ML20072P858

Answers to Interrogatories XXIX-3 Through XXIX-21,XXIX-24 & XXIX-25 on Contention III.1 Re Emergency Planning. Certificate of Svc Encl.Related Correspondence

ML20072P858
Person / Time
Site:	Seabrook
Issue date:	03/31/1983
From:	Curran D, Jordan W HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
NUDOCS 8304040399
Download: ML20072P858 (9)

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.g ppg -1 P2 51 UNITED STATES OF AMERICA  ?;'

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443 NEW HAMPSHIRE, et al. ) 50-444

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(Seabrook Station, Units 1 )

and 2) )

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. NECNP ANSWERS TO APPLICANTS' INTERROGATORIES XXIX-3 THROUGH XXIX-21, XXIX-24 AND XXIX-25 By order of March 24, 1983, the Board directed NECNP to answer a number of interrogatories relating to emergency planning issues, including interrogatories on Contention III.l. Because of the extremely short time period allowed for preparing these answers, NECNP was unable to complete them all in time to serve them on Applicants by March 30, in order that

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Applicants would receive them by March 31. Consequently, wp' '

I have prepared a separate filing on the interrogatories relating to Contention III.1 which are being served on Applicants by

.,,- telecopier March 31.

XXIX-3. The following changes should be made with respect to the deficiencies identified by NECNP in response to Interrogatory XXIX-2:

a) Applicants should provide some justification and explanation for the classification of various system failures as unusual events, alerts, site area emergencies, or general 8304040399 830331 PDR ADDCK 05000443 G PDR

emergencies, that would allow a determination of whether they met the criteria for those classifications, b) The transients incorrectly classified by Applicants should be reclassified. See r esponse to Interrogatory XXIX-6.

c) Applicants should reclassify transients to provide greater response time in , consideration of local f actors delaying evacuation.

d) Applicants should identify the apparatus and personnel that will be relied upon in responding to the events listed in the emergency classification scheme. Applicants should also reclassify transients incorrectly classified, as stated in b) above.

e) Applicants have not yet supplied emergency action levels as required by 10 C.F.R. S 50.47(b)(4). Therefore there is nothing to evaluate, f) Applicants must identify emergency action levels and identify equipment that will be used to respond to, analyze, and monitor the symptoms of transients.

XXIX-4. NECNP seeks a logical explanation of the basis for the classification of each transient in light of the criteria for classification outlined in NUREG-0654.

XXIX-5. The purpose of the classification scheme is to provide early and prompt notification of potential accidents.

It is therefore important that transients be classified correctly according to the potential severity of their implications, in order that the operator can respond with l

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proper speed and appropriate action. Applicants' classification scheme does not provide for sufficiently significant response to the various transients.

XXIX-6. NECNP contends that for the following transients, Applicants either minimize the significance or fail to provide enough information to determine the significance:

Unusual Event Conditions For events numbered 1, 5, and 6, Applicants have not completed their description of the event, and therefore the severity of the transients cannot be -assessed.

Event number 8, " Fire that threatens'but does not defeat a plant safety train or function," should be classified as an

" Alert."

Event' number 9 comprises " Events or conditions which require a plant mode reduction in accordance with technical specifications which include but are not limited to the following:

a. Loss of engineered safeguards

b. Loss of containment integrity (if at power)

c. Loss of offsite power

d. Loss of onsite AC power capability."

The above should be classified as an " alert."

Event number 15, " System or component failures which result in individual or collective initiation of ECCS, containment spray and/or emergency feedwater system," should be classifie6 as a site emergency if these events are collective. ,

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1' Alert Conditions Event number 2, items a and b should be classified as a site emergency.

Event number 3 should be classified as a site emergency.

No duration is given for events 7 and 8, and therefore the signficance of these transients cannot be evaluated.

Ev'nt e number 11 should be classified as a site emergency, particularly if the manual scram f ails.

Event number 16 should be classified as a site emergency.

Event number 19 should be classified as a site emergency.

Area Emergency Conditions Event number 1 should be considered a general emergency.

No level for "high" airborne radioactivity releases is' specified for event number 4, and therefore its significance is impossible to evaluate.

Event number 5 should be classified as a general emergency.

Event number 6 should be classified as a general emergency.

The defeat of redundant safety systems or equipment could be a general emergency if critical safety systems were affected. Applicants do not provide enough information to determine whether this classification is proper.

XXIX-7. (i) Applicants' classification of the transients listed above provides a general indication of how Applicants perceive their significance. (ii). NECNP has not undertaken any study or analysis to determine the potential for each transient.

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XXIX-8. NECNP described the changes in response to Interrogatory XXIX-6.

XXIX-9. Applicants' classification scheme fails to show that Applicants have considered local conditions at all. NECNP has not performed an independent study that would identify all local conditions affocting the speed of evacuation. However, some of the local conditions that Applicants have not considered include local traffic patterns, adverse weather conditions, evacuee directional bias, and the evacuation shadow phenomenon. Seb response to Interrogatory XXXII-3.

XXIX-10. (i-iii) NECNP has not performed any evacuation time studies for Seabrook. (iv) In general, Applicants must plan for earlier notification and more rapid preparation to respond to transients.

XXIX-ll. NECNP has not made a study of all the specific plant circumstances which could affect the classification scheme. Applicants' plan does not give any indication that such factors were considered at all. Accordingly, NECNP's contention encompasses all such circumstances.

XXIX-12. See response to XXIX-ll.

XXIX-13. This contention is not concerned with specific items or categories of apparatus or personnel, but with a classification scheme that fails to provide the requisite reasonable assurance regardless of item or category. Thus, NECNP does not intend to litigate this contention with respect to particular items or categories. We note that Applicants

c' have failed to make the required showing of "the specific instruments, parameters, or equipment status...for establishing each emergency procedure," as required by NUREG-0654.

NUREG-0654 at 36. Thus, NECNP is unable to provide the information required in this interrogatory until Applicants provide the information required by NUREG-0654.

XXIX-14. See the first paragraph of the response to XXIX-13.

XXIX-15-17. See the first paragraph of the response to XXIX-13.

XXIX-18. NECNP has not performed any analyses to allow us to quantify the expression "quickly enough." On a qualitative level, however, NECNP considers the term to mean that personnel and apparatus will be ready to respond to an accident before it happens in light of indications that it may happen.

XXIX-19. NECNP has not performed any analyses to allow us to quantify the expression " adequate state of readiness." We consider the term to mean that plant apparatus and personnel are equipped to r espond immediately to whatever conditions may result from the transient, and to implement full emergency response measures immediately.

XXIX-20. Yes.

XXIX-21. NECNP has reviewed Applicants' Radiological Emergency Plan, NUREG-0654, and NRC regulations at 10 CPR 50.47.

XXIX-24. Applicants must consider all transients j applicable to pressurized water reactors as listed in  !

EPRI-NP-2330, ATSW, "A Reappraisal, Part III, Frequency of Anticipated Transients." NECNP has not identified the symptoms for each of these transients.

XXIX-25. NECNP has not undertaken a study to identify all such "other indicators." An example would be a situation-in, which the operator is directly informed that a transient is imminent rather than required to interpret symptoms of the transient.

Respectfully submitted, Diane Curran

M William S.

T/M ordan III IIARMON & WEISS 1725 I Street, N.W.

Suite 506 i March 31, 1983 Washington, D.C. 20006 (202) 833-9070 4

CERTIFICATE OF SERVICE I certify that on March 31, 1983, copies of NECNP ANSWERS TO APPLICANTS' INTERROGATORIES XXIX-3 TIIROUGH XXIX-21, XXIX-24 AND XXIX-25 were served by first-class mail or as otherwise indicated on the following:

• Helen F . Hoyt , Esq. Robert A. Backus, Esq.

Chairperson, Atomic Safety 116 Lowell Street and Licensing Board P.O. Box 516 U.S. Nuclear Regulatory Commission Manchester, NH 03105 Washinton, D.C. 20555 Phillip Ahrens, Esq.

• Dr. Jerry Harbour Assistant Atty. General Administrative Judge State House, Station 16 Atomic Safety and Licensing Board Augusta, ME 04333 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Jo Ann shotwell, Esq.

Assistant Atty. General

• Dr . Emmeth A. Luebke Office of the Atty. Gen.

Administrative Judge One Ashburton Place, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Beverly Hollingworth Washington, D.C. 20555 Coastal Chamber of Commerce

• Roy P . Lessy, Jr., Esq. 822 Lafayette Rd.

Robert Perlis, Esq. P.O. Box 596 Office of Exec. Legal Dir. Hampton, NH 03842 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Anne Verge, Chair Board of Selectmen Atomic Safety and Licensing Board Panel Town Hall U.S. Nuclear Regulatory Commission South Hampton, NH 03842 Washington, D.C. 20555

• • Robert K. Gad, Esq.

Atomic Safety and Licensing Board Thomas G. Dignan, Jr., ES@

Appeal Panel Ropes and Gray U.S. Nuclear Regulatory Commission 225 Franklin Street Washington, D.C. 20555 Boston, MA 02110 Ruthanne G. Miller, Esq. Sandra Gavutis Law Clerk to the Board RFD 1 Atomic Safety and Licensing Board East Kensington, NH 03827 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 n

George Dana Bisbee, Esq. John B. Tanzer Edward Cross, Esq. 5 Morningside' Drive Asst. At ty. Generals lla mpt on , Nil 03842 Office of the Atty. General Dr. Mauray Tye, President Letty liett, Selectman Sun Valley Association RFD Dalton Road 98 Emmerson Street -Brentwood, Nil 03833 IIaver hill, MA- 01830 Calvin A. Cannery Edward F. Meany City lianager -

155-Washington Rd. City Itall Rye, NII 03870 Portsmouth, N!! 03801 Roberta C. Pevear Drinkwater Road llampton Falls, Nil 03844

• y ecopier L b