ML19290C056
| ML19290C056 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/17/1979 |
| From: | Remy M, Vandervelden M FRIENDS OF THE EARTH, REED, SAMUEL & REMY |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML19290C052 | List: |
| References | |
| NUDOCS 8001090101 | |
| Download: ML19290C056 (17) | |
Text
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IENTO MUNICIPAL UTILITY
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Docket No. 50-312 (SP)
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(Rancho Seco Nuclear Generating
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FIRST SET OF FRIENDS OF THE EARTH INTERROGATORIES TO MUCLEAR REGULATORY COMMISSION STAFF Pursuant to 10 CFR, section 2.740b, the following interrogatories are directed to Nuclear Regulatory Commission Staff.1/
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 inter-rogatories, which are served by mai'. on De7 ember 17, 1979, are due to be filed on December 31, 1979.
Pursuant to Section 2.740(e),
these interrogatories should be supplemented as required by the above-referenced rule.
These interrogatories are intended to be continuing in nature, and the answers should be 'promptly supplemented or amended as appropriate, should NRC Staff obtain any new or differing infornation, responsive to the interrogatories.
_l/
An "F.O.E.
Request to Produce" directed to NRC Staff is being served contemporaneously with these interrocatories.
1730 017 8001090/Ol
We, request that the presiding officer find that a..swers to these Interrogatories are necessary to a proper decision in this proceeding, that the answers are not reasonably obtainable from any other source and, accordingly, that the NRC Staff must respond to these Interrogatories within 14 days of service.
Definitions 1.
The term " ' MUD" shall mean the Sacramento Municipal Utility District, including all directors, officers, employees, contractors, agents and other persons or entities acting at the direction of or under the control of SMUD.
2.
The term "NRC" shall mean the Nuclear Regulatory Commission, including all persons employed by the NRC and all persons or entities acting at the direction or under the control of the NRC.
3.
The term " facility" shall mean the Rancho Semo Nuclear Generating Station.
4.
The term " document" shall include by way of illustra-tion only and not by way of limitation, the following, whether printed or reproduced by any process, or written, and/or produced by hand, and whether or not claimed to be privileged or otherwise excludable from discovery, namely; studies, analyses, notes, correspondence, communicati'ns of any nature, telegrams, memoranda, notebooks of any, character, summaries or records of personal conversations, checkbooks, checkbook stubs, passbooks, cancelled checks, bills, paid and unpaid, diaries, reports, publications, photographs, minutes or records of meetings, transcripts of oral tes-imony or statements, reports and/or summaries of investigations, agreenents and contracts, including all modifications and/or revisiens thereef, reports and/or sammaries of negotiations, court papers, 1730 018 brochures, pamphlets, tape recordings, records and dictation belts.
Any document bearing on any sheet or side thereof, any marks, including, by way of illustration only and not by way of limitation, initials, stamped indicia, any comment or any notation of any character and not a part of the original text, or any reproduction thereof, is to be considered a separate document for purposes of these interrogatories.
5.
As used herein, the terms " identify" or " describe" shall mean the following, as the context shall make appropriate:
a.
When used with respect to a dccument, that NRC shall set forth the general nature of the docunent, the author or originator, the date, each addressee, all individuals designated to receive a copy or otherwise known to have received a copy, the location and custody of such document as of the date of NRC's answer to these interrogatories, the use (s), if any, made of the document by NRC, and the purposes (s) for which the document was prepared.
Where a document is in the custody of NRC, NRC shall state the means whereby NRC obtained custody of the document.
b.
When used with respect to any person, that NRC shall set forth the last known address, and office or position held by such person (1) as of the date of the events and transactions as to which such identification is requested, and (2) as of the
.date of NRC's answers to these interrogatories.
If the person to be identified is a corporation or other entity, NRC is also re-quested to set forth its principal place of business.
Once a person has been thus identified in an answer to an interrogatory, it shall be sufficient thereafter, when identifying that person, merely to state his,her, or its name.
1730 019 With respect to any statement, c.
act, practice, occurrence., event, device, scheme, meeting, conference, communica-tion or other utterance, the date thereof, the party or parties causing, issuing or communicating said statement, communication or utterance, the parties to whom and in whose presence the state-ment, communication or utterance was given or transmitted, the parties who participated in, caused or had knowledge of any act, practice, occurrence, event, device, scheme, meeting or conference, and whether any of the foregoing was in' writing (in which event WRC is requested to describe the terms thereof, or annex a copy to the answers to these interrogatories), or in oral form (in which event NRC is requested to state the substance thereof).
.Because of the interrogatories served on NRC Staff by the CEC, dated November 15, 1979, and because of the fact that F.O.E. is entitled to receive a copy of Staff's responses to those interrogatories, and all accompanying documents associated with said responses, F.O.E. has been able to keep its independent requests to a minimum.
To preserve its rights, and in lieu of serving the same interrogatori?s, F.O.E. Interrogatory No. 1, below, adopts the CEC interrogatories as its own.
To the extent that satisfactory answers to the CEC interrogatories have been or are supplied with a copy to F.O.E., F.O.E. will deem them to comply with this request.
Interrocatory 1 Provide responses to the questions and requests for information contained in the documents "First Set of CEC Inter-rogatories to the NRC Staff," dated, November 15, 1979.
1730 020
_4_
Interrogatory 2 Following the substantive response to each of the following interrogatories, identify by name and affiliation each individual who has knowledge which served as the basis for that interrogatory.
Interrogatory 3 Following the substantive response to each of the sub-sequent interrogatories posed by F.O.E.,
identify all documents and studies relied upon by NRC Staff in providing the answers to that interrogatory.
The identification should be specific to the portion of the document or study relied upon.
Studies shall include observa-tions, calculations, literature and other types of work, whether recorded or not, which consist of an examination or analysis of a phenomenon.
Interrogatory 4 Describe in detail the current process, procedures, standards or other criteria and evaluations that NRC uses to certify the competency and fitness of licenses.
In what manner have these been applied to management personnel at SMUD.
Interrogatory 5 Describe in detail the current process, procedures, standards, or other criteria and evaluations that NRC uses to determine or judge that the competency of a licensee is deficient.
In what manner have these been applied to manage-ment personnel at SMUD.
Interrogatory 6 Describe the review mechanism required by NRC of utility training programs for all operational personnel, including main-tenance and technical personnel.
1730 021
_3_
Interrogatory 7 Regarding Interrogatory 6, describe the process and basis by which such training programs are judged to provide sufficient assurances that safety-related functions will be effectively carried out.
Define explicitly how sufficient assurances are determined.
Interrogatory 8 Describe the extent and nature of emergency duties included in NRC training program reviews, and their applicability to Rancho Seco.
Interrogatory 9 Describe all procedures and documents related to NRC review of in-plant drills.
Include all criteria used to assess acceptability and success of such drills as they specifically relate to Rancho Seco.
Interrogatory 10 Describe all NRC efforts to date, on going, and in the future, to implement SECY 79-330E.
Describe in detail impediments that may exist to implementation at the Rancho Seco facility.
Interrogatory 11 Describe all documents, processes, and procedures used by NRC with regard to the renewal of operator licenses.
When have these been applied at Rancho Seco?
Interrogatory 12 Describe all processes and procedures used by NRC to identify individuals committing operational errors identified in licensee event reports.
Identify all such individuals identified in Rancho Seco L.E.R.'s in the past three years.
1730 022 Interrogatory-13 Describe how such processes and procedures, referred to in Interroga;ory 12,will or do affect the quality of reports received by NRC.
If NRC believes that the quality of the L.E.R.'s is unaffected, please explain why this is so.
Interrogatory 14 Describe all documents, processes, and procedures used by NRC to determine the level of the individual shift supervisor or shift technical advisor's technical knowledge in the area of transient and accident response and, in the case of a shift supervisor, the managerial ability to command and control the activities of shift personnel.
Hou have these determinations been made with regard to Rancho Seco.
Interrogatory 15 Regarding Interrogatory 14, explicitly describe the criteria used by NRC to detemine the level of acceptable performance of individuals.
Interrogatory 16 Describe all documents, processes and procedures currently utilized by NRC to incorporate, collect, disseminate, or otherwise learn from the operating experience of utility shif t personnel.
Interrogatory 17 Describe all processes and procedures NRC requires and deems acceptable for requalification of utility shift personnel and instructors.
When have these been applied with regard to Rancho Seco?
Interrogatory 18 Describe all processes and procedures NRC requires and deems acceptable to determine the quality, efficacy, and relevancy 1730 023 of simulator training programs.
In particular, describe the basis for determining the acceptability of B & W simulation training, if such a determination has been made.
Interrogatory 19 Regarding Interrogatory 18, describe the criteria and basis for determining that a simulator training program is sufficient to provide reasonable assurances of utility shift personnel competency to respond to off-normal or transient conditions.
Interrogatory 20 Describe current NRC minimum requirements, their basis and enforceability, for shift supervisor and senior reactor operator qualifications.
Interrogatory 21 Regarding Interrogatory 20, describe all on going efforts to up grade requirements of utility shift personnel qualifications.
Interrogatory 22 Regarding Interrogatory 21, explain the nature of up graded requirements and the schedule for implementation of said requirements.
In particular, provide the Rancho Seco implementation schedule.
Interrogatory 23 Regarding Interrogatory 22, describe the instructional guidelines for such up grading of requiremen*.s.
Interrogatory 24 Describe all documents processes, and procedures, related to NRC's ability to monitor and verify the licensee's management and technical support during normal operation and 1730 024 during an emergency.
Include in this response all criteria used by NRC to determine the acceptability of licensee management and technical support capabilities at Rancho Seco.
Interrogatory 25 Describe all documents, processes, and procedures, to determine the qualifications and level of adequate training for non-licensed personnel such as managers, engineer, auxillary operators, maintenance personnel, and technicians.
On what basis are present NRC guidelines regarding this matter determined to be suitable for an operating licensee.
Interrogatory 26 Describe all documents, processes and procedures which refer to minimum shift staffing of licensed reactor operators.
Interrogatory 27 Describe all processes and procedures which relate to NRC review of licensee administrative procedures regarding utility shift personnel, including criteria for determining the acceptability of said administrative precedures at Rancho Seco.
Interrogatory 28 Describe the criteria used by NRC to determine the acceptability of emergency operating procedures for nuclear plants.
In particular, how have Rancho Seco emergency operating procedures been determined to be acceptable.
Interrogatory 29 Regarding Interrogatory 28, describe the criteria by which NRC determines the acceptability of a licensees consideration of the compatibility of the design bases of the systems involved, with the discipline of human factors, in the development of 1730 025
emergency operating procedures.
Describe how this has been applied at Rancho Seco.
Interrogatory 30 Describe all Documents, processes and procedures utilized by NRC in developing minimum acceptable cirteria for operations verifications procedures.
Include the status a'nd timetable for implementation of the installation of status monitoring equipment in conforming with Regulatory Guide 1.47 at Rancho Seco.
Interrogatory 31 Pursuant to the Recommendations of NUREG-0578, each licensee is now required to have an operations experience evaluation group.
Describe all processes and procedures utilized by NRC to determine the competency and acceptability of the personnel, procedures, analyses, or other efforts of SMUD's OEEG.
Interrogatory 32 Describe all documents, processes and procedures utilized and proposed by NRC, to assure that operators and other operations personnel are continually provided with lessons learned from operating experience at other reactors in the United States.
Interrogatory 33 Describe all documents, processes and procedures utilized by NRC to determine explicit criteria for control room design review.
Include all specific requirements for backfitting existing control rooms to currect deficiencies.
Interrocatory 34 Describe all documents, processes, and procedures utilized by NRC to evaluate the technical basis for definative licensing criteria for manual and automatic operations for systems which 1730 026 execute plant safety functions and safety-related functions.
Interrogatory 35 Regarding Interrogatory 34, describe all documents, processes, and procedures related to the determination of the feasibility of backfitting existing plants, in particular, Rancho Seco.
Interrogatory 36 Describe all documents, processes and procedures related to the establishment of standard design requirements for control rooms.
Describe the evaluation of standard design requirements with reference to their applicability to existing control room designs.
Interrogatory 37 Decribe all documents, processes, and procedures related to evaluating the interaction of non-safety and safety grade systems during normal operation, transients, and design basis accidents to assure that any interaction will not resulu in exceeding the acceptance criteria for any design basis event.
Include an explicit definition of the acceptance criteria.
Interrogatory 38 Describe all design features necessary to mitigate the consequences of a core melt or severe core damage which provide reasonable assurances that the health and safety of the public are protected.
On what basis does NRC determine what assurances are reasonable.
Likewise, on what basis doer NRC determine what design features are necessary to provide such assurances.
1730 027 Interrogatory 39 Regarding Interrogatory 38, in lieu of such features, describe additional and supplemental means of preventing core damage or core-melt accidents, through improved engineered safety features.
Interrogatory 40 In Reference to Interrogatory 38, describe the objective of such design features.
Describe the design objectives by a set of specific acceptance criteria.
Interrogatory 41 In reference to Interrogatory 38, describe the character-istics and functions of such design features.
Interrogatory 42 In reference to Interrogatory 38, describe in detail:
A.
The probabilities and consequences of the various event sequences that might result in releasing significant amounts of radioactivity to the environraent.
Which sequences are amenable to interdiction and by what means?
B.
The expected effectiveness and performance of sug-gested means of reducing the consequences of events in which severe damage or substantial melting of the core occurs, in particular, systems for controlled, filtered venting of the containment and for preventing the uncontrolled combustion of hydrogen.
C.
Other requirements, and in particular those for siting, emergency plans and procedures, training or other related areas, which would be modified if such design features were required.
~
l730 028 D.
Additional information required or desirable before setting requirements.
E.
The final form of the requirement.
What will be the implementation schedule for new plants, plants under construc-tion, and operating plants?
Interrogatory 43 Describe in detail the approach, methods, and organiza-tion of the NRC staff in performing post-licensing reaiews of nuclear plants with particular attention paid to'the following specific items:
A.
An overall system level, integrated review that gives full consideration to operational safety aspects and pro-vides for a design basis accident assessment function from event initiation through consequence mitigation, including the review of emergency operating procedures.
B.
Timely analysis of operating experience and implementation of needed changes derived from operating experience C.
Discipline in the application of a single overall safety goal.
D.
Technical oversight of Safety Evaluation Reports to assure increased emphasis on safety while still satisfying the requirements of the administrative process of regulation.
E.
Assurance cf adequate operations experience and train-ing for the NRC technical review staff, especially those staff members assigned responsibility in accident response situations.
F.
Dedication of adequate resources to the three principal functions of the Office of Nuclear Reactor Regulation:
reactor licensing, oversight of operating reactors, a.ad resolution of generic safety issues.
1730 029 G.
Use of a formal procedure for follow-up on questions and requests from the Advisory Committee on Reactor Safeguards and its individual members.
Interrogatory 44 For each of the TMI lessons learned task force short term recommendations describe the basis or criteria utilized by NRC to determine:
A.
Compliance; B.
That recommendations explicitly provide reason-able assurances that Rancho Seco can be operated safely.
Interrogatory 45 Will SMUD adhere to the implementation schedule required by NUREG-0578?
If not, what sanctions will NRC impose?
If none, why not?
Interrogatory 46 Describe any additional measures not included in the May 7 Order, NUREG-0578, or I & E Bulletins issued, identified by NRC, SMUD, or others, that would enhance the safety and reliability of Rancho Seco in responding to var..ous uransient events or provide greater assurance of the safe and reliable operation of the facility.
Interrogatory 47 For any improvement that could increase safe ar.d reliable operation of Rancho Seco identified in response to Interrogatory 46, what criteria and procedures are used by SMUD and the NRC in determining whether to implement them and the timetable for implementation, and whether to. shut down er derate the plant pending successful implementation.
I730 030 Interrogatory 48 Are the safety design and operation requirements for Rancho Seco as stringent as those for new plants applying for a C.P. or O.L.?
Interrogatory 49 Regarding Interrogatory 48, if requirements differ, are there two different standards for design and operation?
Interrogatory 50 Based on present licensing criteria and regulations applicable to plants seeking a C.P.
or O.L.,
would the NRC approve the present Rancho Seco design configuration for an O.L.?
Interrogatory 51 Regarding Interrogatory 50, if not, why not?
If so, why so?
Interrogatory 52 Which, if any, of the following are necessary to provide a reasonable assurance of Rancho Seco's safe and reliable operation?
A.
Redundant power operated relief valves that can override releases of primary system radioactive coolant.'
B.
A recombiner to mitigate hydrogen formation.
C.
Better radiation monitoring devices at Rancho Seco and surrounding areas to properly quantify radiation re-leases in the event they occur.
D.
Use of other reactor systems that would provide less risk to the public in the event of feedwater transients.
E.
Venting of hydrogen from the reactor core at Rancho Seco if it is created by circumstances similar to those that cccurred at Three Mile Island.
F.
A revised evacuation and emergency response plan for Rancho Seco and surrounding communities, j }
}
G.
An automatic accident notification system.
H.
A controlled, filtered venting system to mitigate unavoidable releases of radionuclides.
I.
A revised measurement system to better inform Rancho Seco operators of hydraulic conditions in the steam generator, pressurizers, and reactor vessel.
J.
Redesign of Rancho Seco's control room to be consistent with modern principles of human engineering.
K.
Revised consideration of the. possibility of multiple and common-mode failures in Rancho Seco's design and operating procedures.
Interrogatory 53 Describe and identify any outstanding long-term generic issues related to the Commission Order of May 7, as it specifically concerns Rancho Seco.
Interrogatory 54 Describe all documents related to the risk implications of the sensitivity of the B & W design and on the potential interactions arising from the I.C.S.
Interrogatory 55 Describe any evidence or documents which suggest whether B & W plants are overly sensitive to feedwater transients due to the OTSG concept, as coupled with the pressurizer sizing, I.C.S.
design, and PORV/ Reactor trip set points.
Interrogatory 56 Regarding Interrogatory 55, describe any increase in the frecuency in reactor trips or AFW actuation as a result of modifications in the May 7 Commission order.
1730 032
Interrogatory 57 Describe any documents or criteria which define the point at which a given Crequency rate for reactor trips or AFW actuation is:
A.
Desirable; B.
Undesirable; C.
Unacceptable.
Respectfully Submitted, REED, SAMUEL & REMY r~
e 7
./ MICHAEL H.
REMY Attorneys for Petitioners
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MARK A. VANDERVELDEN Friends of the Earth DATED:
December 17, 1979 1730 033