ML20155H357
| ML20155H357 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/12/1988 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#488-7277 OL-1, NUDOCS 8810200050 | |
| Download: ML20155H357 (9) | |
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4 00CEEiE0 U3NPC October 12, 1988 T6 0CT 17 P6 :45
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UNITED STATES OF AMERICA 00CC
- NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSIt'G BOARD
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In the Matter of
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PUBLIC SERVICE COMPANY
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Docket Nos. 50-443-OL-1 OF NEW HAMPSHIRE, at al.
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50-444-OL-1
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(Seabrook Station, Units 1
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(Onsite Emergency and 2)
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Planning and Safety
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Issues)
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APPLICANTS' RESPONSE TO JOINT INTERVENORS' NOTION FOR LEAVE TO FILE A REPLY %
THE RESPONSES OF THE APPLICANTS AND STAFF TO THE ON-SITE EXERCISE CONTENTION Under date of October 7, 1988, the Attorney General of i
The Commonwealth of Massachusetts, the Town of Hampton, New England Coalition on Nuclear Pollution and Seacoast Anti-Pollution League (hereafter "Joint Intervenors") have filed a i
Motion for Leave to File Reolv to the Responses of the Aeolicants and Staff to the On-Site Exercise contention.
To this is attached a twenty-one page reply.
For the reasons set forth below, the Applicants say that the motion should be denied.
a 8310200050 001012 PDR ADOCK 05000443 i
PDR I
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Under the Rules of Practice, there is no right of reply to the answer to a motion.
10 CFR S 2.730(c).
Any right to reply is a matter for the sound discretion of the Licensing Board.
Id.
The prolix reply contemplated to be filed pursuant to this motion contains not one argument that could not have been made in the original filing.
In the event that the Licensing Board decides to grant the motion, the Applicants further respond to the attached reply as follows:
Ins':i.ar as the Reply seeks to further argue the issue of whether tb7 late-filed contention standards are met, Applicants continue to rely upon the arguments made in their original response to the original motion.1 Insofar as the Reply is directed to the issue of reopening the record, the Applicants say as follows:
The argument that the Licensing Board, in its consideration of whether the issue raised is a significant one, is not to consider matters such as that set forth in the affidavits which accompanied the Applicants' original response, is specious.
The whole purpose of requiring af fidavits of a rigorous nature is to winnow out matters which, in fact, have little safety significance.
In addition, the Applicants wish to bring to the attention of 1
Aeolicants' Resoonse to Moti.on to Admit Exercise Contention or, in the Alternative, to Roopen the Record (Sept. 28, 1988) at 5-9.,
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the Board Pages 8-10 of NRC Region I Inspection Report No. 50-443/88-10 the relevant portions of which are attached hereto and marked "A."
These pages wholly confirm the position taken by the Applicants in their original response and the affidavits filed therewith and confirm the lack of any significant safety irsue.
Respectfully submitted, Thomas G.
Dignan, Jr.
George H.
Lewald Kathryn A.
Selleck Jeffrey P. Trout Jay Bradford Smith Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for Applicants __-
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(Closed) Open Item 88-O'9-01: TSC/ EOF Technical Support. The inspec-tor participated in the NRC evaluation team which observed the 1988 Annual Graded EP Exercise on June 27-28, 1988, as documented in NRC:RI Inspection Report 50-443/88-09.
Several open items were generated concerning exercise weaknesses. The following presents amplification and clarification of certain technical concerns' iden-tified in paragraph 3.) of the above report.
Inspection Report 50-443/88-09 sta+ed,
" The Technical Support Center (TSC) and Emergency Operations Facility (EOF) staff displayed questionable engineering judge-ment and/or did not recognize or address technical concerns (50-443/88-08[9]-01)."
Several issues addressed below were cited as examples. Overall engi-nearing judgement displayed in both the TSC and EOF was adequate, however, the following activities were noted to be isolated areas of weakness which were intended to be addressed by the licensee.
In foline-up subsequent to the exercise with licensee technical support, operations and emergency preparedness staff, the following additional information was provided.
The resolution of each sub-item of inspector follow-up item 88-09-01 is described individually below.
(1) "Efforts continued to restore the emergency feedwater pump (EFW) after a large break LOCA" The licensee correctly sta'ted that the EFW pump would be required to operate to support steam generator cooldown in the recovery phase and continued repair ef forts were pru-dent. The inspector agrees and determined that the stated activity did not detract from the overall recovery effort, nor did it diminish other high priority recovery action in progress or planned, and that TSC judgments were made with long-term recovery in mind.
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9 (2)
"A questionable fix for the containment building spray (CBS) system" The inspector met with the Technical Support Manager and a Technical Support Engineer and discussed the rationale behind the corrective action taken to rig an alternative water source for the CBS system. Although the capability of the proposed modification to the system to reduce con-tainment pressure was never proven due to the eventual repair of a CBS pump, the inspector determined, based on this additional information, that the engineering judgment and methodology involved in the proposed system and opera-ting procedure changes were acceptable.
The licensee actions were appropriate since this fix was considered to be a "last resort" measure after all prudent and subsequent extraordina ry measures had failed to provide containment spray by other means due to additional scenario controller intervention.
Additionally, the licensee had previously determined that the composition of the present TSC engineering staff, while adequate, could be enhanced by providing an augmented staff roster.
NHY has committed to implement this initiative.
(3) "A lack of ef fort to locate and isolate the release path" This apparent lack of effort was the result of licensee decisions not to pursue entry into the containment enclosure due to high radiation levels.
Discussion with the licensee confirmed that iridirect measures, such as remote temperature, pressure and sump level indications, were taken in a timely fashion to provide an alternate assessment of potential leakage paths.
The inspecior was unaware of these activities during the drill. The licensee decision to postpone entry into the containment enclosure was intentional, based upon other recovery efforts assoc 1-ated with depressuring the containment.
Restoration of a CBS pump was inninent and activation of this system would have stopped the release.
CBS restoration was subse-quently, and repeatedly, delayed by controller intervention so that the operators were prevented from affecting repairs.
The licensee decisions in this regard were appropriate.
(4) "No ef fort was noted to blowdown steam generators ($/G) to lessen the heat load in containment" This comment implied that S/G blowdown was appropriate.
The actual concern was that a step in the emergency proced-ure required the S/G to be depressurized. This step was not performed because the TSC staff was unsure of the integrity l
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10 of the S/G tubes because no sample was available due to blowdown system isolation.
This TSC staff concern was expressed to the inspector when he questioned them during the exercise.
The NRC position in this area is that improved guidance to the operator may be warranted and should be evaluated, however the decision not to vent or blowdown the S/Gs without sampling appears to have been reasonable and appropriate.
(5) "Neither the EOF or TSC staff questioned a release of greater than 7000 curies per second with only clad damage and no core uncovery" The inspector reviewed the player and controller logs for selected TSC, EOF and engineering support center (ESC) staff. These logs revealed that several staff members did question and/or comment on the mismatch between the reactor coolant activity and the release rate. Subsequent discussions with the TSC and EOF controllers and players also indicated that they were aware of.this mismatch.
In actuality, the ESC staff made very accurate core damage assessmer,ts based upon the data supplied by the TSC.
The EOF dose assessment staff made accurate dose projections based upon the release rate, as well as correlation of field data to the release rate. A review of previous drill comments, as well as the player instruction for this exer-cise, indicated that this level of activity is recognized to be an unrealistic number, which is required to provide the offsite dose rates necessary to exercise the entire emergency planning zone. The technical staffs had repeat-edly identified and questioned these mismatches in previous drills and were told by the controllers that this high release rate was necessary to test the off-site plans, and that they should Mot challenge the data.
Although NRC review of the specific scenario used for the exercise was acceptable, the above described problem indi-cates that the licensee should place more effort in developing exercise scenarios where core damage and release rates are consistant.
With respect to the above identified weaknesses, the exercise inspec-tion confirmed that the TSC/ EOF staff possesses adequate capabil-ities to protect public health and safety. This open item is con-sidered closed.
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CERTIFICATE OF SERVICE T8 TN I, Thomas G.
Dignan, Jr., one of the attorneys for the Applicants herein, hereby certify that on OctoBeril2,.1988,t,'I made service of the within document by deposit'ihs ~ copies thereof with Federal Express, prepaid, for delivery to (or where indicated, by depositing in the United States mail, first class postage paid, addressed to) the individuals listed below.
Administrative Judge Sheldon J.
Robert Carrigg, Chairman Wolfe, Esq., Chairman, Atomic Board of Selectmen Safety and Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Emmeth A.
Diane Curran, Esquire Luebke Andrea C.
Ferster, Esquire 4515 Willard Avenue Harmon & Weiss Chevy Chase, MD 20815 Suite 430 2001 S Street, N.W.
Washington, DC 20009 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S.
Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies)
U.S. Nuclear Regulatory i
U.S. Nuclear Regulatory Commission Commission one White Flint North, 15th Fl.
East West Towers Building 11555 Rockville Pike 4350 East West Highway Rockville, MD 20852 Bethesda, MD 20814
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S.
Nuclear Regulatory 116 Lowell Street memission P.O.
Box 516
'Nton, DC 20555 Manchester, NH 03105
Philip Ahrens, Esquire Mr. J.
P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue one Ashburton Place, 19th Floor P.O.
Box 360 Boston, MA 02108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
- Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S.
Senate Lagoulis, Clark, Hill-Whilton &
Washington, DC 20510 McQuire (Attnt Tom Burack) 79 State Street Newburyport, MA 01950
- Senator Gordon J. Humphrey Mr. Peter J. Matthews one Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn:
Herb Boynton)
Newburyport, MA 01950 Mr. Thomas F. Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Stract Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 - _ _ _ - _ _ _ _ = - _ - _ _ _ _ _ _ _ _
Mr. Richard R. Donovan Judith H. Mizner, Esquire Federal Emergency Management 79 State Street Agency Second Floor Federal Regional Center Newburyport, MA 01950 130 228th Street, S.W.
Bothell, WA 98021-9796 Thomas U. Dignan, Jr.
(*= Ordinary U.S.
First Class Mail.)
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