ML20212M742

Responses to NRC 860808 Interrogatories Re Onsite Emergency Planning & Safety Issues.W/Certificate of Svc & Svc List

ML20212M742
Person / Time
Site:	Seabrook
Issue date:	08/25/1986
From:	Backus R, Doughty J, Ducharme S SEACOAST ANTI-POLLUTION LEAGUE
To:	Atomic Safety and Licensing Board Panel
References
CON-#386-486, RTR-NUREG-0737, RTR-NUREG-737, TASK-1.D.2, TASK-TM OL-1, NUDOCS 8608270111
Download: ML20212M742 (4)

Text

. .- _ -- . . .

Filed: August 25,19hSN C UNITED STATES OF AMERICA '86 ALE 26 P1 :43 NUCLEAR-REGULATORY COMMISSION GFFICE OF nug wn 00CHEilNG 4 5! Pvicf~

before the BRANCH ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE COMPANY OF Docket Nos. 5 0 - 4 4 3 -OL-/

NEW HAMPSHIRE, ET AL 50-444-OL.-

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

, . Planning & Safety Issues SAPL'S RESPONSE TO NRC STAFF INTERROGATORIES TO SAPL PURSUANT TO THE BOARD ORDER OF J ULY 25, 1986 The following are the Seacoast Anti-Pollut ion League's responses

, to the NRC Staff's Interrogatories of August 8, 1986.

Contentions N.H.-20 and NECNP 111.1

1. No.

2. No.

Contention NECNP I . B. 2

1. No.

2. Yes. SAPL plans to cross examine on the completed environmental qualificat ion review in SER Supplement No. 5. SAPL has not yet determined which specific' portions of the document it will cross examine upon, but may include 3.11.3, 3.11.3.1, 3.11.3.3, 1

3.11.3.3.1, 3.11.3.3.2, 3.11.3.3.3, 3.11.3.3.5, 3.11.3.4, 3.11. 4 an d 3.11. 5. SAPL also reserves its right to cross examine upon any documents obtained in response to interrogatories with respect to this contention.

o111 060825 hojB2jDOCK0500o443 G

1 PDR i

Contention SAPL Supp. 6

1. SAPL does no t at this time intend to of fer any direct testimony, but reserves the right to alter this intention following review of the Staff's and Applicants, responses to SAPL's interrogatories.

2. Yes.

3. Yes , SAPL does so contend. As basis, SAPL holds that Applicants have not met the requirements of NUREG-0737, Items I . D.1 and I.D.2, and having not met those requirements, Applicants have not met the burden of proof of showing that " actions can be taken to operate the nuclear power unit safely" as GDC 19 requires (emphasis added). SAPL does not yet know whether the lessons learned as the result of the Salem ATWS incident have been adequately addressed.

4. SAPL does not know.

5. SAPL does not know.

6. SAPL does not know.

7. Yes, SAPL does so contend. SAPL holds that the deferral of the evaluation and resolution of human engineering discrepancies (IIEDS ) with respect to control room furnishings and operator protective equipment and emergency equipment storage, the dererral of evaluation of the control room environment, and the deferral of banding of indicators until prior to start up from the first refueling outage is contrary to the i n t e n t o f NUREG-0737, I . D.1 requirements. SAPL also holds that operating the plant at any level with inconsistent color coding of the Video Alarm Sys tem (VAS) pr f or to commercial operat ion is also contrary to the i n t en t o f t he NUREG-0737, I . D.1 r eq u i r eme n t s . SAPL does not yet know whether or not the existing control room inventory unduly prejudiced the Applicant's function and task analysis, but has reason to believe it did.

8. Yes, SAPL does so contend. The Draft License dated June 20, 1986 for Seabrook Station, NPF-56, listed the following 6 modi fica t ions that were to be operat ional on the Saf ety Parameter Display System (SPDS) prior to restart following the first refueling outage:

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

2) Addi t ion of, or sa t is f actory j us t i ficat ion f or , not adding RilR flow and hydrogen concentration parameters to appropriate SPDS screens,

3) Addi t ion of a containment isola t ion s tatus screen on SPDS, or improvement to the current containment isolation display to be satisfactorily recognizable from the assigned SPDS location in the control room,

_g.

a ..

4) Addition of a radiation monitoring screen to display at least steam generator (or steam line) and stack radiation,

5) Improvement of the Heat Sink screen for consistency in labeling, and the Suberi t icali ty screen for mode dependency so as not to mislead operators, and

6) Addition of approved isolation devices between the Reactor Vessel Level Instrumentation System (RVLIS) and SPDS.

SAPL holds that there is no supportable rationale for allowing Seabrook to operate for any period without full compliance with NUREG-0737, Item I.D.2.

SEACOAST ANTI-POLLUTION LEAGUE By: fhmb- TLb Jane Dohghty Field Director d4 Personally a,,peared the above-named Jane Doughty and made oath that the foregoing statements by her subscribed are true to the best of her knowledge and belief.

Before me, W A. W Justice of the Peace /Netery~

-Pet + h:~

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

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

/$f 'i * ^U . ,fx > .

/

. Rober;t A. Backus

. _ - _ - - _ - _ - _ - . . - - - - - - - - - - - - 1

. 6 CERTIFICATE OF SERVICE AND SERVICE LIST Jose Asst.Gn.Cnsl.. Sheldon J. Wolfe, Chrm." Thomas Dignan, Esq.+

Fed. ph Flynnhigmt Emerg, . Agcy. Admn. Judge Ropes & Gray 500 C.St. So. West Atomic Safety & Lic Brd. 225 Franklin St.

Washington, DC 20472 USNRC Boston, b!A 02110 Washington, DC 20555 Office of Selectmen Dr. Jerry Harbour "

Town of Hampton Falls Docketing & Serv. Sec. c

. Admin. Judge Office of the Secretary .

Hampton Falls, NH 03844 Atomic Safety & Lic Brd. USNRC USNRC Washington, DC 20555 Washington, DC 20555 Shenvin E. Turk, Esq.

• Office of Exec. Legl. Dr. Dr. Emmeth A. Luebke

• Jane Doughty USNRC Admin Judge SAPL Wahsington, DC 2055_

Atomic Safety & Lic. Brd. 5 Alarket Street USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq. Paul McEachern, Esq. George Dana Bisbee, Esq.

Asst. Atty. General ahtthew Bruck, Esq. Attorney General's OFF.

State House, Sta. #6 251hplewood Ave. State of New Hampshire Augusta, ME 04333 P.O. Box 3GO Concord, NH -03301 Portsnouth, NH 03801 Carol Sneider, Esq., Asst.AG Diane Curran, Esq.

One Ashburton Place, William S. Iord Ilarmon, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430 Boston, MA 02108 Town Hall-Friend St.

hashington, DC 20009 Amesbury, MA 01913 Richard A. Hampe, Esq. Shynard Young, Chainmn Sandra Gauvutis New IIanpshire Civil Defense Board of Selectmen Town of Kingston Agency 10 Central Road Box 1154 Ilampe & McNicholas Rye, NII 03870 East Kensington, Nil 03827 Con N bh301

• Edward 'Ihomas Mr. Robert liarrison FDIA Pres, & Chief Exec. Officer 442 J.W. McCormack (POGI) PSCO Boston, MA 02109 P.O. Box 330 hhnchester, N!! 03105 Roberta Pevear State Rep.-Town of Hanpt Falls Drinkwater Road Hanpton Falls, NH 03844

• Federal Expressed

.