ML19257C357
| ML19257C357 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/17/1980 |
| From: | Ellison C, Lanpher L CALIFORNIA, STATE OF |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML19257C358 | List: |
| References | |
| NUDOCS 8001280483 | |
| Download: ML19257C357 (13) | |
Text
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UNITED STATES OF AMERICA
'IUCLEAR REGULATORY C0'iMISSION 3SfJllS_TiSEQMIC_11FETY 41LLICE11111_3111Q In the Matter of*
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Docket No. 50-312 (SP)
SAC 9AMENTO MUNICIPAL UIILITY
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DISTRICT
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(Rancho Seco luclear Generating
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Station)
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CALIFOR!!IA ENElGY COMMISSION SUPPLEMENTS TO
' ESP 0flSES TO FI9ST SET OF NRC STAFF INTERROGATORIES AND RESPONSES TO T9E NRC ST4FF'S SECO:!D SET OF INTE990GATORIES The California Energy Commission, pursuant to 10 C.F.R.
SS 2.740(b) and 2.740(e), hereby supolements its responses to the NRC Staff's First Set of Interrogatories (Interrogatories 1-9 below) and orovides responses to the 11RC Staff's Second Set of Interrogatories (Interrogatories 10-19 below).
Interrotatory 1:
With regard to each of CEC's admitted issues, orovide the following information.
A.
Identify the individual (s), if any, whom CEC intends to cresent as witnesses in this proceeding on the subject matter of each of its issues.
The identification should include the individual's name, affiliation, acd a summary of the educational and professional background of that individual.
B.
Provide a reasonable description of the substance of the testimony of any witness (es) that CEC intends to have testify with regard to each of its issues, including an identification of all documents that will be relied upon in that testimony 1819 146 G
"*0483
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C.
Following the substantive response to each of the subsequent interrogatories cosed by the Staff, identify all documents and studies relied upon by CEC in providing the answers to that interrogatory.
The identification should be specific to the portion of the document or study relied uoon.
Studies shall include observations, calculations, literature and other tyoes of work, whether recorded in writing or not, which consist of an examination or analysis of a ohenomenon.
D.
Following the substantive response to each of the subsequent interrogatories cosed by the Staff, identify by name and affiliation each individual who has knowledge which served as the basis for the answer to that in t e r ro g a to ry.
Sucolemented Resoons2 Uith resoect to Issues 3-1, 3-2, and 3-3, the Snergy Commission may call Dale G.
9ridenbaugh as a witness.
His qualifications are attached hereto.
The Energy Commission does not now intend to call Mr. Nebb as a witness on these issues.
Mr. Bridenbaugh will testify concerning the adequacy of oost-TMI-2 training of and emergency procedures for Rancho Seco coerators and the importance of licensed reactor operators having an analytical understanding of the coerations they are required to oerform.
Mr. Bridenbaugh may review and comment on the deoositions of Rancho Seco coerators which will deal with these matters.
With respect to Issue 5-1, the Energy Commission may call Mr. Bruce Mann as a witness.
His qualifications are attached hereto.
The Energy Commission does not now intend to call Mr. ?!ix as a witness on this issue.
Mr. Mann will identify the systems which transported radioactivity from P'-
vr r-
the containment building during the accident at TMI, discuss the possibility that similar releases could occur at Rancho Seco, and discuss steps which are being or could be taken to control such releases.
'41th resoect to Issues 1-1 and 1-12, the Energy Commission may call Mr. Gregory Minor as a witness, as well as Mr. Nebb.
Mr. Minor's qualifications are attached hereto.
The testimony of these persons will focus on the carticular design and equipment sensitivities of 3 % 1 reactor systems such that they are more vulnerable to feedwater transients and resulting challenges to safety systems.
The testimony will describe that these particular physical sensitivities are still cresent at 9ancho Seco desoite the actions taken subsequent to TMI-2.
Interro7atories ?
No sucolemental resconse.
Interrotatory 1:
The following questions deal with CEC Issue 5-1.
A.
Describe the " systems" which are referenced in tns-issue.
B.
Provide the reascns for your concern on this issue.
langlemented 3esconse.
The " systems" which have been identified are the waste gas vent header and compressers 10 the waste gas system, the reactor coolant bleed holdup tank relief valve in the let i8i9 I48
2
-4' down system, the fuel handling and auxiliary building sumo tanks, the rad waste system pumos which took suction from the reactor coolant bleed tanks, and the valves and instruments in the reactor coolant makeup and ourification system.
lag NRC Response to CEC's First Set of Interrogatories, No. 9.
Interrosatorv 6.
No sucolemental response.
Interrotatorv 7:
The following questions deal with CEC Issue 5-3a.
A.
Define the term "scecial features" as that term is used in this issue.
Does CEC contend that additional "soecial features" are required at the 9ancho Seco facility.
If so, identify those "scecial features" and the reasons for your claim that such additional features are necessary.
3.
Identify the term " instruments" as that term is used in this issue.
Does CEC contend that additional instruments are necessary at the 9ancho Seco facility?
If so, describe the additional instrumentation required and the reasons to suoport your claim that such instrumentation is necessary.
C.
Provide the reasons for your concern on this issue.
Sucolemented Desconse In addition to the concerns previously addressed, the Energy Commission also intends to address the issue of human factors engineering and, particularly, the question Nhether studies should be undertaken by the Licensee to improve control room design, layout or instrumentation.
There has been considerable study recently, carticularly the recent EP9I Study, "'iuman 0 actors Methods for Nuclear Control Room 1819 149
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Design",the Kemeny Commission Report on " Control Room Design and Performance", and NUREG-0535 at pages A-11 through A-13, which lead almost inescapably to the conclusion that nearly every oower reactor control room could be improved from a human factors engineering point of view.
The Energy Commission is reviewing documents and will inspect the 9ancho Seco facility to determine whether to cresent testimony asserting that changes in Rancho Seco facility should be made or studied.
Interrotatory 3.
No supplemented response.
Interrocatorv 0:
The following questions deal with CEC Issue 1-1.
A.
Define the term " pressure and volume control sensitivities" as that term is used in this issue.
Identify the source of the sensitivities, their nature and reasons for occurrence.
B.
Identify the " safe ty sys tems" referenced in this issue.
C.
Provide the reasons for your concern on this issue.
Succlemented Resoonse.
The " pressure and volume control sensitivites" as intended by the CEC have the same meaning and description (including their source and reasons) as an attachment to the 19C '4emorandum of November 16, 1979, from Darrell G.
Eisenhut to Steve Scott, " Rancho Seco Soard Notification 10 C.F.9. 50.54 9equest Regarding Design Adequacy of Sabcock and Wilcox N3SS."
1819 150
Interrotatory 12.
A.
Does CEC contend that the short-term modifications and actions required by suboaragraphs (3) through (e) at oage 4 of the Commission's Order of May 7, 1979, are inadequate?
If so, soecifically describe the inadequacies.
3.
If the answer to Interrogatory A above identifies any inadequacies, provide the reasons succorting CEC's claim of inadequacies.
Resconsi The California Energy Commission believes that subsequent events establish that the short-term modifications were inadequate.
At the time of the 'iay 7 Order, NRC procedures required at least one reactor coolant cump (RCP) to remain operating in the event of high pressure injection (HPI) initiation.
Subsequently, the NRC significantly changed these procedures to require that all RCP's be tripoed if 9PI were initiated.
This change was made due to concern that for certain small break LOCA's, continued RCP operation can prolong or aggravate the uncovering of the reactor core.
To be
" adequate", the May 7 Order should have required that the 79-OSC orocedures (including approoriate operator training) be imolemented orior to restart of 3 i W facilities.
Other similar " inadequacies" include, for example, the many short and long-term recommendations of the T'tI Lessons Learned Task Force, many of which the NRC has ordered to be implemented.
The Task Force described the short-term recommendations as being " judged to orovide substantial, additional orotection 9hich is required for the public health and safety".
- c. 6.
Clearly, it vould 1819 151
. have been oreferable for these short-term recommendations to have been isolemented orior to restart of 3ancho Seco since the goal of the M9C always has been to achieve the maximum safety possible.
If these short-term recommendations had been known as of May 7, 1979, we are confident that some of them would have been incoroorated as part of that Order.
Interrogatory 11.
A.
Does CEC contend that the long-term modifications and actions required by the Commission's Order of May 7, 1979 in this proceeding (c. 5) are inadequate?
If so, soecifically describe the inadequacies.
3.
If the answer to Interrogatory A above identifies any inadequacies, orovide the reasons supporting CEC's claim of inadequacies.
Resoonse.
As in resoonse to Interrogatory 10, the failure of the May 7 Order to require the trioping of RCP's on HPI -
initiation renders the whole Order inadequate.
The long-term modifications are also inadequate for not adopting the modifications subsequently identified in MURE3-0578.
- Thus, uhile ve do not question the good faith of the NRC in issuing that Order, subsequent events reveal that other actions, in addition to those set forth in that Order, also should be imolemented.
After comoletion of discovery and indeoendent assessments, other inadequacies may also be indicated.
1819 152
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Interrogatoies 12-14 Lotarroistorv 12.
A.
Does CEC contend that Rancho Seco oersonnel inadequately understand the mechanics of the facility, basic reactor ohysics, or other fundamental asoects of the operation of the 9ancho Seco Cacility?
If so, specifically describe the inadequacies.
B.
If the answer to Interrogatory A above identifies any inadequacies, orovide the reasons suoporting CEC's claim of inadequacies.
Interrogatory ll.
4.
Does CEC contend that 9ancho Seco oersonnel are not adequately aoorised of new information pertinent to the facility's safe ooeration and/or ability to respond to transients, particularly information on ooerating experience of other reactors?
If so, soecifically describe the inadequacies.
B.
If the answer to Interrogatory A above identifies any inadequacies, orovide the reasons supporting CEC's claim of inadequacies.
Interro?atory 14 A.
Does CEC contend that emergency instructions are inadequately understood by or not adequately available to plant oersonnel in a manner that allows quick and effective imolementation during an emergency?
If so, specifically describe the inadequacies.
B.
If the answer to Interrogatory A above identifies any inadequacies, provide the reasons suppo.' ting CEC's claim of inadequacies.
9esconse.
The Energy Commission does not at this time contend that there are any cersonnel or crocedural inadequacies as suggested in these interrogatories.
'Je actively are 1819 153
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pursuing discovery on these issues and will not be in a position to respond until we have reviewed final NRC Staff and SMUD responses to our outstanding discovery requests and until we have deposed SMUD operators.
'f e d o n o t e, however, our concern that the coerator training actions instituted since TMI do act correct the physical sensitivities of 3 % *i reactor systems.
Accordingly, reactor ooerators are being expected to respond to unanticipated events that may be excerbated by these sensit! lties.
Laigrrogatory 15.
A.
Does CEC contend that sy;tems identified as contributing to releases of radioactivity during the TMI accident, which are outside of containment, should be changed to vent into the containment building?
If so, soecifically identify those systems and the reasons for your oosition.
Resoonse.
lag sucolemented resoonse to Interrogatory 5.
The Energy Commission contends that studies should be undertaken to determine whether it is cost-ef fective and advisable for any such venting changes (or other means to control offsite releases) to be adopted.
The reasons for our oosition are set forth in our December 5, 1979 response to NRC Interrogatory 5.
Additional NRC requirements have yet to determine the acceptability of utility programs instituted as cart of NUREG-0573.
1819 154
- Interroestory 16.
A.
Does CEC contend that the containment building should be modified to provide over-oressurization orotection with a controlled filtered venting system to mitigate unavoidable releases of radionuclides.
B.
If the answer to Interrogatory A above is in the affirmative, orovide your reasons.
Resoonse.
For the reasons set forth in our December 5, 1979 resconse to NRC Interrogatory 6, we believe the Licensee should be directed to undertake studies regarding the benefits, costs and feasibility of installing such over-oressurization orotect'on.
More carticularly, the CEC believes that reasonable measures to mitigate the consequences of containment accidents should be included as cart of the defense-in-depth concept for nuclear olant safety.
InterrogatorL_ll.
A.
Does CSC contend that the soecial features and instruments installed at 9ancho Seco are inadequate to aid in diagnosis and control af ter an of f-normal condition engendered by a loss-of-feedwater transient?
If so, soecifically describe the soecial features and instruments.
B.
If the answer to Interrogatory A above is in the affirmative, orovide your reasons.
9esconse.
122 Sucolemented 9esponse
.o F Interrogatory 7.
Of additional soecific concern to the C'"
is that an coerator be able to. comprehend.quickly olant status and respond to 18i9 155
_11 unanticioated low crobability events.
Additional soecial features and/or lack of critical instrumentation include such things as hydrogen monitoring and control in the crimary system or containment, instrumentation for detection of inadequate cooling, reliable instrumentation for crimary system water level, safety and relief valve position indicators, emergency cower sucoly for cressurizer heater and oower coerated relief valves, automatic initiation of time-critical events, and raoid retrieval of information during an emergency.
I m crocatory 13.
With regard to CEC's Answers, specifically its Resconse to Interrogatory 3, identify and describe all "...
indications that personnel at TMI-2 did not have such information..." and "... indications that oersonnel at other operating reactors may not have such information."
9esconse.
Both the Michaelson and Cresswell nemoranda predicted problems with B
'e 4 OTSG sensitivities before T'iI-2 but no resconsive action was taken and the information was not diseminated to personnel at operating reactors.
We have no further information at this time but hooe to develop further data in review of final discovery resconses and in depositions.
18i9 156
. Interro?atory_ll.
With regard to CEC's Resoonse to Interrogatory 6, identify and describe "Other rassible event scenarios related t'o feedwater transieats [which] could cause overpressurization leading to a breach of containment".
Resoonse.
The event scenarios contemplated in the earlier resconse are those identified in NAS9-17400 or other low-probability events leading to a core-melt accident.
Rancho Seco may also have atypical weldments which could fracture during a severe over-cooling event, which could also contribute to such scenarios.
Resoectfully submitted, CALIFORNIA ENERGY COMMISSI0tl
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C9RIST0@'iER ELLIS0'l 6
08+V L'AWRE' ICE COE LANP9'h Attorneys for the California Energy Commission DATED:
January 17, 1930.
1819 157
U'IITED STATES OF AMERICA MUCLC A9 REGUL ATORY CO'iMISSION 3:20 'l e Ul_1TQ_'11C S ATETY A1D LIC USI'IG 99A92 In the 'iatter of:
S ACR AMEtiTO MU'!ICIP AL UTILITY Docket No. 50-312(SP)
DISTRICT
)
(Rancho Seco Nuclear Generating Station)
)
DECLARATION OR CLI FORD M.
'E 9 8 I, Clif ford
't.
'4e b b, have consulted in and reviewed the attached California Energy Commission Sucolements to Resoonses to cirst Set of NRC Staff Interrogatories and Resoonses to the NRC Staff's Second Set of Interrogatories.
To the best of my '<nowledge, the ansvers set forth therein are true and correct.
^N.)
DATcD:
January 17, 1980 CLIF'c0RD M.
'E B B Sworn to and subscribed before me thisi f day of January, 1980.
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' M h t M % A T
Notary Public My Commission expires.O - O c - V C.
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