidents." 10 C.F.R. Part 50, f Appendix A, Criterion 4.

Given this factual dispute over the adequacy of the steam generators in providing residual heat removal capabilities, the Staff's and Applicant's Motions for Summary Disposition of Contention NECNP-I.B.1 should be denied.

Respectfully submitted, 1

THE STATE OF NEU HAMPSHIRE GREGORY H. SMITH ATTORNEY GENERAL l ([ "t y p.

[ . By: - - - Y ' 0' ~ - .

l George Dana Biebee Attorney l Envircnnental Pro.ection Divie:on l Officc of A*tc"r_ General ,

l state Hvace Anne:-

Concerd,  : m.: riarpshire 03301 l C03-;71-3c'.c s >

ttd: March 23, 1983

STATE!!ENT OF !!ATERI AL PACTS AS TO UIIICII TilERE IS DISPUTE

1. In view of the fact that the integrity of Westinghouse steam generator tubes has been under question, due to repeated occurrences of tube ruptures, it is important to

determine how the residual heat renoval systen will function if the efficiency of the stean generator is impaired due to the loss of a portion of the heat transfer surface resulting from the defective tubes.

2. This tube integrity problen has persisted with Westinghouse's latest Itodel F stean generator.

3. Furthermore, due to low tenperature driving force and the possibility of flow reversal in sone of the tubes during natural circulation conditions, the margin of safety for heat transfer may not be large.

4. Based on the above considerations, the design of the residual heat renoval systen should be thoroughly studied

to fully assess the design limit and effectiveness of the systen and to determine if additional means of residual i

heat renoval should be introduced to ensure adequacy of the systen.

5. Unless and until this study is performed there is insufficient assurance of a reliable residual heat renoval systen that is environmentally qualified, satisfying the requirenents of GDC 34 and GDC 4.

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