ML19254B068

Revised Contentions of Intervenor Association of Community Organizations for Reform Now.Submits Safety Contentions 1-33 & Environ Contentions 1-7

ML19254B068
Person / Time
Site:	Comanche Peak
Issue date:	08/21/1979
From:	ASSOCIATION OF COMMUNITY ORGANIZATIONS FOR REFORM
To:
Shared Package
ML19254B062	List: ML19254B063 ML19254B066 ML19254B068
References
NUDOCS 7909240031
Download: ML19254B068 (11)

Text

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SA E_T. _Y___C.O. N T.E._N_T._I O N S_

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Original is set forth below:

The CPSES* design failr, to adequntely account for the effect of asy; actric loading resul ting f rota a pipe break in the area between the reactor veasel and the shield wall.

.P. o s i t l on E

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

A (W) A (U) A

.Typ Original is set forth below:

Kh'C Staf f review 15, inadequate to identify and correct t. odes of int eraction between reactor systens in the OpSICS design which can adversely affect the redundance or independence of sa f e t:. systens.

Poaltfon 1

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A (W) N ~A Th.re e.

Neither the Applicants nor the Staff has a reliable nethod for evaluating or ensuring that C l a r <, IE safety-relat ed equi;n.: ut is designed to accorrodate the ef fects of and to be compat ible wit h the conditions associated with the

• "CPSES" has been substituted for " Comanche Peah" in all of the contentions.

A0 Key:

A Agreeuent as to wording and substance A ('..') - Agree. nt as to wordinn only N " No agr ecuent as to wording or substance '

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2, rnost severe pontulated accident, thun, General Design Criterion 4 has not been natinfied.

Position TU S 1 A (U) A ,

A Your Neither the Applicants nor the Staf f has reliable i ethods for evaluating and ensuring that struct ures, systens and components impert ant to safety are designed to withstand the effects ef the safe sh u t d ce..u earthquake without lo' sing the capability to pcrform their safet y functionn; thus, Cencral Design Criterion 2 har not been satisfied. t

p Position .

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(W) (W) A Vive The elect rical cabler, for all redundant safety syste:us have not been designed and located to mininize the probability and ef fect of fires and explosions; thun, General Design criterion 3 has not been satisfied.

PonitIon TU S I A (U) A (W) A fil5 Original is net forth,below:

The D.C. Power Syst em for the CPSES plant f ails to w "t the single failure cr iterion an defined in 10 CFit Part 50 Appen-d ir. A. .

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4 Position TU S 1 N N A Seven One change - cc:ma inserted af ter the word " adequate" on the first line.

The CPSES design docs not provide adequate, reliable instru-raentation to c.onitor var _ bler, a n.1 syster.s affecting the integrity of the reactor core, the pressure boundary or the containment after an accident, in violation of General Design Criterion 13 of Appendix A of 10 CFR Part 50.

Position TU S I A (W) A (W) A 4i

f. i ght_ g Original is set forth below:

The CPSES design does not adequately account far failure of passive cor:ponents in fluid systems important to safety.

Position TU S 1 N N A Nine Original is set forth below:

The CPSES design does not provide adequate equipment outside of the control roon to pr,mptly put the reactor in hot shut-down and so maintain it until attaining, cold shutdown, also l \

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. fron outside the control rocn, as required by Genera] lie s igo Criterion 19 of Appendix A to 10 CFR Part LJ.

Posit ion TV S 1 A (U) A (U) A

.Tal Neither the Applicants nor the Staff has adequately considered the effects of aging and cumulative radiat ion on safety-rel ated equip:..ent which must be seismically and environacutally qualified, t h u t. , General Design Criterion 4 has not been satisfied.

Position TU S 1 A(U) A (U) A

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} cye_n Original it, set forth belou:

The CPSES design fails to address the possibility of a Class 9 Accident.

Pcsition TU ,

S 1 A (U) A (U) A (W) .

.Twelyg Uithdrawn.

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Thirteen Applicants lack the ability to detcet and adequately <;ize fla. s within 1) the reactor vev;e1 and 2) pipes within the cont airu cat .

Position TU S I

. A (U) A (W) A Fourteen One change - a slash has been innerted after the word "prennure" on the third line:

Appl i can t s ' FSAR fails to present a mean~. for dealing with prennure transients produced by co;nponent fa il u re , personnel error, or r,puriour valv. actuation which exceed the pressure /

te:perature 1 I r.ii t s of the reactor ves<:el.

Position TU S 1 A (U) A (U) A Fifieen 96 0##

Withdrevn.

_S i x t e n ,_ Srn en t een , Eiy_h t e en ,_a nd ?' i n e t e en Incorporated in 1;oard': QA/qc cont ent ion.

Ponition TU S 1 N N A

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.Tweilt y The CPf>::S design f ail- to protect againnt corrocica within the ste:u generators which causes cracking of pipen and lea': age of radioact ive water.

Position TU S I A (W) A (W) A The CPSES design in inadequate to prevent a water hanner proble:a which could af f ect a nu::ber of critical safety corponents.

_ Ppsit10y TU S 3 A (U) A (U) A Trientv-Tuo

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.Twp n t y;_7_h_rT e c; Original is set forth beleu:

The CPSFS design does not adequately address the possibility of a steati line break inside con t a limen t , nor does it insure the ability of equipn. int within containnent to nurvive such -

an event so as to assure safe shutdown of the plant.

Positien TU S I A (W) A (W) A i-

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Twentv-Four The CPSE5 design do, . not adequately in:..ure the reliab]c operation cf en-site criergency power.

Position TU S I

, A (W) A (U) A T_ wen ty-J'iv_e The words "due Lo" (on the last line) have beca deleted and the word "and" has been inserted in lieu thereof.

The CPSES design han not adequat ely resolved a generic safety-problen for pressurized water react ors wherein the steam generator and reactor coolant pump support materials are sub-ject to lauellar tearing and low fracture toughnis<.

- Position TV S I A (W) A (U) A

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Twentv-Six The CPSi:S design deer not ad:quately insure t.h a t sa fety-related w. iter supplien vill be available for plant operation in the event of ice build-up at the service water intake st ructure, ,

Posi. tion TU S I A (U) A (U) A

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'I '.:( o t y- S even The CPSES deaign has twt given due con ;f der ation to the need to withstand nn act of rabotage.

Posit ion 1V S I

. N A (W) A Tuentv-Eighti The CPSES design fails to protect against accidents involving the trovettent and handling of he; vy load: in the vicinit y of spent fuel at the f ac ility.

, Position, TV S I

,A (W) A (U) A Twe_n t y--N i n e incorporated in P.vard's QA/QL contention.

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,Th i r ty, 1he CI'S F.S de <:i gn doca no t adequately protect against potential damar,e fro.

t urbine ni? ' iles to synters e ntial to the cooling and safe r. hut down of t he pl. nit .

Posit ion TV S I A (U) A (W) A

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'l h i t t y__On e Applicants have f a 31ed t o co. . ply wi t h 3 0 Ci'it Par t 50, Appendix E, regarding emergency planning, bec.iu:.e there is no provinion for e:.;ert;ency planning for Glen Rose or the Ibilas/Ft. L'or t h I m t rople: .

Position TU S 1 A (W) A A Thirty-Two Neither the App 11cante nor the Staf f hn, ade<piately considered the licalth ef fects of, low-level radiat ion on the population surrounding CPSES.

_Po s i t ion, TU S 1 A (W) Defers A e

• 1eh i r t y '1=h r e e l

Original is set forth below:

The CPSES design doe:, not adequately protect human safety and insure that rad ic iod ine rel e;" . <. are ar. "Jou as reasonably achlevable".

Position 10 S I A (U)

Defers A 4

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- 30 ENVIPO: MENTAL CON 11. a lONS 01g The energy to be generated by CPSES is unneeded, unsalable and unecononically priced in view of the order of the Texas Public Utility Co:.aission in Docket No. 14, and thur a favorable cost-benefit balance cannot be struck.

Position TU S .I .

A (U) A (U) A 1"P.

Applicants have failed to de: astrat e a need for the potter to be generated by CPSES because:

a. The reserve margins presented in the ER reflect adequate margins through 1985 without CPSES.

b. The figures for the Applicants' capabilities, demands and reserves set foith in the ER are inaccurate, incomplete and out of date.

Position (U) (U) A N Ihye_q Uithdrawn.

Four The Applicants have not considered the costs of replacement of major piecer of equipnent and their disposal in their cost-benefit balance.

Position TU S I A (U)_

A (U) A  ; i _. 1

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Five Applicants have not consid .r ed Llw envii ennent al effects of storar,e and ul t ii':it e d isposal of nuclear s acte in the ir cost-bene fit halnnce.

Position TU S I

. A (U) A (U) A Six The Applicant s have f ailed to postulat e the possibilities, the effect on the avitonnent, and t.he cost of "cleanupa" wh ich necessarily follow a nuclear acrident such'that a favorable cost-benefit balance cannot be struck.

E"E! tion TU S I A (U) A (W) A J ('!!

'i Applicants have not considered the costs of safeiy decor :innicni .g the

a.ility after its useful life in the cost-benefit balance.

E0ALLion TU S I

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