ML20195D198
| ML20195D198 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/13/1988 |
| From: | Dean G, Mullett D MASSACHUSETTS, COMMONWEALTH OF, VERMONT, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#288-6541 88-567-04-OLA, 88-567-4-OLA, SLA-2, NUDOCS 8806230065 | |
| Download: ML20195D198 (5) | |
Text
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DOCKETEC-USNRC 88 JN 16 Pl2:04 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE a RL' t PJ '
^ 9vitf.
ATOMIC SAFETY AND LICENSING BOARD PANEL 00CKEigr Before Administrative Judges Charles Bechhoefer, Chairman
'Glenn O. Bright Dr. James H. Carpenter
)
In the Matter of
)
Docket No. 50-271-OLA-2
)
(Testing Requirements for VERMONT YANKEE NUCLEAR
)
POWER CORPORATION
)
)
(ASLBP No. 88-567-04-OLA)
(Vermont Yankee Nuclear
)
Power Station)
)
)
JOINT CONTENTION OF THE STATE OP VERMONT AND THE COMMONWEALTH OF MASSACHUSETTS i
Pursuant to the Atomic Safety and Licensing Board 's order of May 24, 19R8 in this matter, the State of Vermont and the Commonwealth of Massachusetts hereby jointly submit the following contention.
CONTENTION The license amendment proposed by Vermont Yankee Nuclear Power Corporation (Vermont Yankee) is inconsistent with the protection of the public health and safety and of the environment, in that the increase in risk of failure of the subject systems occasioned by the proposed elimination of testing is not
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2 outweighed by any reduction in risk attributable to the testing changes proposed by the amendment.
BASIS FOR CONTENTION The basis for the contention is the fact that the confidence in the reliability of safety systems is adversely affected if the testing of the operable components is eliminated.
Whenever there is a failure of a component in a safety system, the reliability of that system is adversely affected.
This decrease in reliability is compensated for by frequent testing of the remaining significant safety components.
If those components are not tested, this eliminates the compensating effect, and results in a decreased level of reliability of the safety systems and, correspondingly, a decrease in the level of safety provided by the i
engineering safety systems of the plant.
Nor should it be overlooked that abolition of daily testing in this context virtually guarantees that common mode failures will not be detected.
Vermont Yankee has not provided any quantitative support for its accortion that testing the componente adversely affects their reliability. Nor has Vermont Yankee provided any quantitative support to justify its reliance on other testing programs to provide the assurance that the remaining safety components will operate as intended.
There has also been no showing that components cannot be feasibly designed to enable them to be tested without either shutting '. hem down or posing undue challenges to i
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those. components.
Finally, it has not been established that less drastic proposals, such as maintenance of direct communication between the control room and the testing areas, would not better ensure the protection of public health and safety than would the proposed amendment.
In sum, testing done on specific key safety components performed following a failure clearly provides a greater degree of assurance that those components will function than any tests done prior to the failure on a generic basis.
Respectfully submitted, STATE OF VERMONT BY:
n I
f) u Das4d' J. Mullety
)
Special Ass,istaqt Attorney General Special Counsel Vermont Department of Public Service 120 State Street Montpelier, Vermont 05602 (802) 828-2811 COMMONWEALTH OF MASSACHUSETTS BY: >
W b E}8d WM) p rm A
George B. dean Assistant Attorney General Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, Massachusetts 02108 (617) 727-1083 June 13, 1988
PO
- s 00LKEIEC' (nHht UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g a 16 P12
- 04 ATOMIC SAFETY AND LICENSING BOARD PANEL qy7 f0C HG A 'Ei'VICI-Before Administrative Judges BRANCH Charles Bechhoefer, Chairman Glenn O. Bright Dr. James H. Carpenter
)
In the Matter of
)
Docket No. 50-271-OLA-2
)
(Testing Requirements for VERMONT YANKEE NUCLEAR
)
' POWER CORPORATION
)
)
(ASLBP No. 88-567-04-OLA)
(Vermont Yankee Nuclear
)
Power Station)
)
)
CERTIFICATE OF SERVICE I hereby certify that I served a copy of the Joint Contention of the State of Vermont and the Commonwealth of Massachusetts causing a true copy hereof to be placed in the United States mail, postage prepaid, addressed as follows:
Charles Bechhoefer, Esquire, Chairman Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Glenn O. Bright Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. James H. Carpenter Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Adjudicatory File Atomic Safety and Licensing Board Panel Docket (2 copies)
U.S. Nuclear Regulatory Commission Washington, DC 20555
Q 7,.
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George B. Dean, Esquire Assistant Attorney General Department of the Attorney. General One Ashburton Place Boston, MA 02108 Ann P Hodgdon, Esquire (Federal Express)
Office'of the General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the General Counsel-Bethseda U.S. Nuclear Regulatory Commission Washington, DC -02555 R. K. Gad III (Federal Express)
Ropes and Gray 225 Frenklin Street Boston, PA 02110 3
DATED at Montpelier, Vermont this 13th day of June, 1988.
VERMONT DEPARTMENT OF PUBLIC SERVICE D
l Ai i BY:
Gw i.
o Da916 J. liulle,tt ' ~
Special Couns(1
.