ML20069J712

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Corrected Version of Answer in Opposition to Applicant & NRC Motions for Summary Disposition of Contention NECNP-I.B.1 Re RHR Sys Failure to Meet GDC 4 & 34.Statement of Matl Facts as to Which There Is Dispute & Certificate of Svc Encl
ML20069J712
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 04/21/1983
From: Bisbee G
NEW HAMPSHIRE, STATE OF
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20069J705 List:
References
NUDOCS 8304260049
Download: ML20069J712 (3)


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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS'SI

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ATOMIC SAFETY AND, LICENSING B &

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7 In-the matter of:

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PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE)

Docket Nos. :

50-443 ET AL.

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and

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50-444 (Seabrook Station, Units 1 and 2)

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April 21, 1983 THE STATE OF NEW HAMPSHIRE'S.' ANSWER TQ THE APPLICANT'S AND THE STAFF'S MOTIONS FOR

SUMMARY

DISPOSITION OF CONTENTION NECNP-I.B.1 Pursuant to 10 C.F.R. 52.749 the State of SeV Hampshire hereby i

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answers the Staff's and the Applicant's MotilonEfor Summary I

Disposition of Contention NECNP-I.B.1, arth opposes these motions for the reasons explained below.

Contention NECNP-I.B.1 asserts in broad terms that the residual heat removal system for Seabrook Station does 5pt satisfy the requirements of GDC 4 and GDC 34.

New Hampshire has raised the particular question of the reliability o5,the steam generator tubes as the heat sink in the residual heat removal system.1/

The Applicant and Staff in their respective motions for summary I

disposition on this contention do not respond to New Hampshire's fg expressed concerns a, bout this issue.

New Hampshi.re has questioned tv a.

the ability of the Westinghouse steam generators to serve as an in

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'88 SeeNewHampshire'shanuary 17, 1983 Answers to Applicant's wo 1/

Interrogatories, at p. 16, and New Hampshire's

g February 19, 1983 Answer to Applicant's Motion to Compel, at

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p. 9.

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w adequate heat sink in light of the repeated occurrences of tube

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ruptures with this type of steam generator.

Tube # rupture problems have persisted'even with Westinghouse's rec,ent model steam generators. ' Affidavit of Dr. Stephen S. T. Fan, 12.

Given this evidenceofunreliabilityofthesteam'geherato[s, it is important to determine how the steam generators will function if their efficiencyisimpairedduetolossofaportion'gftheheattransfer

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surface resulting from defective tubes.

In light of the above, the Applicant has complied with neither GDC 34, in failing to provide for an adequate residual heat removal system, nor GDC 4, in f ailing to demonstrate thait the steam generator is able to " accommodate the effects 6J and to be compatible with the environmental conditions associated with normal operation.

. and postulated accidents."

10

.F.R.

Part 50,

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Appendix A, Criterion 4.

4 "Given this factual dispute over the adequacy of the steam generators in providing residual heat removal capabilities, the l

Staff's and Applicant's Motions for Summary Disposition of l

Contention NECNP-I.B.1 should be denied.-

Respectfu).ly submitted, THE STATE OF NEW HAMPSHIRE GREGORY H. SMITH ATTORNEY GENERAL By:

t George' Dana Bierbee Attorney Environmental Protection Division Office of Attorney General State House Annex Concord, New Hampshire 03301

(

603-271-3678 l

Dated:

April 21, 1983 l

.p STETEMENT OF MATERIAL FACTS AS TO WHICH THERE I6 DISPUTE i

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In view of tMe fact that t e integrity of Westinghouse steam generator tubes has been under question, due to repeated occurrences of tube ruptures, it is important to determine how the residual heat removal-system-will function if the efficiency of the steam generator is impaired due to the loss of a portion _of the heat transfer surface resulting from the defective tubes.

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This tube integrity problem has persisted witW Westinghouse's recent model steam generators. ~~ -

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Furthermore, due to-low. temperature driving fo'rce and the possibility of flow reversal in some of the tubes during natural circulation conditions, the margin of safety for heat transfer may not be large.

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Based on the above considerations, the desigh'of.the residual heat removal system should be thoroughly" studied to fully assess the design limit and 6'ffectiveness of the system and to determine if additional m5ans of residual heat removal should be introduced-to ensure -adequacy of' the system.

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Unless and until this study is performed there is-insufficient assurance of a reliable residual heat removal system that is environmentally qualified, satisfying the'

-requirements of GDC 34 and GDC 4.

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