ML20205C603

Interrogatories & Requests for Production of Documents Re Seacoast Anti-Pollution League Supplemental Contention 6 on Compliance w/NUREG-0737 Requirements for Control Room Design.W/Certificate of Svc.Related Correspondence

ML20205C603
Person / Time
Site:	Seabrook
Issue date:	08/08/1986
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#386-280, RTR-NUREG-0737, RTR-NUREG-737, TASK-1.D.1, TASK-1.D.2, TASK-TM OL, NUDOCS 8608120403
Download: ML20205C603 (9)

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gTb skiLATED GUMW'unsweg h UdlXETET Filed: August 8,1986 UMC UNITED STATES OF AMERICA E 11 A10:47 NUCLEAR REGULATORY COMMISSION OFFICE C a.t ur 00CKETINL *. svig' before the SRANCH ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE COMPANY OF Docket Nos. 50-443-OL-/

NEW HAMPSHIRE, ET AL 5 0 - 4 4 4 -OL -/

(Seabrook Station, Units 1 and 2) On-Site Issues ,

SEACOAST ANTI-POLLUTION LEAGUE'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE NRC STAFF INSTRUCTIONS FOR USE The Seacoas t Ant i-Pollut ion League hereby reques ts that the NRC Staf f, pursuant to 10 C.F.R 02.740(b) and 02.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce and permit inspection and copying of the original or best copy of all documents identified in their response to interrogatories below, and that subsequent to filing answers to these interrogatories and producing documents herein identified, the Staff file supplemental responses and produce additional documents as required by 10 C.F.R. 02.740(e). .

Where identification of a document is requested, briefly describe the document (e.g. book, letter, memorandum, report) and state the following information as applicable for the particular document; name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person (s) having possession of the document.

The term " document [s]" as used herein shall mean any written or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all correspondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, int ra-corporation or intra-o f f ice communi ca t ions , no t ebooks , dia r ies , s ke t ches , diagrams , maps ,

forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals,

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orders, confirmations and all other writ ten or graphic materials of any nature whatsoever.

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Interrogatories SAPL Supplemental Contention 6 (Formerly NH-10)

The Seabrook Station Control Room Design does not comply with General Design Criteria 19 through 22 and 10 C.F.R.

Par t 50, Appendix A, and NUREG-0737, I tems I .D.1 and I . D. 2

1) List all documentary or other materials the NRC Staf f may employ in this proceeding to support its position (s) with respect to this contention. in addition to listing such documents and other materials, provide a copy of all of them pursuant t o 10 C. F. R. 6 2. 741

2) State the names and provide the curriculum vita (e) of any person or persons relied upon to substantiate in whole or in part the staff's position (s) with respect to this contention.

3) Identify any person or persons the NRC S t a f f may call as a witness on this contention, and, if the information has not been -

provided in response to question 2, provide curriculum vita (e) of said person or persons.

4) Provide a summarization of the proposed testimony, views or positions of all persons named in response to interrogatories (2) and (3) above that may be presented by the NRC Staf f in this procedding.

5) State the specific bases and references to documents which the persons named in response to interrogatories (2) and (3) above may rely upon or reference regarding this contention.

6) State with specificity the reasons why the staf f believes that stack monitor and steam generator (or steamline) radiation need not be added to the Saf ety Parameter Display Sys tem (SPDS) until prior to restart following the first refueling outage.

7) Does the staff hold that the period of operation prior to the first refueling outage is any safer than any other period of operation, and if so, upon what basis or bases?

8) State with specificity the reasons why the Draft License for Seabrook Station, NPF-56, holds that the following modifications should be included on the SPDS prior to restart following the first refueling outage. Provide the staff's reasons for requiring each of the 6 modifications listed below, treating each separately:

1. Continuous display of the top level critical safety function summary at the assigned SPDS control room location,

11. Addition of, or satisf actory j ustification for, not adding RHR flow and hydrogen concentration parameters to appropriate SPDS screens,

i III. Addition of a containment isolation status screen on SPDS, or improvement to the current containment isolation display to be satisfactorily recognized from the assigned SPDS location in the control room, .

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IV. Addition of a radiation monitoring screen to display at least steam generator (or steam line) and stack radiation, V. Improvement of the Heat Sink screen for consistency in labeling, and the Suberiticality screen for mode dependency so as not to mislead operators, and VI. Addition of approved isolat ion devices between the Reactor Vessel Level Instrumentation System (RVLIS) and SPDS.

9) Name the person or persons who were responsible for deciding that the modifications listed in interrogatory 8 could be deferred and handled with license conditions and state when this decision made.

10) State the bases upon which the decision was made to allow ,

Applicants to def er review of the control room f urnishings f or Human Engineering Discrepancies (HEDs) until prior to startup from the first refueling outage.

11) Name the person or persons who made the decision referred to in interrogatory 10 and state when this decision was made.

12) State the bases upon which the decision was made to allow Applicants to def er review of the operator protective equipment and emergency equipment storage for HEDs until prior to startup f rom the first refueling outage.

13) Name the person or persons who made the decision referred to in interrogatory 12 and state when this decision was made.

14) Describe the staff's justification for not requiring that a preliminary evaluation of the control room environment be done prior to fuel loading.

15) List any other specific actions and/or requirements, if any, that the NRC Staff is allowing Applicants to defer until the first refueling outage.

16) NUREG-0737 II.B.1 requires that reactor coolant system vents be remotely operated from the control room. Identify all documents which relate to the staf f's review of the displays and controls which have been added to the control room as a result of II.B.1. Please produce such documents pursuant to 10 CFR I 2.741.

17) NUREG-0737 II.D.3 requires that reactor coolant system relief and safety values be provided with positive idication in the control room. Identify all documents which relate to the staff's review of the displays and controls added to the control room as a result of II.D.3 and produce them pursuant to 10 CFR 12.741.

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18) NUREG-0737 II.F.1 requires additional accident monitoring instrumentation and associated displays and controls to be added to the control room. Identify all documents which relate to the staf f's review of the displays and controls added to the control room as a result of this requirement. Please produce these documents pursuant to 10 CFR 92.741.

19) NUREG-0737 II.F.2 relates to additional instrumentation for detection of inadequate core cooling. Identify all documents which relate to the staf f's review of the types and locations of displays and alarms to be added to the control room as a result of this instrumentation. Please produce such documents pursuant to 10 CFR 92.741.

20) State whether the NRC Staff has reviewed the results of the July 1986 Westinghouse tests of isolation related to the isolator circuit in the RVLIS monitor output feeding the plant computer (See SBN-987 at 2). If so, please state the staff's conclusions based upon review of those tests. I f no review has been done, state why i t ,

has not been done.

21) State whether or not the staff has reviewed the program manual for the computer system methods of exchanging information relative to the SPDS. If so, please state the staff's conclusions. If not, please state the staff's reasons for not having done so.

22) When the NRC Staff performed the combined Design Verification and Design Validation audi t of SPDS on May 20-21, 1986, did the human factors audit scheduled for Day 2 at 9 AM occur in the Cont rol Room, t he TSC, t h e EOF , the Control Room Simulator or the SPDS engineering simulator?

23) Provide all documents detailing the staff's SPDS review of the saf ety analysis report, the implementation plan and the verification and validation plan and the findings thereof.

24) Describe and present the conclusions of the staff's review of the Applicant's incorporation of the lessons learned from the Salem ATWS event in the DCRDR.

25) State whether or not the staff believes that the Applicants' DCRDR system function and task analysis and subsequent comparison of results of the analysis with the control room inventory fully satisfies the requirements of Supplement 1 to NUREG-0737 and name the person or persons who assume responsibility for the staff's conclusion on this matter. Provide the documents related to the staff's review.

26) State whether or not the staff believes that the Applicants' DCRDR review is sa t is f actor ily comple ted and HED's satisfactorily resolved for each of the following items and provide any documents detailing the staff's assessment:

f a) video alarm system and associated computer aids to the operator b) hard-wired annunciators ,

c) radiation monitoring system d) lighting e) control room access and architecture relative to supervision, storage of emergency equipment, escape, limit ing access of unauthorized personnel, rest rooms, and eating facilities f) storage of operating procedures and keys, tagging, shift turnover, and other administrative procedures g) remote shutdown panel h) MSIV panel -L i) fire panel .

j) consistent abbreviations k) hierarchical labeling

1) steam dump meter - legibility m) atmospheric dump valve controllers - accessibility NECNP Contention I . B. 2 The Applicant has not satisfied the requirements of GDC 4 that all equipment important to safety be environmentally qualified because it has not specified the time duration over which the equipment is qualified.

1) List all documentary or other materials the NRC Staf f may employ in this proceeding to support its position (s) with respect to this contention. In addition to listing such documents and other materials, provide a copy of all of them pursuant t o 10 C. F. R. 0 2. 714

2) State the names and provide the curriculum vita (e) of any person or persons. relied upon to substantiate in whole or in part the the staffs position (s) with respect to this contention.

3) Identify any person or persons the NRC Staff may call as a witness on this contention, and, if the information has not been provided in response to question 2, provide curriculum vita (e) of said person or persons.

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4) Provide a summarization of the proposed testimony, views or

positions of all persons named in response to interrogatories (2) and

(3) above that may be presented by the NRC Staf f in this proceeding.

5) State the specific bases and references to documents which the persons named in response to interrogatories (2) and (3) above may rely upon or reference regarding this contention.

6) State whether or not the NRC Staf f has reviewed the Applicants' 4 analysis suppor t ing conformance wi th Reg Guide 1.75. If so, provide l the documentation related to this review.

7) State with specificity the reasons why the NRC Staff position is that an environmentally qualified instrument to monitor the containment sump water temperature and an environmentally qualified instrument to monitor either accumulator tank pressure or accumulator tank level should be installed before startup from the first refueling.

8) State why the staf f holds the position that this equipment can be done without up until the first refueling but should not be done without thereafter.

9) Has the NRC Staff independently verified that the results of WCAP-8822, Supplement 2, are applicable to the Seabrook Model F Steam generator?

10) What uncertainties are taken into account in the Seabrook Cycle 1 nuclear design calculated shutdown margin at end of life?

11) State why the NRC Staff does or does not believe it necessary to consider the scenario of high energy line breaks (HELBs) occurring contemporaneously in both pipe chases. State what would be expected to occur under such a scenario.

12) State why the NRC Staff does or does not believe it necessary to consider the scenario of more than one control rod failing to insert contemporaneously with HELB in one of the pipe chases. State what would be expected to occur under such a scenario.

13) State how the NRC S ta f f chos e the 12 qualification files it audited on Feb. 25, 26, and 27, 1986.

14) State why the NRC Staf f did not choose to audit additional files upon having found deficiencies in the audited files.

15) State whether or not the NRC Staff has or intends to verify that the deficiencies identified as a result of the qualification file audit have been or will be corrected prior to fuel load.

16) State the staff's position with respect to the qualification of post-accident monitoring equipment. Provide any documents the staff relys upon to support its position.

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Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By Its Attorneys, BACKUS, MEYER & SOLOMON 4 SChW" R,0 birt A.*Backus

4. O. Box 516 Manchester, NH (603)668-7272 -

I hereby certify that copies of the above have been sent Federal Express to those indicated by an

• on the attached service list and first-class postage prepaid to other parties on the service list.

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13eber t A. Ba'c k u s ~

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o 1 CERTIFICATE OF SERVICE AND SERVICE. LIST i

d Jose Asst.Gn.Cnsl. Sheldon J. Wolfe, Chrm." Thomas.Dignan, Esq.+

Fed. ph FlynnEmerg. Egmt. Agcy. Aden. Judge Ropes & Gray 500 C.St. So. West Atomic Safety & Lic Brd. 225, Franklin St.

Washington, DC 20472 USNRC Boston, MA 02110 Washington, DC 20555 l Office of Selectmen Dr. Jerry Harbour. *' Docketing & Serv. Sec.a Town of Hampton Falls Admin. Judge i Hampton Falls, NH 03844 Atomic Safety & Lic Brd.

Office of the Secretar)

USNRC USNRC Washington, DC 20555 Washington, DC 20555 l Off e of ec. Legl Dr. d$11n u ge SA L i Atomic Safety & Lic. Brd. 5 Market Street ahs ngton, DC 20555 USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq. Paul McEachern, Esq. George Dana Bisbee, Esq. -:

Asst. Atty. General Matthew Brock, Esq. Attorney General's OFF.

State H0use, Sta. #6 25 Maplewood Ave. State of New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsnouth, NH 03801 Cazul Sneider, Esq. , Asst. AG Diane Curran, Esq. William S. Iord One Ashburton Place, Harmon, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430 Town Hall-Friend St.

Boston, MA 02108 Washington, DC 20009 Amesbury, MA 01913

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Richard A. Hampe, Esq. Maynard Young, Chairman Sandra Gauvutis New Hampshire Civil Defense Board of Selectmen Town of Kingston

, Agency 10 Central Road Box 1154 Rye, NH 03870 Hampe & McNicholas East Kensington, NH 03827 35 Pleasant St.

• 1 Concord, NH 03301 Edward Thomas Mr. Robert Harrison FDIA Pres, & Chief Exec. Officer 442 J.W. McConmck (POG) PSCD Boston, MA 02109 P.O. Box 330 Manchester, NH 03105 Roberta Pevear i

State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, hTI 03844

• Federal Expressed i

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