ML20203L757
| ML20203L757 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/25/1986 |
| From: | Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| References | |
| CON-#386-519 OL-1, NUDOCS 8608290155 | |
| Download: ML20203L757 (12) | |
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PECATID Comte 570 00LKETED U.3NRC UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION
'86 AIXi 28 P3:57 BEFORE TIIE ATOMIC SAFETY AND LICENSING BOkET t GkYhYdt BRANCH In the Matter of
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Docket Nos. 50-443 - OL-1 PUBLIC SERVICE COMPANY OF
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50-444 OL-1 NEW IIAMPSHIRE, et al.
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Onsite Emergency Planning (Seabrook Station, Units 1 and 2)
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and Safety Issues NRC STAFF'S RESPONSE TO NECNP'S FIRST SET OF INTERROGATORIES AND REQUEST FOR TIIE PRODUCTION OF DOCUMENTS TO TIIE NRC STAFF The NRC Staff
(" Staff") hereby submits its responses to "New England Coalition on Nuclear Pollution's First Set of Interrogatories and Request for the Production of Documents to the NRC Staff," filed August 6, 1986. 1 INTERROGATORY 1 What is the NRC's position on the adequacy of Applicants' environmental qualification program with respect to qualification times?
What is the basis for your position?
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The Staff notes that the filing of interrogatories to be answered by the Staff is governed by the procedures set forth in 10 C.F.R.
I 2.720(h)(2)(ii), rather than 10 C.F.R. I 2.740b, and that NECNP has not demonstrated any attempt to comply with those provisions.
Nonetheless, the Staff has undertaken to provide these discovery responses voluntarily, according to the schedule established by the Board, as if the Staff was subject to 10 C.F.R. I 2.740b. Similarly, without waiving the applicability of 10 C.F.R. 5 2.741(e), the Staff has undertaken to respond voluntarily to these document requests, except as o'ojected to herein.
Insofar as the Staff objects to the instant interrogatories, the Staff hereby requests that the Licensing Board issue a protective order pursuant to 10 C.F.R. 5 2.740(c) that further discovery with respect to these matters not be had.
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RESPONSE
The NRC Staff's position is that the applicants' environmental qualification program with respect to qualification times is adequate and acceptable.
See Safety Evaluation Report (SER) related to the operation of Seabrook Units 1 and 2, Supplement No. 5, NUREG-0896.
INTERROGATORY 2 Please identify and provide access to all documents on which you rely or intend to rely during this proceeding to support your position on NECNP Contention I.B.2.
This includes all documents used in answers to these interrogatories, summary disposition motions,
testimony, and cross-examination of witnesses during hearings.
RESPONSE
Documents responsive to this interrogatory and request, other than privileged documents, if any, will be made available for inspection and copying by NECNP upon reasonable notice to the Staff, i
INTERROGATORY 3 Please identify all persons on whose factual knowledge, opinions, or technical expertise you rely or intend to rely for your position on Contention I.B.2.
RESPONSE
Harold Walker.
INTERROGATORY 4 Please identify all persons you may call as witnesses on this contention during these proceedings; describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.
RESPONSE
See response to Interrogatories 1, 2, and 3, above.
In addition, see 10 C.F.R. I 50.49, NUREG-0588, Reg Guide 1.89, and IEEE Standard 323-1974.
INTERROGATORY 5 Please provide access to all documents reflecting the NRC staff's analysis of the adequacy of Applicants' environmental qualification program with respect to qualification times.
RESPONSE
See response to Interrogatory 2 above.
INTERROGATORY 6 Please provide access to all notes, drafts, evaluations, and reviews, and any other documents prepared in connection with the environmental qualification audit conducted by EG&G Idaho and NRC on February 24, 1986.
RESPONSE
See response to Interrogatory 2 above.
INTERROGATORY 7 With respect to the February 24-27 audit, please describe the criteria by which the NRC chot,e the qualification files to be audited and the criteria by which it determined how many files to audit.
RESPONSE
The Staff normally selects at least 10 files for audit, and will review as many additional files as time permits.
The Staff follows a practice of randomly selecting files to be audited, unless the Staff has reason to believe that discrepancies may exist in certain files, and those files will then be included in the group of files to be audited.
In addition, other considerations may influence the Staff's decision as to which files should be selected for audit, such as the knowledge that some l
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difficulty-has existed in qualifying a particular piece of equipment for a similar application in another plant; or where qualification results differ significantly from what would be expaected for a particular piece of equipment; or an indication that insufficient. information has been submitted for a particular piece of equipment for the Staff to conclude that the file is complete.
For Seabrook, the qualification information (EQ submittal) provided by the applicants to the Staff indicated that seven files appeared to contain conflicting information as to the status of qualification, while four files did not contain sufficient information for the Staff to conclude that the files were complete.
These eleven files were selected for audit, and an additional file was selected on a random basis.
INTERROGATORY 8 Please describe the NRC's criteria, if any, for judging the results of environmental qualification audits insofar as they reflect on the quality of applicants' and licensees' environmental qualification programs.
RESPONSE
The Staff does not utilize any set of codified or rigid criteria in judging the results of an environmental qualification audit, insofar as the audit results may reflect upon the quality of an applicant's EQ program.
The audit team typically reaches a preliminary determination as to adequacy prior to the conclusion of the audit.
In general, a favorable determination will result if the audit team finds (based on the files reviewed) there is reasonable assurance (1) that the applicant has conducted sufficient testing and analysis to demonstrate that the plant can be shutdown safely in the event of a design basis accident, using
environmentally qualified equipment, and (2) that the EQ program meets the requirements of 10 C.F.R. 550.49. The audit team normally discusses this determination with the applicant before concluding the audit, and the audit team's determination is then reviewed by NRC Staff management prior to formal transmission to the applicant.
INTERROGATORY 9 Please describe the criteria by which the NRC decides whether a licensee's environmental qualification program fails an audit, the steps prescribed by NRC for correction of environmental qualification programs that have failed audits, and the criteria by which the NRC decides whether to order further audits after a licensee or applicant has failed an audit.
RESPONSE
The Staff normally agrees to conduct an audit only after it reviews the applicant's EQ submittals and discusses the EQ program with the applicant in sufficient detail for the Staff to make an initial judgment that the EQ program appears to be adequate.
Accordingly, there is generally a high degree of assurance that the EQ program will be found to be acceeptable upon conducting the audit.
During the audit,
some documentation deficiencies or omissions typically are discovered, but these generally have not been so significant as to result in a finding that the EQ program, itself, is unacceptable. Nonetheless, the Staff could require that additional files be audited, or reach a finding of unacceptability if the audit results demonstrate that 'the EQ program fails to meet the requirements of 10 C.F.R. 550.49 and applicable Staff guidance.
INTERROGATORY 10 Does the NRC consider that this audit demonstrates an adequate environmental qualification program for Seabrook? If not, in what aspects is it inadequate, and what remedial steps are required?
RESPONSE
With the correction of the deficiencies identified during the Seabrook EQ audit, the Staff considers that the Seabrook EQ program is adequate.
INTERROGATORY 11 Please describe all follow-up actions that the NRC has taken with respect to the February 24-27 audit,
including directions to the Applicents,
further audits or inspections, or request for more information.
RESPONSE
See meeting summary dated April 11, 1986.
INTERROGATORY 12 Plea'se provide copies of all notes, memoranda, reports, and any other documents relating to the NRC Staff's evaluation of Applicants' environmental qualification program with respect to qualification times.
RESPONSE
See response to Interrogatory 2.
Respec,tfully submitted, 1/.42 Sherwin E. Turk Senior Supervisory Trial Attorney Dated at Bethesda, Maryland this 25th day of August,1986
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443 OL-1 NEW IIAMPSHIRE, et _al.
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50-444 OL-1
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Onsite Emergency Planning (Seabrook Station, Units 1 and 2)
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and Safety Issues AFFIDAVIT I, Harold Walker, being duly sworn, hereby state that I am employed as a Mechanical Engineer in Section A of the Electrical Instrumentation and Control Systems B ranch, Division of PWR Licensing-A, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.
The information reflected in the Staff's responses to "NECNP's First Set of Interrogatories and Request for the Production of Documents to the NRC Staff," attached hereto, is true and correct to the best of my knowledge, information and belief.
f Harold Walker '
Sworn to and subscribed before me this 25th day of August,1986
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Notary Public My Commission expires:
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PROFESSIONAL QUALIFICATIONS OF HAROLD WALKER
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I am currently a Mechanical Engineer in Section A of Electrical Instrumentation and Control Systems Branch, Division of PWR Licensing-A, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission.
From September 1981 to November 1985 I was a Mechanical Engineer in the Environmental Qualification Section of the Equipment Qualification Branch, Division of Engineering, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission.
In both positions my duties have included performing technical reviews, analyses and evaluations of the adequacy of the environmental qualification of electrical and mechanical equipment whose failure, due to such environmental conditions as temperature, humidity, pressure and radiation, could adversely affect the performance of safety systems.
I was previously a Materials Engineer in the Materials Engineering Branch where my duties and responsibilities involved the review and evaluation of Materials performance from the standpoint of operability and functional capability and integrity under normal, abnormal, and accident loading conditions, and analyzing fracture toughness of reactor vessel materials including specific data to assure that the materials will behave in a non brittle manner.
PriGJ to my position in the Materials Engineering Branch, I was a materials engineer in the Engineering Brr.nch, Division of Operating Reactors. My duties and responsibilities included the review of operating problems to determine if safety requirements were being satisfied and to assure that operating problems were corrected, and met with due regard for safety and environmental protection.
Prior to my position in the Engineering Branch, I was a ACRS Fellow at the Advisory Committee on Reactor Safeguards. My duties included collecting and consolidating information pertaining to non-destructive testing methods.
I have a B.E. Degree in mechanical engineering from the City College of the City University of New York and I have taken graduate courses at the University of Pittsburgh.
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. Prior to joining-the NRC, I was an engineer at Westinghouse Research Corporation in Pittsburgh, Pennsylvania where my duties included the application of the state of the art fracture mechanics as well as the study of structural integrity of materials in various environments and under various loading anditions.
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1 DOCXETED USNRC y 428 P3 57 UtilTED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 0FFICE OF 5MWF 00CKligigtFM BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443 OL-1 NEW HAMPSHIRE, et al.
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50-444 OL-1
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On-site Emergency Planning (Seabrook Station, Units 1 and 2)
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and Safety Issues CERTIFICATE OF SERVICE J'
I hereby certify that copies of "NRC STAFF'S RESPONSE TO NECNP'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF" in the above proceeding have been served on the following by deposit in the United State mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system or, as indicated by a double asterisk, by express mail, this 25th day of August,1986.
Sheldon J. Wolfe, Chairman
- Dr. Emmeth A. Luebke*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Jerry Harbour
- Carol Sneider**
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission One Ashburton Place,19th Floor Washington, D.C.
20555 Boston, MA 02108 Beverly Hollingworth Stephen E. Merrill 209 Winnacunnet Road Attorney General Hampton, NH 03842 George Dana Bisbee**
Assistant Attorney General Sandra Gavutis, Chairman Office of the Attorney General Board of Selectmen 25 Capitol Street RFD 1 Box 1154 Concord, NH 03301-6397 Kensington, NH 03827 Richard A. Hampe, Esq.
New Hampshire Civil Defense Agency 107 Pleasant Street Concord, NH 03301
Calvin A.- Canney, City Manager Allen Lampert City Hall - /
Civil Defense Director 126 Daniel Street Town of Brentwood Portsmouth, NH 03801 20 FrankUn Street Exeter, NH 03833 Roberta C. Pevear State Representative Angie Machiros, Chairman Town of Hampton Falls Board of Selectmen Drinkwater Road 25 High Road Hampton Falls, NH 03844 Newbury, MA 09150 Mr. Robert J. Harrison Jerard A. Croteau, Constable President and Chief Executive Officer 82 Beach Road, P.O. Box 5501 Public Service Co. of New Hampshire Salisbury, MA 01950 P.O. Box 330 Manchester, NH 03105 Diane Curran, Esq.**
Harmon & Weiss Robert A. Backus, Esq.**
2001 S Street, N.W.
Backus, Meyer & Solomon Suite 430 116 Lowell Street Washington, D.C.
20009 Manchester, NH 03106 Edward A. Thomas Philip Ahrens, Esq.
Federal Emergency Management Agency Assistant Attorney General 442 J.W. McCormack (POCH)
Office of the Attorney General Boston, MA 02109 State House Station, #6 Augusta, ME 04333 H.J. Flynn, Esq.
Thomas G. Dignan, Jr., Esq.
Assistant General Counsel Ropes a Gray Federal Emergency Management Agency 225 Franklin Street 500 C Street, S.W.
Boston, MA 02110 Washington, D.C.
20472 i
Jane Doughty Atomic Safety and Licensing Seacoast Anti-Pollution League Board
- 5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, D.C.
20555 Atomic Safety and Licensing Paul McEachern, Esq.
i Appeal Panel
- Matthew T. Brock, Esq.
I U.S. Nuclear Regulatory Commission Shaines & McEachern Washington, D.C.
20555 25 Maplewood Avenue P.O. Box 360 l
Portsmouth, NH 03801 I
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Docketing 5 and Service Section*
William Armstrong Office of the Secretary Civil Defense Director U.S. Nuclear Regulatory Commission Town of Exeter Washington, D.C.
20555 10 Front Street Exeter, NH 03833 Maynard L. Young, Chairman Board of Selectmen Peter J. Matthews, Mayor 10 Central Road City Hall Rye, NH 03870 Newburyport, MA 09150 Michael Santosuosso, Chairman William S. Lord Board of Selectmen Board of Selectment South Hampton, NH 03827 Town Hall - Friend Street Amesbury, MA 01913 Mr. Robert Carrigg, Chairman Mrs. Anne E. Goodman, Chairman Board of Selectmen Board of Selectmen Town Office 13-15 Newmarket Road Atlantic Avenue Durham, NH 03824 North Hampton, NH 03862 R. K. Gad III, Esq.**
Gary W. Holmes, Esq.
Ropes & Gray Holmes & Ellis 225 Franklin Street 47 Winnacunnet Road Boston, MA 02110 Hampton, NH 03842 Judith II. Mizner, Esq.
Silverglate, Gertner, Baker Fine and Good 88 Broad Street Boston, MA 02110 L
Sherwin E. Turk Senior Supervisory Trial Attorney
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