ML19257A071

Answers to NRC First Set of Interrogatories.Includes Info Re NUREG-0560 & NUREG-0578 Asserting That Operation of B&W NSSS Results in Frequency Rate for Feedwater Transients Greater than Other NSSS Designs.Certificate of Svc Encl

ML19257A071
Person / Time
Site:	Rancho Seco
Issue date:	12/07/1979
From:	Remy M, Vandervelden M AFFILIATION NOT ASSIGNED, FRIENDS OF THE EARTH
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8001020041
Download: ML19257A071 (7)

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RELATED CORRESPONDENCE 3

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION c

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

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SACRAMENTO MUNICIPAL UTILITY

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DOCKET No. 50-312 (SP)

DISTRICT

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Rancho Seco Nuclear Generating Station )

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ANSWERS OF PETITIONERS, FRIENDS OF THE EARTH, TO FIRST SET OF STAFF INTERROGATORIES Petitioners, Friends of the Earth, offer the following responses to the First Set of NRC Staff Interrogatories.

INTERROGATORY NO. 1 Pending completion of discovery, for each of the contentions, Friends of the Earth [ hereinafter, F0E] is unable, at this time, to identify individuals as witnesses, nor is F0E able, pending completion of discovery, to provide a. reasonable description of the substance of the testimony or d o c um.e n t s which may be relied upon by those witnesses.

INTERROGATORY NO. 2 Numerous NRC Staff docunents, memoranda and correspondence including NRC Status Report on Feedwater Transients (April 25, 1979), NUREG-0560, and dUREG-0578, in d i ca t e ', in the clearest possible terms, that the configuration and operation of the 1665 096 8001020

PAGE 2 Babcock and Wilcox NSSS and auxillary systems, results in a frequency rate for feedwater transients greater than for other NSSS designs.

In spite of this well-documented occurance in Babcock

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and Wilcox NSSS, numerical criteria for AFW reliability do not exist and estimates of the reliability actually achieved are also not available (NRR Status Report, April 25).

In addition, to date, NRC has failed to identify, in quantitative terms, an assessment of Babcock and Wilcox system 2-designs, including ICS, aimed at identifying obvious accident sequences leading to core damage having a high frequency as compared to the Reactor Safety Study.

To date, no study or findings exist to determine the risk implications of the sensi-tivity of the Babcock and Wilcox design and on the potential inter-actions arising from other systems, including,but not limited to,

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ICS.

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In an October 25, memo fron NRC (Denton) to TVA (H.G. Parris),

enclosure 1, Primary System Perturbations Induced by OTSG, suggests that it is the Staff's judgment that the Babcock and Wilcox plants i

are currently experiencing an undesirable frequency rate for feedvater transients.

This is pa r ticula rly the case in light of the short term actions required by'the Commission with regard to Babcock and Wilcox facilities in its May orders.

FOE contends that absent numerical criteria for Babcock and Wilcox NSSS reliability or the frequency rate for ATW transient events, and absent explicit criteria for the acceptability, from

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a safety stand point, of that criteria and those frequency rates, no reasonable assurances exist that Ran cho Seco can be operated 4

safely.

This is true, particularly in light of the modifications f.o required by the May 7 order, in that those modifications have

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h. i resulted in an increased potential for more reactor trips and ja j...

feedwater transients.

We assume a relationship between NSSS reliability and safety, and will submit amended answers to these interrogatories when we can identify the individuals and sources supporting this assumption.

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INTERROGATORY NO. 3 m'

F0E objects to this interrogatory on the basis that it is not the obligation of 1ntervenors to provide criteria (or a m-schedule of completion of modifications, nor the schedule

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itself.

This contention stems from a concern that, prior to the rosumption of operation of Rancho Seco on July 5,

1979,

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many short term actions necessary to " provide substantial additional protection which is required for the public health' p~:

and safety, "were identified in NUREG-0578 with a schedule of implementation.

There is no apparent basis for that schedule; nor does there appear to be a complete identification, 4;[.1 i

in any NRC document of further long-term modifications,

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a schedule for such modifications, or the basis for that schedule.

FOE contends that if the NRC finds both short and long-term modifications which " provide substantial additional protection 1665 098 9

PAGE 4 which is required for the public health and safety," then it is the obligation of the NRC, not the public, to define the criteria and justification for the distinction between the two.

Thus far, the basis for NRC drawing a distinction between short and long-term actions appears to be at least arbitrary and capricious, and at worst an unconscion able capitulation to the convenience of SMUD.

DOCUMENTS:

May 7 Confirmatory Order F0E Request for Hearing, May 15 NUREG-0578 INTERROGATORY NO. 4 ITEM A as used in this contention, the term " Facility Management Competence," refers is two distinct definitions.

The first definition pertains to the competent management of the Rancho Seco Facility.

The second pertains to the competency of the management personnel responsible for the safe operation of the facility.

F0E cannot answer this interrogatory until completion of discovery process, including discovery against Licensee (SMUD).

INTERROGATORY NO 5 F0E cannot answer this interrogatory until the completion of the Discovery process.

In addition, F0E contends that absent a clear enunciation by the NRC of standards, criteria and procedures to determine operator competence, the intervenors are under no obligations to propose such standards, criteria, or procedures.

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PAGE 5 I declare under penalty of perjury that the foregoing is true and correct.

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MICHAEL H.

REMY A'torney og Petitioners S

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.l5 AY-l UNITED STATES OF AMERICA g\\W l

NUCLEAR REGULATORY COMMISSION l

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BEFORE THE ATOMIC SAFETY'AND LICENSING BOARD d'

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In the Matter of:

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DOCKET NO.

50-312 (5P)

SACRAMENTO MUNICIPAL UTILITY r

DISTRICT

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I Rancho Seco Nuclear Generating Station

)

i:

4 PROOF OF SERVICE I, CONNIE S; GILLETTE, declare that on December 7, 1979, I

I deposited copies of the attached

" ANSWERS OF PETITIONERS,

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FRIENDS OF THE EARTH, TO FIRST SET OF STAFF INTERROGATORIES" in the United States mail at Sacramento, California, with first class postage thereon fully prepaid and addressed'to the following:

ELIZAB2TH L.

BOWERS, ESQ.

MR. MARK VANDERVELDEN ATOMIC SAFETY & LICENSING BOARD MS. JOAN REISS U.S.

Nuclear Regulatory Commission MR. ROBERT CHRISTOPHERSON Washington, D.C.

20555 FRIENDS OF THE EARTH California Legislative Office DR. RICHARD F.

COLE 717 K Street, Suite 208 ATOMIC SAFETY & LICENSING BOARD Sa c ramen to, CA 95814 U.S.

Nuclear Regulatory Commission Washington, D.C.

20555 DOCKETING & SERVICE STATION OFFICE OF THE SECRETARY MR. FREDERICK J.

SHON U.S.

Nuclear Regulatory Comm.

ATOMIC SAFETY AND LICENSING BOARD Washington, D.C.

20555 U.S.

Nuclear Regulatory Commission Washington, D.C.

20555 MR. LAWRENCE BRENNER n

COUNSEL FOR NRC STAFF ll DAVID S.

KAPLAN, ESQ.

U.S.

Nuclear Regulatory Comm.

SECRETARY AND GENERAL COUNSEL Office of the Executive Legal Dir d P O Box 15830 Washington, D.C.

20555 Sacramento, CA~

95813 Q

RICHARD D.

CASTRO TIMOTHY V.

A.

DILLON, ESQ.

2231 "K"

Street Suite 380 Sacramento, CA 95816 it 1850 K Street, N.W.

Washington, D.C.

20006 STEPHEN LEWIS OFFICE OF THE EXECUTIVE GARY HURSH, ESQ.

LEGAL DIRECTOR 520 Capitol Mall, Suite 700 U.S.

Nuclear Regulatory Comm.

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Sacramento, CA 95814 Washington, D.C.

20555 THOMAS A.

BAXTER 1800 "M" Street N.W.

Washington, D.C.

20036

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t JAMES S.

REED, ESQ.

EXECUTIVE DIRECTOR FOR OPERATIONS MICHAEL H.

REMY, ESQ.

U.S.

NUCLEAR REGULATORY COMM.

REED, SAMUEL & REMY Washington, D.C.

20555 717 K Street, Suite 405 Sacramento, CA 95814 CHRISTOPHER ELLISON, ESQ.

CALIFORNIA ENERGY COMMISSION ATOMIC SAFETY & LICENSING BOARD 1111 Howe Avenue U.S.

Nuclear Regulatory Commission Sacramento, CA 95825 Washington, D.C.

20555 MR. LARRY LANPHER, ESQ.

ATOMIC SAFETY & LICENSING BOARD HILL, CHRISTOPHER, & PHILLIPS APPEAL PANEL Attorneys at Law U.S.

Nuclear Regulatory Commission 1900 M Street, N.W.

Washington, D.C.

20555 Washington, D.C.

20036 I am, and was at the time of the service of the attached document over the age of 18 years and not a party to the proceeding involved.

I declare under penalty of perjury that the foregoing is true and correct.

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d CONNIE S.

GILLETTE 1665 102