ML19290B801

First Set of Interrogatories.Seeks Info on Contentions 22,25,30,32 & 34

ML19290B801
Person / Time
Site:	Rancho Seco
Issue date:	12/04/1979
From:	Larson L SACRAMENTO MUNICIPAL UTILITY DISTRICT, SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Castro R, Hursh G AFFILIATION NOT ASSIGNED, HURSH, G.
Shared Package
ML19290B802	List: ML19290B801
References
NUDOCS 7912140124
Download: ML19290B801 (4)

Text

December 4, 1979 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 DISTRICT

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Docket No. 50-312

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(Rancho Seco Nuclear Generating

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Station)

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LICENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENORS RICHARD CASTRO AND GARY HURSH These interrogatories are filed pursuant to 10 C.F.R.

S 2.740b, which requires that the interrogatories be answered by Richard Castro and Gary Hursh ("Intervenors") separately and fully in writing and under oath or affirmation, within 14 days after service (i.e., on or before December 24, 1979).

These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, should Intervenors obtain any new or differing information responsive to the interrogatories.

Because of the interrogatories serveu on Intervenors by the NRC Staff, dated November 9, 1979, and because of the fact that Licensee is entitled to received a copy,f Intervenors' respenses to those interrogatories, Licensee has been able to keep its independent requests to a minimum.

To preserve its rights, and in lieu of serving the same or similar interrcgatories, 1214SI@

1577 283

. Licensee, in Interrogatory No. 1 below, adopts the above-referenced NRC Staff interrogatories as its own.

To the extent that satisfactory answers to the NRC Staff interrogatories have been or are supplied, with a copy to Licensee, Licensee will deem them to comply with this request.

General 1.

Provide responses to the questions and requests for information contained in the document "First Set of NRC Staff Interrogatories to Gary Hursh and Richard Castro," dated November 9, 1979.

2.

Fellowing the substantive response to each of Interrogatories 3 through 6, 8 and 9 below, identify by name and affiliation each individual who has knowledge which served as the basis for that interrogatory.

Interrogatories On Contention H-C 22 3.

In view of the existence of instrumentation directly measuring water level in the pressurizer (see Final Safety Analysis Report, Figure 4.2-1), explain why Intervenors consider that cpera-tors do not have sufficient data available in the control room on the water level in the pressurizer.

4.

In view of Licensee's April 16, 1979, letter to the Nuclear Regulatory Commission, by which Licensee is committed to revise its operating procedures to provide for continued 1577 284

- operation of the high pressure coolant injection system until plant behavior is stable and 50 degrees of subcooling is achieved, explain why Intervenors consider it necessary for control room operators to have direct data on water level in the reactor vessel.

Interrogatory On Contention H-C 25 5.

In the light of Licensee's installation of indica-tion in the control room of flow in the auxiliary feedwater lines (see NRC Staff Safety Evaluation of June 27, 1979), explain why Intervenors consider there to be a problem of inadequate control room instrumentation indicating auxiliary feedwater valve position.

Interrogatories On Contention H-C 30 C.

Describe what analyses Intervenors feel should be done which are necessary for safety.

Explain why Intervenors consider such analyses to be necessary.

7.

Provide the information with respect to Contention H-C 30 which is requested for other contentions in paragraphs A, B and C on page 2 of the "First Set of NRC Staff Interroga-tories to Gary Hursh and Richard Castro" dated November 9, 1979.

Interrogatory On Contention H-C 32 8.

In the light of the testing of licensed operators which has occurred since March, 1979 (see NRC Staff Safety 1577 285

a Evaluation of June 27, 1979), give the basis for your allega-tion that there has not been adequate testing and evaluation as to personnel responses to a loss of feedwater transients.

Interrogatory On Contention H-C 34 9.

Describe in detail each action which would be required of unlicensed operators in the event of loss of feed-water transient and for which Intervenors claim adequate training has not been given.

Specify why each action described would be required and describe the scenario or sequence of events which leads to each required action.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE

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Thomas A.

Baxter Lex K. Larson Counsel for Licensee 1800 M Street, N.W.

Washington, D.C.

20036 (202) 331-4100 1577 286