ML19291B893
| ML19291B893 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/04/1979 |
| From: | Larson L SACRAMENTO MUNICIPAL UTILITY DISTRICT, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | CALIFORNIA, STATE OF |
| Shared Package | |
| ML19291B894 | List: |
| References | |
| NUDOCS 7912140033 | |
| Download: ML19291B893 (6) | |
Text
4 December 4, 1
a l i?r, 4
M UNITED STATES OF AMERICA 6
NUCLEAR REGULATORY COMMISSION DEC 51979 > b h
%" W BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4fll0 In the Matter of
)
)
SACRAMENTO MUNICIPAL UTILITY DISTRICT
)
Docket No. 50-312
)
(Rancho Seco Nuclear Generating
)
Station)
)
LICENSEE'S FIRST SET OF INTERROGATORIES TO CALIFORNIA ENERGY COMMISSION These interrogatories are filed pursuant to 10 C.F.R.
S 2.740b, which requires that the interrogatories be answered by California Energy Commission
(" CEC") separately and fully in writing and under oath or affirmation, within 14 days after service (i.e., on or before December 24, 1979).
These inter-rogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, should CEC obtain any new or differing information responsive to the interrogatories.
Because of the interrogatories served on CEC by the NRC Staff, dated Navember 9, 1979, and because of the fact that Licensee is entitled to receive a copy of CEC's responses 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 interrogatories, 1582 i80 7912140
, Licensee, in Interrogatory No. 1 below, adopts the NRC Staff interrogatories as its own.
To the extent that satisfactory answers to the NRC Staff interrogatories have been or are sup -
plied, with a copy to Licensee, Licensee will deem them to comply with this requast.
General 1.
Provide responses to the questions and requests for information contained in the document "First Set of NRC Staff Interrogatories to the California Energy Commission (CEC) "
dated November 9, 1979.
2.
Following the substantive response to each of Interrogatories 3 through 19 below, identify by name and affilia '
tion each individual who has knowledge which served as the basis for that interrogatory.
Interrogatory On Issue CEC 1-l~*/
3.
Define " increased challenges to safety systems."
Does this refer to increased frequency of actuation and/or operation of safety systems?
Interrogatories On Issue CEC 1-12-*/
4.
Does " increase challenges to safety systems" have the same meaning as in CEC's answer to Interrogatory 3 above?
If not, explain.
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The Licensing Bdard has not yet admitted this contention as a matter in controversy; however, Licensee respectfully requests CEC to respond in the interest of maintaining a reasonable schedule.
1582 181
3-
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Interrogatories On Board Question CEC 1-2~~
5.
Is it CEC's assertion that there may be poor under-standing of natural convection in the Rancho Seco system?
If so, explain the basis for this assertion.
6.
Identify the individual (s), by name or job description, who CEC alleges to have a poor understanding of natural convection in the Rancho Seco system.
7.
For each person or category identified in your answer to Interrogatory 6, explain in what respect (s) their understanding is considered to be inadequate and describe in detail the basis for your opinion that the understanding is inadequate.
8.
Describe, for each person or category identified in your answer to Interrogatory 6, the resulting " situation" referred to in this issue and the scenario or sequence of events which leads to the " situation," keeping in mind the modifications of subparagraphs a-e.
Explain how each " situation" described might lead to inadequate cooling.
Interrogatory On Board Question CEC 1-4 9.
For each safety and/or relief valve in the pria.mry system, what unsafe conditions do you consider might occer as a result of failure of such valve?
Taking into account the
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This and the other interrogatories that follow refer to Board questions based upon proposed CEC issues, set forth in the Licensing Board's " Order Ruling on Scope and Contentions" dated October 5, 1979.
1582 182
. modifications and actions of subparagraphs a-e, describe the basis for any allegation that each such alleged unsafe condition would occur as a result of valve failure.
c Interrogatories On Board Question CEC 1-6 10.
State in detail the basis for the proposition, implicit in this issue, that the Rancho Seco auxiliary feedwater system was in a condition of low reliability prior to the modifications of subparagraphs a-e.
Identify any actual Pancho Seco operating experience upon which CEC relies.
11.
Describe in detail the basis for CEC's concern that, despite the modifications of subparagraphs a-e, the Rancho Seco auxiliary feedwater system might be in a state of low re-liability.
Specify any particular subsystem (s) or component (s) which CEC considers may contribute to insufficient reliability.
For each such subsystem or component, provide the basis for CEC's concern that a lack of reliability may exist.
Interrogatories On Board Question CEC 1-7 12.
What is CEC's understanding of those operator training actions responuing to subparagraph (d) of subparagraphs a-e which have already occurred or are planned at Rancho Seco?
13.
What is CEC's understanding of the attention already given to appropriate analytical bases for operator actions, in the training referred to in Interrogatory 12 above?
I532 183
. 14.
Identify each operator action for which you consider that inadequate analytical bases have been provided in training.
For each such action, identify the analytical bases which CEC believec are required for safety to be included in the training, describe the reasons why providing such analytical bases is considered to be necessary for safety, and describe the changes to operator training actions CEC believes are indicated in order to give " sufficient" attention to analytical bases.
Interrogatories On Board Question CEC 1-10 15.
What is CEL's understanding of the phrase " unsafe accumulation of steam or other gases"'?
Identify what "other gases" are referred to.
Describe where in the primary system such unsafe accumulation would occur.
16.
What is CEC's criterion for determining what quantity of steam or other gases would be considered unsafe?
17.
Describe in physical terms how such unsafe accumulation of steam or other gases might come about, despite the modifications and actions of subparagraphs a-e.
18.
Identify precisely what aspects of the physical configuration of the Rancho Seco primary system are considered i5B2 184
. to contribute to the alleged unsafe accumulation of steam or other gases in spite of the modifications and actions of sub-paragraphs a-e.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE
, ~~
/- '_
_ - :/.
1.- 2.
Thomas A.
Baxter Lex K.
Larson Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 331-4100 15B2 185