ML20069G478

Answer to Util Motion for Full Summary Disposition & NRC Motion for Partial Summary Disposition of Contention NH-13. Opposes Disposition of NUREG-0737,Items I.C.1 & I.A.I.I But Not II.B.4.Related Correspondence

ML20069G478
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
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-1.C.1, TASK-2.B.4, TASK-TM NUDOCS 8303250162
Download: ML20069G478 (4)

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UNITED STATES OF AMERICA

] NUCLEAR REGULATORY COMMISSION Before the ATOMIC SAFETY AND LICENSING BOARD

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In the matter of: )

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l PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE) Docket Nos.: 50-443 ET AL. ) and

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

) March 23, 1983 THE STATE OF NEW HAMPSHIRE'S ANSUER TO APPLICANT'S SIXTH MOTION FOR

SUMMARY

DISPOSITION AND TO THE STAFF'S MOTION FOR PARTIAL

SUMMARY

DISPOSITION OF CONTENTION NH-13 Pursuant to 10 C.F.R. S2.749 the State of New Hampshire hereby answers the Applicant's motion for full summary disposition, and the Staff's partial motion for summary disposition, of Contention NH-13.

i Insofar as the Applicant has asserted its commitment to implementing fully the special training for mitigating core damage required by NUREG-0737, Item II.B.4, as interpreted in Enclosure 3 i

to H.R. Denton's March 28, 1980 letter, and in light of its submission of an acceptable outline of such training, New Hampshire no longer asserts non-compliance with that NUREG-0737 requirement with regard to the listed operations personnel.

New Hampshire opposes, however, both summary disposition motions as to NUREG-0737, Item I.C.I. The Staff and the Applicant assert 8303250162 830323 PDR ADOCK 05000443 O PDR

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1 that the Applicant has complied with this requirement since it has 4

committed to follow the Uestinghouse owners Group recommendations for developing emergency procedures. However, as the Applicant's affiant, George S. Thomas, stated in his af fidavit' accompanying the Applicant's summary disposition motion, the-Uestinghouse Owners

) Group is still "in the process of finalizing emergency response guidelines." Until such time as these guidelines are completed, there is no assurance that the Applicant's " commitment" to implementing them will satisfy the mandate of NUREG-0737, Item I.C.l. Therefore, as a matter of law, the Applicant's and staff's motions for summary disposition on this issue should be denied, i

The Applicant also is not entitled to summary disposition in its favor as to its compliance with NUREG-0737, I.A.1.1.1/ By its own admission it is still seeking staff approval to obviate the need for a separate Shift Technical Advisor (STA) (see George S. Thonas affidavit), so that this NUREG-0737 requirement has not been met.

The Applicant must provide an STA as required by Item I.A.1.1 l until such time as "the qualifications of the shift supervisors and senior operators have been upgraded, and the man-machine interface in the control room has been acceptably upgraded." NUREG-0737, Item I

I.A.1.1. (Emphasis added.) At the present time the Applicant has I

not demonstrated that the control room design as it pertains to

" man-ma' chine interface" has been acceptably upgraded, and it is not,

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i- U The Staff has not moved f;; suprar3 G1cposittor. on thit issue. See Staff's Februar. .4, .E;? r~ticn for Partit.t S Ji l'; )

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therefore, in compliance with NUREG-0737, Item I.A.l.l. On this 4

basis the Applicant's Motion for Sumnary Disposition as to this NUREG-0737 requirement must be denied.

Respectfully submitted, THE STATE OF NEW HAMPSHIRE GREGORY H. SMITH  :

ATTOP.NEY GENERAL

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By: ")

, George Bana Bisbee l

Attorney Environmental Protection-Division office of Attorney General State House Annex j Concord, New Hampshire 03301 603-271-3678 Dated: March 23, 1983 l

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i STATEMENT OF FACTS AS TO WHICH THERE IS DISPUTE

1. Because the Applicant has not demonstrated that the ,,,

, qualifications of-shift supervisors and senior operators have been upgraded and that the " man-machine interface" in the control room.has also been adequately upgraded, it has not complied with NUREG-0737, Item I.A.l.1 in providing for shift technical advisors, t

2. Because the Applicant, through the Westinghouse owners Group, has not finalized emergency response guidelines based on an analysis of transients and accidents, it has not complied with NUREG-0737, Item I.C.1.

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