ML19211A139
| ML19211A139 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/13/1979 |
| From: | Hoefling R, Lewis S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7912170082 | |
| Download: ML19211A139 (6) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGUALT0RY COMMISSION 11/13/79
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~f BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
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,', ~.. gd In the Matter of
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SACRAMErlTO MUNICIPAL UTILITY
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Docket No. 50-312 (SP) tt/
DISTRICT
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(Rancho Seco Nuclear Generating
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Station)
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NRC STAFF RESPONSE TO THE RESTATEMENT OF ISSUES OF CONCERN AND REQUEST FOR CLARIFICATION OF RULING BY THE CALIFORNIA ENERGY COMMISSION INTRODUCTION By its " Order Ruling on Scope and Contention" of October 5, 1979, the Atomic Safety and Licensing Board ruled on the scope of this proceeding and on the admissibility of the contentions and issues put forth by the parties. With regard to certain issues raised by the California Energy Commission (CEC) which the Board considered to be within the scope of this proceeding, it granted CEC fif teen days from the issuance of the Order to submit restated issues. By its " Restatement of Issues of Concern and Request for Clarifica-tion of Ruling" of October 24, 1979, CEC presented two restated issues to the Board and also requested a clarification of the Board's ruling excluding consideration of loss of off-site power in this proceeding.
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. DISCUSSION The Staff has reviewed CEC resubmitted Issue Nos.1-1 and 1-12 and believes these issues to now be adequately articulated for admission in this proceeding. We, therefore, support their admission.
CEC additionally seeks clarification of the Licensing Board's ruling that:
As to "various transient events" as the phrase is used at page 4 of the Comission's May 7 Order, we believe that, taken in the context of page 5 of that same Order, the scope of this proceeding can be expanded no further than"... feedwater and/or trip of the turbine..."
We will, therefore, not allow matters such as loss of off-site power to be raised and considered among the contentions here.
CEC argues that:
However, we understand the Board's ruling to allow considera-tion of events that may initiate feedwater transients as well as the ability of the Rancho Seco system to respond to such a sequence of events. Because the loss of off-site power can initiate a feedwater transient we believe that in this limited aspect the loss of off-site power is within the scope of this hearing as defined by the Board's order.
CEC concludes by asking the Board to rule that:
The ability of Rancho Seco to respond to feedwater transients caused and accompanied by the loss of off-site power is a proper subject for adjudication in this hearing.
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, The Staff supports the ruling of the Licensing Board. The Board correctly looked to the Comission's Order of May 7,1979 to determine which types of transients would be litigable in this proceeding.
In explaining the basis for the actions it was requiring, the Commission noted (p.1):
... the Nuclear Regulatory Comission's Staff has ascertained that B&W designed reactors appear to be unusually sensitive to certain off-normal transient conditions originating in the secondary system. (emphasis supplied)
This emphasis on transients originating in the secondary system is repeated throughout the Order. See, for example, p. 3.
Loss of main feedwater and turbine trip are conditions originating in the secondary system and the Commis-sion's focus on these two initiating events is made urrtistakably clear in the short and long term actions it required of the Licensee. Specifically, the Commission required the Licensee to implement a hard-wired reactor trip "that would be actuated on loss of main feedwater and/or turbine trip."
(pp. 4, 5, 7). Also, the Commission required the development and implementation of pro-cedures for initiating and controlling the auxiliary feedwater ( AFW) system independently of the Integrated Control System (ICS), the AFW system being the back-up to the main feedwater system.
(pp. 4, 7).
Loss of off-site power is not an event originating in the facility's secondary system. The Commission took express note in its May 7,1979 Order (p. 2) of loss of off-site power as a potential initiating event which can call upon 15?6 176
. the AFW system, the ICS, and the emergency core cooling system (ECCS) for recovery. Having taken note of that potential initiating event, the Commission did not, however, further address it. Loss of off-site power might independently be a matter of some significance, but it is apparent that the Commission did not intend to have that matter considered in this proceeding.
CEC argues that loss of off-site power should be considered in this proceeding because it can initiate a loss of main feedwater transient. As noted above, the Commission expressly recognized this possibility. Transients initiated by loss of off-site power would likely proceed, however, in a manner fundamentally differ ent from transients originating in the secondary system. The Commission and the Board correctly reflected this distinction in their Orders.
CONCLUSION For the reasons developed above, the Staff takes the following positions on CEC's resubmission and request:
1.
Resubmitted Issues 1-1 and 1-12 should be admitted as issues in controversy in this proceeding.
2.
CEC's request for clarification should be denied in that the issue of loss of off-site power is beyond the scope of this proceeding.
Respectfully submitted, N.
s Stephe H. Lewis Co nsel f r NRC <taff H.M f or-Richar K. Hoefling Dated et Bethesda, Maryland Counsel for NRC Staff this 13th day of November,1979 1596 177
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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SACRAMENTO MUNICIPAL UTILITY
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Docket No. 50-312 DISTRICT
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Rancho Seco Nuclear Generating
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Station
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO THE RESTATEMENT OF ISSUES OF CONCERN AND REQUEST FOR CLARIFICATION OF RULING BY THE CALIFORNIA ENERGY COMMISSION." in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 13th day of November, 1979:
Michael L. Glaser, Esq., Chairman Gary Hursh, Esq.
1150 17th Street, N.W.
520 Capitol Mall Washington, D.C.
20036 Suite 700 Sacramento, California 95814
- Dr. Richard F. Cole Atomic Safety and Licensing Board Panel Mr. Richard D. Castro U.S. Nuclear Regulatory Commission 2231 K Street Washington, D.C.
20555 Sacramento, California 95816
- Mr. Frederick J. Shon James S. Reed, Esq.
Atomic Safety and Licensing Board Panel Michael H. Remy, Esq.
U.S. Nuclear Regulatory Commission Reed, Samuel & Remy Washington, D.C.
20555 717 K Street, Suite 405 Sacramento, California 95814 David S. Kaplan, Esq.
General Counsel Christopher Ellison, Esq.
Sacramento Municipal Utility District Dian Grueneich, Esq.
P. C.
Box 15830 California Energy Commission Sacramento, California 95813 1111 Howe Avenue Sacramento, California 95825 Timothy V. A. Dillon, Esq.
Suite 380 1850 K Street, N.W.
Washington, D.C.
20006 1596 178
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- Atomic Safety and Licensing Mr. Michael R. Eaton Board Panel Energy Issues Coordinator U.S. Nuclear Regulatory Commission Sierra Club Legislative Office Washington, D.C.
20555 1107 9 Street, Room 1020 Sacramento, California 95814
- Atomic Safety and Licensing Appeal Board Panel Thomas A. Baxter, Esq.
U.S. Nuclear Regulatory Comission Shaw, Pittman, Potts & Trowbridge Washington, D.C.
20555 1800 M Street, N.W.
- Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Herbert H. Brown, Esq.
Lawrence Coe Lanpher, Esq.
Hill, Christopher and Phillips, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 N
SL iL Stephen H. Lewis Counsel for NRC Staff 1596 179