ML20206C662
| ML20206C662 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/08/1988 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#488-7490 OL-1, NUDOCS 8811160364 | |
| Download: ML20206C662 (17) | |
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1990 CCCKETE0 November 8, ihb' ?
s UNITED STATES OF AMERICA D iC/14 P4 :07 NUCLEAR REGULATORY COMMISSIOtt before the ATOMIC SAFETY AND LICENSING 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, kg A1
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50-444-OL-1
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(Seabrook Station, Units 1
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(Onsite Energency and 2)
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Planning and Safety
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Issues)
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APPLICANTS' RESPONSE TO BOARD ORDER OF OCTCBER 25, 1988 (DIRECTING ADDITIONA7, BRIEFING AND AFFIDAVITS)
On October 25, 1988, this Licansing Board issued an r
ORDER (Directing Additional Briefing and Affidavits) with respect to the Intervenors' Motion to Admit Exercise Contention, or, In the Alternative, to Roopen the Record filed under date of September 16, 1988.
This action seeks to have the board hold hearings on certain alieged deficiencies l
in the Seabrook Station onsite energency plan.
The notion having been filed, the Applicants filed a response thereto.1 Thereafter the Staff also filed a responser the Intervenors 1 uclicants' Renconne to Motion to Admit Exercise A
1 Contention, or, in the Alternative. to reocan the Record (Sept. 28, 1988) hereafter cited and referred to as "Applicants' Response,"
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8811160364 081100 0
y5 POR ADOCK 05000443 0
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t filed a notion for leave to file a reply; and the Applicants and Staff filed responses to that motion.
The Applicants response to the motion for leave to file a reply attached pages 8-10 of an inspection report put out by NEC Region I j
(Inspection Report No. 50-443/88-10) which it hereinafter referrod to as the "Inspection Repcrt" and so cited by ite.n number.
In addition, in that reply, the Applicants tocX the position that the Inspection reports j
"wholly confira[s] the position taken by the Applicants in their original response and the affidavits filed therewith and confirm s) the lack of a significant safety asue."
l'n tha order, this Board directed, inter alia, that:
"the Applicants shall file a brief, as I
supported by af fidavits, which shall npecifically and in detail show (as t
argued at ptge 3 of their response of i
I October 12), wherein pages 8 through 10 of the Staff's Inspection report ' wholly f
confirm the position taken by the Applicants in their original response and the affidavits filed therewith and i
confirm the lack of any significant l
safety issue'."3 i
t Herein, the Applicants, relying upon the affidavits filed with their original response, respond to the above quoted i
L portion of the order.
i 2Apolicants' Rennense to Joint Inte rva no rs ' Motion for Leave to File a Renly to the Resnonses of the Acolicants and Staff to the Onsite Exercise contentLED (Oct 12, 1988) at 3.
30rder at 2.
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I The instant controversy had its origin in an inspection report issued by the staff on July 6, 1988.
Therein the i
Staff made reference to a "weakness" which it described as follows:
"1.
The Technical support Center (TSC) and Emergency operations Facility (EOF) staff displayed questionable engineering judgment and/or did not address technical concerns (50-443/88-08-01)."
j This statement was then followed by five examplest Neither the EOF or TSC staff questioned a release of greater j
than 1000 curies per second with only clad damage and no core i
uncovery Efforts continued to restore the Emergency Feedwater Pump i
after a large break LOCA A questionable fix for the Containment Building spray systemt l
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l A lack of effort to locate and l
isolate the release paths and No effort was noted to blowdown r
I steam Generators to lessen the i
i heat load in containment."4 j
Below, we discuss in detail each example quoted above, f
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quoting, he each case our argument with respect to it made in
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1 eur original response, and then setting forth, with comments, l
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t N32_Inanection Report of July 6.
1988 at 5.
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1 the portion of the Staff Inspection Report which we believe confirms the position we had taken.
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Neither the EOF or TSC staff questioned a release of greater than 7000 curies per second with only clad damage and no core uncovery.
With respect to the above referenced example, we stated in our original response:
"With respect to the release of greater than 7000 curies per second, it appears that (a) the release figure was supplied by the controllers and, therefore, was not to be questioned under the rules, (b) a review of exercise events reveals that, in fact, the lack of correlation between the release condition and core cooling indications was recognised and discussed by Tsc persor.nel, and (c) the lack of correlation in no way hindered the response and implementation of energency
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procedures. 5 l
With respect to this matter, the following appears in the Inspection Report:
"The inspector reviewed the player and controller logs for selected TSC, EOF and engineering sappcrt center (ESC) staff.
These logs reveal that several scaff aembers did question and/or connent on the nisaatch between the reaccor coolanc j
activity and the release race.
Subsequent discussions with the TSC and EOF controllers and players also indicated that they were aware of this alssacch.
In actuality, che ESC Staff 5 nnlicants' Resogngg at 12.
Citing the Affidavit of A
l James A. MacDonald 11 4-6.
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i nade very accurace core damage assessmenes based upon the data supplied by the Tsc.... [T]his level of activity is recognized eo be an unresLLscic number. which is required to prov.tde che offsico dose races necessary to exercise che entire energency planning sone.
The technical staffs had repeatedly idencLited and quescLoued chose massacches in previous drL11s and were cold by the concrollers chat this high release race was necessary to cesc the offsite plans, and t challengethedata."}attheyshould not It is submitted that the above quoted portion of the Inspection Report, particularly those portions set forth with emphasis fully confirm the Applicants' position on this matter.
2.
Efforts continued to restore the Emergency Feedwater Pump after a large break LOCA.
I With respect to the above referenced example, the Applicants, in their original response stated the following:
"The continued ef forts to restore the Emergency Feedwater (ErW) pump (a) did not hinder nor would it have effected the response of th's TSC to higher priority activities, (b) was recognised as an effort which may nc?,be needed to mitigate a large break LOCA, and (c) was continued for good and sufficient reason anyway in light of the fact that no higher priority item was being interfered with."7 i
6Tnseaction Recort, Iten 5.
(Emphasis added).
7Anolicants' Resoonse at 12-13 citing the Affidavit of Gary J.
Kline at 11 4-10.
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The Inspection report states with respect to this item:
"The licensee correccly stated that the ErW pump would be required to operate to support steam generator cooldown in the recovery phase and conetnued repair efforcs were prudene.
The inspector agrees and determined that che stated 1
activity did not detract from the overall recovery effore, nor did Le diminish other higher priority aceton in progress or planned, and that TSC judgments wer made with long term recovery in mind."g l
Applicants believe that the above quoted portion of the Inspection report fully supports the position taken in i
Applicants original Response.
3.
A questionable fix for the containment Building spray system.
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With respect to the above referenced example, the Applicants took the following position in their original response:
"The "questionable fix for the containment Building spray system" was (a) in fact a contingency plan developed in case the normal flow path of the system could not be reestablished (the i
controllers interceded and declared l
l efforts to reestablish the flow to be ineffectual on four occasions), (b) was technically sound, and (c) if needed, the l
fix would have been reviewed by KRC before implementation, a review not carried out because the normal flow path l
l was escatablished."9 l
S inroaction Recort, Iten 1.
(Emphases added).
9Acolicants' Resconse at 13.
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This position was taken on the basis of the Affidavit of Gregg F. Sessler, which stated, in material part, as follows:
"5.
In order to understand the actions taken, the plant status should first be reviewed.
At the time an Alert was declared, the "A" train CBS pump was out of service and being repaired.
These repair efforts continued until the LOCA occurred.
Because of the radiation levels associated with a LOCA, the equipment vaults, where the pump is located, had to be exited for personnel safety.
Since the repair work was incomplete, the "A" train pump was still out of service.
Coincident with the
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postulated LOCA, there was also a postulated failure of the "B" train CBS pump to start.
Initial ef forts by the Control Room to start the "B" train pump manually proved to be unsuccessful.
With a loss of both redundant trains, the TSC with the assistance of other support j
groups undertook the following actions:
l (1) as a first priority, restore / repair t
i the normal CBS flow path components; and (2) as a second priority, develop a contingency plan for an alternate CBS l
flow path which would be implemented in the event all efforts to restore normal l
CBS flow failed.
Both of these efforts were initiated to restore containment l
spray to mitigate the impact of the ongoing release by increasing cooling to l
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the containment (thereby reducing j
pressure) thereby removing some radiciodine from the containment i
atmosphere.
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"6.
As indicated above, the first t
priority efforts were underway to restore / repair the normal CBS components.
Specifically a team from the operational Support Center (OSC) was being assembled to troubleshoot the hypothetical electrical failure experienced by the "B"
l train pumps.
This repair effort used acceptable procedures, techniques and l
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equipment.
The spare parts used were i
acceptable for the intended use.
i "7.
In parallel, I coordinated the development of the alternate C.BS flowpath contingency plan.
The alternate CBS flowpath concept was to use components and systems not necessarily associated 4
with the normal CBS flowpath as a means i
to restoring the containment spray function.
My efforts included reviews of available components, system interconnections, plan parameters, design i
characteristics, and operating modes.
"S.
During the development of the alternate flowpath the NRC Inspector, who l
had made the observation, asked several I
detailsd questions concerning this solution.
Within the constraints of the l
exercise on communicating with observers i
answers to his questions were provided.
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However, since the alternate flowpath effort was in fact a contingency plan, it was not appropriate at that time to caucus with the KRC da vould have been l
required for a final plan prior to 1
i implementation.
As such the information available to the Inspector was not a complete description or analysis of the alternate flowpath.
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"9.
The alternate CBS flowpath developed
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was technically sound.
It was a feasible means to provide water to the CBS spray rings in containment and restore the i
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containment spray function for accident j
mitigation if the normal flowpath was not l
returned to operation.
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As can be seen from paragraph 5 above. Le was prudene to develop a i
contingency plan since chere was a loss l
a of both crains of CSS and because inicial l
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efforcs by the Control Room to manually rescare proved unsuccessful.
Furthermore l
the exercise controllers. in order to t
i assure offsite response activities would i
concinue consensurace with exercise l
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objectives, caused the repair accivieles of the
- B' train pump to be continued (i.e.,
che controllers interceded and declared rescart/ repair efforts ineffectuei approximacely four clans during the exercise).
"11.
The alternate CBS flowpath, as it was a contingency plan, would have been subjected to formal reviews, including those of the NRC, prior to its actual implementation.
Nowever, che repair efforts for the
'B' train CBS pump *s electriest system were finally successful and containment spray initiated via che notani flowpath.
Accordingly, che contingencyplanneverproce*{gd into the review /inplementacion stage."
The inspection report deals with this item as follows:
"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 i
proposed modification was never proven due to the eventual repair of a CBS pump, che inspector determined based on this additional information, that the engineering Judgnent and anchodology involved in the proposed systen and operating procedures changes were acceptable.
The licensee actions were appropriate since this fix was considered to be a 'last resort' measure after all prudent and subsequent extraordinary measures had failed to provide containment spray by other means due eo additionsi scenario controller intervention.*11 10 Affidavit of Greca F.
Sessler (Sept. 28, 1988) at 11 5-11. (Esphases added).
i 11 nseaction Recort, Item 2.
(Emphases added).
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a The Applicants believe that the above quoted portion of the Inspection Report fully supports the Applicants' position on this issue.
4.
A lack of effort to locate and isolate the release path.
With respect to this item., the Applicants, in their original response took the following pcsition:
"In fact, a concerted effort was made to j
locate and isointe the containment bypass I
leakage but was curtailed because of the i
fact that entry into the areas necessary for ultimate isolation or repair had to be postgned due to high radiation levels therein.42 With respect to this iten, thin Inspection Report has the following to says "This apparene lack of effort was the result of licensee decisions noe eo pursue entry into che containment enclosure due to high radiacion leveis.
Discussion with the licensee confirmed I
that indirect 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 Inspector 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 associated with depressuring the containment.
Restoration of a CBS pump was imminent and activation of this system would have stopped the release.
12Acolicants' Responq3 at 13 citing the Affidavit of Gary J. Kline at 11 11-14.
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CBS restoration was subsequently, and l
repeatedly, delayed by controller intervention so that the operators were prevented from affecting repairs.
The Licensee deci in this regard were approprLace."{fons l
Applicants submit that the above quoted portion of the Inspection report fully supports and confirme the Applicants
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position on this matter.
5 No effort was noted to blowdown steam Generatore to lessen the heat load in containment.
I The position taken by the Applicants as to the above referenced matter in their original response was as follows:
"As to the assertion that "(nlo effort was noted to blowdown the Steam Generators to lessen the heat load in the i
containment," it appears that (a) in fact i
such an effort was considered and temporarily postponed to assess its l
i possible radiological consequences, (b) prior to complethon of the assessment necessary to determine whether such an action would lead to introduction of accident levels of radioactivity to areas of the plant as yet unaffected, Day #1 of the exercise ended, and (c) subsequent analysis has shown that such action would have had no practical effect in reducing t
thetemporggureandpressureof interest."A This position was based upon the information set out in the i
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13rnamaction Renort, Item 3.
(Emphases added).
f 14&gplicants' Reanonne at 13-14.
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accompanying affidavit of Gregg F. Sessler, which stated, in material part:
"13.
It was recognized by the operators in the Control Room and the energenc/
responders in the TSC that a step in the d
applicable Emergency Operating Procedures
-l called for a controlled depressurization of the steam generators.
It was also recognised, however, that this action could introduce accident level
'tadioactive material to areas of the plant that at the time were unaffected i
(e.g. Primary Auxiliary Building) which could hamper later accident mit:,gation efforts.
14.
Since it woulJ not delay further actions under the Emergency Operating Procedures (i.e., one could continue onto the next step), it was decided that the depressurization of the steam generators could be temporarily postponed until the respits of a steam generator secondary 4
s i'~
sample were available.
In addition, t?
.eam generators were not required to 1
c' town the plant.
j Before completion of sampling
.vities and any simulation of steam
,terator depressurization, the exercise
.or Day #1 was terminated."
j With respect to this matter, the Inspection report has the following observations:
"This comment imp 21ed that s/G blowdown was appropriate.
The actual concern was that a step in the energency procedure required the S/G to be depressurised.
This step was not performed because the TSC staff was unsure of the integrity of the S/G tubes because no sample was avaliable due to blowdown systen isolation.
This TSC staff concern was exprensed to the inspector when he questioned them during the exercise.
The o
NRC position in this area is that improved guidance to the cporator may be warranted and should be evaluated, however the decision not to vent or
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blowdown che S/Gs withou*. saapting appears to ha and appropriace."{g been reasonable Applicants believe that the above quoted portion of the Inspection Report fully supporta the position taken by the I
Applicants in their original renponse.
CONCLUSION As an overall conclusion, the Inspection Report statest j
"With respect to tha above identified weaknesses, the exercise inspection contirmed that the TSC/ECT staff possesses adequate capablitcLes to protect public health and safety.
This open item is considered closed."
This further supports and confirms the position taken by the i
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15Insnaction Report, Item 4.
(Emphases added).
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6 Applicants in their original response.
The Motion should be denied.
Respectfully submitted, i
Thomas G.
D L(bih, J r.
George H.
Lewald Kathryn A. Selleck Jef frey P. Trout Jay Bradford Smith Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for Appitcants t
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gfJtTIFIcATE OF SERVICE I, Thomas G.
Dignan, Jr., one of the attorn skohthe :07 4
Applicants herein, hereby certify that on November 8, 1988, I made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery tto (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to) the individuals l
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 l
Bethesda, MD 20814 1
Administrative Judge Emmeth A.
Diane Curran, Esquire 4
Luebke Andrea C.
Ferster, Esquire 4515 Willard Avenue Harmon & Weiss Chevy Chase, MD 20815 Suite 430 l
2001 S Street, N.W.
Washington, DC 20009 i
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 U.S. Nuclear Regulatory Commission Commission One White Flint North, 15th Fl.
East West Towers Building 11555 Rockville Pike i
4350 East West Highway Rockville, MD 20852 l
Bethesda, ND 20814 l
- Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street l
Commission P.O.
Box 516 j
Washington, 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 03401 Mrs. Sar,dra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectman City Manager RFD 1 - Box 1154 City Hall Route 107 126 Danisl Street Kensington, NM 03827 Portsmouth, NH 03801
- Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate
- Lagoulis, Tark, Hill-Whilton &
Washington, DC 20510 McQuire (Attn Tom Burack) 79 State Street Newburyport, MA 01950
- Senator Gordon J. Humphrey One Eagle Square, Suite 507 Concord, NH 03301 (Attn Herb Boynton)
Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter TcWn Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NM 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire office of General Counsel Murphy and Graham Federal Emergency Manngement 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Cary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McMicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 2-
4 Mt. Richard R. Donovan Judith H. Minner, Esquire Federal Einergency Management 79 State Street 1.gency Second Floor Federal Regional Center Newburyport, MA 01950 130 228th Street, S.W.
Bothell, WA 94021-9796 M,WMT" 7, f
f Thomas G. Dign C r.
(*= Ordinary U.S. First Class Mail.)
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