ML19208B677
| ML19208B677 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/20/1979 |
| From: | Remy M REED, SAMUEL & REMY |
| To: | |
| References | |
| NUDOCS 7909210174 | |
| Download: ML19208B677 (10) | |
Text
.
'QMb M UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION WC PWLTC DOCmr)7 g m In the Matter of:
cNet Po.
50-312 SACRAMENTO MUNICIPAL UTILITY DISTRICT
)
)
Rancho Seco Nuclear Generating Station )
NOTICE OF APPEARANCE AND CONTENTIONS The law firm of REED, SAMUEL & REMY will appear in the prehearing conference
'n behalf of Friends of the Earth, the Environmental Council of Sacramento, and the Original SMUD Ratepayers Association.
CONTENTIONS 1.
In light of unresolved safety questions the May 7, 1979 shut down order is insufficient to provide adequate assurances of public health and safety.
Operations of the Rancho Seco Nuclear Facility must be suspended by order of the Commission until the applicant SMUD has submitted, and the Commission has considered sufficient information to determine whether there are reasonable assurrances of adequate protection for the public health and safety.
The recort before the Atomic Safety and Licensing Board is insufficient to support such reasonable assurrances of public health and safety because-it fails to disclose:
(a) evaluation or comment on the acceptability of 27 feedwater transients over the past year in nine Babcock and Wilcox (B & W) reactors, a frequency which is 50 percent greater than the 9 )y corresponding rate for other pressurized reactors; qs
/
iS'*d9
(+
's pc or s
I dN
- q A t.
gm u
g pd* e6@
190@N }'L
- [el#[c as
~-
en
-~
(b) adequate evaluation, consideration and adoption of safety measures identified in NUREG-0560 to 'further increase the safety margins in B & W plants and their specific applicability to the Rancho Seco facility; (c) a recognition that serious accidents will occur at nuclear facilities no matter how diligent regulatory authorities and power plant 'perators are; o
(d) evidence of evaluation, consideration and adoption of studies, reports and analysis received by the Commission between the shutdown order of May 7, 1979 and the reopening of the Rancho Seco facility; (e) evidence that emergency response plarning around the Rancho Seco facility, which in its present state has clearfy been shown to be insufficient, has been or will be sufficiently upgraded or modified; s
(f) express finding by the Commission that the Rancho Seco facility is safe to operate; (g) express finding by the Commission that the terms and conditions of uhe shutdown order were sufficient to insure safe operation of the Rancho Seco facility; (h) safety risk evaluation of lonj. term modifi' cations and reasonable time-table for implementati'gr. by applicant SMUD; (i) evidence of safety risk assessment of the short-term modifications required of applicant SEJD by the shutdown order; (j) evidence of reliability assessment of the short-term modifications required of applicant FMUD by the shd down order; (k) annlysis of whether the nanagement competence and control are adequate at the Rancho Seco fagility.
OhN>.i.Mf s
-3~
2.
The Rancho Seco Nuclear facility should be ordered to suspend operations until the NRC has developed adequate and systematic procedures for implementing needed remedial _ actions or modifications identified in licensee event or accident reports for operating nuclear facilities.
3.
The Three Mile Island accident has brought to light sufff.cient evidence of design failure, equipment malfunction, regulatory problems and human error to require that the NRC initiate relicensing of the Rancho Seco Nuclear facility to assure incorporation and implementation of all necessary health and safety measures and provide adequate consideration of the environmental and economic implications of needed short-term and long-term modifications.
Operation of the Rancho Seco facility should be suspended until the relicensing process called for has been completed to provide reasonable assurance of public health and safety.
CONCLUSION We urge that operation of the Rancho Seco Nuclear facility be suspended until the concerns raised by these contentions have been addressed and resolve'.
Respectfully, 414
/
/
/MXOHAELH. REMY
/
REED, SAMUEL, & REMY 717 K Street, Suite 405 Sacram nto, CA 95814 COUNSEL FOR PETITIONERS DATED:
July 20, 1979 00.
b0
O 1 0 UNITED STATES OF AMERICA cocMU NUCLEAR REGULATORY COMMISSION uS@
... i b'
4\\q79 ?
BEFORE THE COMMISSION g2 jz, In the Matter of N
SACRAMENTO MUNICIPAL UTILITY
)
- )
DISTRICT
)
- d I
)
Docket No. 50-312 Rancho Seco Nuclear Generating
)
Station
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " NOTICE OF APPEARANCE AND CONTENTIONS" in the above captioned preceeding _have been served on the following by deposit in the United States mail, first class, this 20th day of July, 1979:
DAVID S.
KAPLAN, Esq.
LEONARD BICKWIT, Esq.
Secretary & General Counsel General Counsel P O Box 15830 U.S.
Nuclear Regulator Commission Sacramento, CA 95813 Washington, D.C.
20555 TIMOTHY V.A.
DILLON, Esq.
ATOMIC SAFETY AND LICENSING Suite 380 BOARD PANEL 1850 K Street, N.W.
U.S.
Nuclear Regulatory Commission Washington, D.C.
20006 Washington, D.C.
20555 MR. RICHARD D.
CASTRO ATOMIC SAFETY & LICENSING MR. GARY HURSE APPEAL BOARD PANEL Sacramento Municipal Utility U.S. Nuclear Regulatory Commission District Washington, D.C.
20555 6201 S Street-P O Box 15830' Sacramento, CA 95817 MR. SAMUEL J. CHILK Secrstary of the Commission MR. MARK VANDERVELDEM U.S. Nuclear Regulatory Commission MS. JOAN REISS Washington, D.C.
20555 MR. POBERT CHRISTOPEERSON Friencs of the Earth DOCKETING AND SERVICE SEC'1 ION.
California Legislative Office Of fice of the Secretary 717 K Street, Suite 208 U.S.
Nuclear Regulatory Commission Sacramento, CA 95814 Washington, D.C.
20555 9
e~-
.ICEAEL H.
REMY
/
Counsel for Petitioners
[N'A>d,70
FRIE N DS OF TH E EARTH CALEORMA LEGISLAUVE Omcz 717 K SrRzzT, #208. SACRAMENTO, CALFORMA 95814 (916) 446-3109 C
6 h Affidavit of o
7 C MARK A.
VANDERVELDEN
% gNNc3#p#
Q representing Affiant dW E
g k 4*315, 9
$ gg
$/
and FRIENDS OF THE EARTH and g
its Members s,.,, ~2 I, Mark Vandervelden, declare under penalty of perjury as follows:
1.
I reside at 1314 19th Street, Sacramento, California.
I am the Energy Policy Coordinator in the California Legislative Office of Friends of the Earth, Inc. located at 717 K Street, Sacramento, California 2.
My personal residence is within 25 miles of the Rancho Seco
. Nuclear Generating Station.
I am therefore personally interested in the health and safety aspects of the plant.
Safety problems unaddressed in the May 7 order will have a direct affect on my family and me.
3.
Friends of the Earth, Inc. is a non-profit corporation with principle business in Sacramento County.
4.
Friends of the Earth, Inc. engages in public interest research and advocacy.
It has over 300 members within the zone of interest and thousands more near the zone of interest.
G i,,
4 "i s v L) s].S.1.
Page 2 5.
Friends of the Earth, Inc. principle concern of relevance here is with the potential health, safety and environmental risks associated with generic and other problems not adequately considered in any previous hearing, or the May 7 Order.
6.
Friends of the Earth, Inc., is concerned that these unexamined problems and. risks expose it's members and the general public to hazards which can seriously affect their health, safety, and economic well-being.
I declare under penalty of perjury and the laws of the United States that the foregoing is true and correct.
DATED:
UN[ 20 [f s-N hW\\ h N
h's dN V VELDEN Energy Policy Coordinator Friends of the Earth 717 K Street, Suite #208 Sacramento, CA 95814
ENVIRONMENTAL COUNCIL OF SACRAMENTO 909 12th Street Sacramento, California 95814 4
A.
8 Affidavit of 9
br.
Z JOAN REISS 2
g%'[p representing Affiant
/
and ECOS y
/
M M
I, Joan Reiss, declare under penalty of cerjury as follows:
1.
I reside at 2l00 Rockwood Drive, California.
I am a member of the Environmental Council of Sacramento (ECOS), an interested party in this proceeding.
2.
My personal residence is within twenty miles of the Rancho Seco Nuclear Generating Plant.
I am therefore personally interested in the safety aspects of the plant. Any safety problem will'have a direct affect on my family and me.
3.
ECOS as an organization is also vitally interested in this issue.
I am the Co-Chairperson of the ECOS Energy Comittee. Along with that organization, I will perticipate in all hearings and vigorously prosecute our point of view.
4 ECOS is a proper party to this proceeding. All membership groups have offices within the County of Sacramento and all have individual members who reside within this County.
Member Organitarsons
&&![
)*
Audubon Society Sacramento MM Auxiliary o
in o mets te IM UTe League of nbmen Voters Save the American River Anociation Lung Anociation Sretta Cub Ranned Parenthood Zero l%culation Growth 10C% aECYCLE:: *aPEm
2 I declare under penalty of perjury and the laws of the United States of America that the foregoing is true and correct.
Dated: July 15, 1979
~I h
@M J
oan Reiss, Co-chairperson ECOS Energy Comittee e
O A-AFFIDAVIT OF
, > - 8 x$
3 PATRICIA MACDONALD
{
4 Representing Affiant and the 5
Original SMUD Ratepayers 4
~
I, PATRICIA MACDONALD, declare under penalty of perjury as follows:
1.
I reside at 2749 10th Avenue, Sacramento, California.
I am Co-Chairperson of the Original SMUD Ratepayers, an interested party in this proceeding.
2.
My personal residence is within 20 miles of the Rancho Seco Generating Station.
I am therefore personally interested in the health and safety aspects of the Plant.
Safety problens unaddressed in the May 7 Order will have a direct affect on my family and me.
3.
The Original SMUD Ratepayers founded in 1974 is an unincor-parated organization which has participated in numerous SMUD Board proceedings related directly to the safe operation of the Rancho Seco f acility.
The Original SMUD Ratepayers principle concern of relevance here is with the potential health, safety and environ-16 mental risks associated with genered and other problems not adecuately considered in any previous hearing, on the May 7th Order.
..m
... 4.
The Original SMUD Ratepayers represents numerous individuals living within the zone of interest.
5.
The Original SMUD Ratepayers is concerned that unexamined problems and risks expose its m2mbers and the general public to hazards which can seriously affect their health, safety and economic well-being.
I declare under penalty of perjury and the laws oi the United States, that the foregoing is true and correct.
DATED:
diLbi F
' 'i ' O J
"LYb.) ?
71Ch'VZD/
I t
PATRICIA MACDONALD Co-01 airman Original SMUD Ratepayers 2749 10th Street Sacramento, California
(;. g} n.s.L f 9 4 OL
.