ML20072S655

Answer to Interrogatory XXIII-2.Certificate of Svc Encl. Related Correspondence

ML20072S655
Person / Time
Site:	Seabrook
Issue date:	04/04/1983
From:	Curran D, Jordan W HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
NUDOCS 8304070278
Download: ML20072S655 (6)

Text

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,83 APR pr il 4, A

1983 6 A!0:26 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION:,haig, t me.4 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

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In the Matter of

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PUBLIC SERVICE COMPANY OF

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Docket Nos. 50-443 NEW HAMPSHIRE, et al.

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50-444

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(Seabrook Station, Units 1

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and 2)

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NECNP ANSWER TO APPLICANTS' INTERROGATORY XXIII-2 Due to a clerical error in the Board's order of March 24, 1983, NECNP did not understand that the order required a response to Applicants Interrogatory XXIII-2 until it was too late to prepare an answer by the deadline established in the Order.

As a result, NECNP contacted Applicants, who consented to an additional three days to submit an answer, and NECNP moved for permission to file the answer within that time period.

NECNP now submits its answer to Applicants '

Interrogatory XXIII-2.

The interrogatory reads as follous:

XXIII-2.

Please state each and every reason why NECNP contends that the Program does not meet the requirements of App.: B, specifying in detail:

(i) each specific part of the Program which NECNP contends is not in compliance, (ii) each part of App. B with which NECNP contends the specific part of the Program is not in compliance, and (iii) each and every addition to, deletion o!ohojjg O

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. from, or change in the Program which NECNP contends must be made in order to bring the Program into compliance.

At this point, NECNP's contention is limited to the inadequacy of the PSAR with respect to quality assurance for replacement materials and parts obtained or installed during operations and with respect to quality assurance for repair or rework during operation.

NECNP's position is two-fold.

First, as demonstrated in NECNP's filing of June 17, 1983, Appendix B requires that the operations quality assurance program extend to these matters.

Second, as discussed in NECNP Opposition to Motions for Summary Disposition and Notification of Withdrawn Contentions, filed March 24, 1983, at 24-28, the FSAR fails to discuss "how the applicable requirements of Appendix B will be 2

I satisfied" with respect to these matters."

This discussion is i

required by 10 C.F.R. S 50.34(b)(6)(ii).

Applicants' interrogatory appears to misinterpret the contention as involving specific concerns about the adequacy of quality assurance.

This misses the point of the contention.

NECNP has not yet challenged specific aspects of the operations quality assurance program in these areas because Applicants have not yet provided the required information concerning how the quality assurance program will be implemented in these areas.

The information in the FSAR is extremely general in nature, and it may provide an adequate outline for a discussion r,r--

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. of how Applicants will meet the requirements of Appendix B, but it-does not include the discussion required by 10 C.F.R.

S 50.34(b)(6)(ii).

Thus, NECNP has not yet been able to

. evaluate whether specific parts of the program comply with Appendix B or to determine the additions to, deletions from, or

-changes in the program that would be necessary to compy with Appendix B.

Once the FSAR is brought into compliance with 5 50.34(b')(6)(ii), NECNP will amend-the contention or file a new-contention, as'necessary.

In the' interim,1 Appicants fail to comply with that regulation.

Although NECNP's most significant point here is Applicants' failure to comply with S 50.34(b)(6)(ii), this failure also constitutes a violation of all of the Criteria of Appendix B since all relate in some way to quality assurance for replacement parts and for rework and repair.

Since the Criteria must be read together with 5 50.34(b)(6)(ii), the 8

• . Moreover, Applicants themselves admit that "The' procedures which implement the QA program are not yet fully approved and are still under review and' development." 'Since these are the.

documents that provide the information on which it is possible to base a review of the adequacy of the QA program, and they are not yet available, NECNP has not yet been able to undertake.

l the evaluation necessary to identify specific aspects of the l

operations QA program for replacement parts er rework and repair that do not comply with Appendix-B.

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. Board must conclude that the Criteria have not been met if Applicants have not provided the information to demonstrate how they have been met.

Respectfully submitted, SC William S. JorM n III lane Curran HARMON & WEISS 1725 I Street, N.W.

Suite 506 Washington, D.C.

20006 (202) 833-9070 April 4, 1983

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CERTIFICATE OF SERVICE l

I certify that on April 4, 1983, copies of NECNP l

ANSWER TO APPLICANTS' INTERROGATORY XXIII-2 were served by first-class mail, or as otherwise indicated, on the following:

1 Helen F. Hoyt, Esq.

Robert A. Backus, Esq.

Chairperson, Atomic Safety 116 Lowell Street and Licensing Board P.O. Box 516 U.S. Nuclear Regulatory Commission Manchester, NH 03105 Washinton, D.C.

20555 Phillip Ahrens, Esq.

Dr. Jerry Harbour Assistant Atty. General Administrative Judge State House, Station 96 Atomic Safety and Licensing Board Augusta, ME 04333 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Jo Ann Shotwell, Esq.

Assistant Atty. General Dr. Emmeth A. Luebke Office of the Atty. Gen.

Administrative Judge One Ashburton Place, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Beverly Hollingworth Washington, D.C. 20555 Coastal Chamber of Commerce Roy P._Lessy, Jr., Esq.

822 Lafayette Rd.

Robert Perlis, Esq.

P.O. Box 596 Office of Exec. Legal Dir.

Hampton, NH 03842 U.S. Nuclear ~ Regulatory Commission Washington, D.C.

20555 Anne Verge, Chair Board of Selectmen Atomic Safety and Licensing Board Panel Town Hall U.S. Nuclear Regulatory Commission South Hampton. NH 03842 Washington, D.C.

20555

• Rober t K. Gad, Esq.

Atomic Safety and Licensing Board Thomas G..Dignan, Jr., Esq Appeal Panel Rcpes and Gr ay U.S. Nuclear Regulatory Commission 225 Franklin Street Washington, D.C.

20555 Boston, MA 02110 Ruthanne G. Miller, Esq.

Sandra Gavutis Law Clerk to the Board RFD 1 Atomic Safety and Licensing Board East Kensington, NH 03827 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 n-

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7 John B. Tanzer George Dana Bisbee, Esq.

Edward Cross, Esq.

5 Morningside Drive Asst. Atty. Generals llanpton, N!!

03842 Office of the Atty. General Dr. Mauray Tye, President Letty Hett, Selectman Sun Valley Association RFD Dalton Road 98 Emmerson Street Drentwood, NII 03833 Haverhill, MA 01830 Calvin A. Cannery Edward F. Meany City Manager 155 Washington Rd.

City !!all Rye, NH 03870 Portsmouth, NH 03801 Docketing and Service Roberta C.

Pevear U.S.

Nuclear Regulatory Drinkwater Road m

ssi Hampton Falls, N!! 03844 C.

20555 l

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' Diane Curran

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