ML20069G478
| 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: |
| 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
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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.:
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and
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50-444 (Seabrook Station, Units 1 and 2)
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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
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that the Applicant has complied with this requirement since it has committed to follow the Uestinghouse owners Group recommendations 4
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
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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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U The Staff has not moved f;; suprar3 G1cposittor. on thit issue.
See Staff's Februar.
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.E;? r~ticn for Partit.t 31C'Csitlor.,
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therefore, in compliance with NUREG-0737, Item I.A.l.l.
On this basis the Applicant's Motion for Sumnary Disposition as to this 4
NUREG-0737 requirement must be denied.
Respectfully submitted, THE STATE OF NEW HAMPSHIRE GREGORY H. SMITH ATTOP.NEY GENERAL
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By:
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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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