ML19260B409
| ML19260B409 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/09/1979 |
| From: | Hoefling R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Castro R, Hursh G CASTRO, R. & HURSH, G. |
| Shared Package | |
| ML19260B410 | List: |
| References | |
| NUDOCS 7912100137 | |
| Download: ML19260B409 (12) | |
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UNITED STATES OF AMERICA e
4 NUCLEAR REGULATORY COMMISSION
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J BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
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
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Station)
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FIRST SET OF NRC STAFF INTERR0GATORIES TO GARY HURSH AND RICHARD CASTR0 Pursuant to 10 CFR Q 2.740b, the following interrogatories are directed to Gary Hursh and Richard Castro (Castro-Hursh).E Each interrogatory not objected to is to be answered separately and fully in writing under oath or affirmation by the individuals having personal knowledge of the answers.
Section 2.740b requires interrogatories to be answered within 14 days of service.
Five days are added to this time under Section 2.710 when service is by mail. Accordingly, responses to these interrogatories, which are served by mail on November 9,1979, are due to be filed on November 28, 1979.
Pursuant to 6 2.740(e), these interrogatories should be supplemented as required by the above-reference rule.
y An "NRC Staff Notice To Produce Directed to Gary Hursh and Richard Castro" is being served contemporaneously with these Staff interrogatories.
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Interrogatory 1 With regard to each of the contentions admitted on behalf of Castro-Hursh,U specifically, Contentions 2, 3, 4, 5, 6, 7, 8, 9, 10, 16, 20, 21, 22, 24, 25, 26, 29, 31, 32, and 34, provide the following information.
A.
Identify the individual (s), if any, whom Castro-Hursh intend to present as witnessas in this proceeding on the subject matter of each of its conten-tions. The identification should include the invidual's name, affiliation, and a summary of the educational and professional background of the individual.
B.
Provide a reasonable description of the substance of the testimony of any witnesses that Castro-Hursh intend to have testify with regard to each of its contentions, including an identification of all documents which will be relied upon in that testimony.
C.
Following the substantive response to each of the subsequent interroga-tories posed by the Staff, identify all documer s and studies relied upon by Castro-Hursh in providing the answers to that interrogatory. The identifica-tion should be specific to the portion of the document or study relied upon.
Studies shall include observations, calculations, literature and other types of work, whether recorded in writing or not, which consist of an examination or analysis of a phenomenon.
y The Staff's interrogatories are propounded with reference to the Castro-Hursh contentions admitted by the Atomic Safety and Licensing Board in its " Order Ruling on Scope and Contentions" of October 5,1979.
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L D.
Following the substantive response to each of the subsequent inter-rogatories posed by the Staff, identify by name and affiliation each indi-vidual who has knowledge which served as the basis for the answer to that interrogatory.
Interrogatory 2 The following questions deal with Castro-Hursh Contention 2.
Provide, in reasonable detail, the reasons for your allegation that the Rancho Seco facility is unsafe due to a steam generator design which operates with a relatively small liquid volume in the secondary side.
Provide a definition of the term "relatively small" as that tann is used in this contention.
Interrogatory 3 The following question deals with Castro-Hursh Contention 3.
In light of the installation at Rancho Seco of a hard-wired control-grade reactor trip that would be actuated on loss of main feedwater and/or turbine trip (see the June 27, 1979 NRC Staff " Evaluation of Licensee's Compliance With the NRC Order dated May 7, 1979, Sacramento Municipal Utility District, Rancho Seco Nuclear Generating Station, Docket :o. 50-312," a copy of which is attached to these interrogatories), provide in reasonable detail the reasons for your allegation that the Rancho Seco facility is unsafe due to a lack of direct initiation of a reactor trip upon the occurrence of aff-nonnal condi-tions in the feedwater system.
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Interrogatory 4 The following question deals with Castro-Hursh Contention 4.
In light of the implementation of procedures to provide for control of steam generator level by use of safety grade AFW bypass valves in the event that ICS steam generator level control fails (see Staff Evaluation of June 27,1979),
provide, in reasonable detail, the reasons for your allegation that the Rancho Seco facility is unsafe due to a reliance upon an integrated control system to automatically regulate feedwater flow.
Interrogatory 5 The following question deals with Castro-Hursh Contention 5.
In light of changes to decrease the reactor high pressure trip point and increase the pressurizer pilot-operated relief valve setting and implementation of oper-ating instructions to define operator action for potential small breaks (see Staff Evaluation of June 27,1979), provide, in reasonable detail, the reasons for your allegation that the Rancho Seco facility is unsafe due to an actuation before reactor trip of a pilot operated relief valve on the primary system pressurizer which, if the valve stays open, can aggravate an accident.
Interrogatory 6 The following question deals with Castro-Hursh Contention 6.
Provide the reasons for your allegation that the driving head for natural circulation flow at the Rancho Seco facility is inadequate. What driving head do you consider adequate. Provide your reasons.
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I Interrogatory 7 The following ouestions deal with Castro-Hursh Contention 7.
In light of the actions taken at Rancho Seco to upgrade the timeliness and reliability of delivery from the Auxiliary Feedwater System by carrying out actions as identified in Enclosure 1 of the licensee's letter of April 27, 1979 (a copy is attached to these interrogatories; see also the Staff Evaluation of June 27,1979), provide, in reasonable detail, the reasons for your allega-tion that the Rancho Seco facility is unsafe due to the insufficient time-liness and reliability of its emergency feedwater system.
Interrogatory 8 The following question deals with Castro-Hursh Contention 8.
In light of the implementation at Rancho Seco of operating procedures for initiating and controlling auxiliary feedwater independent of Integrated Control S.vstcm control (see Staff Evaluation of June 27,1979), provide the reasons for your allegation that the Rancho Seco facility is unsafe due to a lack of operating procedures for initiating and controlling the emergency feedwater system independent of the integrated control system.
Interrogatory 9 The following questions deal with Castro-Hursh Contention 9.
In light of the installation at Rancho Seco of a hard-wired control-grade reactor trip that would be actuated on loss of main feedwater and/or turbine trip (see Staff Evaluation of June 27,1979), provide the reasons for your allegation 1517 322
( that the Rancho Seco facility is unsafe as it has not installed an inade-quate hard-wire control-grade reactor trip on loss of main feedwater and/or on turbine trip. Describe, in reasonable detail, how Contention 9 differs from Contention 3e Interrogatory 10 The following questions deal with Castro-Hursh Contention 10.
In light of the completion by SMUD of analyses for potential small breaks and develop-ment and implementation of operating instructions to define operator action (see Staff Evaluation of June 27, 1979, and B&W Report entitled " Evaluation of Transient Behavior and Small Reactor Coolant System Break in the 177 Fuel Assembly Plant" provided to you by Staff letter of October 24,1979), pro-vide the reasons for your allegation that the Rancho Seco facility is unsafe because it has not completed an adequate analysis for potential small breaks in a loss-of-coolant accident nor developed and implemented operating instruc-tions to define operator action in such an event.
Interrogatory 11 The following questions deal with Castro-Hursh Contention 16.
A.
Provide your reasons why the failure mode and effects analysis per-formed of the integrated control system is inadequate. What would consti-tute an adequate analysis in this area in your view.
Provide your reasons.
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t Interrogatory 12 The following question deals with Castro-Hursh Contention 20.
Describe the reasons for your allegation that a hydrogen recombiner should be physically installed at the Rancho Seco facility.
Interrogatory 13 The follow ng questions deal with Castro-Hurs~n Contention 21.
A.
Provide the reasons for your allegations that the Rancho Seco facility has a pressurizer tank and quench tank which are of inadequate size to accommodate the volume of gas or liquid that may be required to be stored in the event of a loss of feedwater transient.
Be specific in your response with regard to assumptions regarding containment isolation and the effects of pressurizer tank and quench tank overflow.
B.
Provide your position with regard to adequate pressurizer tank and quench tank sizing.
Provide the basis for that position.
Interrogatorf 14 The following questions deal with Castro-Hursh Contention 22.
A.
Provide your understanding of operator actions needed to " interpret information on temperature and pressure in the primary loop".
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6.
Provide your understanding of the operator action required to "extrapo-late water level".
C.
Provide the reasons for your allegation that the Rancho Seco facility is unsafe because operators must " interpret information on temperature and pressure in the primary loop" and "extrapolatc water level."
Interrogatory 15 The following questions deal with Castro-Hursh Contention 24.
A.
As is used in this contention, please define the term " bubble" and identify its source and composition.
B.
Provide the reasons for your allegation that the Rancho Seco facility is unsafe as it is " unable to avoid" bubble formation.
C.
Provide the reasons for your allegation that the Rancho Seco facility is unsafe as it is " unable to control" bubble formation.
Interrogatory 16 The following questions deal with Castro-Hursh Contention 25.
A.
Identify specifically which " auxiliary feedwater valves" and "pressur-izer relief valves" are the subject of this contention.
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t B.
Provide the reasons for your allegation that the Rancho Seco facility does not have control room instrumentation to indicate auxiliary feedwater valve position.
C.
Explain, in reasonable detail, the concern that is embraced by the phrase "... instrumentation to open or close such valves automatically...".
Instrumentation is normally used to indicate equipment status while manual or automatic controls are normally used to actuate equipment.
Do you con-tend that auxiliary feedwater valves should actuate automatically.
If so, provide your reasons.
Do you centend that the pressurizer relief valves should actuate automatically.
If so, provide your reasons.
Interrogatory 17 The following questions deal with Castro-Hursh Contention 26.
A.
Provide the reasons for your allegation that the Rancho Seco facility is " unsafe" because it utilizes a once-through steam generator.
Define the meaning of the word " unsafe" as it is used in this contention with specific reference to the types of incidents you view as unsafe and the types of consequences you associate with those incidents.
B.
Explain, in reasonable detail, the difference between Contention 26 and Contention 2.
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- Interrogato.y 18 The following questions deal with Castro-Hursh Contention 29.
A.
Identify the additional instrumentation needed at the Rancho Seco facility to achieve an acceptable level of safety.
Provide your reasons.
B.
Identify the additional " capability to immediately retrieve necessary infonnation or data during a loss of feedwater transient" that is required at the Rancho Seco facility to achieve an acceptable level of safety.
Provide your reasons.
C.
Describe, in reasonable detail, how Contention 29 differs from Conten-tion 22.
Interrogatory 19 The following questions deal with Castro-Hursh Contention 31.
A.
The Staff is confused by use of the word " avoid" in this contention.
Do you contend that a properly designed control room will permit plant operators to " avoid" a loss of feedwater transient? Or do you contend that a properly designed control room would aid plant operators in responding to a loss of feedwater transient? Provide your reasons.
B.
Describe the control room configuration inadequacies at the Rancho Seco facility that fonn the basis for this contention.
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. Interrogatory 20 The following questions deal with Castro-Hursh Contention 32.
A.
Describe the tenn " personnel" and the term " management" as they are used in this contention. The description should identify for each tenn by job function, position title, or some other means the individuals you con-sider have not had their competence adequately tested and evaluated.
B.
For each group identified in response to A. above, provide your reasons for the allegation that there has not been adequate testing to ensure that the group idenMfied would act responsibly and appropriately during a loss of feedwater transient.
C.
For each group identified in response to A. above, provide your reasons for the allegation that personnel interviews have not been conducted to properly evaluate the test results.
D.
Provide your reasons for the allegation that "some of the employees have never been tested because of grandfathering".
Specify which employees have been grandfathered and the nature of the grandfathering.
Interrogatory 21 The following questions deal with Castro-Hursh Contention 34. Provide your reasons for the allegation that unlicensed operators have not been adequately 1517 328
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trained to respond to orders necessary for action which would be required in the event of loss of feedwater transient.
Respectfully submitted,
/
Richard K. Hoefling Counsel for NRC Staf Dated at Bethesda, Maryland this 9th day of November,1979.
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