ML20204J876

First Set of Interrogatories & Request for Production of Documents Re Onsite Emergency Planning & Technical Issues. Related Correspondence

ML20204J876
Person / Time
Site:	Seabrook
Issue date:	08/06/1986
From:	Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20204J826	List: ML20204J822 ML20204J850 ML20204J876 ML20204J890
References
OL, NUDOCS 8608110220
Download: ML20204J876 (8)

Text

. gND,cOh August 6, 1986 1

UNITEDSTATESNUCLEARREGULATORYCOMMI[kkkhf0

% mm u ~ ~ _ _ BEFO_RE THE ATOMIC SAFETY AND LICENS -NG BOARD

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In the Matter of )

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h 3 sa,y' y ity Public Service Company of )

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New Hampshire, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 & 2) ) ONSITE EMERGENCY l

) PLANNING & TECHNICAL

) ISSUES NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PPODUCTION OF DOCUMENTS TO APPLICANTS INSTRUCTIONS FOR USE The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the Ap-plicants with personal knowledge of the facts or information re-quested in each interrogatory. We remind you of your obligation to supplement answers to interrogatories, under 10 C . F.R. S 2.740(e).

The following definitions shall apply to these interrogatories:

1) " Document" shall mean any written or graphic matter of commu nica tion, however produced or reproduced, and is intended to l be comprehensive and include without limitation any and all cor-respondence, 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, charts, analyses, intra-corporate or intra-office '

0608110220 860806 ADOCK 05000 3 PDR G ,

1 commu nications, notebooks, d iar ies, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, j ournals,

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

2) " Identify" with respect to any document shall mean to state the following: the document's title, its date, the author o f the document, the person to whom to document was sent, all persons who received or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any and all copies of the document.

3) " Identify" with respect to any action or conduct shall mean state the following regarding any such action or conduct:

the person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; and any document recording or documenting such action.

4) " Describe" with respect to any action or matter shall mean state the following regarding such action or matter: the {

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substance or nature of such action or matter; the persons parti-cipating in or having knowledge of such action or matter; the current and past business positions and addresses of such persons; and the existence and location of any and all documenta relating to such action or matter.

. 5) " Identify" with respect to an individual shall mean s tate the individual's name, address, employer, occupation, and title.

INTERROGATORIES

1) Please state Applicants' position regarding NECNP Con-tention I.B.2.

2) Please identify and provide access to all documents on which you rely or intend to rely during this proceeding to sup-por t your position on NECNP Co ntention I . B.2. This includes all documents used in answers to these interrogatories, summary dis-position motions, testimony, and cross-examination of witnesses during hearings.

3) Identify all persons on whose factual knowledge, opinions, or technical expertise you rely or intend to rely for your position on Contention I.B.2.

4) Please identify all persons you may call as witnesses on this contention during these proceedings; describe the sub-stance of their test,imony; and identify and describe any docu-ments and the portions thereof that they may rely on for their testimony.

5) Please provide access to the following documents referenced in Applicants' Qualification Evaluation Worksheets:

a. Impell Letter No. 0 570-032-NY-156, dated 2/2/8 6,

" Environmental Qualification of Electrical Equipment, Summary of Class lE Equipment Submerged as a Result of Design Bases Events;"

b. Impell memorandum from G. Mo ore to A. Biswas, dated 2/22/86;

c. UE&C Flooding Study Ma trix, SBU-96263;

d. UE&C Engineering Change Authorization No.

037114514A;

e. FP-73400-02, Qual. Test Report for Class lE Solenoid Valves, QR-526-5683-6, rev.D, dated 4/19/84;

f. Seabrook FSAR, RAI 430.62, Amendment 48, Jan. 1983, pp. RAI 430-47,-48;

g. The following Equipment Qualification Files and all Documentation Re ferences lis ted in the corresponding Qualifica-tion Evaluation Worksheets:

-- EQ File No. 113-03-01;

-- EQ File No. 113-06-01;

-- EQ File No. 113-17-01;

-- EQ File No. 113-18-01;

-- EQ File No. 113-19-01;

-- EQ File No. 113-20-01;

-- EQ File No. 113-22-01;

-- EQ File No. 118-03-01;

-- EQ File No. 120-01-01;

-- EQ File No. 129-01-02;

-- EQ File No. 171-01-01;

-- EQ File No. 171-01-01;

-- EQ File No. 173-07-12;

-- EQ File No. 171-01-01;

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-- EQ File No. 174-00-01;

-- EQ' File No. 174-15-01

-- EQ File Wo. 236-11-06;

-- EQ File No. 248-05-01;

-- EQ File No. 248-37-01;

-- EQ File No. 248-37-02;

-- EQ File No. 248-37-03;

-- EQ File No. 248-38-01;

-- EQ File . No. 248-41-01;

-- EQ File No. 248-45-01;

-- EQ File No. 248-47-01;

-- EG File No. 248-65-01;

) -- EQ File No. 252-16-01;

-- EQ File No. 600-01-01;

, -- EQ File No. 600-01-04;

-- EQ File No. 600-01-09;

-- EQ File No. 600-06-01;

-- EQ File No. 600-08-01;

-- EQ File No. NSS-220-01;

-- EQ File No. NSS-220-02;

-- EQ File No. NSS-220-03;

-- EQ File No. NSS-220-05;

6) For each piece of equipment described in the above equipment qualification files, what is the basis for assigning an i

operating time of one year for the " postulated environment? "

i l

7) For each of the following pieces of equipment, please state the reason (s) f or Applicants' s ta tements in the qualifica-tion evaluation work sheets that submergence qualification "need not be addressed" or "is not required":

a) SkV Power Cable (Equipment Qualification File No.

113-01-01);

b) Coaxial Cable (EQF No. 113-06-01); Ins tr ument Cable (EOF No. 113-19-01);

c) 600V Control Cable (EQF No. 113-22-10);

d) Electric Conductor Seal Assembly (EQF No. 118-03-01).

8) Please describe the flood elevations for all parts of the Seabrook plant, and provide access to all drawings and other documents that describe flood elevations at Seabrook.

9) Please describe the methodology by which Applicants determined the flood elevations for the Seabrook plant. Identify and provide access to all documents that describe or discuss this methodology.

10) What is the accuracy (n.argin of error) of Applicants' determination of flood levels in the Seabrook plant?

11) Please identify all types of accidents that were con-sidered in determining flood levels at the Seabrook plant. In so doing, describe the assumptions that Applicants made regarding each type of accident and its behavior.

12) For each accident described in answer to Interrogatory 11, please describe the flood level that was calculated.

7-  !

13) After determining flood level and equipment elevation, what criteria did Applicants use to determine whether equipment needed to be qualified for submergence? Please identify and pro-vide access to all documents that contain or discuss those criteria.

14) What are the parameters of a " worst case" flood, and what are Applicants' criteria for determining what constitutes a worst case flood?

15) For areas outside of containment, what is Applicants' basis for assuming that the areas will be pumped? What systems will be available to pump the water? Where will the water be p ump ed to?

16) For areas outside of containment, what levels of radio-active contamination of floodwater have been calculated?

17) Have Applicants identified and environmentally qualified "nonsafety-related equipment" whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions, as defined in 10 C.F.R. 50.49(b)(2)? If so, please describe Applicants' criteria and methodology for identifying that equipment and list the pieces of equipment that fall under that definition.

8-

18) Is the equipment identified under 10 C.F.R. 50.49(b)(2) distinct f rom " safety-related equipnent," as defined in 10 C . F.R.

5 0. 4 9( b) (1 ) ?

Respectfully submitted,

< L,. 4 -

bfaEe Cur'ran HARMON & WEISS 2 001 "S" S t ree t N. W. Suite 430

&?ashington, D.C. 20009 August 6, 1986 (202) 328-3500 i

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