ML20070M035
| ML20070M035 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/05/1983 |
| From: | Dignan T, Gad R, Johnson W PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NEW HAMPSHIRE, STATE OF |
| References | |
| ISSUANCES-OL, NUDOCS 8301120235 | |
| Download: ML20070M035 (49) | |
Text
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January 5, 1983 00LKETED unac
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UNITED STATES OF AMERICA
"-Q;,hSEFV!CF l
-. m un NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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PUBLIC SERVICE COMPANY OF NEW
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Docket Nos. 50-443 OL HAMPSHIRE, et al.
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50-444 OL
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(Seabrook Station, Units 1 & 2)
)
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APPLICANTS' FIRST ANSWERS TO "THE STATE OF NEW HAMPSHIRE'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, INC."
AND MOTION FOR PROTECTIVE ORDER Pursuant to 10 CFR S 2.740b, the Applicants hereby respond to the " State of New Hampshire's Second Set of Interrogatories and Request for Production of Documents to Public service Company of New Hampshire, Inc.,"
served on them by mail on December 15, 1982.
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By arrangement with New Hampshire, these answers are being filed now, even-though answers.to certain of the interrogatories are.not presently available.
Answers to those interrogatories will.be filed as soon as they are available.
M SPECIFIC INTERROGATORIES Interrogatory No. NH 9.34 NH 9.34 With regard to the location of certain radiation monitoring instruments, explain why_the location was selected for each of the area monitors listed in FSAR Table 12.3-137
Response
As noted in section 12.3.4.1 of the FSAR, radiation detectors are located in areas which may be normally occupied without restricted access and which may have a potential for radiation fields in excess of the radiation zones described in section 12,3.1 of the FSAR.
This statement applies to all but three of the area monitors listed in table 12.3-13.
For the three monitors given below, additional criteria apply.
Section 12.3.4.lb.3 of.the FSAR (In-Containment High Range Monitoring) states that redundant detectors are located inside containment near the top of the dome to monitor post-LOCA conditions.
Placement of these monitors (Re-6576A,B) was dictated by NUREG-0737, II.F.1, Attachment 3, Clarification (3), page II.F.1-11.
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The Personnel Hatch (Post-LOCA) ion' chamber (RE-6536-
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1,2) is located to monitor post-LOCA conditions in s'
containment..This monitor was installed'at our option, there peing no regulatory requiremenE'for such a monitor.
External to containment, this monitor serves as a backup to the in-containment post-LOCA monitors.
.B.4 (Conta[ ment'I
-The FSAR in section 37 Manipulator Crane-RE 6535 A, B ),' states these monitors are located on the manipulator crane so that they can isolate containment-purge in the eve't of a fuel n
handling accident.
Spent fuel is handled from the manipulator crane.
Interrogatory No. NH 9.35 NH 9.35 With regard to your answer to Interrogatory 9.12,'
explain why the other monitors listed in FSAR Tables 12.3-13, 12.3-14, and 12.3-15 are not Class 1E (safety-related).
In your explanation, identify the criteria used to make this determination.
Identify all documents which are used as a basis for your explanation and produce such documents in accordance with 10 CFR 2.741.
Response
All the monitoring functions in Tables 12.3-13, 12.3-14 and 12.3-15 have been categorized as Class 1E (safety- '
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The criteria used to make these determinations was imposed by NUREG 0737, and the definition of Class 1E as indicated in IEEE Standard 308-1978.
RM-6535A and E.
6506A and B, and 6507A and B are Class j
lE as they perform the safety-related function of isolating the containment and the Control Room (FSAR Sections 12.3.4.1 and 12.3.4.2).
RM-6576A and B.
and 6533A are Class 1E as they are post-accident monitors required by NUREG-0737 (FSAR Sections 12.3.4.1 and 12.3.4.2).
The other monitors are not required to be Class 1E by the criteria listed above.
Interrogatory No. NH 9.36 NH 9.36 With regard to NUREG-0737 II(B)(2), the NRC staff has indicated that no formal submission addressing this action has been made by the Applicant.
Please advise whether the Applicant intends to rely for compliance on the document identified in its answer to Interrogatory 9.13.
" Post-Accident DOR Engineering Manual, Seabrook Station", dated April 28, 1982.
If another document is to be relied upon, please identify such document or explain when it will be available.
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submittal is referenced in a letter to the' NRC;
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s Seabrook Station",. is the Engineerin,g-Manual, 4 - - /
4 No other Appli' cants response toINUREG-0737 II(B)(2).
s documents age be'ing prepa' red in respor.se to II(B)(2)..
. Interrogatory No NH 9.'37.' '
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Is the radiation monitoring system capable of detecting releases of radioactivity from the reactor containment?
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If so, please explain how'the system is designed to detect such releases.
Response
Section 1.2.2.3 (Containment Enclosure) of the FSAR describes the design and function of the containment enclosure building.
This structure encloses the containment and is maintained at a negative pressure.
During'an accident, any leakage froa the containment structure is trapped, filtered and released from the containment enclosure to the vent stack.
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As noted in section 12.3.4.2.b.4(e) of the FSAR, the containment enclosure monitor (RE-6568) is located in-the exhaust duct from the containment enclosure at the inlet to.the cleanup filter.
This detector monitors the gross activity exhausted from the containment enclosure.
Finally, the effluent is monitored for particulates and noble gases and sampled for iodines by the plant vent monitor (RE-6533).
As noted in response 9.34, the manipulator crane monitor isolates containment purge in the event of a fuel handling accident.
During on-line purge, the purge line monitor (REG-6527) detects activity increases and terminates the purge.
Any activity released is monitored by the plant vent monitor before discharge to the environment.
Interrogatory No. NH 9.38 NH 9.38 The Applicant has indicated that it is committed to installing a leakage detection system.
Please explain how such system will be coordinated with the radiation monitoring system.
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Response
The radiation monitoring system utilized two monitors to detect leakage of main coolant ~1nside containment.
These are the containment air particulate and radiogas monitors.
(RE-6526).
These monitors constantly monitor the containment atmosphere for increasing airborne activity due to leakage of reactor coolant.
These monitors are part of the total Seabrook radiation monitoring system and will alarm in the control room through the system's computer.
Interrogatory No. NH 9.39 NH 9.39 Explain what steps have been taken to insure that the leakage detection system does not interfere with or disrupt the Radiation Monitoring System.
Response
As explained in the response to 9.38, the reactor coolant leakage detectors are a part of the total radiation monitoring system.
There are no
" interference" or " disruption" problems.
The question needs clarification.
a.
Interrogatory No. NH 9.40 NH 9.40 Is the radiation monitoring system capable of detecting releases of radioactivity from the reactor coolant pressure boundary.
If so, please explain how the system is designed to detect such releases.
Response
See the response to question 9.38.
This question seems redundant.
We have assumed the leakage detection system is the reactor coolant pressure boundary leakage detector.
Interrogatory No. NH 9.41 NH 9.41 With regard to the answer to Interrogatory 9.23 relating to the plant ventilating system, the Applicant indicated "In some cases, these dampers are also provided with limit switches which, in conjunction with other instrumentation, will annunciate a system failure."
Identify each of the "some cases" referred to which are designed with instrumentation to annunciate a system failure.
Also, please identify the "other instrumentation" and explain how a system failure will be annunciated in each case.
Response
[To be submitted.] 1
o Interrogatory No. NH 9.42 NH 9.42 With regard to the previous Interrogatory, explain the criteria used to select which " cases" (or dampers) would be designed with limit switches such that a system failure would be annunciated.
What differentiates these selected cases from other dampers which are not equipped with limit switches.
Response
[To be submitted.]
Interrogatory No. NH 9.43 Referencing the Applicant's answer to NH 9.30:
during accident conditions, how will control room personnel be able to determine the actual airborne hazard in the WPB and/or the PAB if the noble gas ventilation exhaust monitors in these buildings are indicating their maximum high range value of lO-aMCi/cc while the plant vent monitor is indicating a value well above this?
Response
A situation in which the WPB or PAB noble gas ventilation monitors were at their maximum would indicate hazardous radiological conditions in these buildings.
The actual radiological conditions would be evaluated by health physics personnel using portable instruments if there was a need to enter these areas.
Interrogatory No. NH 9.44 No. 9.44 Referencing the Applicant's response to NH 9.11:
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(a) Provide the correlation between detector RD numbers and FSAR instrument tag numbers; (b) Referencing document #UE & C Foreign Print #71920 concerning the calibration of 2D 60, General Atomic Company did not correct the iodine detector's response for charcoal cartridge self-absorption effects and detector geometry effects as a function of depth of penetration of iodine in the charcoal.
Also, they did not check the detector for linearity as a function of source intensity.
Please provide documents indicating that this has or will be done.
(c) Referencing document #UE & C Foreign Print #71849 concerning the calibration of RD 59, General Atomic Company has only calibrated this detector with chlorine-36 and barium-133 check sources and has not determined the detector's response to actual radioactive gases.
Please provide documents indicating that this has or will be done.
Response
(a)
The detector RD number is a designation used by the RDMS vendor (GA) to identify their various radiation detection products.
The FSAR instrument tag number is the designation provided by the A/C (UE&C) to identify an entire monitor.
Thus, there is no correlation between RD numbers and tag numbers.
(b)
Iodine effluent monitors are not practical because of potential noble gas interference O
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problems.
Regulations require sampling, not monitoring of iodine.
Therefore it is our intention not to use RD-60's iodine detector.
Charcoal samples will be taken and examined in the laboratory wherein isotopic analysis can be performed.
(c)
UE&C Foreign Print (FP) #71849 was incorrectly called calibration report.
This FP is actually an instrument manual.
GA product literature shows that the radios.ctive gases Xe-133 and KR-85 were used to calibrate the gas detector.
A certified calibration report is being obtained from GA.
Interrogatory No. NH 9.45 NH 9.45 Please resolve the discrepancies between plant and detector numbers mentioned in the Applicant's response to Interrogatory NH 9.12, and those listed in FSAR Table 12.3-14.
Response
[To be supplied.]
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Interrogatory No. 10.14 NH 10.14 Please provide a drawing or picture of the Main Control Board, all other displays located in the Control Room, and the Remote Safe Shutdown Control Panels.
The purpose of this request is so that the State can have a pictorial representation of the Seabrook Main Control Board and other displays, controls, and instruments as originally proposed.
Response
Those drawings which provide information on the Main Control Board and all other displays located in.the Control Room were submitted in response to Interrogatory NH 10.3.
The drawings for the Remote Safe Shutdown Control Panels are 9763-F-500093 and 9763-F-500375.
Interrog tory No. 10.15 NH 10.15 Please provide a detailed description of all changes to the Main Control Board, all other displays located in the Control Room and to the Remote Safe Shutdown Control Panels as of the date of' answering this interrogatory.
Explain the reasons for these changes.
Please provide the most up-to-date pictorial representation of the above-mentioned control boards, controls, and displays.
Response
Engineering changes are made on Control Panels for various reasons.
As plant design progresses, systems -
change.
Many of these changes in systems call for associated changes in controls or instrumentation.
This, in turn, means that a Control Panel must be changed to accommodate the additional controls.
The majority of the changes on the Seabrook Control Board have been of this kind, and have been reviewed and approved in accordance with appropriate procedures.
Additionally, as the design of the plant and of the Control Board progresses, periodic reviews are made to look at operability and maintainability of the board.
Two major reviews of this type were performed during the design process on the board, resulting in significant changes and improvements.
A third such reviewis currently under way.
Because this is the third in the series, it is expected that it will discovery very few changes.
The major changes made because of the two operability and maintainability reviews are included in the file titled, "MCB - Seabrook Human Factors, 199.99.29",
furnished to NHAG as a part of the response to Interrogatory NH 10.3.
Further changes resulting from the current Human Factors Review will be available for !
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review as soon as the review is complete.
Any other changes were made necessary because of changes in system design, which required control and instrumentation changes on the board.
To provide a detailed description of all changes to the Main Control Board as well as the reason behind each change would be a monumental task; and provide little, if any, usable information.
A large amount of t
additional information, such as loop and logic diagrams, would be required :o fully understand the basis for the changes.
The general changes and the reasons behind them are discussed above.
Main Control Board and Remote Shutdown Panel drawings have been provided which show the results of the changes.
If, based on a review of the presently available documents, additional specific information is needed on a particular part of the board design, it can be supplied.
However, a general submittal on all changes would be useless. ;
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o Objection and Motion for Protective Order Except as so stated in the foregoing response, the Applicants object to this interrogatory on'the ground that it is inadequately focussed and unduly burdensome, and they move for a protective order with respect to it.
Interrogatory No. NH 10.16 NH 10.16 Documents (see letter dated 11/4/80, DeVincentis to Sturgeon) reflect that Human Factors review of Main Control Board was accomplished using General Electric Owner's Group Control Room Audit program.
Please indicate whether this is the basis of review or whether other programs were used.
If others used, please identify.
Please produce the results of such audit.
Response
The Control Board Survey portion of the Seabrook Control Room Design Review is currently being accomplished.
Those persons developing this Survey portion of the review used a checklist developed by the GE Owner's Group as a starting point for the development of their own checklist.
This checklist as developed for the Seabrook Control Room Design Review, is titled, III CONTROL ROOM REVIEW, and consists of e
s Parts A, Panel Layout and Design; B, Instrumentation and Hardware; C, Nonomputer Alarm / Status Lights; and D, Video Alarms and Computers; and is on file at Yankee Atomic Electric Company, Framingham, Massachusetts.
Copies of the checklist, including the resultant raw data developed, were provided to you in recponse to Interrogatory NH 10.2.
As stated in the response to Interrogatory 10.2, the Control Room Reivew is still under way.
The raw data has not yet been analyzed to produce results.
Interrogatory No. NH 10.17 NH 10.17 Letter from DeVincentis to Sturgeon, dated 12/9/80, states that certain changes suggested by Seabrook staff would not be included in Main Control Board because of the construction schedule.
Please identify changes not included and indicate whether changes were eventually included.
If not, explain why not.
Response
The words " construction schedule" above refer to the construction schedule for fabrication of the Main Control Board.
There comes a time in the fabrication of any component when no further changes can be made during the fabrication process; they must wait u.til l
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1 the fabrication is complete, then be incorporated as changes.
This is what the letter refers to.
The comments made and changes suggested by the NRC Seabrook staff were reviewed by the Engineering and Operations staff of Yankee Atomic Electric Company and Public Service Company of New Hampshire at a meeting on December 3, 1980.
In this meeting, agreement was reached on what changes should be made on the Main Control Board while it was in the fabrication process.
A list of outstanding items was developed and documented in Letter No. SB-10645, previously provided to you.
The status of the outstanding items identified in Letter No. SB-10645'is as follows:
1.
The modification to read out to 1/10 of 1* F. has been completed.
The method of indicating signal out of range is still open, and will be assessed as a part of the current Control Room Design Review (CRDR).
2.
This item will be recommended for correction during the CRDR.
3.
This item will be recommended for enhancement during the CRDR.
4.
This item has been incorporated..
s 5.
This item remains open, and will be assessed during the CRDR.
6.
This item remains open, and will be assessed during the CRDR.
7.
This problem has been alleviated by using only 2 pens of a 3-pen recorder, and changing the scale usage.
8.
This change has been incorporated.
9.
The specified recorder has been added.
- 10. This item remains open, and will be assessed during the CRDR.
Interrogatory No. NH 10.18 NH 10.-18 Please identify the location of the damper status lights on MainControl Board.
Response
Damper status indication for control dampers is located as follows:
In the Control Room on MCB Section CR, and on CP-23.
Throughout the rest of the plant on the Remote Safe Shutdown Panels CP-108A and B; on various Motor Control Centers; and on local control panels in various buildings.. _ -
The indication requirements for tornado dampers and backdraft dampers are still under review.
Interrogatory No. NH 10.19 NH 10.19 During the Control Room Design Review of the Seabrook plant, will Control Boards in locations other than the Control Room be included?
If so, please identify and provide a comprehensive description and/or pictorial representation of such boards.
, Response During the Control Room Design Review of the Seabrook plant, Control Boards in locations other than the Control Room will not be included.
Interrogatory No. NH 13.1 NH 13.1 Identify all persons who were or are responsible in a supervisory capacity for the general preparation of Ch.
- 13. of the FSAR, and, in particular, Sectons 13.1 and 13.2
Response
Mr. George S. Thomas, Vice President - Nuclear Production, Public Service Company of New Hampshire and Mr. John DeVincentis, Seabrook Project Manager, Yankee Atomic Electric Company were and are responsible for i._. -
the general preparation of all sections of FSAR Chapter 13.
Interrogatory No. NH 13.2 NH 13.2-The February 12, 1982 John DeVincentis letter to Frank Miraglia of the NRC provides in an " initial discussion" of the Applicants's compliance with NUREG 0737.
Please provide an update on the status of the Applicants's compliance with the following items of NUREG 0737.
(a)
I.A.1.1; (b)
I.A.2.3; and (c)
II.B.4
Response
The status of each of these items is dis:ussed below:
(a.)
Task I.A.1.1 Shift Technical Advisor (NUREG -
0737 Position Each licensee shall provide an on-shift technical advisor to the shift supervisor.
The Shift technical advisor (STA) may serve more than one unit, at a multi-unit site, if qualified to perform l
the advisory function for the various units.
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The STA shall have a bachelor's degree, or equivalent, in a scientific or engineering disciline and have received specific training in the response and analysis of the plant for transients and accidents.
The STA shall also receive training in plant design and layout, including the capabilities.of instrumentation and control in the control room.
The licensee shall assign normal duties to the STA's that pertain to the engineering aspects of assuring safe operations of the plant, including the review and evaluation of operating experience.
Response
1 PSNH has upgraded the Shift Superintendent and Unit Shift Supervisor training to encompass the requirements for the STA training, obviating the need for a separate STA.
This approach to compliance with this item is currently under staff review. l 4
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'(b.)
Task I.A.2.3 Administration of Training Programs (NUREG-0737)
Position Pending accreditation of training institutions, licensees and applicants for operating licenses will assure that training center and factility instructors who teach systems integrated responses, transien, and simulator courses demonstrate senior reactor operator qualifications and be enrolled in appropriate requalification programs.
Response
A fully qualified simulator staff, with previously SRO licensed instructors, will implement and conduct the simulator training program.
Permanent and guest classroom instructors not previously SRO licensed will demonstrate the knowledge in that subject required of a SRO. Such knowledge will be documented by the completion of an instructor qualification program for the subject area. :
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(c.)
Task II.B.4 Training for Mitigating Core Damage (NUREC-0737)
Position Licensees are required to develop a training program to each the use of installed equipment and systems to control or mitigate accirdents in which the core is severly damaged.
They must then implement the training program.
Response
A training program to teach the use of equipment and systems to mitigate accidents involving core damage will be developed prior to fuel load and be completed prior to full-power operations.
Operating personnel from the Station Manager through the operations chain to the licensed operators will receive training equivalent to that identified in to H. R. Denton's March 28, 1980 letter.
Portions of the training will also be administered to supervisors and technicians in the Instrumentation and Control, Health Physics, and Chemistry departments commensurate with their responsibilities.
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Interrogatory No. NH 13.3 NH 13.3 Identify and produce pursuant to 10 C.F.R.
Section 2.741 all documents prepared by the Applicant addressing the Applicant's compliance with the three NUREG-0737 items listed in the previous interrogatory.
Response
Compliance with the-previously discussed NUREG-0737 items is addressed in the following documents, available in the PDR.
1)
Letter from J. DeVincentis to F. Miraglia dated February 12, 1982 2)
Letter from W. P. Johnson to R.L. Tedesco dated February 18, 1982 3)
Letter from J. DeVincentis to F. Miraglia dated March 11, 1982 4)
Letter fro J. DeVincentis to J. B. Kerrigan dated September 28, 1982.
5)
Seabrook Station FSAR, Section 13.2.
These items are also discussed in a memorandum from G.S. Thomas to J. DeVincentis dated September 21, 1981 (attached).
Interrogatory No. NH 13.4 NH 13.4 Describe-in detail how and to what extent each phase of the control room operator training progtram provides or will provide for the following aspects of emergency response training:.
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(a) recognition of emergency conditions; (b) classification of observed emergency conditions in-accordance with the emergency classification system; (c) notification of emergency to off-site authorities; (d) recommendation of protective actions to off-site authorities; and (e) direction of station staff to take protective actions.
Response
[To be submitted later.]
Interrogatory No. NH 13.5 NH 13.5 Identify and produce pursuant to 10 C.F.R.
Section 2.741 all documents relating to FSAR Ch. 13 review meeting with the NRC Region I representatives on January 4-6, 1982, which were submitted by the Applicant to the NRC following that meeting.
Response
Several handouts were provided to the NRC representatives following the meeting.
These handouts are attached to a letter from Mr.
L.
L. Wheeler dated January 25, 1982 entitled " Meeting Summary".
This letter was issued to the docket and should be available in the public docket room.
The major purpose of the meeting was to discuss the 630 series RAIs.
Two letters were written to the NRC subsequent to the meeting which documented PSNHs responses to these RAIs:
(1) PSNH letter dated February 18, 1982, " Upgraded Qualifications for Seabrook Station Licensed Operators", W.P. Johnson To R.L. Tedesco.
(2) PSNH letter dated March 11, 1982, " Submittal of Responses to Seabrook Station FSAR Chapter 13 Requests for Additional Information",
J.
DeVincentis to F.J. Miraglia.
Both of these letters are available in the public docket room.
In addition, the responses to the 630 series RAIs were incorporated in the FSAR as part of Amendment 45.
Interrogatory No. 13.6 NH 13.6 Please describe the " oral or demonstrative audits" which will be conducted periodically to evaluate the effectiveness of the operator licensing training program, which audits are mentioned on p.13.2-4 of the FSAR.
Indicate what " independent third party" will perform these audits.
Response
The Seabrook Training Center has as part of its plan for monitoring the effectiveness of instruction, a program of oral audit examinations administered annually by an independent third-party audit group.
l These audit exams are standardized to a wide cross-section of the nuclear industry operators and i
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o comparable to the level of knowledge and depth of understanding tested for in the Nuclear Regulatory Commission operator license examination.
A program was established with Personnel Qualification Services, Inc. in February, 1979 tp provide independent audit monitoring for the Seabrook license training program.
This company is a recognized expert in the area of nuclear operator qualification and its examiners include ex-NRC examiners and senior industry training representatives.
The objectives of the oral audit program are as follows:
1.
Provide timely feedback of strengths and weaknesses of contracted and company run license training program instruction.
2.
Monitor the retention level of previously covered course work.
3.
Provide each license candidate with an appreciation of how much knowledge was retained.
4.
Provide feedback of the motivation climate pertaining to any aspect, technical or administrative, of the license training program.
5.
Acclimate the license candidates to the oral examination method of evaluation.
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In the first quarter of 1981, audit exams were conducted for two groups of license candidates.
Group A, consiting of twenty people, and Group B, with nineteen people, had completed nuclear reactor fundamentals (NRF) instruction in December of 1980.
A third group of twelve people, Group C, completed NRF training and were examined in the first quarter of 1982.
Oral examinations are graded based upon a
" satisfactory", " marginal", or " unsatisfactory" criteria.
The examination sampled student knowledge of six categories of theory, heat transfer (H/T), fluid dynamics, instrumentation and controls (I/C), chemistry and radiological protection.
In the initial license program, the annual oral audits will include future instruction completed as of the audit date.
An element for evaluation of simulator operational demonstration is included.
Independent third-party audit of the requalification program will be conducted annually.
It is anticipated s
that a sample of 20 percent of the Seabrook license holders will assure maintenance of quality training.
Interrogatory No. NH 13.7 NH 13.7 How many candidates for licensed operators are currently in any phase of training?
Response
There are presently 47 candidates enrolled in the Seabrook licensed operator training program.
A breakdown of department and license level is provided below:
Operators 26 SRO 14 RO Station 2 SRO Management Training 4 SRO Center 1
RO Staff Interrogatory No. NH 13.8 NH 13.8 How many licensed operators does the Applicant estimate to be necessary for fully manned shift crews for the plant's operation?
Indicate how many licensed operators will be necessary per unit per shift, and in what capacity they will be needed.
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Response
The shift crew composition is identified on Table 6.2.1~
of the Technical Specifications volume of the FSAR.
Interrogatory No. NH 20.1 NH 20.1 Please identify all the persons who were or are responsible in a supervisory capacity for the development generally of the Seabrook Station Radiological Emergency Plan, submitted as a separate volume of the Final Safety Analaysis Report. -Also identify'those persons who were or are responsible in a supervisory capacity for the development of each of the following specific sections of the Emergency Plan:$ 6.0
" Emergency Facilities and Equipment;"
$ 7.0 " Communications;"
$ 8.0 " Organization;"
$ 11.0 " Emergency Notification and ?ublic Information;"
and 5 12.0 " Maintaining Emergency Preparedness."
Response
For Seabrook Station Radiological Emergency Plan in general and Sections 6, 7,
8, 11, and 12 specifically, the individuals who were and are responsible in a supervisory capacity are:
James A. MacDonald, Manager, t
Radiation Protection Group, Yankee Atomic Electric Company end George S.
Thomas, Vice President, Public 3
Service Company of New Hampshire. 8M/ Mr./8tucebec/I!8 f
Trged planey,8Lhe Seeviec Co>,7any aP New phmfshe..
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Interrogatory No. NH 20.2, r,
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NH 20.2 The Emergency Plan contains, as yet, no complete
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Emergency Action Levels.
When does,the' Applicant expect to submit the Emergency Action > Levels referenced in Appendix A of the Emergency Plan?
Pleane produce, pursuatn to 10 C.F.R. Section 2.7413 all documents which have been developed to date with regard to
,s Emergency Action Levels.
Response
Emergency Action Levels (EAL) will be added when the emergency classification procedure is completed.
Current schedule calls for this procedure to be ready s
by the summer of 1983.
No EAL documents have been produced as yet.
s Interrogatory No. NH 20.3 s
NH 20.3 Describe what steps have been taken to discuss the Emergency Action Levels with State and local governmental authorities.
Please also describe the nature of the comments received from these authorities.
Identify all' documents which relate'to such discussions and comments and produce these documents pursuant to 10 C.F.R. Section 2.741.
Response
Since Emergency Action Levels have not been specified to date, there have been no discussion regarding them
)
i with off-site authorities.
See response to Interrogatory No. NH 20.2 Interrogatory No. NH 20.4 NH 20.4 Will emergencies of various classifications be declared whenever the Emergency Action Levels (EAL) indicate that such declarations are in order?
Or will the Emergency Director have the discretion not to declare an emergency even though it is indicated by the applicable EAL?
If the latter, describe the factors upon which the Emergency Director must make his determination.
Identify all documents which relate to the process of declaring an emergency and produce such documents pursuant to 10 C.F.R.
Section 2.741.
Response
Any situation or set of conditions that meet or exceed an Emergency Action Level (s) established as part of the.
emergency classification procedure will produce an emergency declaration.
See response to Interrogatory No. NH 20,2.
Interrogatory No. NH 20.5 NH 20.5 Describe what steps have been or will be taken to ensure that the shift superintendent or unit shift supervisor will properly and promptly recognize emergency conditions and classify the observed conditions in accordance with the emergency classification system. i b
kesponse The steps to be.taken to insure this consist of an accurate and detailed emergency classification procedure that includes EAL's for various emergency events in each of the four emergency classes and a training program to insure operators have the understanding necessary to execute with this procedure.
Interrogatory No. NH 20.6 NH 20.6 Specify what steps have been or will be taken to ensure that the appropriate State of New Hampshire authorities will be notified within fifteen minutes of a classifiable event.
Response
Notification of New Hampshire State Police will be assured within fifteen minutes of an emergency declaration by the execution of emergency implementing procedures.
Interrogatory No. NH 20.7 NH 20.7 Identify and produce pursuant to 10 C.F.R.
Section 2.741 all documents which have been prepared for the purpose of studying, reviewing, or critiquing the emergency response organization and procedures as described in Section 8.2 of the Emergency Plan... -
Response
Emergency implementing procedures have not been developed as yet.
There are no other documents associated with the information presented in Section
.8.2 of the Emergency Plan.
Interrogatory No. NH 20.8 NH 20.8 Please describe in detail the " radio paging" system referred to at page 3-3 of the Emergency Plan as the primary notification mechanism for notification of members of the Emergency Response Organization.
Response
One of the methods to mobilize additional PSNH and Yankee NSD personnel in an emergency is by the activation of radio pagers.
The current arrangment for Yankee is the use of a commercial radio paging service.
The arrangement selected by PSNH may either be a commercial service or a PSNH operated and maintained syctem tnat serves the residential areas of station employees.
l __
Interrogatory No. NH 20.8-a NH 20.8-a-Identify and describe in detail the back up-system which will be used to notify members of the Emergency Response Organization.
Response
- As identified in response to NH 20.8, the use of radio pagers is one of the means for mobilizing Emergency
't Response Organization personnel.
Radio paging methods will be supplemented (backed up) by commercial telephone notification.
Interrogatory No. NH 20.9 NH 20.9 Describe in detail the primary and back-up communications systems for use between:
(a) the Emergency Operations Facility and the Media Center; (b) the Technical Support Center and the Emergency Operations Facility; i
(c) the Technical Support Center and the New Hampshire Incident Field Office for Seabrook; and (d) all the emergency response centers described in Section 6.0 of the Emergency Plan and the New l
Hampshire Emergency Operations Center in Concord.
Please identify all documents which describe the communications systems referred to above and produce such documents pursuant to 10 C.F.R.
Section 2.741.
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Response
Refer to Section 7 of the Emergency Plan, in particular, Figure 7.3.
There are on other documents other than the description given in Section 7 of the Emergency Plan that describe these systems as they are to be used for Seabrook Station emergency communications.
Interrogatory No. NH 20.10 NH 20.10 Identify and produce pursuant to 10 C.F.R.
Section 2.741 all documents pertaining to the study, review, or critique of the communications systems described in answering Interrogatory NH 20.9.
Response
See response to Interrogatory No. NH 20.9.
Interrogatory No. NH 20.11 NH 20.11 Have the communications systems described in Sections 7.1 and 7.3 of the Emergency Plan been tested by the Applicant?
What are the results of any such testing?
Please identify all documents relating to any such testing, and produce such documents pursuant to 10 C.F.R.
Section 2.741.
Response
The Emergency Communications Network, shown in Figure 7.3, has not yet been installed at Seabrook Station.
I n
Interrogatory No. NH 20.12 NH 20.12 Has the Applicant considered whether a data transmission communications system is required to communicate the necessary amounts of information to the New Hampshire Emergency Operations Center?
If so, explain how this has been considered.
Identify all documents relating to this consideration, and produce such documents pursuant to 10 C.F.R.
Section 2.741.
Response
No such consideration for this purpose has been made.
Interrogatory No. NH 20.13 NH 20.13 Describe the steps that the Applicant has taken or will take to ensure that Seabrook Station's Radiological Emergency Plan properly interfaces with the State of Ifew Hampshire radiological emergency response plan,
Response
The process of establishing the Seabrook Station Radiological Emergency Plan involves direct and regular interface with the New Hampshire Civil Defense and Radiation Control Agencies and their development of the State of New Hampshire Radiological Emergency Response Plan. i e
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.R Interrogatory No. NH 20.14 NH'20.14 4,
- What factors were considered in'the decision to locate
. the emergency Operations Facility at the Seabrook Station Training Center?
. Identify and produce pursuant to 10 C.F.R. 2.741 all documents relating to the Applicant'sdecision to locate 'the Emergency Operation Facility there.
Response
1 The' final location of the Seabrook' Station Emergency-i-
Operations Facility is under-review at.the current
- tinte.
Interrogatory No. NH 20.15 NH 20.15 What factors were considered in the decision to locate the Emergency Operations Facility at the Media Center at Firemen's Association Building in Seabrook?
Identify all documents' relating to the Applicant's decision to locate the Emergency Operations Facility there.
Response
This Interrogatory is not understandable.
t Interrogatory No. NH 20.16 NH 20.16 i
Identify all documents pertaining to any agreements f
I which the Applicant believes to exist between the Applicant and the State of New Hampshire relative to
. protective action recommendations, such as the one referred to on page 3-3 of the Emergency Plan.
Explain I
i
i d.-
f what "other station parameters" (again on page 3-3) the Emergency Director or other station personnel will use to identify the potential for radiological releases.
Response
The agreement that exists between the applicant and the State of New Hampshire, relative to protective action recommendations, is simply a continuation of the same arrangement already implemented for the same purpose between Vermont Yankee and the State of New Hampshire.
The Seabrook arrangement will parallel the arrangement already implemented there.
Interrogatory No. NH 20.17 NH 20.17 Describe in detail the manner in which, and the extent to which, the Applicant will monitor all emergency station personnel accountability.
Response
The principle means for monitoring accountability of personnel in an emergency will be provided by security personnel implementation of a specifically developed accountability procedure.
This procedure will be completed by the fall of 1983. _
Y Interrogatory No. NH 20.18-NH 20.18 Explain how the persons _ responsible for off-site radiation dose projections will make those projections and how-those projections will be transmitted to the appropriate governmental entities.
Response
Projections of off-site radiological consequences will be-performed by Seabrook Station Emergency-Response personnel using all available information and data-associated with radiological releases, meteorological parameters, and off-site monitoring results.
Results of these projections will be transmitted to'off-site authorities verbally via emergency communication links and directly to off-site agency representatives who respond to the Seabrook Station EOF.
Interrogatory No. NH 20.19 i'
NH 20.19 Please identify the radiological monitoring and dose assessment personnnel who will be available for "immediate emergency action", as defined in Table 8.1 of the Emergency Plan.
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'All of the personnel-identified in Table 8.1 will be available for "immediate-emergency actions" in an emergency situation at Seabrook Station.
Interrogatory No. 1GI 21.1 NH 21.1_
Please identify all the persons who were or are responsible in a supervisory capacity for the development of the following sections of the Emergency Plan:
$ 9.0 " Emergency Response," and 6 10.0 " Emergency Measures."
Responce See the response to Interrogatory No. NH 20.1.
Interrogatory No. NH 21.2 Describe the arrangements which have been made for transportation of and medical treatment for injured personnel, specifying which particular hospital and transportation services have been arranged, and the training and experience of the hospital and transportation personnel in handling radiation emergency patients.
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+
Response
Arrangements are now being made for emergency medical treatment of injured Seabrook Station personnel.
These arrangements are underway with Exeter Hospital for treatment services.
For emergency medical
. transportation, an arrangement is being made with the on-site ambulance capability athat is maintained at
^
Seabrook Station.
For both emergency medical treatment and emergency transportation services, all personnel involved will be appropriately trained prior to initial start-up of Unit 1.
The emergency department physician at Exeter Hospital responsible for their end of the arrangement has attended the course for this purpose given by the Radiation Emergency Assistance Center Training Site operated by Oak Ridge Associated Universities for the United States Department of Energy.
Interrogatory No. NH 21.3 NH 21.3 Section 10.3 of the Emergency Plan, at page 10-3, states that " measures will be taken to minimize personnel exposures from external and/or internal sources of radiation."
Please describe these measures.
Identify all documents which discuss these measures and
~, -
produce such documents pursuant to 10 C.F.R.
Section 2.741.
Response
The " measures" that would.be utilized consist of emergency radiological protection techniques and approaches appropriate to the radiological aspects of the emergency conditions at the time.
Interrogatory No. NH 21.4 NH 21.4 Describe in detail the " emergency radiological protection programs" referred to on page 10-3 of the Emergency Plan.
Response
" Emergency radiological protection programs" techniques and approaches would be developed by Seabrook Ctation Emergency Response Organization personnel at the time of an emergency condition.
They would be specific to the radiological conditions being experienced.
Interrogatory No. SAPL Supp. 3.13 SAPL Supp. 3.13 In response to Interrogatory No. SAPL Supp. 3.6, Applicant indicates that it has not done an analysis of transients and accidents which postulate multiple failures includes operators' errors.
Under NUREG 0737, I.C.1, the Applicant is required to perform such an j i l
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J analysis.
Please explain why such analysis has not been done to date and when it'will be completed.
Identify the documents which have been or will be produced to satisfy this requirement.
Response
(The Applicants understood the original question-(Interrogatory No. SAPL Supp. 3.6) to refer to system design reviews, not to reviews for Evaluation and Development of Procedures for Transients and Accidents (NUREG 0737, I.C.1).
The following response pertains to the interrogatory as now framed.)
The Applicants are participating in the Westinghouse Owners Group (WOG) effort to develop the documents to satisfy NUREG 0737, Item O.C.l.
The first issue of the documents, entitled "The Emergency Response Guidelines," were submittted by the WOG to the NRC for comment in November, 1981.
We anticipate that the Guidelines will be revised and resubmitted to the NRC in mid-1983.
Plant specific procedures will be developed based on the Guidelines. -
r Interrogatory No. SAPL Supp. 3.14 SAPL Supp. 3.14 Has the Applicant reconsidered the issue of ATWS since the adoption of the report, " Westinghouse Anticipated Transients Without Trip Analysis (1974)", in light of the publication of WASH-1400 (1975), NUREG-0460 (1978) and NUREG/CR-1400 (1978)?
Please identify any review, reconsideration, or. study that was conducted.
Response
The question of ATWS is being considered explicity in the Seabrook Station PRA.
Interrogatory No. SAPL Supp. 3.15 SAPL Supp. 3.15 Why was General Electric user group data used for the review of the Control Room Design Review?
Are data from PWR users available?
Response
[To be submitted.]
Signatures As to Answers:
I, Wendell P. Johnson, being first duly sworn, do depose and say that the foregoing answers are true, expect insofar as they are based on information that is available to the Applicants but not within my personal knowledge, as to which I, based on such information, believe them to be true.
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01ts./Q hfendell P.'Jo s6n
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Sworn to before me this 4M day of N r7 9
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As to Objections:
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Thomas G.
Dignan, Jr.
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R.
K.
Gad III A
-4 Ropes & Gray 225 Franklin Street
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Boston, Massachusetts 02110
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Telephone:
423-6100
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CERTIFICATE OF SERVICE I,
Robert K. Gad III, one of the attorneys for the Applicants herein, hereby~ certify that on January 5, 1983 I made service of the within " Applicants' First Answers to
'The State of New Hampshire's Second Set of Interrogatories and Request for Production of Documents to Public Service Company of New Hampshire, Inc.' and Motion for Protective Order" by mailing copies thereof, postage prepaid, to:
Helen Hoyt, Chairperson Rep. Beverly Hollingworth Atomic Safety and Licensing Coastal Chamber of Commerce Board Panel 209 Winnacunnet Road U.S. Nuclear Regulatory Commission Hampton, NH 03842 Washington, DC 20555 Dr. Emmeth A.
Luebke William S.
Jordan, III, Esquire Atomic Safety and Licensing Harmon & Weiss Board Panel 1725 I Street, U.W.
U.S.
Nuclear Regulatory Commission Suite 506 Washington, DC 20555 Washington, DC 20006 Dr. Jerry Harbour E.
Tupper Kinder, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Office of the Attorney General U.S. Nuclear Regulatory Commission 208 State House Annex Washington, DC 20555 Concord, NH 03301 Atomic Safety and Licensing Roy P.
- Lessy, Jr.,
Esquire Board Panel Office of the Executive Legal U.S.
Nuclear Regulatory Commission Director Washington, DC 20555 U.S.
Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Robert A. Backus, Esquire Board Panel 116 Lowell Street U.S.
Nuclear Regulatory Commission P.O.
Box 516 Washington, DC 20555 Manchester, NH 03105 <
w.
, s Philip Ahrens,. Esquire Edward J.
McDermott, Esquire Assistant Attorney General Sanders and McDermott Department of the Attorney Professional Association General 408 Lafayette Road Augusta, ME 04333 Hampton,-NH 03842 David L. Lewis Jo Ann Shotwell, Esquire Atemic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S.
Nuclear Regulatory Commission Department of the Attorney General Rm. E/W-439 One Ashburton Place, 19th Floor Washington, DC 20555 Boston, MA 02108 Mr. John B. Tanzer Ms. Olive L. Tash 5 Morningside Drive R.F.D.
1, Dalton Road Hampton, NH 03842 Brentwood, NH 03833 State Representative Edward F. Meany Roberta C.
Pevaar
-155 Washington Road Drinkwater Road Rye, NH 03870 Hampton Falls, NH 03844 Robert K.
Gad III. -. -
-.