ML19260C421
| ML19260C421 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/17/1979 |
| From: | Hoefling R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | FRIENDS OF THE EARTH |
| Shared Package | |
| ML19260C420 | List: |
| References | |
| NUDOCS 7912260329 | |
| Download: ML19260C421 (3) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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
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Station)
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SECOND SET OF NRC STAFF INTERR0GATORIES TO FRIENDS OF THE EARTH (F0E)
Pursuant to 10 CFR S 2.740b, the following interrogatories are directed to F0E.
Each interrogatory not objected to is to be answered separately and fully in writing under oath or affirmation by individuals having personal knowledge of the answers.
Pursuant to the schedule agreed to by the parties and accepted by the Licensing Board by its " Order Relative to Proposed New Schedule" of December 4,1979, these interrogatories are served on December 17, 1979, and final responses are to be served by January 17, 1980.
Pursuant to Q 2.740(e), these interrogatories should be supplemented as required by the above-reference rule.
Interrogatory 6 With reference to the " Answers of Petitioners, Friends of the Earth, to First Set of Staff Interrogatories" (Answers) filed in this proceeding on December 7,1979, specifically the response to Interrogatory No. 2, provide the following infomation.
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A.
Describe in reasonable detail the meaning of the phrase "... numerical criteria for Babcock and Wilcox NSSS reliability..." as that tenn is used in the penultimate paragraph of this response.
B.
Describe in reasonable detail the phrase "... frequency rate for AFW transient events..." as that term is used in the penultimate paragraph of this response.
C.
Provide the reasons for F0E's contention that "... explicit criteria for the acceptability, from a safety standpoint, of that criteria and those frequency rates,..." are necessary to provide reasonable assurance that the Rancho Seco facility can be operated safely.
D.
Provide the reasons for F0E's contention that the modifications at the Rancho Seco facility as a result of the May 7, 1979 Order have "...resulted in an increased potential for more reactor trips and feedwater transients."
Interrogatory 7 This Interrogatory deals with F0E's Answers to Interrogatory No. 4.
The Staff does not understand the distinction drrm by F0E in its response to the NRC Staff interrogatory requesting a definition of the tenn " facility management competence."
It appears to the NRC Staff that the terms "...compe-tent management of the Rancho Seco facility..." and "... competency of the 1618 299
management personnel responsible for the safe operation of the facility..."
are essentially synonomous.
Please provide, in detail, F0E's basis for asserting that these tenns are distinct and separate.
Interrogatory 8 This Interrogatory seeks information relative to the Answers of F0E to Interrogatory No. 5.
Provide the basis for F0E's contention that there is no "... clear ennuncia-tion by the NRC of standards, criteria and procedures to detennine operator competence....".
Respectfully submitted, w
Richard K. Hoefling Counsel for NRC Staff Dated at Bethesda, Maryland this 17th day of December, 1979 1618 300 4