ML19254D312
| ML19254D312 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/31/1979 |
| From: | Kaplan D SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | |
| References | |
| NUDOCS 7910230665 | |
| Download: ML19254D312 (14) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of:
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SACRAMENTO MUNICIPAL UTILITY DISTRICT
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Docket No. 50-312
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Rancho Seco Nuclear Generating Station )
PREHEARING STATEMENT OF SACRAMENTO MUNICIPAL UTILITY DISTRICT We are filing this prehearing conference s.tatement to set forth, for the convenience of the Board, our position with respect to each of the contentions set forth by the petitioners.
Contentions of Friends of the Earth, The Environmental Council of Sacramento, and Original SMUD Ratepayer's Association Contention 1(a) :
The record before the Board fails to disclose evaluation or comment on the acceptability of 27 feedwater transients over the past year in nine Babcock and Wilcox (B&W) reac tor s, a frequency which is 50 percent greatre than the corresponding rate for other pressurized reactors.
SMUD's position on Contention 1(a) :
This is not a separate contention or a separate issue.
It is a reference to certain data which the Board may, if it wishes, consider as evidence in determining whether the facility will respond safely to feedwater transients.
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Contention 1(b):
The record before the Board fails to disclose adequate evaluation, consideration and adoption of safety measures identified in NUREG-0560 to further increase the safety margins in B&W plants and their specific applicability to the Rancho Seco facility.
SMUD's position on Contention 1(b) :
This is not a separate contention or a separate issue.
It is a reference to a document, NUREG 0560.
The Board may, if it wishes, consider NUREG 0560 in determining whether the facility will respond safely to feedwater transients.
Contention 1(c):
The record before the Board fails to disclose a recognition that serious accidents will occur at nuclear facilities no matter how diligent regulatory authorities and power plant operators are.
SMUD's position on Contention 1(c) :
This is simply a statement that serious accidents will inevitably occur at nuclear facilities.
We do not believe that it meets the requirement in the Board's July 3 Order that the basis for each contention be set forth with reasonable specificity.
Contention 1(d) :
The record before the Board fails to disclose evidence of evaluation, consideration and adoption of studies, reports and analysis received by the Commission between the shutdown order of May 7, 1979 and the reopening of the Rancho Seco facility.
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SMUD's position on Contention 1(d) :
We do not believe this constitutes a proper contention in its present form.
If petitioners believe that any of the studies, re por ts, or analyses to which they refer indicate that the facility cannot be operated with reasonable assurance that it will respond safely to feedwater transients and similar problems, we believe that petitioners should identify the particular document or documents to which they refer and set forth with reasonable specificity the material in such document upon which they base their contention.
Content' 1n 1(e) :
The record before the Board fails to disclose evidence that emergency response planning around the Rancho Seco facility, which in its present state has clearly been shown to be insuf ficient, has been or will be sufficiently upgraded or modified.
SMUD's position on Contention 1(e):
We believe this contention is outside the scoge of the broad issues set forth in the Commission's June 21 Order.
Those issues refer to the ability of the facility to respond safely to feedwater transients.
Emergency response planning is an entirely separate matter.
Contention 1(f,) :
The record before the Board fails to disclose express finding by the Commission that the Rancho Seco facility
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7,50 is safe to operate.
SMUD's position on Contention 1(f) :
We do not believe this is either a contention or an issue.
We assume that at the
conclusion of this hearing the Board will expressly find whether or not the facility is safe to operate.
Contention u(g):
The record before the Board files to disclose express finding by the Commission that the terms and con-ditions of the shutdown order were sufficient to insure safe operation of the Rancho Seco facility.
SMUD's position on Contention 1(g) :
Our position is essentially the same as our position on 1(f).
Contention 1(h):
The record before the Board fails t'o disclose safety risk evaluation of long-term modifications and reason-able time table for implementation by SMUD.
SMUD 's position on Contention 1(h) : We do not believe this adds anything to issues 2 and 3 as set forth in the Commission's June 21 Order.
We assume the Board will determine, in the Order which it issues at the conclusion of the hearing, whether the long-term modifications specified in the shutdown order are sufficient and whether the time table under which they will be implemented is reasonable.
Contention 1(i):
The record before the Board fails to disclose evidence of safety risk assessment of the short-term modi-fications required of applicant SMUD by the shutdown order.
bf f) l SMUD's position on Contention 1(i) :
We do not believe this adds anything to issue 1 as set forth in the Commission!s June 21 Order.
We assume the Board will determine, in the Order which it issues at the conclusion of the hearing, whether
the short-term modifications required by the shutdown order are suf ficient.
Contention 1(j ) :
The record before the Board fails to disclose evidence of reliability assessment of the short-term modi-fications required of SMUD by the shutdown order.
SMUD's position on Contention 1( j) :
Our position is the same as our position on 1(i).
Contention 1(k):
The record before the Board fails to disclose analysis of whether the management competence and control are adequate at the Rancho Seco facil.i'y.
SMUD's position on Contention 1(k) :
The discussion at the public meeting of the Commission on July 11 shows that the Commission did not intend to preclude the Board from considering this issue.
However, the discussion also shows that there is nothing presently before the Commission to indicate that management competence and control is a problem at Rancho Seco.
Under the circumstances, we suggest that the Board ask the petitioners (a) to set forth their contentions with respect to this issue with greater specificity and (b) to make at least a prima facie showing, perhaps by affidavit, that there is a problem before deciding whether to consider this as an.ssue.
1189 552 Contention 2:
The Rancho Seco Nuclear facility should be ' ordered to suspend operations until the NRC has developed adequate and systematic procedures for implementing needed remedial actions or modifications identified in licensee event or
or accident reports for operating nuclear facilities.
SMUD's position on Contention 2:
We do not believe this is a proper contention or a proper issue.
It is not set forth with reasonable specificity, as is required by the Board's July 3 Order.
Contention 3:
The Three Mile Island accident has bror it to light sufficient evidence of design failure, equipment malfunction, regulatory problems and human error to require that the NRC initiate relice; sing of the Rancho Seco Nuclear facility to assure incorporation and implementatio'n of all necessary health and safety measures and provide adequate consideration of the environmental and economic implications of needed short-term and long-term modifications.
Operation of the Rancho Seco facility should be suspended'until the relicensing process called for has been completed to provide reasonable assurance of public health and safety.
SMUD's position on Contention 3:
Our position on this contention is the same as on the preceding contention.
Contentions of Directors Hursh and Castro Contention LA: Babcock and Wilcox reactors are too susceptible to feedwater transients which may result in an accident.
1189 353 SMUD's position on Contention lA: We do not believe this adds anything to the three broad issues set forth in the Commission's June 21 Order.
Moreover, it is not set forth with reasonable specificity, as contemplated by the Board's July 3 Order.
Contention 1B:
Rancho Seco does not have an adequate evacuation plan.
SMUD 's position on Contention 1B: We believe this is outside the scope of the three broad issues set forth in the Commission's June 21 Order.
Those issues relate to the ability of the facility to respond safely to feedwater transients.
Evacuation planning is an entirely different subject.
Contentica 1C: Rancho Seco has inadequate radiation monitoring devices.
SMUD's position on Contention IC: Our position is esse'ntially the same as our position on Contention 1B.
Contention 1D: Rancho Seco has inadequate notification proced-ures for informing local authorities in case of a potential accident.
SMUD's position on Contention 1D: Our position is essentially the same as our position on Contentions 1B and IC.
Contention IE Rancho Seco does not have a recombiner.
SMUD's position on Contention lE: We believe this is outside the scope of the three broad issues set forth in the Com-mission's June 21 Order.
Those three issues relate to the ability of the facility to respond safely to feedwa ter transients.
The function of a recombiner is to enable the plant operator to remove hydrogen from the containment building.
A recombiner does not help the facility respond safely to feedwater transien ts.
A recombiner would be used only if a facility failed to respond safely to feedwater 1189 554 trancients.
Contention 1F:
The present elevation of the steam generator is a design defect.
SMUD's position on Contention 1F:
This contention raises an issue that is generic to Babcock & Wilcox reactors.
We believe it is outside the scope of the Commission's June 21 Order since problems associatcd with the elevation of the steam generator could only arise if the facility failed to respond safely to feedwater transients.
However, if the Board should take a contrary view, we are prepared to show that natural circulation can be maintained in the primary system with the steam generator in its present elevation.
Contention 1G:
Pressurizer, steam generator, vessel and plumb-ing arrangements are improperly designed with respect to bubble formation in hydraulic high points.
SMUD's position on Contention 1G:
The issue raised by this contention is generic to all pressurized water reactors.
We believe it is outside of the scope of the broad issues set forth in the Commission's June 21 Order since bubble formation is a matter separate from feedwater transients.
However, if the Board should rule to the contrary, we are prepared to show that the plant's operators are prepared to deal with the possibility of bubble formation.
Contention III:
Babcock and Wilcox's once through steam generator level measurement is a design deficiency.
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SMUD's position on Contention lH:
We do not believe this adds anything to the three broad issues set forth in the Com-mission's June 21 Order.
The contention is that the once-through steam generator makes Babcock & Wilcox plants mora sensitive to feedwater transients.
The Board will determine in this proceeding whether the facility can respond safely to feedwater transients.
Contention II:
Feedwater system and auxiliary feedwater systems are too susceptible to common-mode failures.
SMUD's position on Contention lI: We believe this contention should be set forth with more specificity.
However, we are prepared to show that the facility's feedwater systems and auxiliary systems can be separately controi?.ed and operated.
Contention lJ: Babcock and Wilcox' pressurizer tank and quench sizes are too small.
SMUD's position on Contention lJ: We are prepared to show that the facility can be operated safely with its present pressur-izing and quench tanks.
Contention 1K: Babcock and Wilcox's primary loop arrangement is defectively designed with respect to steam bindings, steam bubble formation, and pump cavitation.
SMUD's position on Contention 1K: We believe this contention is virtually identical to contention 1G.
Contention lL: Operator data on pressurizer level / vessel level are unreliable and can be misleading during an accident.
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SMUD's position on Contention lL: The issue raised by this contention is generic to all Babcock and Wilcox reactors.
We ar2 prepared to show that the facility can be operated safely with its present ins trumentation which gives re-liable data on temperature and pressure in the primary loop.
Contention 1M: Inability to isolate steam generator B under some circumstances.
SMUD's position on Contention 1M: We to not understand this contention.
Both of the steam generators can be isolated.
Contention 1N: Inadequate reliability of off-site power.
SMUD's position on Contention 1N: We believe this contention is outside the scope of the issues set forth in the Commission's June 21 Order.
However, we are prepared to show that the facility's off-site power supply is reliable.
Contention 10: Problems with relief valves sticking open.
SMUD's position on Contention 10: It would be helpful if the petitioners would identify the particular relief valves to which they refer.
However, we are prepared to show that the relief valves in the facility have functioned properly.
Contention 1P: Insufficient instrumentation and data for post-accident monitoring.
ONUD's position on Contention lP: We believe this contention is outside the scope of the issues set forth in the Commission's 1189 557
June 21 Order.
Those issues relate to the ability of the facility to respond safely to feedwater transients.
Possible accident monitoring is an entirely separate matter.
Contention 10: Inadequate level instruments.
SMUD's position on Contention lQ: We believe this contention is identical to Contention IL.
Contention 1R: Insufficient analysis between what functions should be hard equipment responsibilities and what can be a sof t procedural function.
SMUD's position on Contention 1R: We believe this, contention should be set forth with more ~ specificity.
In particular, we would like to know what " functions" petitioners are referring to.
Contention IS:
Inadequate control room design.
SMUD's position on Contention IS: We believe this contention should be set forth with more specificity.
We believe that petitioners should state the respects in which they contend the control room design is inadequate.
Contention lT:
Question of competence of plant personnel and management to operate Rancho Seco.
SMUD's position on Contention 1T:
The discussion at the public meeting of the Commission on July 11 shows that the Commission did not intend to preclude the Board from considering this issue.
However, the discussion also shows that there is 1189
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nothing pr sently before the Commission to indicate ; hat management competence and control is a problem at Rancho Seco.
Under the circumstances, we suggest that the Board ask the petitioners (a) to set forth their contentions with respect to this contention with greater specificity and (b) to make at least a prima facie showing, perhaps by af fidavit, that there is a problem before deciding whether to consider this as an issue.
Contention 2A: Sufficient modifications 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.
In support of this contention and incorporated herein by this reference I refer to communications to NRC from the ACRS regardi".g TMI since March 28, 1979 which state specific recommendations which have not been adequately addressed.
SMUD's position on Contention 2A:
We believe this contention should be set forth with more specificity.
We believe petitioners should identify the particular communications to which they refer and identify the recommendations set forth in those communications which they believe have not been adequately addressed.
Contention 2B:
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 would be adequate in a second TMI-2 type or similar accident.
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SMUD's position on Contention 2B:
We believe this contention is outside the scope of the three broad issues set forth in the Commission's June 21 Order.
Those issues relate to the ability of the facility to respond safely to feed-water transients.
The ability of the Nuclear Regulatory Commission to act quickly and decisively during an acci-dent is a separa te matter.
Contention 2C:
Adequacy of training requirements and job descriptions of plant operators and associated personnel.
SMUD's position on Contention 2C:
We believe this is a proper issue to the extent that it relates to the adequacy of the training the plant operators and associated personnel have been given to respond to problems related to feedwater transients.
However, we are prepared to show that our plant operators and associated personne] have received proper training in all other pertinent areas as well as in this area.
Contention 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 in a safe manner.
SMUD 's position on Contention 3 :
We do not believe this con-tention adds anything to the first of the three issues set forth in the Commission's June 21 Order.
In determining that issue, the Board will necessarily decide whether.the short term modifications provided for in the May 7 Order i185360
art sufficient to provide reasonable assurance that the facility will respond safely to feedwater transicnts pending completion of the long term modifications set forth in the same Order.
Dated July 21, 1979 Respectfully submitted, 3
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D4pid'S. Kaplan General Counsel SACRAMENTO MUN IPAL UTILITY DISTRICT P O Box 15830 Sacramento CA 95813 Telephone (916) 452-3211 1189 361 P