ML20005A998

Statement of Matl Facts Not Genuinely in Issue Re Atws. Westinghouse Design Has Inherent Mitigation Capabilities & Satisfies NRC Requirements.Kaku Testimony Does Not Address Probability or Risk of ATWS

ML20005A998
Person / Time
Site:	Summer
Issue date:	05/07/1981
From:	SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20005A994	List: ML20005A993 ML20005A998 ML20005B000 ML20005B001 ML20005B002
References
ISSUANCES-OL, NUDOCS 8107060190
Download: ML20005A998 (3)

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Date: May 7, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of:

SOUTH CAROLINA ELECTRIC AND )

GAS COMPANY, et al. ) Docket No. 50-395-OL

)

(Virgil C. Summer Nuclear )

Station, Unit 1) )

APPLICANTS' STATEMENT OF MATERIAL FACTS NOT GENUINELY IN ISSUE

1. Applicants and their NSSS supplier, Westinghouse, have addressed ATWS in the FSAR and correspondence and references therein as well as in the reports and analy-ses referenced in the affidavits submitted herewith.

2. The attached affidavits and the references therein tend to show that the Summer design, operating proce-dures and training render full power operation accept-1 I able in satisfaction of NRC ATWS requirements pending further rulemaking action, and that identified modific-ations can be readily made if required by such rulemaking.

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3. The NRC Staff has analyzed the generic safety issue of I ATWS for Westinghouse plants as reported in NUREG 0460 1

and SECY-80-409, noting that the Westinghouse design has inherent ATWS mitigation capability, and concluded that while additional features might be required as a matter of prudence, that this be made the subject of rulemaking and that operation and issuance of new licenses could 8107060190 810507.-

PDR ADOCK 05000395 PDR G

continue, subject to recommended and appraved training and procedures, pending initiation, conduct, and comple-tion of rulemaking, which is not scheduled to begin until mid-1981. See NUREG 0717 515.3.5 and NUREG 0717 Supp.1, Appendix C.

4. The NRC Staff has analyzed the ATWS issue for Summer and concluded that with procedures and training which it has required and approved, the Summer plant meets existing NRC ATWS requirements and can be licensed for full power operation pending the ATWS rulemaking, and further that Applicant will be required to meet such requirements as emerge therefrom. NUREG 0717 $15.3.5 and NUREG 0717 Supplement 1, Appendix C.

5. Contention A3 states:

, "The Applicant has not met the requirements of the NRC Staff to assure that the probability of occurrence of an ATWS event is acceptably small."

6. Intervenor Bursey was under a Board order of December 30, 1980 to reveal any direct evidence in support of, inter alia, his contention A3 regarding ATWS by January 31, 1980.

7. The only proposed evidence identified by intervenor Bursey in regard to his ATWS contention is a portion of the statement he distributed on April 7, 1981 as i

being a summary of the testimony of one Michio Kaku.

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8. The summary of Dr. Kaku's testimony consists of a very brief and general statement of possible ATWS conse-quences and does not reveal that he has conducted any analysis of ATWS for Cummer, or for that matter, of Westinghouse PWR's of the Summer type.

9. The summary of Dr. Kaku's testimony does not address the probability or risk of ATWS for Summer nor show that NRC requirements are not met nor, in any event, contradict any of the matters covered in statements 1-4 above.

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