ML20206J678

Response Opposing Motion to Withdraw Contention NH-10 on Grounds Withdrawal Premature.Second Suppl to Answers to Interrogatories Encl

ML20206J678
Person / Time
Site:	Seabrook
Issue date:	06/19/1986
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20206J684	List: ML20206J678 ML20206J703
References
CON-#286-673 OL, NUDOCS 8606270243
Download: ML20206J678 (5)

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Filed: June 19,1986 BS,

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

4. s BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

PUBLIC SERVICE COMPANY OF DOCKET NOS. 50-444 OL NEW HAMPSHIRE, ET AL 50-443 OL

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(Seabrook Station, Units 1 and 2) i SEACOAST ANTI-POLLUTION LEAGUE'S OBJECTION TO MOTION TO WITHDRAW 3

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- CONTENTION NH-10

. - 4 Nbi.The jSeacoast.c. Anti-Pollution ' League hereby objects to the withdrawEl of

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cContentionlNH-10 3on the grounds that such withdrawal is premature. Contention NH ;

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"'4;f.910, Jamended by the State. of New.. Hampshire and Gregory H. Smith, Attorney General

(.ofth'e' State of New Hampshire on May 24, 1982, reads as follows:

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e The Seabrook Station Control Room Design does not compl with General

Design Criteria 19 through 22 in 10 CFR Part 50, Appendix A, and NUREG-0737, Items.I.D. I and I.D. - 2.

In the. State of New = Hampshire's statement of basis for Contention NH-10, the State declared that:

It is especially critical at Seabrook that accident monitoring a d control

' room design be the optimum because of. the difficulties inherent'in carrying

.out protective actions for the population in the immediate Nicinity of the plant.1 -

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By Board Order of Sept. 14, 1982, the Board admitted SAPL Supplement.,6 in e..

which SAPL joined in and adopted as its own the contentions and bases of the State 1

of New Hampshire and Attorney General Gregory Smith, Nos; 4 through 10, and 12 through

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1 See Amendment and Supplement tsthe Petition for,Le, ave to Intervene an.d.Requestq.fn,,, m wo 3 Attorney General of, o

. for. Hearing of the State of New: Hampshire and Gregory.H. Smithj$

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16. The Board stated that it would permit SAPL to participate as a Joint Intervenor with New Hampshire. Contention NH-10, therefore, cannot be withdrawn without SAPL's assent. SAPL does not lend its assent to this action for the reasons set forth herein.

The Seacoast Anti-Pollution League does not believe that the results of the Detailed Control Room Design Review (DCRDR) nor the design of the Safety Parameter Display System (SPDS) are adequate at this time.

Particularly in view of the Chernobyl 4 reactor accident, SAPL holds that additional variables need to be displayed on the

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Further, SAPIl does not believe it acceptable to allow the so-called lower

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priority Human Engi' dering' Discrepancies (HEDs) resolutions to remain uncorrected until n

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the.,first refuelingioutagea < Additionally, SAPL asserts that the change to the Video b}QdN n.

. AlarmiSystem'(VAS).colN!. coding scheme, to make it.more consistent with other control f

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. room;CRT's shouldjbe{z{ accomplished prior to fuel load and low-power te SAPL r ey y qqk A 3

g also holds that 'a preliminary evaluation of the control room environment (including such 3

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variables as humidity, acoustic noise auditory signals, airflow and temperature) ought j

to. be, accomplished prior to fuel -load.

SAPL is aware of no evidence that such a preliminary review has been accomplished except on some auditory signals.

Additional Parameter Displays needed on SPDS

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SAPL.does not believe that the Applicants' justifications for non-inclusion of i

T three safety parameter; displays, and the deferral of inclusion of two others until the i

first-refueling outage, as ~ described at P. 9 of SBN-987, should be at all acceptable to 1

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i this Board._ The'three parameters.the Applicants do not intend to include are RH'R' i

i flow, Containment Isolation and Containment Hydrogen Concentration.

Residual Heat Removal Flow is a key indicator of the efficacy of heat removal i

1 when steam. generators are not available.

Applicants argue that ;RHR flow is not a,

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"" stand alone" parameter, and they, assert that; the; core cooling status tree on the SPDS. W g

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holds that Lit would greatly ' enhance safety to have both parameters displayed., This 1

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would be consistent with the NRC's avowed defense in depth philosophy.'

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Containment isolation is important for a rapid assessment of the conditions prevailing in the containment and can provide additional assurance of containment integrity.

Aoplicants argue that since there are status light indicators for every containment isolation valve on the main control board, it is not necessary to add containment isolation to the SPDS. Applicants assert that the status light indicators are visible from the SPDS console. In an emergency situation, there could be many i

people walking around in the control room who could obstruct the line of vision to the main control board. This potential problem should be eliminated prior to operation at any level by installation of the appropriate parameter display on the SPDS console.

Containment hydrogen concentration is a key parameter required to monitor j

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combustible gas control. Aaplicants aver that this parameter display is unnecessary

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d bS$aiN it is indicated on the main control. board, is not likely to cause any need for QQ35

1. actionlwithin the first few hours of any accident, that an operators emergency support i

group would be in place at any time hydrogen concentration would be a threat, and that it{is a parameter reviewed in the emergency procedures set. SAPL, urges that this line of argument be found non-persuasive.

Particularly in view of the questions that are

]1 yet unanswered with regard to the role of hydrogen in the breach of the Chernobyl 4 containment, the monitoring of combustible gases is very important. It is possible that, even in light water moderated reactors, combustible gases could accumulate much more quickly.than anticipated via processes not ye,t fully understood.:

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' The Applicants s,eek a deferral of the incorporation of parameter, displays for St'eam ' Generator ' Radiation and Stack Monitor until the first refueling outage. This

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should be wholly unacceptable. These parameters are very important and without them the SPDS will be incapable of displaying information trowing the assessment of radiation

',in the secondary steam system when 'the steam ' generators and/or their steamlines.are

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> ' isolated. ' Applicants point to 'the fact that the,re.is' a: radiation ' monitoring console in :

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Applicants do.not detail whether?or not the. information on then

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~ l radiation monitoring console is readable from the vantage point of the SPDS console.

In SAPL's view, there is no justification for postponement of installation of these parameter displays. All 5 of the above-mentioned parameter displays ought to be installed prior to fuel load and station operators should be thoroughly trained in their use prior to any operation of the plant.

HEDS Resolutions Including the VAS Color Coding Scheme In SBN-839, the Applicants on July 17, 1985 committed to review the control room furnishings for HEDs "at least 120 days PTLF" (prior to loading fuel). However, SER Supplement 4, transmitted to the Board and parties by the staff on June 4,1986, indicates as follows:

Subsequent' to completion of installation of furnishings in th'e control room

._a review:will be ' conducted by PSNH and any HEDs found.will be resolved,

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' prior to startup from the first' refueling outage.

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3. In'SBN-839, th'e Applicants said that operator protective'eghipment and emergency equipment storage would be reviewed at least 120 days PTLF and any HEDs submitted for 'NRC review. Yet, SER Supplement 4 says:

> Once the equipment has been purchased and installed, the storage facilities 3

will be re-evaluated by PSNH. Any HEDs found will be resolved prior to start up from the first refueling outage.

SER Supplement 4 goes on to state that final evaluation of the control room environment will be completed and reported to NRC for confirmatory' review after a year of commercial operation has been achieved. However, there, appears to SAPL to N

h' be no good reason why 'a preliminary evaluation and identification 'of HEDs cannot be undertaken prior to' fuel loading.

In sum, it appears to SAPL that the rush to. core load Seabrook is causing the i

NRC and Applicants to push aside tasks that ought to be completed before any operation 1yC for the plant is allowed, even in,the face of' A=plicant's own prior commitment to t

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,m,s q The color-related HED in the Video Alarm System clearly ought to be corrected before any operation of the plant is allowed.

Plant operators should accustom themselves to the change in color-coding before the plant operates at any level. It is imprudent to allow the plant to be low power tested while the color coding is still inconsistent with other CRT's. This will only serve to reinforce this anomalous situation in the minds of the operators and could lead them to make an error when the plant is put into full power operation with the color code mo' ified.

d In attachment 1 to SBN-948,,in the discussion related to the need for a sensitive containment pressure indicator, applicants note that they have " committed to banding indicators by the end of the first refueling outage.". Again, SAPL urges this Board to find that there -is no~ acceptable' justification for ' deferring irhpr'oNements that will aid e

the plant operators in monitoring plant conditions, i %

r SAPL'would call to attention again the State of New Hampshir 's statement of x

April 5,1982, that monitoring and control room design should be: optimum because of the population in the immediate vicinity. The State of New Hamhhire appears to be retreating from its prior commitment to protect public health and safety in its withdrawal of Contention NH-10. Although this is truly unfortunate, the f MRC ought nonetheless

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insist on a high standard of safety. For the reasons set forth Nbove, SAPL objects to N>

and opposes the Motion to Withdraw Contention NH-10 on ithe : grounds that such

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t Respectfully submitted, SEACOAST. ANTI-POLLUTION LEAGUE -

By its Attorney, BACKUS, MEYER & SOLOMON i

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