ML20066L022
| ML20066L022 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/23/1982 |
| From: | Jordan W HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| NUDOCS 8211290724 | |
| Download: ML20066L022 (8) | |
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if0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '82 g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD II 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 and 2)
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NECNP SECOND SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS TO APPLICANTS ON CONTENTIONS I.A.2.,
I.B.l.,
I.B.2.,
and I.C.
The New England Coalition on Nuclear Pollution (NECNP) requests that the Applicants, pursuant to 10 C.F.R. SS2.740(b) o and 2.741, 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 the responses to interrogatories below, and that subsequent to filing answers to these interrogatories and producing documents therein identified, the Applicants file supplemental responses and produce additional documents as required by 10 C.F.R. S2.740 (e).
Where identification of a document is requested, briefly l
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 publishir, addressee, date written or approved, and the name and address of the person (s) having possession of the document.
8211290724 821123 DR ADOCK 05000 3
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--2 As used in these discovery requests the term " document (s)"
includus publications of any format, letters, memoranda, notes,
reports, analyses, test results or data, recordings, transcriptions and printed, typed or written materials of every kind.
It encompasses all manner of recording information, whether written, electronic, magnetic, or otherwise.
This set of interrogatories is NECNP's immediate.
follow-up to the first set with respect to Contentions I.A.2.,
I.B.l.,
I.B.2.,
and I.C.
Their primary purpose is to provide clarifying information to permit expert review.
The responses to this set of interrogatories will also provide information necessary to permit effective document review with respect to both of the first two sets, which we hope to schedule soon after we have received the answers to this set.
He expect to file further discovery requests after we have received that information 'ad have had an opportunity for extensive expert review and consultation.
INTERROGATORIES 1.
In response to NECNP's first set of interrogatories i
l on Contentions I.A.2.,
I.B.l.,
I.B.2.,
and I.C.,
Applicants consistently used the term " safety related" and took the position that all safety related equipment had been environmentally qualified.
l In response to Interrogatory 3, Applicants stated that, "no l
distinction was made between " safety related" and "important l
to safety."
In response to Interrogatory 21, Applicants asserted that all safety related systems are also "important l
to safety."
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,,a.
Define the term " safety related" as used by Applicants.
(1)
State the technical, legal, regulatory, or other basis for this definiticn.
(2)
State the criteria used by Applicants to determine whether equipment is safety related.
(3)
Is it Applicant's position that only safety related equipment is required to be environmentally qualified?
If so, state the technical, legal, regulatory, or other basis for that position.
If not, identify and describe all other equipment that must be environmentally qualified.
b.
Define the term "important to safety" as used by Applicants.
(1)
State the technical, legal, regulatory, or other basis for this definition.
(2)
State the Applicants' understanding of the difference, if any, between " safety related" equipment or systems and equipment or systems that are "important to safety."
State the principle, if any, that distinguishes the two.
(3)
Identify and describe all equipment and systems, if any, that are "important to safety," but are not " safety related," and therefore, according to Applicants, do not need to be environmentally qualified.
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2.
In response to Interrogatory 5, Applicants noted that the proposed rule referred to in the Interrogatory had been revised in April 1982.
NECNP is unable to find any reference to this revision.
Please identify specifically, with appropriate citations, the document containing the April revision.
3.
In response to Interrogatory 10, Applicants noted that while there were no environmentally qualified electrical connectors commercially available when CLI-80-21 was issued, that was not true of electric valve operators, a.
Describe and state the function of an electrical connector.
b.
Identify all electrical connectors that are used in connection with safety related electric valve operators.
(1)
State the function of the electrical connector in each case.
(2)
State whether the use of the electrical connector is essential to the use of the elect'ic valve operator.
r c.
Identify and describe the function of all safety related electrical connectors.
d.
Explain how safety related electrical connectors can comply with IEEE 323-1974 whe.u the Commission stated in CLI-80-21 that there were at that time no commercially available electrical connectors that complied with IEEE 323-1974.
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In response to Interrogatory 15, Applicants stated that, "The safety-related equipment that is required to withstand the effects of the accident environment will do so for a minimum of one year. "
The answer did not explain the basis for that statement, as the interrogatory had requested.
a.
Explain the basis for the statement quoted above, b.
Explain the basis for choosing one year as a sufficient period of time to assure adequate I
protection.
j 5.
Interrogatory 31 asked whether it was Applicants' position 1
j that structures, systems and components governed by GDC 4 must be able to accommodate the effects of and be compatible with a
the environmental conditions associated with loss of coolant 4
accidents throughout the operating lifetime of the plant.
Applicants responded that such structures, systems, and components are able to withstand accident conditions during the operating life of the i
plant, but did not state a position on the question that was asked.
1-Accordingly, is it Applicant's position that safety-related j
structures, systems, and components must be able to accommodate the effects of and be compatible with the environmental conditions i
associated with loss-of-coolant accidents throughout the operating i
life of the plant?
i a.
If not, please respond to Interrogatory 31(a).
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6.
Interrogatory 34 asked for Applicants' position on l
the question of whether Applicants need to establish that
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structures, systems, or components governed by GDC 4 will remain l
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environmentally qualified for any period of time once an accident begins.
It also asked the periods of time that Applicants contend they must show that structures, systems, and components governed by GDC 4 will remain environmentally qualified once an accident begins.
Applicants responded that all structures, systems or components that are required to be operational are qualified to remain operational for the time required to perform their safety function.
As a result, Applicants did not respond to either of the questions asked in the interrogatory.
a.
Assuming the facts are as Applicants state them, is it Applicants' position that it must so convince the Board in order to meet its burden of proof?
b.
For each structure, system, and component referred to in Applicants' answer, state the time required to perform its safety function under a design basis accident that represents the worst case for the structure, system, or component in question.
In each case, describe the design basis accident.
Respectfully submitted, 6/kY]AW lQr=
William.v. Jordan, III IIARMON & WEISS 1725 I Street, N.W.,
Suite 506 Washington, D.C.
20006 (202) 833-9070 t
November 23, 1982 Counsel for NECNP i
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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing NECNP SECOND SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS TO APPLICANTS ON CONTENTIONS I.A.2.,
I.B.l.,
I.B.2.,
and I.C.,
have been mailed, first class, postage pre-paid to the following this 23rd day of November, 1982:
llelen Hoyt, Esq., Chairperson Phillip Ahrens, Esq.
Atomic Safety and Licensin9 Assistant Attorney General Board Panel Department of time Attorney U.S. Nuclear hegulatory Concissian General Washington, D.C.
20555 Augusta, ME 04333 Dr. Emmoth A.
Luobke Robert A.
Backus, Esq.
Atomic Safety and Licensing 111 Lowell S treet Board Panel P.O.
Box 516 U.S.
Nuclear Regulatory Commission Manchester, Nil 03105 Washington, D.C.
20555 Robert L. Chiesa, Esq.
Dr. Jerry Harbour Wadleigh, Starr, Peters, Atomic Safety and Licensing Dunn, & Kohls Board Panel 95 Market Street U.S.
Nuclear Regulatory Commission Manclies te r, Nil 03101 Washington, D.C.
20555 Thomas G.
Dignan, Esq.
Atomic Safety and Licensing R.
K.
Gad, III, Esq.-
Boar.d Panel Ropes and Gray U.S.
Nuclear Regulatory Commission 225 Franklin Street Washington, D.C.
20555 Boston, MA 02110 Atomic Safety and Licensing E.
Tupper Kinder, Esq.
Appeal Board Panel Assistant Attorney General U.S.
Nuclear Regulatory Commission Office of the Atty. General Washington, D.C.
20555 208 State Ifouse Annex Concord, ml 03301 Docketing and Service U.S.
Nuclear Regulatory Roy P.
Leasy, Jr., Esq.
Commission Robert G.
Porlis, Esq.
Washington, D.C.
20555 Of fice of tire Executive Legal Director Rep. Beverly llollingworth U.S.
Nuclear Regulatory Comc Coastal Chamber of Commerce mission 209 Winnacunnet Road Washington, D.C.
20555 llampton, Nil 0384 2 Edward J.
McDermott, Esq.
Sanders and McDermott Professional Association 408 La f aye t te Road Irampton, Nil 03842 D
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Wil f rect 11. Sanders, Jr.,
Esq.
David R.
Lewis Sanders,,jdid McDers.tott Atomic Safety and Licensing Board Professional Association U.S.
Nuclear Regulatory Commission 408 Lafayette Road Room U/W-439 llampton, Nil 0384 2 Washington, D.C.
20555 Jo Ann Shotwell, Esq.
Assistant At.torney General Environmental Protection Division Public Protection Bitreau Departri.ent of tite Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 C -; '/ / f f,f sp November 23, 1982 Will,ia/
m S.
Jordan, III e