ML19296A879
| ML19296A879 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/30/1980 |
| From: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Ellison C, Lanpher L, Lewis S CALIFORNIA, STATE OF, HILL, CHRISTOPHER & PHILLIPS, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8002190209 | |
| Download: ML19296A879 (21) | |
Text
m
's S H Aw, PITTM AN, PoTTs & TROWB RIDG E 18 0 0 M S T R E E T, N. W.
WAS HINGTON, D. C. 2 0 03 6
?TS STEVEN L. M E L
+ 202: 3 31 - **C O O. PO, f t M A N O AULIC TT ER h
44 W $ Af S'E UA AT L P
CEAN GE3 AGE F T RO ~e m e OG E sOHN ENGEL STEPHEN 3 DOTTS STEDMEN 6 MUTTLEO TELECOpeER 2',"n: 5"e' :X'c
- "le"s" " "w'L l
4
- aa > 2ee c a **
- 2n "
a nMorwy mANLON nOSERT E Z AHLE A GEORGEM aOGERS. JR miCHAno E.GALEN s C e4 N $ 4 MIN C LA N DE R ACSEnT 9 ROBS'N S TELEX A AS F ?
E33-D e s-26 93, SM AWLAw ws M J C Lt E N CHOLSO 4. JR
%=:2"4^O 2Lu?2 'A2 N
- ^e" " b"."'% a
~~
4 cAeuc~s-*wv~"
mL M'"assOTT, c; ='!N Y
ET -e h @h E l'?OilrO'e'"d"OLos JL"sl."ET" ?!E4METON O
d " " "
ME8
- a'G'NEa n'L ?:Ekl.*ti k
o M'."/ "l'E ".' "c','
%"% " R.'c%'5!,t g
'DUIo% *s" Eat"
?C'">.*e^n??"
' *S EW'.I'#G E /
- s"4^ " c"A f ^.""..
O 3"S?f"~ic** lib.
02 L'n"ic"^~"lJ' AL'E'I'MO"Jf " 'JEn-A a7 NG'T ~$ ~ ggaa$"
- January 30, 1980 o
1
- eof AOasi FTE D 'N O C.
Stephen H.
Lewis, Esquire Gary Hursh, Esquire Office of the Executive Suite 700 Legal Director 520 Capitol Mall U.S.
Nuclear Regulatory Sacramento, California 95814 Commission Washington, D.C.
20555 Mr. Richard D.
Castro 2231 K Street Lawrence Coe Lanpher, Esquire Sacramento, California 95816 Hill, Christopher & Phillips 1900 M Street, N.W.
James S.
Reed, Esquire Washington, D.C.
20036 Michael H.
Remy, Esquire Reed, Samuel & Remy Christopher Ellison, Esquire 717 K Street, Suite 405 California Energy Commission Sacramento, California 95814 1111 Howe Avenue Sacramento, California 95825 In the Matter of Sacramento Municipal Utility District (Rancho Seco Nuclear Generating Station)
Docket No. 50-312 Gentlemen:
In the telephone conference on January 16, 1980, the Atomic Safety and Licensing Board encouraged the parties to con-fer in advance of the prehearing conference and attempt to agree on an identification of those closely related contentions, raised by different parties, which mignt be heard at the same time.
The parties subsequently agreed to meet for this purpose at 3:00 p.m.,
February 5, at California Energy Commission offices.
8 00219 e O
m SHAW, PITTMAN, POTTS & TROWBRIDGE Stephen H.
Lewis, Esquire Lawrence Coe Lanpher, Esquire Christopher Ellison, Esquire Gary Hursh, Esquire Mr. Richard D.
Castro James S.
Reed, Esquire Michael H.
Remy, Esquire January 30, 1980 Page Two s
Because of the large number of issues raised in this proceeding, I believe it would be useful to our discussions on February 5 and to the prehearing conference to have a common listing of the issues to which we can all refer.
Consequently, I have prepared the enclosed listing for your consideration in advance of our meeting.
I have grouped the contentions and Board questions at two levels.
One broad grouping divides the issues into three general categories, which coincide with the three pieces of written testimony Licensee currently plans to present.
Category I issues, to be addressed for Licensee by Bruce A.
Karrasch, encompass matters generic to the Babcock & Wilcox nuclear steam supply system.
Category II issues, to be ad-dressed for Licensee by Robert A. Dieterich, include SMUD design and engineering considerations.
Category III issues, to be addressed for Licensee by Ronald J.
Rodriguez, include operator and facility management competence, plant procedures, control room instrumentation and operating experience.
We propose to present our three pieces of testimony in the order indicated by these category designations.
Please note, however, that the following contentions and Board questions will be ad-dressed by two Licensee witnesses, and therefore appear in two of the categories:
CEC 1-1, CEC 1-2, CEC 1-6, CEC 1-7, CEC 1-12, H-C 7, H-C 10, and each of the Additional Poard Questions of January 7, 1980.
The second level of grouping occurs within each of the three categories.
These smaller groups involve closely related issues which our witness will address simultaneously in one passage of testimony.
Mr. Karrasch, for example, will address Hursh-Castro contentions 4 and 16 together because they both deal with the integrated control system.
Similarly, he will addrest Board question CEC 1-10 with Hursh-Castro contention 24 becau e they both deal with void formation.
The enclosed listing also identifies the order in which we expect these groups of issues to be addressed in each of Licensee's three pieces of testimony.
The list assumes, for the moment, that all motions for summary disposition are denied.
+
SHAW, PITTMAN, POTTS & TROWBRIDGE Stephen H.
Lewis, Esquire Lawrence Coe Lanpher, Esquire Christopher Ellison, Esquire Gary Hursh, Esquire Mr. Richard D.
Castro James S.
Reed, Esquire Michael H.
Remy, Esquire January 30, 1980 Page Three N
N have also included on the list those witnesses identified to date by other parties.
These include witnesses by the NRC Staff and the California Energy Commission (although CEC has not stated with certainty that it will call all of these witnesses).
I would hope that, considering the schedule for filing testimony, the parties will be prepared to identify at our February 5 meeting all of the witnesses to be called to testify at this hearing.
Sincerely yours, K,
Thomas A.
Baxter Cousel for Licensee cc:
Elizabeth S.
Bowers, Esquire Dr. Richard F.
Cole Mr. Frederick J.
Shon David S.
Kaplan, Esquire NRC Docketing and Service Section
TAB: 1/29/80 RANCIIO SECO IIEARING:
Issues and Witnesses Question (s) or Category I Issues Contention (s)
Licensee CEC
.RC Staff Integrated Control System II-C 4 Karrasch Thatcher II-C 16 Karrasch Thatcher Feedwater Transients FOE III(a)
Karrasch Rubin 9/
Anticipatory Trips ABQ l Karraschi Thatcher OTSG Sizing / Sensitivity Il-C 2 Karrasch Rubin II-C 26 Karrasch Rubin ABQ 3 Karraschl/
Rubin Pressurizer & Quench Tanks Sizing II-C 21 Karrasch Matthews Natural Circulation CEC 1-2 Karraschb/
Lewis Norian II-C 6 Karrasch Norian Karraschp/
1 Safety System Challenges CEC 1-1 Minor, Webb Rubin Karrasch j Minor, Webb Rubin CEC 1-12 RCS Void Formation CEC 1-10 Karrasch Lewis Norian II-C 24 Karrasch Norian Small Break LOCAs CEC 1-4 Karrasch Webb Norian CEC 1-7 Karraschl/
Bridenbaugh Wilson II-C 10 Karrasch1/
Wilson, Norian ABQ 2 Karraschb/
Norian NOTE:
"ABQ" = Additional Board Questions, January 7, 1980.
RANCHO SECO HEARING:
Issues and Witnesses Question (s) or Category II Issues Contention (s)
Licensec CEC NRC Staff RC Pressure Trip and PORV Setpoint II-C 5 Dieterich Norian AFW Reliability CEC 1-6 Dieterich1/
Webb Matthews H-C 7 Dieterichl/
Matthews Anticipatory Reactor Trips II-C 3 Dieterich Thatcher H-C 9 Dieterich Thatcher ABQ l Dieterich1!
Thatcher Containment Isolation CEC 5-1 Dieterich Mann Wing Ilydrogen Recombiner II-C 2 0 Dieterich Greene Containment Venting CEC 5-2 Dieterich Nix Greene Long-Term Modifications FOE III(c)
Dieterich Capra Category III Issues Operator / Management Competence CEC 3-1 Rodriguez Bridenbaugh Wilson II-C 3 2 Rodriguez Wilson, Garner, Allenspach, Johnson FOE III(d)
Rodriguez Wilson, Garner, Allenspach, Johnson FOE III(e)
Rodriguez Wilson Small Break LOCAs CEC 1-7 Rodriguezd!
Bridenbaugh Wilson II-C 10 Rodriguez 2/
Wilson, Norian ABQ 2 Rodriguez /
Norian 3
I ABQ 3 Rodriguez /
Rubin RANCHO SECO HEARING:
Issues and Witnesses Question (s) or Category III Issues (cont'd.)
Contention (s)
Licensee CEC NRC Staff Emergency Procedures CEC 3-3 Rodriguez Bridenbaugh Wilson Operating Feedback CEC 3-2 Rodriguez Bridenbaugh Wilson Unlicensed Operator Training li-C 34 Rodriguez Morrill Control Room Design H-C 31 Rodriguez Wilson Instrumentation CEC 5-3a Rodriguez Minor, Finlayson Wilson II-C 2 9 Rodriguez Wilson Pressurizer, RV Water Level H-C 22 Rodriguez Norian AFW Valve, PORV Position Indication H-C 25 Rodriguez Thatcher Automatic vs. Manual Control H-C 30 Rodriguez Novak
[
Webb Matthews AFW Reliability CEC 1-6 Rodriguez /
2 Il-C 7 Rodriguez Matthews AFW Separation from ICS II-C 8 Rodriguez Wilson Safety System Challenges CEC 1-1 Rodriguez /
Minor, Webb Rubin 3
CEC 1-12 Rodriguez /
Minor, Webb Rubin Natural Circulation CEC 1-2 Rodriguez Lewis Norian.
~
FOOTNOTES:
1/
Addressed in part by testimony of R.
J.
Rodriguez.
2/
Addressed in part by testimony of R.
A.
Dieterich.
3/
Addressed in part by testimony of B.
A.
Karrasch.
RANCHO SECO HEARING:
Issues Question (s) or Category I Issues Contention (s)
Text of Question or Contention Integrated Control System H-C 4 Rancho Seco, being a Babcock and Wilcox designed reactor, has a reliance on integrated control system to automatically regulate feedwater flow, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
H-C 16 SMUD, the licensee, has done insufficient analysis of the failure mode and effects analysis of the integrated control system, and therefore Rancho Seco is unsafe and endangers the health and safety of Petitioners, constituents of Peti-tioners and the public.
Feedwater Transients FOE III(a)
The NRC orders in issue do not reasonably assure adequate safety because the orders fail to eval-uate or comment upon the acceptability of 27 feedwater transients over the past year in nine Babcock and Wilcox (B&W) reactors, a frequency which is 50 percent greater than the corre-sponding rate for other pressurized reactors.
Anticipatory Trips ABQ l At a meeting with owners of B&W reactors held on August 23, it was noted that, in the interim then elapsed since the TMI-2 accident, control-grade hard-wired anticipatory reactor trips (ART) had been called on to rcspond four times and had failed once:
a.
Is this typical of performance by control grade trips?
b.
What are the safety implications for opera-tion of Rancho Seco before such trips are upgraded?
s RANCIIO SECO IIEARING:
Issues Question (s) or Category I Issues (cont'd.)
Contention (s)
Text of Ouestion or Contention OTSG Sizing / Sensitivity li-C 2 Rancho Seco, being a Babcoch and Wilcox designed reactor, is designed with a steam generator which operates with relatively small liquid volume in the secondary side and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
II-C 26 Rancho Seco, being a Babcock and Wilcox designed reactor, has a once through steam generator which makes the plant more susceptible and sensitive to a loss of feedwater transient, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
ABO 3 It appears from a Board Notification issued by R.
II. Vollmer on December 5, 1979, that the basic design of the Once Through Steam Generator (OTSG) may so closely couple primary system behavior to secondary system disturbances that gross distur-bance of the primary system is inevitable for feedwater transients.
Further, it seems there are situations in which an operator may not be able to tell exactly what is wrong or what respons( is appropriate (e.g. over-cooling vis-a-vis a small-break LOCA).
a.
What changes in the system and procedures have been made to ameliorate this situation?
b.
What are the implications for safety of operating Rancho Seco before any uncer-tainties are resolved?.
RANCHO SECO HEARING:
Issues Question (s) or Category I Issues (cont'd.)
Contention (s)
Text of Question or Contention Pressurizer & Quench Tanks Sizing H-C 21 Rancho Seco, being a Babcock & Wilcox designed reactor, 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, and therefore is unsafe and endangers the health and safety of Petitioners, constit-uents of Petitioners and the public.
Natural Circulation CEC 1-2 Can poor understanding of natural convection in the Rancho Seco system result in a situation that will lead to inadequate cooling despite the modi-fications and actions of Subparagraphs a-e?
H-C 6 Rancho Seco, being a Babcock and Wilcox designed reactor, has a low steam generator elevation, relative to the reactor vessel, which provides a smaller driving head for natural circulation, and therefore is unsafe and endangers tne health and safety of Petitioners, constituents of Peti-tioners and the public.
Safety System Challenges CEC 1-1 Despite the modifications and actions of Sub-paragraphs (a) through (e) of Section IV of the Commission's Order, will reliance upon the High Pressure Injection System to mitigate pressure and volume control sensitivities in the Rancho Seco primary system result in increased chal-lenges to safety systems beyond the original design and licensing basis of the facility? _ - - _ _ _ _ _. _.. -.
RANCIIO SECO IIEARING:
Issues Question (s) or Category I Issues (cont'd.)
Contention (s)
Text of Question or Contention Safety System Challenges (cont'd.)
CEC 1-12 Despite or because of the modifications and actions of Subparagraphs (a) through (e) of Section IV of the Commission's Order of May 7, will Rancho Seco experience an increase in reactor trips resulting from feedwater transients that will increase challenges to safety systems beyond the original design and licensing basis of the facility?
RCS Void Formation CEC 1-10 Is the physical configuration of the Rancho Seco primary system such as to permit unsafe accumulation of steam or other gases despite the modifications and actions of Cubparagraphs a-e?
II-C 24 Rancho Seco, being a Babcock and Wilcox designed reactor, is unable to avoid or control bubble information in the primary system which may occur subsequent to a loss of feedwater acci-dent, and therefore is unsafe and endangers the health and safety of Petitioners, constit-uents of Petitioners and the public.
Small Break LOCAs CEC 1-4 Will the failure of safety and/or relief valves in the Rancho Seco primary system result in an unsafe condition despite the modifications and actions of Subparagraphs a-e? '
RANCHO SECO HEARING:
Issues Question (s) or Category I Issues (cont'd.)
Contention (s)
Text of Question or Contention Small Break LOCAs (cont'd.)
CEC 1-7 Do the operator training' actions responding to Subparagraph (d) of Subparagraphs a-c for Rancho Seco fail to give sufficient attention to pro-viding appropriate analytical bases for operator actions?
II-C 10 Rancho Seco, being a Babcock and Wilcox designed reactor, has not completed an adequate analysis for potential small breaks in a loss-of-coolant accident nor developed and implemented operating instructions to define operator action in such event, and therefore is unsafe and endangers the health and safety of Petitioners, constit-uents of Petitioners and the public.
ABQ 2 We note (letter D.
Ross to J.
J.
- Mattimoe, December 14, 1979) that there is still some dispute as to the fundamental logic for Reactor Cooling Pump (RCP) trip in a small-break LOCA.
a.
What current instructions to reactor operators govern tripping of the pumps in small-break LOCA's and upon what theory of system behavior are those instructions based?
b.
What are the implications for safety of operating Rancho Seco until the exact behavior of the system in a sm<1l Freak LOCA is well-understood?.
RANCHO SECO IIEARING:
Issues Question (s) or Category II Issues Contention (s)
Text of Question or Contention RC Pressure Trip and PORV Setpoint Il-C 5 Rancho Seco, being a Babcock and Wilcox designed reactor, has an actuation before reactor trip of a pilot operated relief valve on the primary system pressurizer which, if the valve sticks open, can aggravate an accident, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
AFW Reliability CEC 1-6 Will the modifications of Subparagraphs a-e still leave the Rancho Seco emergency feed-water system in a condition of low reliability?
II-C 7 Rancho Seco, being a Babcock and Wilcox designed reactor, has insufficient timeliness and relia-bility of the emergency feedwater system, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
Anticipatory Reactor Trips II-C 3 Rancho Seco, being a Babcock and Wilcox designed reactor, has a lack of direct initiation of reactor trip upon the occurrence of off-normal conditions in the feedwater system, and there-fore is unsafe and endangers the health and safety of the Petitioners, constituents of Petitioners and the public.
RANCHO SECO HEARING:
Issues Question (s) or Category II Issues (cont'd.)
Contention (s)
Text of Question or Contention Anticipatory Reactor Trips (cont'd.)
H-C 9 Rancho Seco, being a Babcock and Wilcox designed reactor, has not installed adequate hard-wire control grade reactor trip on loss of main feedwater and/or on turbine trip, and there-fore is unsafe and endangers the health and safety of Petitioners, constituents of Peti-tioners and the public.
ABQ l At a meeting with owners of B&W reactors held on August 23, it was noted that, in the interim then elapsed since the TMI-2 accident, control-grade hard-wired anticipatory reactor trips (ART) had been called on to respond four times and had failed once:
a.
Is this typical of performance by control grade trips?
b.
What are the safety implications for opera-tion of Rancho Seco before such trips are upgraded?
Containment Isolation CEC 5-1 Whether those systems identified as contributing to releases of radioactivity during the TMI accident, which are outside containment, should be changed to vent into the containment building?
Hydrogen Recombiner H-C 20 Rancho Seco, being a Babcock and Wilcox designed reactor, does not have a hydrogen recombiner which may be necessary in the event of an acci-dent caused by a loss of feedwater transient, and therefore is unsafe and endangers the herlth and safety of Petitioners, constituents of Petitioners and the public..-
RANCHO SECO HEARING:
Issues Question (s) or Category II Issues (cont'd.)
Contention (s)
Text of Question or Contention Containment Venting CEC 5-2 Whether the containment building should be modified to provide overpressurization pro-tection with a controlled filtered venting system to mitigate unavoidable releases of radionuclides?
Long-Term Modifications FOE III(c)
The NRC orders in issue do not reasonably assure adequate safety because there is no reasonable time for implementation of the long-term modifications established in the Commission orders.
Category III Issues Operator / Management Competence CEC 3-1 Whether personnel adequately understand the mechanics of the facility, basic reactor physics, and other fundamental aspects of its operation?
H-C 32 Rancho Seco, being a Babcock and Wilcox designed reactor, is operated by personnel and manage-ment whose competence has not been adequately tested and evaluated, namely testing has not been conducted as to whether such employees can act responsibly and appropriately to make judgment decisions during a loss of feedwater transient, personnel intervicas have not been conducted to properly evaluate the test results with such employees and some employees have never been teste' because of grandfathering, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Pe-titioners and the public..
RANCHO SECO HEARING:
Issues Question (s) or Category III Issues (cont'd.)
Contention (s)
Text of Question or Contention Operator / Management Competence (cont'd.)
FOE III (d)
The NRC orders in issue do not reasonably assure adequate safety because no procedures have been taken to assure facility management competence.
FOE III(e)
The NRC orders in issue do not reasonably assure adequate safety because no procedures exist or have been taken for the determination of the adequacy of operator competence.
Small Break LOCAs CEC 1-7 Do the operator training actions responding to Subparagraph (d) of Subparagraphs a-e for Rancho Seco fail to give sufficient attention to pro-viding appropriate analytical bases for operator actions?
H-C 10 Ranci'o Seco, being a Babcock and Wilcox designed reactor, has not completed an adequate analysis for potential small breaks in a loss-of-coolant accident nor developed and implemented operating instructions to define operator action in such event, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
ABQ 2 We note (letter D.
Ross to J.
J.
Mattimoe, Decem-ber 14, 1979) that there is still some dispute as to the fundamental logic for Reactor Cooling Pump (RCP) trip in a small-break LOCA.
a.
What current instructions to reactor operators govern tripping of the pumps in small-break LOCA's and upon what theory of system behavior are those instructions based?.
RANCliO SECO IIEARING:
Issues Question (s) or Category III Issues (cont'd.)
Contention (s)
Text of Question or Contention Small Break LOCAs (cont'd.)
ABQ 2 (cont'd.)
b.
What are the implications for safety of operating Rancho Seco until the exact behavior of the system in a small-break LOCA is well-understood?
ABQ 3 It appears from a Board Notification issued by R.
11. Vollmer on December 5, 1979, that the basic design of the Once Through Steam Generator (OTSG) may so closely couple primary system behavior to secondary system disturbances that gross disturbance of the primary system is in-evitable for feedwater transients.
- Further, it seems there are situations in which an operator may not be able to tell exactly what is wrong or what response is appropriate (e.g.
over-cooling vis-a-vis a small-break LOCA).
a.
What changes in the system and procedures have been made to ameliorate this situation?
b.
What are the implications for safety of operating Rancho Seco before any uncer-tainties are resolved?
Emergency Procedures CEC 3-3 Whether NRC and SMUD adequately ensure that emergency instructions are understood by and are available to plant personnel in a manner that allows quick and effective implementation during an emergency?.
RANCi!O SECO IIEARING:
Issues Question (s) or Category III Issues (cont'd.)
Contention (s)
Text of Question or Contention Operating Feedback CEC 3-2 Whether personnel are properly apprised of new information pertinent to the facility's safe operation and ability to respond to transients, particularly information on operating experience of other reactors?
Unlicensed Operator Training II-C 3 4 Rancho Seco, being a Babcock and Wilcox designed reactor, has not adequately trained unlicensed operators to respond to orders necessary for action which would be required in the event of loss of feedwater transient, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
Control Room Design II-C 31 Rancho Seco, being a Babcock and Wilcox designed reactor, has a control room configuration which is poorly and inadequately designed for plant operators to avoid a loss of feedwater transient, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
Instrumentation CEC 5-3a Are the special features and instruments installed at Rancho Seco adequate to aid in diagnosis and control after an off-normal condition en-gendered by a loss-of-feedwater transient?
RANCIIO SECO IIEARING:
Issues Question (s) or Category III Issues (cont'd.)
Contention (s)
Text of Questions or Contention Instrumentation (cont'd.)
Il-C 29 Rancho Seco, being a Babcock and Wilcox designed reactor, has insufficient instrumentation and capability to immediately retrieve necessary information or data during a loss of feedwater transient and therefore is unsafe and endangers the health and safety of Petitioners, con-stituents of Petitioners and the public.
Pressurizer, RV Water Level II-C 22 Rancho Seco, Leing a Babcock and Wilcox designed reactor, does not provide control room operators with sufficient data onthe water level in the pressurizer and vessel because the operators must interpret information on temperature and pressure in the primary loop and extrapolate water level, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
AFW Valve, PORV Position Indication Il-C 25 Rancho Seco, being a Babcock and Wilcox designed reactor, does not have control room instrumen-tation which would indicate if the auxiliary feedwater or pressurizer relief valves are open or closed or the instrumentation to open or close such valves automatically, and therefore is unsafe and endangers the health and safety of Petitioners, constituents and Petitioners and the public.
RANCHO SECO HEARING:
Issues Question (s) or Category III Issues (cont'd.)
Contention (c)
Text of Questions or contentions Automatic vs. Manual Control H-C 30 SMUD, the licensee, has conducted insufficient analysis of what operations of the facility should be required to be automated or hard equipment responsibilities and what can be conducted manually or by plant personnel, and therefore Rancho Seco is unsafe and endangers the health and safety of Peti-tioners, constituents of Petitioners and the public.
AFW Reliability CEC 1-6 Will the modifications of Subpdragraphs a-e still leave the Rancho Seco emergency feed-water system in a condition of low reliability?
H-C 7 Rancho Seco, being a Babcock and Wilcox designed reactor, has insufficient timeliness and relia-bility of the emergency feedwater system, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
AFW Separation from ICS H-C 8 Rancho Seco, being a Babcock and Wilcox designed reactor does not have operating procedures for initiating and controlling the emergency feed-water system independent of the integrated control system control, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public..
RANCIIO SECO IIEARING:
Issues Question (s) or Category III Issues (cont'd.)
Contention (s)
Text of Questions of Contentions Safety System Challenges CEC l-1 Despite the modifications and actions of Sub-paragraphs (a) through (e) of Section IV of the Commission's Order, will reliance upon the IIigh Pressure Injection System to mitigate pressure and volume control sensitivities in the Rancho Seco primary system result in increased challenges to safety systems beyond the original design and licensing basis of the facility?
CEC 1-12 Despite or because of the modifications and actions of Subparagraphs (a) through (e) of Section IV of the Commission's Order of May 7, will Rancho Seco experience an increase in reactor trips resulting from feedwater transients that will increase challenges to safety systems beyond the original design and licensing basis of the facility?
Natural Circulation CEC 1-2 Can poor understanding of natural convection in the Rancho Seco system result in a situation that will lead to inadequate cooling despite the modifications and actions of Subparagraphs a-e? _