ML19260A700
| ML19260A700 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 10/24/1979 |
| From: | Brown H, Ellison C CALIFORNIA, STATE OF |
| To: | |
| Shared Package | |
| ML19260A701 | List: |
| References | |
| NUDOCS 7912030107 | |
| Download: ML19260A700 (3) | |
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BEFORE THE ATOMIC SAFETY AND LICENSING EOAR),
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In the Matter of:
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SACRAMENTO MUNICIPAL UTILITIES DISTRICT
) Docke t No. 50-312
)
(Rancho Seco Nuclear Generating
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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 whicts it respectfully requests be considered in this proceeding.
The CEC has elected not to resubmit scme 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 NWhEG-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 order:
1456 001
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II 1912030
CEC Issue 'o.
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 cressure and volume control sensitivities in the Rancho Seco primary system resuit in increased challenges to safety systems beyond the original design and licensing basis of the f acility?
]
l CEC Issue ';o.
1-12 The Board rejected this issue as an observation of f act rather than an issue.
We believe that this issue is acre than a factual observation, and therefore we respectfully ask the Board to reconsider it as reworded belew:
"Despite or because of the modifications and actions of Subcaraaraohs (a) through (e) c:. Section.7 or. the Cc. mission,s Orc.er o:.
1 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 re tests tha the Board clarify its ruling on the secpe of his hearing with regard to the loss of off-site pc.er.
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 nain feedwater and/or trip of the turbine.
(Order, p.
4.)
The Scard distinguished transient events aside f cm feedwater transients, and used the loss of off-site power as an example cf a transient beyond the scope of this hearing.
(: bid.)
We agrec.. i th the Secrd's exclusion of transient events _nrelated to feedwater transients, and we do not seek to adjudiente 1456 002
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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 Secc system to respond to such a sequence of events.
Because the loss of off-site power can initiate a feedwater transient, we
'elieve that in this limited aspect the - loss of off-site r
power is within the scope of this hearing as defined by the Board's order.
We urge the Board to clarify that whi'le loss of off-site cower cer se is outside the sccce of these hearings, the ability of Rancho Seco to respond to feedwater transients caused and acccmpanied by the loss of off-site power is a proper subject for adjudicatica in this hearing.
Oated:
October 24, 1979.
Respectfully submitted, CALIFORNIA ENERGY COMISSION D-
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CHRISTOPHE.:. ELLISON
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C AiERBERT H.
EROWN Attorneys for the California Energy Commission
. 1456 003