ML20049H895

Motion for Admission of New Contention.New Info Re Normal & Emergency Operating Procedures Revealed Per Board Notification 82-7.Mgt Issues Already at Issue.Certificate of Svc Encl

ML20049H895
Person / Time
Site:	Summer
Issue date:	02/24/1982
From:	Bursey B BURSEY, B.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8203040447
Download: ML20049H895 (4)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY & LICENSING BOARD 2 k '/ /! 7-g -] ' "

In the Matter of: )

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' SOUTH CAROLINA ELECTRIC & )

GAS COMPANY, et 61. ) Docket No. 50-395-OL

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(Virgil C. Sumer Nuclear Station, # ^

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Unit 1 ) Fu.

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c [,}*i 'k O 198f. f Motion for Admission of New Contention b $[Q?

Because of new information which has only just come into my adOlb78

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Board Notification BN-82-7 about the normal and emergency operating procedures of the Summer plant, I move that a new contention be admitted and considered in the Operating License proceedings for the V.C. Summer plant.

On February 6,1982, I received in the mail a copy of a Board Notifica-tion (BN-82-7), dated January 28, 1982. That Board Notification reported on a trip by M. S. Medeiros, Jr. , then of the NRC's Human Factors Branch of the Office of Nuclear Regulatory Research, to the Summer plant and his conclusions that the normal and emergency operating procedures .were so " inept" that they

" invite operator error." That report also raises serious questions about the Applicant's manaaement of the operations of. the plant and their commitment to running it in the interest of safety rather than economy.

Therefore, I move that the following contention be admitted and considered:

CONTENTION -

The Applicant and the NRC Staff cannot provide reasonable assurance that t,he Summer plant can be operated without endangering the health and safety of the public because the normal and emergency operating procedures are so badly done that they invite operator error, SCE&G's management has shown W:

8203040447 820224 f PDR ADOCK 05000395 Q PDR

that it does not follow up well enough to ensure that procedures are correct and that they are followed, and SCE&G management has demonstrated through its operating procedures that it places economic concerns before safety. The emergency operating procedures do not meet the Commission's post-TMI requirements in NUREG 0737. Relying upon changes early in the plant's life, as the Staff would do, provides no reasonable assurance of the health and safety of the public in that the TMI accident clearly proved that bad operating procedures under normal and emergency operating con-ditions could cause a severe accidenti early in plant life.

I believe that this contention sould be heard as required by 10 CFR 2.714(a)(i).

This trip report only came into my hands on February 6,1982. Until that time, I had no access to the operating procedures manual at the plant and could not have known, for example, that known uncorrected errors existed, that there were informal hand-written changes in those procedures, or that SCE&G manage-ment was not ensuring that written procedures were followed. I believe that I have good cause for filing this contention now.

I know of no other means to protect my interest than by having this conten-tion heard. The Staff analysis is so daulty that it cannot be relied upon.

Discovery of these problems appears to have been nearly accidental on Mr. Medeiros' part. They did not result because of a normal staff review or audit.

SCE&G has shown in its public r.ronouncements that it does not take human factors engineering seriously, since their representative, Buddy Clack, told the newspapers that "His (Medeiros) primary concern was with the colors in the control room. Are the dials pretty? Are they easy to read - cosmetic things."

Columbia Record, February 10, 1982, p. 2-C. -0bviously, a' company which hasn't figured out the significance of human factors can't be relied upon to cerrect these deficiencies. I As the only intervenor in this case, no other' party can represent my interests.

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This contention does not broaden the issues any because the Board has already raised a question ab.out SCE&G's management attitudes, since this is its first nuclear plant. Some testimony was giver on that natter, but this contention raises a~new aspect of the issue. The Ecard cannot make a sound decision on I

i the Applicants' management attitudes and abilities without thoroughly exploring this matter and hearing testimony from Mr. Medeiros and others. Otherwise, the

] record in this case will be incomplete.

Should having 'more hearings cause any delay, I cannot be held responsible.

I' acted as soon as I had this new inforration available. If the Staff had done j,

an adequate job of reviewing the Summer olant procedures earlier, this conten-

, tion could have been filed earlier. But I should not be charced with any delay which is not my responsibility.

The Applicant has con-inually tried to convince the Board "of the 4

tremendous costs which it faces from delay. However, since the Applicants keep putting off completion date for the plant, the Board should not believe

any claims for cost of delay. The Board has no reason to believe any estimate i of a completion date.

For these reasons, I move that this new contention be admitted and considered..

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( W Brett_Bursey, Intervenor I 5

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UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION 2 v -

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ATOMIC SAFETY AND LICENSIftG BOARD In the flatter of: )

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SOUTH CAROLINA ELECTRIC & )

GAS COMPANY, et_ _al. ) Docket No. 50-395-OL

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(Virgil C. Summer Nuclear )

Station, Unit 1 )

CERTIFICATE OF SERVICE I hereby certify that copies of Intervenor's " Motion for Admission of New Contention" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, on this 24th day of February 1982:

Herbert Grossman, Esq. , Chairman Joseph B.' Knotts, Jr. , Esq.

Administrative Judge Debevoise.& Liberman -

Atomic Safety and Licensir.g Board 1200 17th Street, N.W.

U.S. Nuclear Regulatory Ccamission Washington, D.C. 20036 Washington, D.C. 20555 t George Fischer, Esq.

Dr. Frank F. Hooper Vice President & Group Executive Administrative Judge S.C. Electric & Gas Co.

School of Natural Resources P.O. Box 764 University of Michigan 43109 Columbia, S.C. 29218 Mr. Gustave A. Linenberger Randolph Mahan, Esq.

Administrative Judge Se C. Electric & Gas Co.

Atomic Safety and Licensing Board 100 S. Main Street U.S. Nuclear Regulatory Cc nission Columbia, S.C. 29201 Washington, D.C. 20555 '

Chairman, Atomic Safety and Licensing Board Chairman, Atomic Safety and Licensing Panel Board Panel U.S. Nuclear Regulatory Commission' U.S. Nuclear Regulatory Co mission Washington, D.C. 20555 Washington, D.C. 20555 T L

fir. Chase R. Stephens 4' .

Richard 'P. Wilson, Esq. /

Docketing and Service Section Assistant Attorney General Office of the Secretary ,

- S.C. Attorney General's Office U.S. Nuclear Regulatory Commission

P.O. Box 11549 Washington, D.C. 20555 ^

Columbia, S.C.

29211 John C. Rupff '

Steven C. Goldberg Esq. _P.O. Box 96 ,

Office of the Executive Lecal Jenkinsville, S.C. 29065 Director U.S. Nuclear Regulatory Co :nission Robert Guild, Esq. r.

Washington, D.C. 20555 314 Pall Mall Q Q ,,

Columbia, S.C. 29201 Brett Bursey, Intervenor

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