ML19296B060
| ML19296B060 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/24/1980 |
| From: | Remy M, Vandervelden M FRIENDS OF THE EARTH |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8002190797 | |
| Download: ML19296B060 (7) | |
Text
,?3 i
~
7 nsu.TED co#
C, 7
s w
,cg3
-o
~
Y UNITED STATES OF AMERICA g-4 e,
e.
NUCLEAR REGULATORY COMMISSION g,p 9
F
,t BEFORE THE ATOMIC SAFETY AND LICENSING BOARD N! !.
In the Matter of:
)
)
SACRAMENTO MUNICIPAL UTILITY
)
DISTRICT
)
DOC m NO. 50412 (SP)
(Rancho Seco Nuclear Generating Station)
)
)
RESPONSE OF PETITIONER FRIENDS OF THE EARTH TO THE SECOND SET OF NRC STAFF INTERROGATORIES Petitioner FRIENDS OF THE EARTH, Pursuant to 10 CFR S2.740 (b),
hereby subnits its responses to the NRC Staff's Second Set of Interrogatories, dated December 17, 1979.
INTERROGATORY 6 1
With reference to the " Answers of Petiticaers, 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 information.
A.
Describe in reasonable detail the meaning of the ~
phrase... "as that term is used in the penultimate paragraph of this response.
B.
Describe in reasonable detail the phrase... "fre-quency rate for AFW transient events..." as that term is used in the penultimate paragraph of this response.
C.
Prov'ide the reasons for FOE's contention that "...ex-plicit criteria for the acceptability, from a safety,,
standpoint, of the criteria and those frequency rates,... "
9 0 0s190 eM$ '
l PAGE 2 C.
are necessary to provide reasonable assurance that the Rancho Seco facility can be operated safely.
D.
Provide the rt
.ons for FOE's contention that the modifications
- the Rancho Seco facility as a result of the May 7, 1979 Order have "...resulted in an increased potential for more reactor trips and feed-watar transients. "
~
RESPONSE TO INTERROGATORY 6 A.B.C.
The phrase "... numerical criteria for B&W NSSS re-liability..."
as it is used by F.O.E.
in it's answer to NEC Staff Interrogatory No. 2 refers to the absence of quantitative criteria or analysis which could provica:
a.
A method of assessing the safety impact of any change in the NSSS or AFW system, b.
A diagnostic technique to locate and identify a qpx:llic failure or event by analyzing the failure systems and consequences, c'
A method of quantitatively computing the safety of NSSS and AFW systems, d.
Documented evidence that a complete s'fety analysis a
had been performed on the NSSS and AFW systems.
In short, to our knowledge, NRC does not presently have explict quantitative criteria from which to base a decision on the accepta-bility, unacceptability, or undesirability of the frequency rate for feedwater transients in B&W designs.
Our view has been that'if the NRC is going to refuse to provide explicit assurances to.the public that the modifications specified in the May orders are adequate to provide reasonable assurances of public health and
_j safety, then at least, it is NRC's responsibility to provide the criteria, both qualitative and quantitative, used by NRC to assess the acceptability of both decreased system reliability and the rate t
l PAGE 3 a
at which feedwater transients occur.
This is important because
~
the public seeks to understand the basis for NRC's decisions.
A skeptical public demands, and rightfully deserves, a full explana-tion for the agencies actions.
If that explanation is not forth-
[
E
{
coming, if there is no criteria, quantitative or otherwise, for v
accepting the known frequency rate of feedwater transients in f
B&W plants, the public lacks the assurances it seeks.
D.
The reason for this contention is quite clearly explained in an October 25, 1978 memo frcm NRC (Dention) to TVA (H.G. Parris),
enclosure 1, PRIMARY SYSTEM PERTURDATIONS INDUCED BY OTSG.
y INTERROGATORY 7 This Interrogatory deals with FOE's Answers to Interrogat6ry No.
4.
The staff does not understand the distinction drawn by FOE i
in its response to the NRC Staff. interrogatory requesting a defini-g tion of the term " facility management competence."
It appears to the NRC Staf f that the terms "... competent management of the Rancho
_4 Seco facility..." and "... competency of the management personnel responsible for the safe operation of the facility..." are essentially synonomous.
Please provide, in detail, FOE's basis
~
for asserting that these terms are distinct and separate.
2 RESPONSE TO INTERROGATORY 7
_s After consideration of initial discovery against licensee,
[
FOE is satisfied that " facility management competence" can be viewed under the single definition of "compentency of the management
I PAGE 4 personnel responsible for the safe operations of the facility."
INTERROGATORY 8
'This Interrogatory seeks information relative to the Answers of FOE to Interrogatory No. 5.
Provide the basis for FOE's contention that there is no
,,I i
"... clear ennunicaiton by the NRC of standards, criteria and J
procedures to determine operator competence,..."
RESPONSE TO INTERROGATORY 8 The Three Mile Island accident has thrown into turmoil the NRC'~s standards, criteria, and procedures to determine operation competence.
The President's Commission on Three Mile Island amply documents this fact.
At this point in time, it. appears that NRC standards, criteria, and~ procedures to determine operator competence are emerging and evolving.
We are simply stating that operator competence is hard to define when the very standards, criteria, and procedures are in such a severe state of flux.
With the completion of ERCDC operator depostions, we hope to identify with greater specificity the areas which in our estimation lack clarity.
S e
m e
4
PAGE 5 I declare under penalty of perjury that the foregoing
~
is true and correct.
)
bkd<-8 ? 'i
/h MICHAEL H.
REMY' f
Attorney for Petitioners
\\
T
\\
p
,s
\\
I kl
\\
N,\\ 'h MARK'VANDERVELDEN FRIENDS OF THE EARTH O
P er e
E e
__f:
b O
N K-F o
'CE
~
/,
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION S/
19
- N Y
g\\
-3 B FORE THE ATOMIC SAFETY AND LICENSING BOA.
J In the Matter 7f:
)
)
N SACRAMENTO MUNICIPAL UTILITY
)
DISTRICT
)
DOCKET NO. 50-312 (SP)
(Rancho Seco Nuclear Generating Station)
)
)
)
PROOF OF SERVICE I,
GABY L. WENDT, declare that on January 24, 1980, I deposited copies of the attached RESPONSE OF PETITIONER FRIENDS OF THE EARTH TO THE SECOND SET OF NRC STAFF INTERROGATORIES in the United States mail at Sacramento, California, with first class postage thereon fully prepaid and addressed to the following:
ELIZABETH L.
BOWERS, ESO.
' MR. MARK VANDERVELDEN ATOMIC SAFETY & LICENSING BOARD MS. JOAN REISS U.S. Nuclear Regulatory Commission MR. ROBERT CHRISTOPHERSON Washington, D.C.
20555 FRIENDS OF THE EARTH California Legislative Office DR. RICHARD F. COLE 717 K Street, Suite 208 ATOMIC SAFETY & LICENSING BOARD Sacramento, CA 95814 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 DOCKETING & SERVICE STATION OFFICE OF THE SECRETARY MR. FREDERICK J.
SHON U.S.
Nuclear Regulatory Comm.
. ATOMIC SAFETY AND LICENSING BOARD Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 MR. LAWRENCE BRENNER COUNSEL FOR NRC STAFF DAVID S.
KAPLAN, ESO.
U.S.
Nuclear Regulatory Comm.
SECRETARY AND GENERAL COUNSEL Washington, D.C.
20555 P O Box 15830 Sacramento, CA 95813 RICHARD D.
CASTRO 2231 K Street TIMOTHY V. A.
DILLON, ESQ'.
Sacramento, CA 95816 Suite 380 1850 K Street, N.W.
STEPHEN LEWIS M
Washington, D.C.
20006 OFFICE OF THE EXECUTIVE LEGAL DIRECTOR GARY HURSH, ESQ.
U.S.
Nuclear Regulatr/ry Comm.
520 Capitol Mall', Suite 700 Washington, D.C.
20555 Sacramento, CA 95814
f
.s EXECUTIVE DIRECTOR FOR OPERATION-THOMAS A. BAXTER 1800 M Street N.W.
U.S. Nuclear Regulatory Comm.
Washington, D.C.
20036 Washington, D.C.
20555 JAMES S.
REED, ESQ.
CHRISTOPHER ELLISON, ESQ.
MICHAEL H.
REMY, ESQ.
California Energy Commission REED, SAMUEL & REMY 1111 Howe Avenue 717 K Street, Suite 405 Sacramento, CA 95825 Sacramento, California 95814 MR. LARRY LANPHER, ESO.
ATOMIC SAFETY & LICENSING BOARD HILL, CHRISTOPHER, & PHILLIPS 3
U.S. Nuclear Regulatory Commission Attorneys at Law
[
Washington, D.C.
20555 1900 M Street, N.W.
t Washington, D.C. 20036 ATOMIC SAFETY & LICENSING BOARD APPEAL PANEL U.S. Nuclear Regulatory Commission Washington, D. C. 20555 3
5
-r I am, and was at the time of the service o'f the attached document over the age of 18 years and nota party to the proceeding j
involved.
I declare under penalty of perjury that the foregoing is true and correct.
l,.
- . m { s GABY L. WENDT
.)
r 5
s M
T E
S O
9
%