ML20205C487

Interrogatories & Requests for Documents to Applicant Re Seacoast Anti-Pollution League Supplemental Contention 6 & New England Coalition on Nuclear Pollution Contention I.B.2. W/Certificate of Svc.Related Correspondence

ML20205C487
Person / Time
Site:	Seabrook
Issue date:	08/08/1986
From:	Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
CON-#386-279 OL, NUDOCS 8608120337
Download: ML20205C487 (8)

Text

$

EEt.ATED Conar.arwe%

Filed: August 8,1986 00\\KJED g

C UNITED STAl'ES OF AMERICA

'86 ale 11 A10:47 NUCLEAR REGULATORY COMMISSION OFFICE u K uJt An 00CKET g i Wirt before the ATOVIIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE COMPANY OF Docket Nos. 50-443-OL-/

I NEW HAhPSHIRE, ET AL 50-444-OLy (Seabrook Station, Units 1 and 2)

On-Site Issues SEACOAST ANTI-POLLUTION LEAGUE'S INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO THE APPLICANTS INSTRUCTIONS FOR USE The Seacoast Anti-Pollution League hereby requests that the Applicants, pursuant to 10 C.F.R 62.740(b) and 92.741, 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 Applicants 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, char ts, analyses, intra-corporat ion or int ra-o f f i ce commun ica t ions, no t ebooks, dia r i es, s ke t ches, diagrams, maps,

forms, manuals, brochures, lists, publications, drafts, telephone

minutes, minutes of meetings, statements, calendars,

journals, 8608120337 860808 PDR ADOCK 05000443 G

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

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mk' 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 t ems I.D.1 and I.D. 2 1)

List all documentary or other materials the Applicants may employ in this proceeding to support its position (s) with respect to this content ion.

In addition to listing such documents and other materials, provide a copy of all of them pursuant to 10 C.F.R.42.741.

-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 Applicants' position (s) with respect to this contention.

3)

Identify any person or persons the Applicants 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 Applicants in this proceding.

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 Applicants believe that stack monitor and steam generator (or steamline) radiation need not be added to the Safety Parameter Display System (SPDS) until prior to restart following the first refueling outage.

7)

Do the Applicants hold that the period of operation prior to the first refueling outage is any safer than~ any other period of operation, and i f so, upon what basis or bases?

8)

For the following parameter displays A through E,

state how long it would take to install the parameter display, the cost, any technical problems that might be encountered in its installation, and Applicants' full justification.for not having installed these parameter displays on the SPDS console to date:

a)

RHR flow b)

Containment Isolation c)

Containment Hydrogen Concentration d)

Steam Generator (or steam line) Radiation e)

Stack Monitor n

c e$

b 9)

Have Applicants provided for operator protective equipment to be kept in the control room?

If not, state why not.

Is such protective equipment to be kept in any other location?

I f so, state where.

10)

List all actions or requirements for licensing that the Applicants are deferring until the first refueling outage.

11)

Have Applicants performed a complete system function and task analysis and subsequent comparison of results of the analysis with the control room inventory as is required by NUREG-0737, Supplement I?

12)

Why, when in SBN-839 Applicants commit ted to review the control room furnishings for HEDs "at least 120 days PTLF", are Applicants now seeking to defer this action until prior to startup from the first refueling outage?

13)

Why, when in SBN-839 Applicants said that operator protection equipment and emergency equipment storage would be reviewed at least 120 days PTLF and any HEDs submitted for NRC review, are Applicants seeking to defer this action until prior to startup from the first refueling outage.

14)

Why are Applicants unable to complete banding of indicators prior to fuel load?

15)

State why Applicants have not planned to correct color-related HEDs in the Video Alarm System prior to fuel load and have instead sought to low power test the plant before making the correction.

16)

Are reactor coolant system vents able to be remotely operated from the control room as NUREG-0737 II. B.1 requires?

Provide a description of the related displays and controls.

17)

Is there positive indication of reactor coolant system relief and saf ety valves in the cont rol room as NUREG-0737 II. D. 3 requires?

Provide a description displays and controls.

18)

Are the additional accident monitoring instrumentation and associated displays and controls added to the control room as required by NUREG-0737 II. F.

I?

19)

Describe the types and locations of displays and alarms to be added to the control. room that are related to the instrumentation for detection of inadequate core cooling required by NUREG-0737 II.

F.

2.

20)

Describe the Applicants' incorporation of the lessons learned f rom t he Sal em ATWS even t in the Detailed Control Room Design Review.

21)

Provide a description of how the Applicants have assured the following relative to the SPDS: J m

i 4

a) that appropriate parameters are displayed b) that it is isolated from safety systems c) that it will provide reliable and valid data d) that it incorporates good human engineering practice 22)

Provide the conclusions of the SPDS Verification and Validation (V&V) Program.

23)

Provide a diagram of the control room displaying the location of the SPDS console relat ive to the Main Control Board with distance (s) indicated in appropriate units of measure.

Also indicate the dimensions of the SPDS console (height, etc.).

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NECNP OONTENTION I.B.

2 The Applicants have not satisfied the requirement 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 Applicants 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. 7 41 2)

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

3)

Identify any person or persons the Applicants 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 Applicants in this proceding.

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)

Provide the analysis supporting coaformance wi th Reg. Guide 1.75.

7)

For the following, state how long it would take to install the environmentally qualified equipment, the cost, any technical problems that might be encountered in installation and Applicants' full justification for not having installed the equipment to date:

a)

Monitor for containment sump water temperature b)

Monitor for accumulator tank pressure c)

Monitor for accumulator tank level d)

Monitor for primary coolant radiation level e)

Monitor for narrow range sump water level 8)

Describe how Applicants would perform post accident energy balance calculations without knowledge of the sump water temperature.

9)

Describe how Applicants would per f orm net pos it ive suct ion head calculations for safety system pumps during the recirculation mode without containment sump water temperature.

10)

What uncertainties are taken into account in the Seabrook Cycle i nulcear design calculated shutdown margin at end of life? -

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11)

Describe the assumptions used in determining submergence potential in the containment building.

12) Describe the plant maintenance / surveillance program-related to aging of electrical equipment.

13)

Have corrective measures been taken for all the deficiencies identified by the NRC staff's environmental qualification audit of February 25, 26 and 27, 1986?

Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By Its Attorneys, BACKUS, MEYER & SOLOMON sp; h

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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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/ Rab~ert A '. ~B a c k u s 1

.i CERTIFICATE OF SERVICE AND SERVICE LIST i

Jose Asst.Gn.Cnsl.

Sheldon J. Wolfe, Chrm,"

Thomas Dignan, Esq. +

Fed. ph Flynndgmt. Agcy.

Adan. Judge Ropes &' Gray

Emerg, 500 C.St. So. West Atomic Safety & Lic Brd.

225, Franklin St.

Washington, DC 20472 USNRC Boston, MA 02110 Washington, DC 20555 Office of Selectmen Dr. Jerry Harbour

• Docketing & Serv. Sec.

Town of Hampton Falls Admin. Judge Office of the Secretar3 Hampton Falls, NH 03844 Atomic Safety & Lic Brd.

USNRC USNRC Washington, DC 20555 Washington, DC 20555 Sherwin E. Turk, Esq.

Dr. Emmeth A. Luebke *'.

Jane Dokighty Office of Exec. Legl. Dr.

Admin Judge SAPL USNRC Atomic Safety & Lic. Brd.

5 Market Street Wahsington, DC 20555 USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq.

Paul McEachern, Esq.

George Cana Bisbee, Esq.

Asst. Atty. General Matthew Brock, Esq.

Attorney General's OFF,:

Stato H0use, Sta. #6 25 Mapleucod Ave.

State of'New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsnouth, NH 03801 Carol Sneider, Esq., Asst.AG Diane Curran, Esq.

William S. Lord 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 i

Richard A. Hampe, Esq.

Maynard Young, Chainmn Sandra Gauvutis New Hampshire Civil Defense Board of Selectmen Tosm of Kingston Agency 10 Central Road Box 1154 Hampe & McNicholas Rye, NH 03870 East Kensington, NH 03827 35 Pleasant St.

Concord, NH 03301 Edward Thomas Mr. Robert Harrison FBIA Pres. & Q11ef Exec. Officer 442 J.W. McCorunck (POQI)

PSCO Boston, MA 02109

'P.O. Box 330 Manchester, NH 03105 Roberta Pevear State Rep.-Town of Hanpt Falls Drinkwater Road Hangton Falls, NH 03844

• Federal Expressed i

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