ML20088A807

Supplemental Response to Applicant 821208 Interrogatories on Contention NH-10 Re Control Room Design.Certificate of Svc Encl.Related Correspondence

ML20088A807
Person / Time
Site:	Seabrook
Issue date:	04/10/1984
From:	Fan S NEW HAMPSHIRE, STATE OF
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20088A805	List: ML20088A804 ML20088A807
References
NUDOCS 8404130149
Download: ML20088A807 (8)

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RELATED CO,~,.,_1; ;;;;g;;cg U111TED STATES OF A!1 ERICA NUCLEAR REGULATORY COMMISSION ff E0 Before the 2 p2:08 ATOMIC SAFETY AND LICENSING BOARD.

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PUBLIC SERVICE CO!!PANY OF NEW HA!!PSHIRE ) Docket Hos.: 50-443 ET AL. ) and

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(Seabrook Station, Units 1 and 2) ) April 10, 1984

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THE STATE OF NEW HAMPSHIRE'S SUPPLEMENTAL RESPONSE TO APPLICANT'S INTERROGATORIES FILED ON DECEMBER 8, 1982 INTRODUCTION The _ State of New Ilampshire provides belou its supplemental response to certain interrogatories propounded by the Applicant on December 8, 1982, on Contention NH-10 -- Control Roon Design.

Interrogatory II-2 Please specify in detail each respect in which HIIAG contends that the Seabrook Control Roon Design does not comply with GDC-19.

Interrogatory II-3 Please specify in detail each respect in which NHAG contends that the Seabrook Control Roon Design does not comply with -

GDC-20.

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l Interrogatory II-4 Please specify in detail each respect in which 1HIAG contends that the Seabrook Control Roon Design does not conply with  ;

GDC-21.

Interrogatory-II-5 Please specify in detail each respect in which NHAG contends that the Seabrook Control Roon Design does not conply with 7 GDC-22.

Responses to II-2 through II-5:

See responses to II-6, II-7, and II-8 below.

Interrogatory II-6 l Please specify in detail each respect in which HIIAG contends that the Seabrook Control Roon Design does not comply with HUREG-0737, Iten I.D.l.

Response to II-6:

.The Detailed' Control Roon Design' Review (DCRDR)'re' quired by-

' NU REG . 0737 (Iten I.D.1) and' Supplement-1 thereto has not'been completed. While the Applicant has submitted a DCRDR and one I revision to the NIU2, the document on'its face is not couplete. 'See "Scabrooh Station Control Roon Design Review," subnitted under cover of Public Service Company;of New Hanpshire August 10, 1983,-letter

-to URC, at_pp. 20-21. F.urthernore, the URC Staff in its January 4,-

1984, report entitled "Results of In-Progress Audit of Seabrook'

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Station ~ Detailed Control Roon Design' Review" indicates that the DCRDR is not complete. In fact, the Staff notes that."further.

subnissions will be necessary to fully satisfy 1the requiren'ents of Supplement : 1 to NUREG-0737" . LSee: Audit at.p._17.

The list of particular itens not included in the Seabrook DCRDR is outlined on pages 18 and 19 of the January 4, 1984, URC Staff audit, and on page 21 of the Applicants' August 10, 1983, subnittal to the URC. The State of New Hampshire contends that the failure to include each of these itens in the DCRDR constitutes a lack of.

,9 compliance with UUREG-0737 (Iten 1.D.1) and Supplenent 1 thereto.

Of particular concern is the Applic' ant's failure to include in its DCRDR a review of the safety parameter disnlay systen, the radiation monitoring systen, and the remote shutdown panel.

Furthernore, the State of Ucu Hampshire shares the URC staff' view that the Applicant has not conplied with the systems function and task analysis requirenent of UUREG-0737 and Supplement 1 thereto, and the conconnitant failure to compara the results of this analysis with a control roon inventory.

Finally, the State of New Hampshire contends that the improvenents to the Control Roon Design indicated fron the DCRDR

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have not been properly coordinated with. changes resulting from other improvenent programs in Control Roon Design. The State of New Hampshire agrees with the Staff's statement that the Applicant has not described in detail how the coordination is being acconplished.

New Hanpshire does not agree, however, with the Staff's conclusion that the Applicant is "natisfying" the. coordination requirenent of Supplement 1 to UUREG-0737. See Audit at p. 16. For example, given th.e complete absence of docunentation of the Applicant's conpliance

< with the SPDS requirement (see response to II-7, below), New Hampshire cannot conclude that the SPDS requirenent has been properly coordinated with the DCRDR.

Interrogatory II-7 Please specify in detail each respect in which NHAG contends 3 '

that Seabrook Control Roon Design does not comply with NUREG-0737, Iten I.D.2.

Response to II-7:

In its November 3, 1982, answers to the State of New Hampshire's First Set of Interrogatories, the Applicant indicated that the

" details of the SPDS layout will be developed in our response to the requirements that the NRC's developing for energency response facilities". New Hampshire has seen no further reference or documentation on the Appliant's compliance with the SPDS requirenent. In the couplete absence of any docunentation of compliance, New Hanpshire contends that the Applicant has not complied with any of the requirenonts of NUREG-0737 (Iten I.D.2) and

$4 of Supplement 1 thereto. Furthermore, the Applicant has not prepared a written safety analysis describing the basis on which the selected parameters are sufficient to assess the safety status of each identified function as required by section 4.2 of Supplement 1 NUREG-0737.

Interrogatory II-8 Please specify each change in the Seabrook Control Roon Design that, if nade, would satisfy NIIAG that the Seabrook Control Roon Design conplies with all applicable regulatory requirements.

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Response to II-8:

4 Neu Hanpshire's first concern is that the control roon design undergo a complete review. New Hampshire has indicated above certain aspects of the Detailed Control Roon Design Reviou which have not;yet been completed. When the various improvements to the

. G. control roon design have been coordinated with changes resulting fron other improvenent programs such as SPDS, based on a comprehensive function'and task analysis of the control roon design,

. New Hanpshire will then be able to judge whether the final control roon design comports with all the regulatory requirenants.

Interrogatory II-9 For each change specified in response to the foregoiing interrogatory, please: (i) identify each and every United. States Nuclear: Power Plant that incorporates the change specified, and (ii) identify each and every United States Nuclear Power Plant that does not incorporate the change specified..

Response to II-9:

j- No change from original answer.

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I, the undersigned, being first duly sworn, do depose and say that the foregoing answers are true except insofar as they are based on information that is available to the State of Ilow Hampshire and the IIcu Hanpshire Attorney General, but not within ny personal knowlege as to which I, based on such information, believe then to be true.

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,: Dr. Stephen S.T. Fan Chairman and Professor College of Engineering and Physical Sciences Department of Chemical Engineering Kingsbury Hall University of ITeu Hampshire Durham, IIeu Hanpshire 03864 THE STATE OF lieu-HA!!PSHIRE STRAFFORD, SS.

Personally appeared this day of April 1984, Dr. Stephen S.T. Fan, before ne, the undersigned officer, and made oath that the foregoing statements are true to the best of his knowledge and belief.

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CERTIFICATE OF SERVICE  ??w I, George Dana Bisbee, Esquire, do hereby cer dfySEEhh1 S2ppgy of the foregoing Supplemental Responses to Applicant's Interrogatories Filed on December 8, 1982, and Motion to Withdraw Contention EH-21, has been mailed this loth day of April, 1984, by firstkdlpfp,gmail, postage prepaid, to: BRANCH Helen F. Hoyt, Chm. Dr. Emmeth A. Luebke Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. NRC U.S. NRC Uashington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry Harbour Jo Ann Shotwell, Asst. AG Administrative Judge Office of the Attorney General.

Atomic Safety and Licensinn One Ashburton Place, 19th Floor Board Panel Boston, MA 02108 U.S. NRC Washington, D.C. 20555 Mrs. Beverly Hollingsworth 822 Lafayette Road Roy P. Lessy, Jr., Esquire P.O. Box 596 Robert Perliss, Esquire _ Hampton, New Hampshire 03842 Office of-Executive Legal Dir.

U.S. NRC William S. Jordan, III, Esquire Washington, D.C. 20555 Diane Curran Harmon and Weiss & Jordan Robert A. Backus, Esquire 20001 S. Street, N.W.

116 Lowell Street Suite 430 P.O. Box 516 _

Uashington, D.C. 20006 Manchester, N.H. 03105 Anne Verge Phillip'Ahrens, Esquire Chairperson Assistant Attorney General Board of Selectmen State House, Station #6 Town Hall Augusta, Maine 04333 South Hampton, N.H. 03842 Robert K. Gad, III,-Esquire Atomic Safety and Licensing Thomas G. Dignan, Jr., Esquire Board Panel Ropes and Gray U.S. NRC 225. Franklin Street Washington,'D.C. 20555 Boston, Massachusetts 02110 Office of Selectmen Rep.'Roberta C. Peavear Town of.Brentwood Town of Hampton Falls Brentwood, .New Hampshire 03833 Drinkwater Road Hampton Falls, New Hampshire 03833

Office of Selectmen Ms. Sandra Gavutis Town of Kensington Office of Selectmen Kensington, New, Hampshire 03833 Town of East Kingston RFD 1 East Kingston, New Hampshire G3848 Mr. Calvin A. Canney Mr. Patrick J. McKeon City Manager Office of Selectmen City of Portsmouth Town of Rye 126 Daniel Street 10 Central Road Portsmouth, New Hampshire 03801 Rye, Mew Hampshire 03870

) Dr. Mauray Tye Mr. Angie Machiros President Chairman Sun Valley Association Board of Selectmen 209 Summer Street Town of Newbury Haverhill, MA 01830 Newbury, MA 01950 Brian Cassidy, Regional Counsel Mr. Mendall Clark Federal Emergency Management Agency Director of Civil Defense Region I C/O Town Offices J.W. McCormack POCH Amesbury, MA 01913 Boston, MA 01913 Charles Cross, Esquire Shaines, Madrigan and McEachern 25 Maplewood Ave.P.O. Box 366 Portsmouth, New Hampshire 03801 .

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