ML19254B063

Revised Contentions of Intervenor Citizens for Fair Util Regulation.Submits Revised Contentions I,Iia & B,Iiia & B, & IV-VIII

ML19254B063
Person / Time
Site:	Comanche Peak
Issue date:	08/21/1979
From:	CITIZENS FOR FAIR UTILITY REGULATION
To:
Shared Package
ML19254B062	List: ML19254B063 ML19254B066 ML19254B068
References
NUDOCS 7909240022
Download: ML19254B063 (3)

Text

.

COMA!;CllE PEAK STEA?! ELECTRIC STAT 10 (CPSES)

Citizens for Fair Utility Refyilation (CFUP.) Cont entions Contention I .

Applicants have not demonstrated t.echnical quali fications to operate CPSES in accordance with 10 Crn fiS0.59(a)(4) in that they have relied upon West ing-house to pre pare a portion of the Final Safety Analysis Report (FSAR).

Position

• TU (Applicants) S (Staff) 1 (Intervenor)

A (W) A A '

t Contention II.A One or more of the reports us(d in the construction of couputer codes for the CPSES/FSAR have not been verified and fornally accepted; thus conclusions based upon these conputer codes are invalid.

,1losi t i on TU S I

[

EmlEnti_on 11. B_

11e f e r r ed .

Contention III.A Some accident sequences heretofore considered to have probabilities so low a r. to be considered incredible based upon the findings of WAsil--1400, are in A

Key:

• A = Admissible as to wording,and substance

. A (U) = Admissible as to wording only 7909240o %(z ,_

is

- 2 fact core probable in light of the findfug< of the Lewis Con ::it t ee and should In order to insure conservatisn, be evaluated as credible accidents for CPSES.

the probabilities associated with such accident sequences should be the highest prohr:hilities within the speelfied confidence band.

Position TU S I A (k') A (W) A C,on ty n_t i on llI . li Deferred.

Cont ention IV The Applicants have failed to entnblish and execute a quality assurance / quality control program which adheres to the criteria in 10 CFit 50, Appendi:. U. Appli-cants have f a i.l ed t o den.onst ra te sufficient uanagerial and administ rat ive control to assure safe operation as required in 10 CPR Pai t 50, Appendix E.

Therefore, special operating conditionu nhould be required.

Position k

Contention V There is no assurance that the Spent Fuel Pool area can withstand the effects of t ornadoes, ar required by 10 CFR Part 50, Appendix A, Criterion 2 becaune: .

a. The analyces upon which the Design Basis Tornado (DP,T) is based are perfunctory, outdated and unreliable;

b. The loading analyses based on t he Den i p,n Eas i s Tor nado (DBT) are inappropriate because they fall to consider ,n, a

'k)n[

fa k

the potential loading conbination of the DBT and a tornado-generated missile.

c. The assignment of a loading factor of 1.0 for load cou-bination equationa incorporat ing t ornado loadings in corbination with "nornal and accident conditionn" in .

unacceptable,

d. The DST parawters used in FSAR Section 3.3.2.1 are less connervative than the paraneters found in NRC Regulatory Guide 1.76 c.2.

Position

. A (l') /

Centention VI App [icantshave failed to adequately evaluate whether the rock "overbreak" and subsequent fissure repair using concrete grout have impaired the ability of Category I structuren to withstand seisnic disturbances.

P_o n i t i on.

TU S 1 A (U) A (U) A Coatont_fon VII_

Uithdrawn.

Contention Vill (former IV.D.)

Applicants have failed to adequately evaluate the impacts of the drawdown of the groundwater under CPSES during and as a result of plant operation.

fSS.i t ion

' 'L TU S 1 t .ri ,

L 1 :l '.'

A (U) A (U) A