ML19254F652
| ML19254F652 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 10/24/1979 |
| From: | Brown H, Ellison C CALIFORNIA, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7911160188 | |
| Download: ML19254F652 (3) | |
Text
NRC PUBLIC DOCUMEE M
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5 %.l In the Matter of:
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SACRAMENTO MUNICIPAL UTILITIES DISTRICT
) Docket No. 50-312
)
(Rancho Seco Nuclear Generating
)
S tation)
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RESTATEMENT OF ISSUES OF CONCERN AND REQUEST FOR CLARIFICATION OF RULING In accordance with the Board's Order Ruling on Scope and Contentions
(" Order"), the California Energy Commission
(" CEC") hereby resubmits certain revised issues which it respectfully requests be considered in this proceeding.
The CEC has elected not to resubmit some of the issues which the Board in its order permitted to be resubmitted.
We withdraw these issues principally because the Commission has recently ordered that the additional safety measures recommended by NWREG-0578 be implemented at the Rancho Seco facility.
Although this recent action of the Commission suggests its May 7 order may not have included all safety measures that were reasonable and necessary to ensure the safe operation of Rancho Seco, we believe it is no longer necessary for the Board to consider certain of those issues in this hearing.
Accordingly, we ask the Board to reconsider only the following revised issues in addition to those it accepted in its previous 1347 359 order:
7911160 / i
CEC Issue No. 1-1 "Despite the modifications and actions of Subparagraphs (a) through (e) of Section IV of the Commission's Order, will reliance upon the High Pressure Injection System to mitigate pressure and volume control sensitivities in the Rancho Seco primary system result in increased challenges to safety systems beyond the original design and licensing basis of the facility?
CEC Issue No. 1-12 The Board rejected this issue as an observation of fact rather than an issue.
We believe that this issue is more than a factual observation, and therefore we respectfully ask the Board to reconsider it as reworded below:
"Despite or because of the modifications and actions of Subparagraphs (a) through (e) of Section IV of the Commission's Order of May 7, will Rancho Seco experience an increase in reactor trips resulting from feedwater transients that will increase challenges to safety systems beyond the original design and licensing basis of the facility?"
The California Energy Commission also respectfully requests that the Board clarify its ruling on the scope of this hearing with regard to the loss of off-site power.
In describing the scope of this hearing, the Board construed the phrase "various transient events" (as it is used at page four of the Commission's May 7 Order) to include only loss of main feedwater and/or trip of the turbine.
(Order, p.
4.)
The Board distinguished transient events aside from feedwater transients, and used the loss of off-site power as an example of a transient beyond the scope of this hearing.
(Ibid.)
We agree with the Board's exclusion of transient events unrelated to feedwater transients, and we do not seek to adjudicate 1347 360
_2_
O these matters.
However, we understand the Board's ruling to allow consideration 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.
We urge the Board to clarify that while loss of off-site power per se is outside the scope of these hearings, 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.
Dated:
October 24, 1979.
Respectfully submitted, f
CALIFORNIA ENERGY COfCIISSION CHRISTOPkER ELLISON
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fiERBERT H.
BROICI
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Attorneys for the California Energy Commission 1347 361.