ML19249F255
| ML19249F255 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/01/1979 |
| From: | Ellison C, Grueneich D CALIFORNIA, STATE OF |
| To: | |
| Shared Package | |
| ML19249F251 | List: |
| References | |
| NUDOCS 7910110174 | |
| Download: ML19249F255 (13) | |
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UNITED STATES OF AMERICA NUCLE AR REGULATCRY C07.'1ISSION Before the Atomic Safety and Licensing Board In the Matter of:
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Sacramento Municipal
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Utilities District
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(Rancho Seco Nuclear
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Docket No.53-312 Jenerating Station)
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The State Energy Resources Conservation and Development cmmission (" California Energy Commission") as an interested : are in the above-captioned proceeding, hereby submits this Statemen: Of Issues.
Pursuant to Rule 2.715(c) of the U.S. Nuclear Regulatory
- mmission's Rules of Practice, the California Energy Commicsi:n is not required to take a pcsition with respect to the _ssues ccn2idered y One Atomic Safety ana Licensing Board in these he1 rings.
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like other parties, is the California Energy Commission obliga:'i to submit contentions at the outset of the hearings.
- 'evertheles s,
the California Energy Commission submits this statement for :".e ^cn-
'enience of the Board and other parties.
In doing 30, the Jal_ f t rr.il inergy Commission does not waive its right to address issues ::her than those set forth -. this statement pursuant to R_le 2.715; The California Energy Commission's concerns, as set for:n bel..
in greater detail, center on several major issues.
First, ace:cair :
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to the May 7 Order, these hearings must seriously exsrine """ ether the [short-term) actions required by the Order are sufficient to provide reasonable assurance that the facility will respcnd safely to feedwater transients, pending completion of the lcn -ter-modifications [and] whether the long-term codificaticnc are sufficien:
to provide continued reasonable assurance that the facility till respond safely to feedwater transients. " 1/
The California Energ; Commission sericusly questions the Board's ability to reach an affirmative conclusion on this issue absent development of a thor:us-record.
This record must demonstrate that the measures required b; the NRC for Rancho Seco are sufficient to provide the needed " reason-able assurance".
Such a demonstration on the record is essential since this is the first coportunity afforded by the ':RC for public validation of the adequacy of the actions required to ensure Ranch:
Seco's safe operation.
Therefore, unless this Board develops such a public record, there 4111 be no basis for it to conclude that the required actions are sufficient to provide the needed reasonable assurances.
In order to reach an affirmative conclusion, analysis will be needed to determine what information on the consequences of transien:2 was available to the NRC and SMUD at the time the NR: issued its Jrder and what measures to improve Rancho Seco's ability to respond cuch transients were Known by the NRC and SMUD at that tire.
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'de assume the hearings will cover all types of transients since the original shutdown order of May 7 explicit 1; states that
- ne long-term modifications were imposed to "further enhance the acpability and reliability of the reactor to respord to various transient events."
(Emphasis added.)
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The Board must also focus on how the NRC determined V.ich measure:
should or should not be required and in what time frame.
Finall/,
the Board must probe the criteria the NRC used co determine that the measures set forth in the Order were sufficient in the NRC's view to provide a reasonable assurance of safety so that the plant could resume normal operation upon their successful completion.
The California Energy Commission believes that this analysis is required not only to meet the cerms of the NRC hearing order, bu:
also to restore credibility in the NRC's licensing of nuclear react ::
and SMUD's operation of Rancho Seco.
The events at Three Mile Islar.:
dramatically demonstrate that the NRC in the past has seriousl3 mis-understood the necessary measures, whether design or Operational, that are needed to provide adequate assurances of safety.
Further-more, both the NRC and the nuclear industry have igncred the benefit:
and necessity of meaningful public input into their decision-making process.
More and more examples are coming to light of assumptions analyses, and decisions made by the NRC and the nuclear industry which, when subject to broader public scrutiny, have proved to be unwarran t ed.
The present widespread public distrust of the safety of Rancho Seco is based in large part upon the failure of the :RC and the nuclear industry, subsequent to Three :411e Island, to clearl identify through a process of public validation the criteria that als been used to determine the appropriate level of safety for Rancho Seco and the measures that are required to achieve such criteria.
Since this opportunity now exists in this proceeding, it shculd not be ignored.
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A seccnd major focus of these hearings T.ust be :- intellice :
analysis of the impact of information on Three Mile Island cr : ner relevant events that has been developed since issuance of the ".a:.
Crder.
This information must be examined to determine whether the terms of the Order, which did not have the benefit of the tcre re:er-information, are still sufficient to provide a reasonable assurance of Rancho Seco's safety.
For instance, the NRC's Lessons Learned Task Forca issued its first staff report just last week.
The rep:r:
outlines 23 short-term recommendations for u4111ty and vendor acti:r over the next 18 months which, in the words of Roger 1:attson, the director of the Task Force and chief of system safety analysis in the nuclear reactor regulation branch of the NRC, "wculd provide substantial additional protection which is required fcr public heal:.
2nd safety. "2 /
Given this statement by the NRC staff itself that additional measures are required for public health and safety, the Board must examine this and other information about Three. Mile Islani cr other relevant events that was not available when the May 7 Crder was issued, in order to conclude whether the terms of the Crder are in fact sufficient.
It will be necessary to explore which of One Task Force recommendations or other new information is relevant the safety of Rancho Seco, which of the potential improvements ha ce been implemented at Rancho Seco or are planned for implementation,
and whether failure to implement any of them affects Rancho Seco's ability co respond safely to various transients.
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Statement by Roger Mattson quoted in The Energy Daily, July 23, 1979, p.3
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In sum then, the California Energy Conmission sees that ce r-Cr essential items must be exam'_ned in public hearings in order for thic Board to conclude that there is a reasonable as;urance :f Rancho Seco's ability to provide safe and reliable service and c:
satisfy the concerns of the people of California.
- n particular, there must be a clear identification of the criteria the.'IRC and SMUD have used in determining the level of safety needed to nrovi;e reasonable assurance, specification of the actions required :: a ir. i e - +
such safety, consideration or relevant evidence developed since
-.e Ma:/ 7 Crder which shows the need for additional safety measures, 2.n ;
an opportunity for public involvement and validation.
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ISSUES 1.
'dhat criteria were used by the NRC to deternine that the measures specified in the May 7 shutdown Order.ere sufficient to provide reasonable assurance of the safe and reliable cperation of Rancho Seco?
2.
Are the shoruterm actions required by subparagraphs 'ai through (e) of the May 7 Order sufacient to provide adequate assurance of the reactor's current capability to respond reliably and safely to various transient events?
3 Are the sncrt and long-term measures required by the Ms 7 Order sufficient to provide reasonable long-tern assurance of the safe and reliable operation of Rancho Seco?
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What criteria were used by the NRC in determining which of the measures specified in the May 7 Order warranted short-term response and which warranted long-term response?
5.
Were there any other safety measures (cesign or operatin; procedure changes) which were considered by the NRC or SMUD for Rancho Seco in response to Three Mile :sland prior to issuance of the May 7 Order but which aere not included in the Orded If so, what criteria were used for determining that such measures should not be included within the sec;e of the Orders 7.
Nnat procedures and criteria are now being ased by the NRC and SMUD to determine what corrections or improvements (both design and operational) are necessary to provide a reasonat_e 1077 On
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assurance of the safe and reliable operation of Rancho Seco?
5.
How has the process used by the NRC and S.Vl: to determine that there is a rcasonable assurance of the safe and reliable operation of Rancho Secc been modified since Three Mile Island?
9 Are there additional measures not included.-;ithin the short and long-term modifications of the May 7 Order identified by the NRC, SMUD, or other entities that would enhance the safety and reliability of Rancho Seco in respendin; to various transient events or provide a greater assurance of the safe and reliable cperation ?
10.
For any improvement that could increase safe and reliable operation of Rancho Seco identified in response to Questien 9, what criteria and procedures are used by SMUD and the NRC in determining whether to implement them and the timetable for implementation, and whether to shut d:wn or derate 52+
pirrt pending successful implementation?
11.
How have the NRC and SMUD determined that ~ere is a reasonable assurance of the safc and reliable operation of Ranch:
Seco since additional safety measures have been identified subsequent to the May 7 Crder, in documents such as NUREG-056C, NUREG-0396 the Three Mile Island Lessons learned Task Force Report and by the Governor's Nuclear Power Plant Emergency Review Panel which have not been implemented at Rancho Seco?
12.
How can the NRC and SMUD determine there is a reasonab_e assurance of Rancho Seco's ability to respond safely to various transients based on the actions of the May 7 Crder since the information on needed safety measures contained in more recent documents, such as the TMI Lessons Learned Task Force Report, 1077 093
was not even available when the Order was issued?
13 Is implementation of (or at least consideration of the need to implement) any or all of the measures identified by the NRC in NUREG-0560, NUREG-0396, and the Lessens Learned Task ? cree Report or other relevant documents necessary te provide a reasonable assurance of the safe operaticn of Ranch:
Seco?
14 Does the NRC forsee more safety measures yet to be agreed upon with SMUD that will impact the operaticn of Rancho Seco?
15 Are the safety design and operation requirements for Rancho Seco as stringent as for new plants applying for operating or construction licenses?
16.
If not, are there two different NRC standards for desiEr and operation requirements necessary to provide a reascnable assurance of safe and reliable operation?
17.
Is there a reasonable assurance of safety since Ranch:
Seco is operating at less than the original intended safety design standards?
10.
If there are more stringent design and/or Operation requirements that must be met by new plants what criteria and procedures has the NRC used to determine that Ranche Seco need not satisfy such requirements?
19.
Are che procedures and criteria used by the NRC and SMUD for determining when to shut down Rancho Seco in the even:
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of various transients sufficient to provide the least risk :- 3.s 5
safety of the people of California?
20.
Are the procedures and criteria used by SMUD and the NRC for determin'ng what actions are necessary prior to restart after Rancho Seco is shut down due to varicus transients sufficent to provide the least risk to the safety of the people of California?
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21.
Which, if any, of the following are necessar" to pr:"id-a reasonable assurance of Rancho Seco's safe and reliable opers;i:^'
Redundant power ope' rated relie f valves that can overrida releases of primary system radioactive coolar.t.
A recombiner to mitigate hydrogen formation.
Better radiation monitoring devices at Ranchc Seco and surrounding areas to properly quantify radiation releases ir the event they occur.
Jse of other reactor systems that would provfde less rist.
to the public in the event of feedwater transients.
'lenting of hydrogen from the reactor core at Rancho Seco _f it is created by circumstances similar to thcse that cocurre; at Three "ile island.
revised evacuation and emergency response plan for Ranch:
.4 Seco and surrounding communities.
In automatic accident notification system.
A cent rol] ed, filtered venting system to mitigate unavridatie releases of radionuclides.
A revised measurement system to better inform Rancho Secc Operators of hydraulic conditionc in the stear generat:r, pressurizers, and reactor vessel.
Redesign of Rancho Seco's control room to be consistan: rich T.odern principles of human engineering.
Revised consideration of the possibility of multiple a.nd common-mode failures in Rancho Seco's design and operating procedures.
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22.
Are there any additional design fe?tures ir 5&W rea::src that have been identified since the May 7 Order as being unusuali sensitive to certain off-normal transient ecnditions that would affect Rancho Seco's ability to respond safely?
23 Are there any accident scenarios at Rancho Seco in
. i c ~c a secondary side-trip of the reactor, such as loss o f of f-site
.c..E-r would lead to undesirable conditions?
24
'dhen feedwater transients occur at Ranc ho Seco, are the steam generator and steam supply system of such design that ;r.r t at ie conditicr.s may occur given certain additional failures?
25 Are there other generic types of steam supply systens. n i :.-
avoid these cor.ditions and would be preferred in lieu of the preser-syster a: Rancho Seco so as to provide greater protection to publi:
healtn and safety and allow more reliable operation?
26.
Prior to Three '411e Island, what criteria did SMUD and "? :
use to determine that the sensitivity of Rancho Secc's steam sug;1 c syster tc feedwater transients did not pose an undue ".azard?
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How have the criteria changed in light of Three Mile :slar.i.
Is Rancho Seco unusually prone to bubble formation in hydra. _: high points?
Can these be vented if hazardous?
Are the plant and operations personnel at ?.2ncho See:
proper _
- aalified an d trained so as to prc' tide reastnable assurance c f the
-'s safe operation?
Consideration should be giver. :c :.:
folicwing _ actors:
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Are personnel properly apprised of new inf0rnation pe rtir e'-
to Rancho Seco, particularly information on operating e::;erian;5 of other reactors?
How do NRC and SMUD ensure that emergency instructicns ar' available to plant personnel in a manner that a_ lows qui::: re-farence and use during an emergency?
hhat procedures are used to encourage plant personnel and STIUD management to report uasafe or improper practices cr conditions at the facility to SMUD, the NRC or :thers?
Are plant personnel at Rancho Seco being asked to mitigate design deficiencies at the facility with a higher degree :f operator proficiency tho.r tas envisioned when the plant ias licensed?
Are the qualification and training of operat:rs consistent with the complexity of the equ$pment and safety systems the;-
are handling?
Do personnel adequately understand the mechanics of the facility, basic reactor physics, and other fundamental aspec:s of its operation and what process is used by the NRC and S:7JJ:
to determine this?
dhat specific changes have been made to the Rancho Secc control room to allow operators to better comprenend and resp:nd to unscheduled, abrupt shutdowns?
Are there any other changes that could be made to ensure better conprehension and response by operations personnel 5 I
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30.
Have the.':RC and SMUD given proper consideration to the views and expertise of individuals on its staff, the nuclear industry,
and the utilities in their decisions on the safety of Rancho Seco?
31.
Have the ':RC and SMUD given proper consideration to the views and expertise of individuals, private organizations, and state, regional and local governments in their decisions en the safety of Rancho Seco?
32.
Have the :RC and SMUD prcperly informed the nuclear industry,
the utilities, state, re g; tal, and local governments, and t!.e public of information and events pertaining to the safety of Rancho Seco?
Dated: August 1, 137c Respectfully submi::ed,
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-l(un :Df DIAN M.
GRUENEICH CHRISTOPHEP ELLIS:::
Attorneys for the California Energy Ccemission 005500h0\\[#[
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