ML17139A351
| ML17139A351 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/20/1981 |
| From: | Laverty J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML17139A352 | List: |
| References | |
| NUDOCS 8107220178 | |
| Download: ML17139A351 (5) | |
Text
REGULATO INFORMATION DISTRIBUTION TEM (RIDS)
ACCESSION NBR o 81 07220 1'78 DOC ~ DATE'1/07/20 NOTARIZED YES FACILc50 387 Susquehanna Steam Electric Stationi Unit 1P Pennsylva SO 388 Susquehanna Steam Electric StationP Unit 2P Pennsylva 05000388 AUTH'AME AUTHOR AFFILIATION LAVERTYPJ,H, Hearing Branch 2'
E C IP ~ N AME E C 'I P -I E NT AF F IL"IA'TIO N Atomic Safety and Licensing Boat d Panel SUBJECT!: Response in opposition to applicant 810701 motion for" summary disposition of Content-ion 19.Motion-is incomplete 8
does not" demonstrate absence of genuine issue of mlatl fact ~
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIHG BOARD In the Matter of PENNSYLVANIA POWER AND LIGPIT CO.
AHD ALLEGHENY ELECTRIC COOPERATIVE, INC.
(Susquehanna Steam Electric Station, Units 1 and 2)
Docket Hos.
50-387 yu Q>
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c(Peg NRC STAFF
RESPONSE
OPPOSING APPLICANTSe v
MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 19.
I.
INTRODUCTION On July 1, 1981, "Applicants'otion for Summary Disposition of Contention 19" (Motion) was served on the NRC Staff.
In that Motion, Applicants move the Board for summary disposition in its favor of Contention 19 which alleges, in essence, the Environmental Report (ER) and the Final Safety Analysis Report (FSAR) are inadequate because they do not discuss an accident such as actually occurred at the Three Nile Island Unit 2 facility.
The Licensing Board order admitting this late-filed contention specified the issue to be litigated:
That accident is a series of events of the t e which actually occurred at TMI To be sure, there may be sufficient difference between the boiling water reactors involved in this proceeding and the pressurized water reactor involved in the TMI accident to preclude a similar or com arable accident from occurring at Susquehanna.
PDR ol78 8jp72 8>O~ai ADaCK ppppp~e POR 4 Sjl
(emphasis added).~
Applicants assert that Contention 19 presents no 1/
genuine issue of material fact and that Applicants are entitled to a decision in their favor as a matter of law.
The NRC Staff opposes Applicants'otion on the ground that it is incomplete and does not demonstrate the absence of ~an genuine issue of material fact with regard to the possibility of the occurrence of a THI-type accident at the Susquehanna facility. Applicants'otion does not set forth all the material facts necessary to show that a THI-type accident is very unlikely because Applicants'otion only addresses equipment failures.
The Staff describes a THI-type accident as a small break loss of coolant accident which was not recognized by the plant operators, and which was complicated by equipment failures and human failures.
As human failures have not been addressed in Applicants'otion, the Staff concludes that the Board should not dismiss Contention 19 as a
matter of law.
Respectfully submitted,
~RA/8LQf essica H. Laverty Counsel for NRC Staff Dated at Bethesda, Maryland this 20th day of July, 1981 Ql Penns lvania Power and Li ht Co.
(Susquehanna Steam Electric Station, Units 1 and 2, LBP-79-29, 10 NRC 586, 592 (1979).
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PENNSYLVANIA POWER 5 LIGHT COMPANY and ALLEGHENY ELECTRIC COOPERATIVES, INC.
(Susquehanna Steam Electric Station, Units 1 and 2)
Docket No. 50-387 O.L.
50-388 O.L.
NRC STAFF STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS A GENUINE ISSUE TO BE HEARD CONTENTION 19 l.
A TMI-type accident is a small break loss of coolant accident 'which was not recognized by the plant operators and which was complicated by equipment failures and human failures.
Human failures can occur both before and during a postulated TMI-type accident.
Human failures can include:
improper shift staffing and administration to deal with unusual situations; inadequate emergency operating procedures; inadequate health physics organizations; incompatibility between operators and the systems that they operate; and inadequate operator training.