ML19254B063
| ML19254B063 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/21/1979 |
| From: | CITIZENS FOR FAIR UTILITY REGULATION |
| To: | |
| Shared Package | |
| ML19254B062 | List: |
| References | |
| NUDOCS 7909240022 | |
| Download: ML19254B063 (3) | |
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COMA!;CllE PEAK STEA?! ELECTRIC STAT 10 (CPSES)
Citizens for Fair Utility Refyilation (CFUP.) Cont entions
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Contention I .
Applicants have not demonstrated t.echnical quali fications to operate CPSES in accordance with 10 Crn fiS0.59(a)(4) in that they have relied upon West ing-
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house to pre pare a portion of the Final Safety Analysis Report (FSAR).
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t Contention II.A One or more of the reports us(d in the construction of couputer codes for the CPSES/FSAR have not been verified and fornally accepted; thus conclusions based upon these conputer codes are invalid.
,1losi t i on TU S I
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EmlEnti_on 11. B_
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Contention III.A Some accident sequences heretofore considered to have probabilities so low a r. to be considered incredible based upon the findings of WAsil--1400, are in
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A Key:
- A = Admissible as to wording,and substance
. A (U) = Admissible as to wording only 7909240o %(z ,_
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- 2 fact core probable in light of the findfug< of the Lewis Con ::it t ee and should In order to insure conservatisn, be evaluated as credible accidents for CPSES.
the probabilities associated with such accident sequences should be the highest prohr:hilities within the speelfied confidence band.
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A (k') A (W) A C,on ty n_t i on llI . li Deferred.
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Cont ention IV The Applicants have failed to entnblish and execute a quality assurance / quality control program which adheres to the criteria in 10 CFit 50, Appendi:. U. Appli-cants have f a i.l ed t o den.onst ra te sufficient uanagerial and administ rat ive control to assure safe operation as required in 10 CPR Pai t 50, Appendix E.
Therefore, special operating conditionu nhould be required.
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Contention V There is no assurance that the Spent Fuel Pool area can withstand the effects of t ornadoes, ar required by 10 CFR Part 50, Appendix A, Criterion 2 becaune: .
- a. The analyces upon which the Design Basis Tornado (DP,T) is based are perfunctory, outdated and unreliable;
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- b. The loading analyses based on t he Den i p,n Eas i s Tor nado (DBT) are inappropriate because they fall to consider ,n,
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the potential loading conbination of the DBT and a tornado-generated missile.
- c. The assignment of a loading factor of 1.0 for load cou-bination equationa incorporat ing t ornado loadings in corbination with "nornal and accident conditionn" in .
unacceptable,
- d. The DST parawters used in FSAR Section 3.3.2.1 are less connervative than the paraneters found in NRC Regulatory Guide 1.76 c.2.
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Centention VI App [icantshave failed to adequately evaluate whether the rock "overbreak" and subsequent fissure repair using concrete grout have impaired the ability of Category I structuren to withstand seisnic disturbances.
P_o n i t i on.
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Coatont_fon VII_
Uithdrawn.
Contention Vill (former IV.D.)
Applicants have failed to adequately evaluate the impacts of the drawdown of the groundwater under CPSES during and as a result of plant operation.
fSS.i t ion
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