ML20070M025

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Second Set of Interrogatories & Requests for Documents on Contentions I.D.1,I.D.4,I.F,I.I,I.L & Ii.B.Certificate of Svc Encl
ML20070M025
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 01/07/1983
From: Bishop L, Curran D
HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
NUDOCS 8301120229
Download: ML20070M025 (9)


Text

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LJanuary 7, 1983

R UNITEDLSTATES OF AMERICA 00CNETED

--NUCLEAR REGULATORY COMMISSION J RC BEFORE THE ATOMIC SAFETY AND LICENSING BOARih3 I.N 10 gi)y2

)

' " ' 7 SFcynp In the Matter of

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C i 5:~ ~ A

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'ICH PUBLIC SERVICE. COMPANY OF

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Docket'Nos. 50-443-NEW HAMPSHIRE,.et al.

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50-444

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(Seabrook Station, Units'1 and 2)

)

)

)

NECNP SECOND SET OF-INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO APPLICANTS ON

. CONTENTIONS I.D.l.,

I.D.4.,

I.F.,

I.I.,

I.L.,

and-II.B.

i INSTRUCTIONS FOR USE i

The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the Applicants with personal knowledge of the facts or information requested in each interrogatory.

The following definitions shall apply to thes interro-gatories:

1.

" Document" shall mean any written or graphic matter of Communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer print-outs, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of 8301120229 830107 PDR ADOCK 05000443 o@

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PDR

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(2) meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

2.

" Identify" shall mean with respect to any document, to state the following respecting the document: its title, its date, the author of the document, the person to whom the document was'sent,-all persons who received or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any and all copies of the document.

3.

" Identify" with respect to any action or conduct shall mean state the following regarding any such action or conduct: the person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; any document recording or documenting such action.

4.

" Describe" with respect to any action or matter shall mean state the following regarding such action or matters the substance or nature of such action or matter; the persons participating in or having knowledge of such action or matter; the current and past business positions i

und addresses of such persons; the existence and location of l

any and all documents relating to such action or matter.

l l

i

(3)

I.D.l.

Tacting of Reector Vacc 71'Welda 1.

Identify PSNH's contractor for the preparation of Applicants' " Reactor Vessel Examination Plan."

2.

To what degree is Applicants' " Reactor-Vessel Examination Plan" completed and when will it be submitted to the NRC?

3.

Please-provide access to any drafts of the

" Reactor Vessel Examination Plan."

I.D.2.

Testing of Protection Systems and Actuation Devices 4.

Please complete the last sentence in Applicants' answer to NECNP Interrogatory I.D.2-8.

5.

The answer to NECNP Interrogatory I.D.2-1 is incomplete.

FSAR at 7.1.2.5 does not refer to the specific means by which Applicants determined that the probability that protections systems will fail without testing the equipment is acceptably low.

Describe all quantitative calculations of probability and identify in detail the parameters of all qualitative judgments on probability.

Provide access to all documents relied upon in reaching the judgments which are summarized in the FSAR.

I.D.4 Periodic Testing of Electric Power and Protection Systems 6.

Applicants' answer to NECNP Interrogatory I.D.4-16 is not responsive.

Chapter 7 of the FSAR, Section 7.2, dis-cusses the Reactor Trip system and does not discuss in detail redundancy within the safety systems and the design criteria for the systems.

Please describe how, if at all, there is sufficient redundancy within each safety system to provide redundancy even when degraded by a single random failure.

(4)

,r 7.

Id:ntify and daccribe any torta or ctudico.ct Seabrook on the interaction of safety functions and control functions.-

8.

Identify and describe Applicants' program for periodic testing of diesel generators.used for emergency electric power.

9.

Have Applicants done any probabalistic studies on the importance to safety of diesel generators?

If so, please identify them and describe their results.

10.

Have Applicants performed any analyses of the reliability of diesel generators at Seabrook?

If so, please describe the results and identify and provide access to all relevant documents, 11.

Have Applicants performed any analyses of the re-liability of diesel generators at Seabrook as it relates to the method and frequency of testing?

If so, please describe the results and identify and provide access to all relevant documents.

12.

Do Applicants meet all the requirements of IEEE#338-1977?

If the answer to this question is no, please explain the discrepancy between your answer and the Staff's answer to Interrogatory I.D.4.-l.

I.F.

Diesel Generatcr Qualification 13.

Do Applicants comply with IEEE 323-1974 in every respect?

a)

Identify any and all aspects of noncompliance, b)

For each instance of noncompliance, identify any alternative means by which Applicants intend to comply with i

l

(5).

tha rCquiremento of GDC 17.

14.

Describe the differences between IEEE 323-1974 and IEEE 387-1977.

a)

Do Applicants believe that compliance with-IEEE 387-1977 provides an equivalent assurance of safety as compliance with IEEE 323-1974?

State the reasons for your answer.

15.

In the answer to NECNP Interrogatories I.F.-l and I.F.-7, Applicants state that "The Seabrook Station meets the requirements of IEEE 323-1974."

Does the qualification of diesel generators in particular meet the requirements of IEEE 323-1974?

I.I.

Inadequate Provision of Achieving Cold Shutdown 16.

Applicants' answer to NECNP Interrogatory I.I-8 was not responsive.

NECNP asked Applicants to con-sider a situation in which the single safety grade path to cold shutdown which Applicants plan to identify cannot be used.

NECNP's interrogatory is consistent with NRC regulations, which require Applicants to consider a single failure of safety grade components to determine adequate accident response capability.

17.

Applicants' answer to NECNP Interrogatory I.I-23 was not responsive.

Applicants state that they comply 1

with NUREG-0588.

The question put to Applicants, however, was whether they have complied with all the provisions of IE Bullentin No.79-01B, 7ev.3.

Please answer the question.

(6) 18.

In answering NECNP Interrogatory I.B.1-16, the Staff states that the safety related steam generator power operated atmospheric relief valves are used to vent vaporized secondary coolant.

This action discharges secondary fluid directly to the atmosphere.

If steam generator tubes are leaking at this time, either due to a deteriorated condition prior to the accident or leakage developed during the accidnet, primary coolant containing radioactivity has a direct path to the atmosphere. Does the Seabrook design have any means to detect the discharge of such radio-activity and an appropriate method to isolate the correct steam generator?

I.L.

PORV Flow Detection Monitoring System 19.

Identify the location and function of all power-operated relief valves in the reactor coolant pressure boundary, including valves that provide isolation for the system.

20.

In answer to NECNP Interrogatory I.L-5, Applicants stated that acoustic accelerometers are not used to detect PORV flow.

In light of that statement, please answer the following questions:

a)

Explain the discrepancy between Applicants' answer and the FSAR at Table 1.3-2, sheet 4 and 55.2.2.8, which state that acoustic accelerometers are used.

b)

Explain the reasons for the change.

c)

Identify and provide access to any docun.cnts which reflect the change from acoustic accelerometers to other flow detection devices.

d)

Describe in detail the new flow detection devices.

(7) e)

Are these devices environmentally qualified?

II.B.

Quality Assurance for Operations 21.

Please list those individuals responsible for the implementation of the QA program at Seabrook.

a)

Provide the qualifications of each individual for implementation of the QA program.

b)

Describe the previous experience of each indivi-dual with former construction projects of PSNH and others.

22.

Please identify and provide access to:

a)

Applicants' Quality Assurance Program for operations.

b) all procedures for implementation of Applicants' Quality Assurance Program for Operations.

c)

Any and all programs for the review of Applicants' Quality Assurance Program for Operations.

Respectfully Submitted 2

Diane Curran

/

Lee Bishop Harmon & Weiss 1725 I Street, N.W.

Suite 506 Washington, D.C.

20006 (202) 833-9070 l

l l

CERTIFICATE OF SERVICE I heYuby certify that copies of the foregoing NECNP THIRD SET OF INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO APPLICANTS ON CONTENTIONS I.A.2.,

I.B.l.,

IB.,2., and I.C.,NECNP SECOND SET OF INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO APPLICANTS ON CONTENTIONS I.D.l.,

I.D.4.,

I.F.,

I.I.,

I.L.,

AND II.B., AND NECNP SECOND SET OF INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO NRC STAFF ON CONTENTIONS I.A.2.,

I.B.1.,

I.C.,

I.D.2.,-I.F.,

I.I.,

AND I.M., have been mailed.this 29th day of October, 1982, first class, postage paid, to the following:

Helen Hoyt, Esq., Chairperson Phillip'Ahrens, Esq.

Atomic Safety and Licensing Assistant Attorney General Board Panel Department of the Attorney U.S. Nuclear hogulatory Commission General Washington, D.C.

20555 Augusta, ME 04333 Dr. Emmoth A. Luebke Robert A. Backus, Esq.

ALomic Safety and Licensing ill Lowell Street Board Panel P.O.

Box 516 U.S. Nuclear Regulatory Commission Manchester, NH 03105 Washington, D.C.

20555 Robert L. Chiesa, Esq.

Dr. Jerry Harbour Wadleigh, Starr, Peters, Atomic Safety and Licensing Dunn, & Kohls Board Panel 95 Market Street U.S. Nuclear Regulatory Commission Manchester, NH 03101 Washington, D.C.

20555 Thomas G.

Dignan, Esq.

Atomic Safety and Licensing R.

K.

Gad, III, Esq.

Board Panel Ropes and Gray U.S. Nuclear Regulatory Commission 225 Franklin Street Washington, D.C.

20555 Boston, MA 02110 Atomic Safety and Licensing C. Tupper Kinder, Esq.

Appeal Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission Office of the Atty. General Washington, D.C.

20555 208 State House Annex Concord, NH 03301 Docketing and Service U.S. Nuclear Regulatory Roy P.

Lessy, Jr., Esq.

Commission Robert G.

Perlis, Esq.

Washington, D.C.

20555 Office of the Executive Legal Director Rep. Beverly Hollingworth U.S.

Nuclear Regulatory Com-Coastal Chamber of Commerce mission 209 Winnacunnet Road Washington, D.C.

20555 l

Hampton, NH 03842 l

Edward J.

McDermott, Esq.

l Sanders and McDermott Professional Association 408 Lafayette Road Hampton, NH 03842 l

~

e W

6 Wilfred II. Sanders, Jr., Esq.

David R.

Lewis Sanders ah'd McDerinott Atomic Safety and Licensing Board Professional Association U.S. Nuclear Regulatory Commission 408 Lafayette Road Room E/W-439 ilampton, Nil 03842 Washington, D.C.

20555 Jo Ann Shotwell, Esq.

Assistant Attorney General Environmental Protection Division Public Protection Bureau Departraent of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 January 7, 1983 s-Diane Curran w

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