ML19208C362

Submits Contention in Support of Request for Hearing.Plant Endangers Health & Safety of Population.Sufficient Mods Have Not Been Made Re TMI.Long-term Mods Must Be Implemented Per NRC 790507 Order.Certificate of Svc Encl

ML19208C362
Person / Time
Site:	Rancho Seco
Issue date:	07/23/1979
From:	Castro R, Nursh G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
References
NUDOCS 7909260117
Download: ML19208C362 (4)

Text

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I UNITED STATES OF AMERICA A

p NUCLEAR REGULATORY COMMISSION E

g In the Matter of:

)

)

SACRAMENTO MUNICIPAL UTILITY DISTRICT

)

Docket No. 50-312

)

Rancho Seco Nuclear Generating Station

)

CONTENTIONS IN SUPPORT OF REQUEST FOR HEARING CONTENTIONS:

1.

Rancho Seco Nuclear Generating Station is unsafe with respect to the health and safety of myself and other members of the public who reside or work in the vicinity of Rancho Seco Nuclear facility.

A.

Babcock and Wilcox reactors are too susceptible to feed-water transients which may result in an accident.

B.

Rancho Seco does not have an adequate evacuation plan.

C.

Rancho Seco has inadequate radiation monitoring devices.

D.

Rancho Seco has inadequate notification procedures for informing local authorities in case of a potential accident.

E.

Rancho Seco does not have a recombiner.

F.

The present elevat. ion of the steam generator is a design defect.

G.

Pressuriner, steam generator, vessel and plumbing arrangements are improperly designed with respect to bubble formation in hydraulic high points.

H.

Babcock and Wilecx's once through steam generator level measurement is a design deficiency.

I.

Feedwater systems and auxilary feedwater systems are too scept b1 to ccamon-mode failures.

7909260i11 J.

Sabcock and Wilcox' pressur'fzer tank and quench tank 8

1 n i r; inn

s E00R ORIGlWL sizes are too small.

K.

Babcock and W11cox's primary loop arrangement is defectively designed with respect to steam bindings, steam bubble formation, and pump cavitation.

L.

Operator data on pressurizer level / vessel level are unreliable and can be mislead.ing during an accident.

M.

Inability to isolate steam generator B under some circumstances.

N.

Inadequate reliability of off-site power.

O.

Problems with relief valves sticking open.

P.

Ins uf ficient instrumentation and data for post-accident monitoring.

Q.

Inadequate level instruments.

R.

Insuf ficient analysis between what functions should be hard equipment responsibilities and what can be a soft procedural function.

S.

Inadequate control room design.

T.

Question of competence of plant personnel and management to operate Rancho Seco.

2.

Sufficient modificati.ons have not been made in light of the experience at Three Mile Island Unit No. 2 to allow the Rancho Seco facility to operate in a safe manner.

A.

In support of this contention and incorporated herein by this reference I refer to communications to NRC from the ACRS regarding TMI since March 28, 1979 which state specific recom-mendations which have not been adequately addressed.

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3.

Failure of the NRC Commission to act quickly and decisively during the TMI-2 accident and the absence of any assurance that the exercise of their regulatory authority wculd be adequate in a second TMI-2 type or similar accident.

C.

Adequacy of training requirements and job descriptions of plant operators and associated personnel.

3 The long-term modifications referred to in the May 7, 1979 order of the NRC must be implemented before the Rancho Seco Nuclear facility can operate l'n a safe manner.

CONCLUSION We request that the Nuclear Regulatory Commission address these contentions and provide for the suspension of operation of the Rancho Seco Nuclear Generating Plant, unless they or their designated representatives publicly conclude that, in light of the accident at TMI-2, the Rancho Seco Nuclear Generating Plant can continue to be operated without endangering the health, safety and econc.nic well being of the Petitioners and the people of Sacramento.

Submitted,

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GARY HURSH /

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( "N1If RICHARD D.

saSTRO Members Board of Directors, Sacramento Municipal Utility Dictrict f0,I 1015 102

r P00R BRIGM-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of SACRAMENTO MUNICIAAL UTILITY

)

Docket No.

50 - 312 OISTRICT

)

)

Rancho Seco Nuclear Generating

)

Sta tion

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I hereby certify that copies of" CONTENTIONS IN SUPPORT OF REQUEST FOR HEARING" in the above captioned proceeding have been served cn the following by deposit in the United States mail, first class, this 23rd day of July,1979, and that one copy was delivered by hand to the office of the Nuclear Regulatory Comission in Washington,D.C. on this same day:

DAVID F.

EAP LAI:, Esq.

LEONARD BICKWIT, Esq.

Secrc:ar, General Councel General Counsel c.

P O b o:- 15E30 U.S.

Nuclear Regulator Commission Sacramentc, CA 95E13 Washington, D.C.

20555 TI CTHY

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DILLDI:, Lug.

ATDMIC SAFETY AND LICENSING Sultu 3M BOARD PANEL

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1S50 K Street, I4. K.

U.S.

Nuclear Regulatory Commission

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D.C.

.000t Washington, D.C.

20555 MR.

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CASTRU ATDMIC SAFETY & LICENSING MR GARY HURSH APPCAL BOARD PANEL facramento Municipsi l'tiliry U.S.

' uclear Regulatory -Commission cir ric:

Washington, D.C.

20555 C201 S E t reet-P O b o :- 15830 Fucrament, CA 95S17 MR. SAMUEL J.

CHILK Secretary of the Commission Mi'

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V.::DERVELCE:,

U.S.

Nuclear Regulatory Commission

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' O A:- REISS Washington, D.C.

20555

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P OT:E 7 I C H P I S T O P lie ! W O :

'r:endc ci the Carth DOCKETING AND SERVICE SECTION c 111. c uc a Legisl :ti ve G fi ce Office of the Secretary 717 - Strcot, S ui t.e 2 0 B U.S.

Nuclear Regulatory Commission Sacr _mentc, CA 9581:

Washington, D.C.

20555

'Y i.vh RICHARD D. CASTRO, PETITIONER 2015 21st Street

. Sacramento, CA 95816-

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