ML20147D653

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New England Coalition on Nuclear Pollution (Necnp) Second Set of Interrogatories & Request for Production of Documents to Applicants on Necnp Contention I.V.* W/Certificate of Svc & Svc List.Related Correspondence
ML20147D653
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 01/07/1988
From: Spielberg A
HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20147D575 List:
References
OL-1, NUDOCS 8801200244
Download: ML20147D653 (7)
v • d • e


Text

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gtLATED CCRRES,PONDEN$[i .

January }gggg{g U$NRC UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFE 2V AND LICENSIS 3mR69 N1 :i2 I h M - $ .)((

In the Matter of )

) BRANCH Public Service Company of )

New Hampshire, et al. ) Docket No. 50-443 OL-1

)

(Seabrook Station, Units 1 & 2) ) ONSITE EMERGENCY

) PLANNING & TECHNICAL

) ISSUES

)

NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S SECOND SET OF INTERROGATOR,IES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO APPLICANTS ON NECNP CONTENTION I.V.

INSTRUCTIONS The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the Staff with personal knowledge of the facts or information requested in each interrogatory. We remind you of your obliga-tion to supplement answers to interrogatories, under 10 C.F.R. 5 2.740(e).

DEFINITIONS The following definitions shall apply to these inter- l

rogatories
1) "Document" shall mean any written or graphic matter or communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all cor-respondence, letters, telegrams, agreements, notes, contracts, l

instructions, reports, demands, memoranda, data, schedules,  !

l notices, work papers, recordings, whether electronic or by other h$Ub o

D P

means, computer data, computer printouts, 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 meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

2) "All documents referrina or relatina to" shall mean all documents that in whole or in part constitute, contain, embody, reflect, identify, state, interpret, discuss, explain, apply to, deal with, or are in any way pertinent to a given subject.
3) "Identifv" with respect to any document shall mean to state the following: the document's title, its date, the author of the document, the person to whom to 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.
4) "Identifv" with respect to any action or conduct shall I

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; and any document recording or documenting such action.

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5) "Identifv" with respect to an individual shall mean state the indi*fidual's name, address, employer, occupation, and title.
6) "Describe" with respect to any action, event or matter shall mean state the following regarding such action, event or matter: the date of such action, event, or matter; the substance or nature of such action, event or matter; the persons participa-ting in or having knowledge of such action, event or matter; the curretit and past business positions and addresses of such per-sons; and the existence and location of any and all documents relating to such action or matter.
7) "Describe" with respect to any piece of equipment shall mean the type, manufacturer, and model number of the equipment.
8) "Reliability" shall mean the probability that a steam generator tube will be correctly labelled as "defective",

"cracked", "degraded", "imperfect", or "leaking".

STEAM GENERATOR TUBE INSPECTION

1) Please identify all persons who participated in the preparation of answers to these interrogatories, and identify the portions of your response to which each person contributed.
2) Identify and produce all documents referring or relating to preservice or subesquent testing of the steam generator tubes by heans of nondestructive examination by eddy current testing,

, including but not limited to the interpretations and evaluations of the results of such tests.

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3) With respect to the nondestructive examination by addy current testing which is to be conducted at the Seabrook plant:

a) Identify and describe the estimated probability of a false positive error of such testing, b) Identify and describe the estimated probabiljty of ,

a false negative error of such testing.

c) Produce all documents referring or relating to the responses to Interrogatory Questions 3a) and 3b).

4) Describe any and all diagnostic procedures which are to be used to assess whether primary to secondary side leakage exceeds the Tech Spec limit at the Seabrook plant.
5) For each diagnostic procedure identified in the response to Interrogatory Question 4):
a) Describe its reliability, b) Describe how its reliability is defined.
c) Describe how its reliability was established.

d) Describe what the estimated rate of false positive errors is for the diagnostic procedure.

e) Describe what the estimated rate of false negative errors is for the diagnostic procedure.

f) Describe any evidence both for and against the proposition that the leak rate test combined with the Tech Spec limit on leak rate predicts subsequent tube bursts.

9) Produce all documents referring or relating to the information requested in Interrogatory Questions Sa) through 5g).

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6) If no diagnostic procedure for assessing whether primary to secondary side leakage exceeds the Tech Spec limits was identified in the response to Interrogatory Question 4, explain why no such diagnostic procedure exists.
7) Identify what portion of the FSAR describes the composi-tion of the Seabrook plant's water chemistry.
8) State whether the applicants have evaluated whether there are other nuclear power plants with similar water chemistry to that of the Seabrook plan which have indicated critical areas for possible leaking tubes. Describe applicant's evaluation.

Respectfully submitted, tA.--

f Anne Spielberg HARMON & WEISS 2003 "S" Street N.W. Suite 430 Washington, D.C. 20009 (202) 328-3500

e . .

. ryw Itt UWRC CERTIFICATE OF SERVICE W J5i 19 41:18 I certify that on January 7, 1988, copies of rforegolpg<

NECNP'S SECOND SET OF I!NERROGATORIES AND REQUEST he(ftflig(PRODDC-J TION OF DOCUMENTS TO THE APPLICANTS ON NECNP CONTENTIOWRitW were served by first-class mail on all parties listed on the attached service list.

[ th tw' /

< Anne Spielberg V l

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SEABROOK SERVICE LIST ONSITE LICENSING BOARD

'Sheldon J. Wolfe, Chairman North Hampton, NH 03826 111 Lowell Street Charles P. Graham, Esq.

Atomic Safety and Licensing Manchester,NH 03105 McKay, Murphy and Graham Board J.P. Nedeau 100 Main Street U.S. NRC

'Dr. Jerry Harbour Washington, D.C 20555 Atomic Safety and Licensing Richard E. Sullivan, Mayor

  • By hand Board City Hall Mr. Angie Machiros, U.S. NRC Newburyport,MA 01950 Chairman ** By Overnight Mail Washington, D.C. 20555 Town of Newbury Alfred V. Sargent, Chairman Town Hall,25 High Road

'Dr. Emmeth A. Luebke Board of Selectmen Newbury,MA 01951 5500 Friendship Bhd. Town of Salisbury, MA 01950 Apirtment 1923N N

George Dana Bisbee, Esq.

Chevy Chase, MD 20815 Senator Go JonJ.Humphrey Geoffrey M. Huntington, Esq.

U.S. Senate. Office of the Attorney General Atomic Safety and Licensing Washington, D.C 20510 State House Annex Board Panel (Attn. Tom Burack) Concord,NH 03301 U.S. NRC Washington, D.C. 20555 Se!ccunen of Northan'ptun Allin Lampert Northampton, New Hamp. Civil Defense Director Atomic Safety and Licensing shire 03826 Tcwn of Brentowood Appeal Board Panel Exet.er, NH 03833 U.S. NRC Senator Gordon J. Humphrey Washington, D.C 20555 1 Eagle Square, Ste 507 Richard A. Hampe, Esq.

Concord,NH 03301 Hampe and McNicholas Docketing and Service 35 Pleasant Street U.S. NRC Michael S;ntosuosso, Concord,NH 03301 Washington, D.C 20555 Chairenan Board of Selectmen Gary W. Holmes, Esq.

Mrs. Anne E. Goodman Jewell Street, RFD # 2 Holmes & Ellis Board of Selectmes South Hampton, NH 03842 47 Winnacunnent Road 13-15 New Market Rond Hampton,NH 03842 Durham,NH 03842 Judith H. Mizner, Esq.

Silverglate, Gertner, et al. William Armstrong William S. Lord, Selec: man 88 Broad Street Civil Defense Director Town Hall- Friend Street Boston, MA 02110 10 Front Street Amesbury,MA 01913 Exeter,NH 03833 Rep. Roberta C Pevear i Jane Doughty Drinkwater Road CaMn A.Canney SAPL Hampton, Falls, NH 03844 City Manager 5 Market Street City Hall Portsmouth,NH 03801 Phillip Ahrens, Esq. 126 Daniel Street Assistant Attorney General Portsmouth,NH 03801

C
rol S. Sneider, Esquire State House, Station # 6 l Assistant AttorneyGeneral Augusta,ME 04333 Matthew T. Brock, Esq.

! 1 Ashburton Place,19th Floor Shaines & McEachern Boston, MA 02108 "Thomas d. Dignan, Esq. P.O. Box 360 l R.K. Gad II, Esq. Maplewood Ave.

Stanley W. Knowles Ropes & Gray Portsmouth,NH 03801 Board of Selectmen 225 Franklin Street P.O. Box 710 Boston,MA 02110 Sandra Gavutis RFD : Bcx 1154 Robert A. Backus, Esq. East Kensington, NH 03827 Backus, Meyer & Solomon

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