ML19249D659
| ML19249D659 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/17/1979 |
| From: | Castro R, Hursh G AFFILIATION NOT ASSIGNED, SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | |
| References | |
| NUDOCS 7909250166 | |
| Download: ML19249D659 (7) | |
Text
q
-y
-}-
t AUG221979 7 %
~
I UNITED STATES OF AMERICA T;j, C W b
5"
/
NUCLEAR REGULATORY COMMISSION In the Matter of:
)
u3
)
SACRAMENTO MUNICIPAL UTILITY DISTRICT
)
Docket No. 50-312
)
Rancho Seco Nuclear Generating Station )
CONTENTIONS OF PETITIONERS GARY HURSH AND RICHARD CASTRO 1.
Rancho Seco, being a Babcock and Wilcox designed reactor, is unusually sensitive to off-normal transient conditions originating in the secondary system, and therefore it is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
2.
Rancho Seco, being a Babcock 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 endancers the health and safety of Petitioners, constituents of Petitioners and the public.
3 Rancho Secc, being a Babcock and Wilcox designed reactor, has a lack of direct initiation of reactor trip upon the occurrence of off-ncrmal conditions in the feedwater system, and therefore is unsafe and endangers the health and safety of Petitioner, constituents of Petitioners and the public.
4.
Rancho Seco, being a Babcock and Wilcox designed reactor, has a reliance en integrated control system to automatic &ily regulate feedwater flow, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
5 Rancho Seco, being a Babcock and Wilcox designed reactor, has an actuation before reactor trip of a pilot operated relief valve on the pr* mary system pressuriser anich, if the valve sticks open, can
' m u s o t u, 1024 115
aggrevate an accident, and'therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
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 the health and safety of Petitioners, constituents of Petitioners and the public.
7 Rancho Seco, being a Babcock and Wilcox designed reactor, has insufficient timeliness and reliability of the emergency feed-water system, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
8.
Rancho Seco, being a Babcock and Wilcox designed reactor, does not have operating procedures for initiating and controlling the emergency.eedwater system independent of the integrated control system control, and therefore is unsafe and endangers the health and safety of Fetitioners, constituents of Petitioners and the public.
9 Rancho Seco, being a Babcock and Wilcox designed reactor, has not installed adecuate hard-wire control grade reactor trip on loss of main feedwater and/or on turbine trip, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
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 endancers the health and safety of Petitioners,
_2_
1024 ii6
constituents of Petitioners and the public.
11.
SMUD, the licensee, has not upgraded emergency plans to satis fy Regulatory Guide 1.101 with special attention to action level criteria based on plant perimeters, and therefor Rancho Seco is unsafe and endangers the health and safety of Petitioners,
constituents of Petitioners and the public.
12.
SMUD, the licensee, has not established an emergency operation center for federal, state and local officials and designed a location and an alternate location and provided communications to the plant, and therefore Rancho Seco is unsafe and endangers the health and safety of Petitioners, constituents and the public.
13 SMUD, the licensee, has not sufficiently upgraded off-site radiation monitoring capability, including additional thermoluminescent dosimeters or t,he equivalent, and therefore Rancho Seco is unsafe and endangers the health and safety of Petitioner, constituents of Petitioners and the public.
lh.
SMUD, the licensee, has not assessed the relationship of state / local plans to the licensee plans so as to assure the capability to take emergency actions, and therefore Rancho Seco is unsafe and endangers the health and safety of Petitioners, constituerts of Pe toners and the public.
15 SMUD, the licensee, has inadequate waste management capabilities, including storace and processing for solid, liquid and gaseous wastes in the event of a loss of feedwater transient, and therefore Ranche Seco is unsafe and endancers the health and safety of Petitioners, constituents of Petitioners and the public.
16.
SI!UD, the licensee, has done insufficient analysis of the failure mode and effects analysis of the integrated control system, 1024 Ii7
700RORfaR and therefore Rancho Seco' is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
17 SMUD, the licensee, has not modified emergency plans to address changing capabilities of plant instrumentation, and therefore Rancho Seco is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
18.
SMUD, the licensee, has not extended the capability to take appropriate emergency actions for the population around the plant site to a distance of ten miles, and therefore Rancho Seco is unsafe and endangers the health and safety of Petitioners, constituents and the public.
19 SMUD, the licensee, has not developed and implemented adequate evacuation plans and procedures which would be necessary in the event of an accident caused by a loss of feedwater transient, and therefore Rancho Seco is unsafe and endangers the health and safety of Petitioners, constituents of Pet'
.ers and the public.
20.
Rancho Seco, being a Babccck and Milcox designed reactor, does not have a hydrogen recombiner which may be necessary in the event of an accident caused by a loss of feedwater transient, and therefore is unsafe and endangers the health and safety of Petitioners,
constituents of Petitioners and the public.
21.
Fancho Seco, being a Babcock and Wilcox designed reactor, has a pressurizer tank and quench tank which are of inadequate size to accomodate the volume of gas or liquid that may be required to be stored in the event of a less of feedwater transient, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the nublic.
22.
Rancho Seco, being a Babcock and Wilecx designed reactor,
. 1024 i13
P001 D N ll does not provide contol room operators with sufficient data on the water level in the pressuriser and vessel because the operators must interpret information on temperature and pressure in the primary loop and extrapulate water level, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
23 SMUD, the licensee, has inadquate notification procedures for informing local authorities in the event of a loss of feedwater transient, and therefore Rancho Seco is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
24.
Ranco Seco, being a Babcock and Wilcox designed reactor, is unable to avoid or control bubble formation in the primary system which may occur subsequent to a loss of feedwater accident, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
25 Rancho Seco, being a Babcock and Wilcox designed reactor, does not have control room instrumentation 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 of Petitioners and the public.
26.
Rancho Seco, being a Babcock and Wilcox designed reactor, has a once through steam generator which makes
-hc plant more susceptible and sensitive to a loss of feedwater transient, and therefore is unsafe and endancers the health and safety of Petitioners,
constituents af Petitioners and the p;blic.
27 Hancho Seco, being a Babcoel-and Wilcox designed reactor, 1024 1i?
P9(a DR M cannot be adequately opchated so that the feedwater system and the auxiliary aystem can be controlled and operated separately, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
28.
Rancho Seco, being a Babcock and Wilcox designed reactor, does not have sufficient or reliable off-site power in the event of a loss of feedwater transient causing a reactor trip, and there-fore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
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, constituents of Petitioners and the public.
30.
SHUD, the licensee, has conducted insufficient analysis of what operations of the facility should be required to be automated cr hard equipment responsibilites and what can be conducted manually or by plant personnel, and therefore Rancho Seco is unsafa and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
31.
Rancho Seco, being a Babcock and Wilco:. designet reactor, has a control room confi$uration which is poorly and inadequately designed for plant operators to avoid a loss of feedwater transient, and therefore is unsafe and endancers the health and safety of Peticioners, constituents of Petitioners and the public.
1 32.
Rancho Seco, being a Babecek and Wilcox designed reactor, is operated by personnel and management whose competence has not oeen adequately tested and evaluated, namely testing has not been 1024 120
-e-
P00R ORIGINAL conducted as to whether such employees can act responsibly and appropriately to make judgment decisions during a loss of feedwater transient, personnel interviews have not been conducted to properly evaluate the test results with such employees and some employees have never been tested because of grandfathering, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
33 SMUD, the licensee, cannot be assured of necessary assistance from the Nuclear Regulatory Commission in the event of a loss of feedwater transient because of the Nuclear Regulatory Commission's failure to act quickly and decisively during the TMI-2 accident, and therefore Rancho Seco is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
34.
Rancho Seco, being a Babcock and 'dilcox designed reactor, has not adequately trained unlicensed operators to respond to orders necessary for action which would be' required in t.he event of loss of feedwater transient, and therefore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
CONCLUSION Petitioners offer as evidence of the adequacy of the above contentions, the order and notice of hearing in Docket No. 50-346 for Three Mile Island Nuclear Station, Unit No.
1.
These contentions are subnitted on behalf of GARY HURSH and RICHARD D.
- CASTRO, Petitioners.
Submitted, l
7y
/9 Uu J'. r
! 7,
/ 't,7 y l
I d h'
~
v h' %d.fy GARY HURSH,/ Petitioner Menber Board of Directors Sacramento Municipal Utility District
j I
CERTIFICATE OF SERVICE L.
Michael L. Glaser, Esq., Chairman Atomic Safety and Licensing 1150 17th Street, N.W.
Board Panel Washington, D.C.
20036 U.
S.
Nuclear Regulatory Commissiot Washington, D.
C.
20555 Dr. Richard F.
Cole Atomic Safety and Licensing Atomic Safety and Licensing board Panel Appeal Board Panel U.S. Nuclear Regulatory Commission
- d. S. Muclear Regulatory Commissior Washington, D.C.
20555 Washington, D. C.
20555 David S.
Kaplan, Esq.
Doci:eting and Service Station Secretary and General Counsel Office of the Secretary Sacramento Municipal Utility District U. S. Nuclear Regulatory Commissio:
P.O. Box 15830 Washington, D.
C.
20555 Sacramento, California 95813 Lawrence Brenner, Esq.
Timothy V.
A.
Dillon, Esq.
Stephen H.
Lewis, Esq.
Suite 380 U. S. Nuclear Regulatory Commissiot 1850 K Street, N.W.
Washington, D.
C.
20555 Washington, D.
C.
20006 Mr. Frederick J. Shon Mr. Richard D. Castro Atomic Safety and Licensing 2231 K Street Board Panel Sacramento, California 95816 U.
S.
Nuclear Regulatory Cunmissio:
Washington, D.
C.
23555 James S.
Reed, Esq.
Michael H.
Remy, Esq.
c-l Q Reed, Samual & Remy p
g 717 K Street, Suite 405 V
Sacramento, California 95814 spc hg2,7 j#*
Christopher Ellison, Esq.
Dian Grueneich, Esq.
5 1
cQ h,.%
Y California Energy Commission 1111 Howe Avenue g
s Sacramento, California 95825 j
I, Elisabeth Leep, declare that on August 17, 1979 I forwarded a true and correct copy of the Contentions of Petitioners Gary Hursh and Richard Castro to the parties above-named.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this 17th day of August, 1979, at Sacramento, California.
X' k R.,,G #i-
.c_./
1024 i
2