ML20040F364

Proposed Contentions in Light of SER Suppl 3

ML20040F364
Person / Time
Site:	Black Fox
Issue date:	02/01/1982
From:	Farris J CITIZENS ACTION FOR SAFE ENERGY, FELDMAN, HALL, FRANDEN, REED & WOODWARD
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20040F365	List: ML20040F364 ML20040F374
References
ISSUANCES-CP, NUDOCS 8202090120
Download: ML20040F364 (3)

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s DOCXETE3 Uync UNITED STATES OF AMERICA *82 FEB -5 All :30 a NUCLEAR REGULATORY COMMISSION O <g BEFORE THE ATOMIC SAFETY AND LICENSINGtBOARD p Qg

' .D k In the Matter of the Application of ) SQl gg Sdg 2 Public Service Company of Oklahoma, Associated Electric Cooperative, Inc.

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Western Farmers Electric Cooperative )

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Docket Nos.

STN 50-556CP

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(Black Fox Units 1 and 2) ) STN 50-557CP INTERVENORS' PROPOSED CONTENTIONS IN VIEW OF SUPPLEMENT NO. 3 TO THE SAFETY EVALUATION REPORT Pursuant to the Board's Order of October 14, 1981, Intervenors respectfully propose the following contentions in light of the Safety Evaluation Report ("SER") Supplement No. 3, related to the construction of Black Fox Station, Units 1 and 2.

Intervenors submit that the following contentions should be the subject of evidentiary hearings as challenges to the Staff's review of the Applicants ' response to'NRC Licensing requirements arising out of the TMI-2 accident.

CONTENTION NO. 1:

The SER is deficient because the Applicants' analysis and evaluation did not include the effects of psychological stress on the people within the 10 and 50 mile emergency planning zones; nor did they determine how this may impact 3 D s 8202U90120 820201 PDR ADOCK 05000556 PDR O

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the validity of the Applicants' estimates of evacuation time.

Thus, there is no assurance the Applicants' plan can comply with 10 CFR 50, App. E, Part II requirements.

CONTENTION NO. 2 The SER is deficient because it has not included the Applicants' analysis or the NRC's evaluation of the impact of the announced plan of the General Electric Company to phase out of the nuclear hardware supplier business by 1986. Thus, the

Applicants' plans to rely on General Electric's licensing department, service organization and engineering organization for technical feedback and research and development cannot be relied upon to show compliance with TMI Issue I.C.5 and 10 CFR

50. 34 ( f) (3) (i) .

CONTENTION NO. 3:

The Applicants' assertion and the SER conclusion of ade-quacy of the hydrogen control system for degraded core accident lacks basis and design and/or testing and thus does not provide i

reasonable assurance or compliance with 10 CFR 50. 34 (f) (3) (v) .

CONTENTION NO. 4:

The SER is deficient in the findings regarding automatic restart of LPCI and LPCS (TMI Issue II. (k) ( 3) (21) ) . The Applicant has not prevented the situation (and the NRC has not justified the acceptability of the alternative) where the operator has manually turned of the LPCI and LPCS and thus precluding their operation when vessel water level returns to a low level. Thus, 2

o there is no assurance of compliance with 10 CFR 50.34 (f) (1) (viii) .

CONTENTION NO. 5:-

The final rules against which the Applicants' response must be evaluated has not been issued and thus there is no assurance that the PSAR and the SER cover all the necessary TMI-II issues, thus there is no assurance of the safety of the Black Fox design. (See Supplement No. 3 to SER 1. l(p.1-2).

Respectfully submitted,'

FELDMAN, HALL, FRANDEN & WOODARD By I seph/R. Farris 816 erprise Building Tulsa, OK 74103 ATTORNEiS FOR INTERVENORS r

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