ML19257C154

Response to Jf Doherty Tenth Set of Interrogatories.Includes Statements Re Failure of Facility Safety Relief Valves During Operation.Jg White Affidavit & Certificate of Svc Encl

ML19257C154
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	01/11/1980
From:	Biddle C, Copeland J, Culp R, Newman J, Jason White BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Doherty J DOHERTY, J.F.
References
NUDOCS 8001250071
Download: ML19257C154 (12)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S

HOUSTON LIGHTING & POWER S COMPANY $ Docket No. 50-466 S

(Allens Creek Nuclear S Generating Station, Unit S No. 1)

APPLICANT 'S RESPONSE TO JOHN F. DOHERTY 'S TENTH SET OF INTERROGATORIES In response to the interrogatories propounded by John F. Doherty, Houston Lighting & Power Company (Applicant) answers as follows:

INTERROGATORY NO. 10-1:

Does Applicant currently maintain that none of the data listed in NUREG-0462, on failure of BWR safety-relief valves (SRVs) to open during operation (see text of Doherty Contention 17) apply to the valves it plans to use as SRVs at ACNGS?

RESPONSE

Yes.

INTERROGATORY NO. 10-2:

If the answer to 10-1 (above) is "yes" state the basis for believing this so, please.

RESPONSE

To the best of Applicant's knowledge, valves of the ACNGS design have never failed to open when calleduponforsafetyreliefoperationsinanyap0lication.

181 082 8001250 0 7/

INTERROGATORY NO. 10-3:

Are all Applicant's.SRVs. manufactured by Crosby?

RESPONSE

Yes.

INTERROGATORY NO. 10-4:

Are the SRVs all the same in design and size?

RESPONSE

Yes.

INTEF ROGATORY NO. 10-5:

Does Applicant maintain that the data cited in Doherty Contention 17 on valves cited in Nuclear Safety 19(1) pg. 82, and 20 (1) pg. 84, does not include SRVs?

RESPONSE

See response to Interrogatory No. 10-2.

INTERROGATORY NO. 10-6:

Does Applicant maintain the design of its SRVs cannot be shown to have ever failed to operate properly up to this time?

RESPONSE

See response to Interrogatory No. 10-2.

INTERROGATORY NO. 10-7:

Does Applicant maintain that SRVs manufactured by Crosby for ACNGS have a history of no failure in operation in (a) any application?

1810 083

(b) use with BWRS?

RESPONSE

See response to Interrogatory No. 10-2.

INTERROGATORY NO. 10-8:

Will Applicant's SRVs have any operating history by April 1980, a hypothetical date for the licensing hearing?

RESPONSE

Yes.

INTERROGATORY NO, 10-9:

Of what material is the " disc" marufactured as shown in Fig. 5.2-6 (Amendment 26) " Schematic of Safety Valve with Auxilliary Actuating Device?"

RESPONSE

Inconel 718.

INTFdROGATORY 10-10 :

Does Applicant maintain no SRVs of the decision used in ACNGS are included among those that failed listed in NUREG-0462?

RESPONSE

See response to Interrogatory No. 10-1.

INTERROGATORY NO. 10-11:

Does Applicant maintain that the pilot solenoid of the variety incorporated in the design of the Phipps Bend BWR has nothing t? do with the proper functioning with the SRVs or performing the safety relief function of the ACNGS SRVs?

1810 084

RESPONSE

Yco.

INTERROGATORY NO. 10-12:

Does Applicant take the position that the Dutt-Baker correction factor for Fission gas release (FGR} in the BWR has included all the relevant variables for accurate prediction of clad temperature during a LOCA over all expected fuel exposure (burn-upT ?

RESPONSE

No.

INTERROGATORY NO. 10-13:

If not, does Applicant contedd fuel temperature is irrelevant in determining FGR? (Contention 20)

RESPONSE

No.

INTERROGATORY NO. 10-14:

Does Applicant maintain none of the doses calculated for isotopes of Xenon were exceeded at the Three Mile Island-2 (.TMI-2) accident?

RESPONSE

The information available to Applicant indicates that 10 CFR Part 100 doses were never exceeded anytime during or after the TMI-2 incident.

INTERROGATORY NO. 10-15:

Has Applicant relied en any NRC regulatory guide in calculating the dosage of radioactivity to individuals as required by 10 CFR 100.11 (a) (2)?

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Cal If so, which one?

(bl If not, what' sources were used to make this calculation?

RESPONSE

Yes.

(a) Reg. Guide 1. 3, Rev. 2.

(bl Not applicable.

INTERROGATORY NO. 10-16:

Has Applicant recalculated or checked its release calculations for any design based accidents since the unexplained greater than calculated release of radioactivity at the TMI-2 accident, March, 1979?

(a) If so, has the PSAR been amended?

(b) If the answer to 10-16 (a) is "yes" has that been placed in the PSAR at the Houston Public Library or is it available at Applicant's Energy Center? ,

(c) Have any of the assumptions used to calculate radioactivity releases for design based accidents (DBAs) been changed

1. As a result of orders by the NRC?

2. On Applicant's initiative?

RESPONSE

No.

(a) No.

Cb). Not applicable.

(cl No.

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INTERROGATORY NO. 10-17:

Will Applicant be in full compliance with Regulatory Guide 1.37, " Quality Assurance Requirements for Cleaning of 'J1uid Systems and Associated Components of Water-Cooled Nuclear Power Plants?

RESPONSE

Yes.

INTERROGATORY NO. 10-18:

Of what material will the piping in the following systems he made in the ACNGS?

(a) Residual heat removal system (RHR) .

(b) Emergency core cooling sistem (ECCS).

(c) Feedwater.

(d) Mainsteam line.

RESPONSE

(a) ASTM 106 Grade B and 304L.

(b) ASTM 106 Grade B and 304L.

(c) ASTM 106 Grade B and A155-KC 65.

(d) ASTM 106 Grade B, A155-KF70, and A155-KC65.

INTERROGATORY NO. 10-19:

What changes (if any) have been made in the materials for the four systems listed above, since the SER (Nov. 197 4) ?

RESPONSE

Some piping in the RHR system was changed from 304 to 304L.

l810 087

INTERROGATORY NO. 10-20:

Rave any changes been made to reduce aeration of coolant since November, 1974?

(a)_ If the answer is "yes" please describe the changes.

(bl If the answer is "yes" describe using a quantitative estLmatr 'r calculation what percent the decrease.i. ,.' the total aeration, please.

RESPONSE

No.

(a) Not applicable.

Ob) Not applicab"e.

INTERROGATORY NO. 10-21:

Does Applicant maintain that none of the compounds identified in contention 43 will be used to clean or coat stainless steel in the ACNGS?

(a) If not, please indicate wnich of the list will be used in either capacity, please.

RESPONSE

Yes.

(a) Not applicable.

INTERROGATORY NO. 10-22:

During 1978 did Applicant receive any electric power from Gulf States Utilities which it sold to customers?

RESPONSE

No.

~ ~ '

l810 088 e

INTERROGATORY NO. 10-23:

During 19.79, did Applicant receive any electric power from Gulf States Utilities which it sold to Customers?

RESPONSE

No.

All documents requested.are.available.for inspection and copying at Applicant's Engineering Development Complex.

To date, no expert witnesses have been identified to testify on the subject matter contained in these inquiries.

Respectfully submitted, OF COUNSEL: J. Gregory Copeland C. Thomas Biddle, Jr. [/

BAKER & BOTTS Charles G. Thrash, Jr.

3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Avenue, N.W. 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 Washington, D.C.

ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY 1810 089

STATE OF TEXAS S S

COUNTY OF HARRIS S BEFORE ME, the undersigned authority, on this day personally appeared Jon G. White, who upon his oath stated that he has answered the foregoing Applicant's Response to John F. Doherty's Tenth Set of Interrogatories to Houston Lighting & Power Company in his capacity as Supervising Engineer for Houston Lighting & Power Company, and all statements contained therein are true and correct to the best of his knowledge and belief.

.Y

(/ Jon G. Wh.tte SUBSCRIBED AND SWORN TO BEFORE ME on this the

// day of January, 1980, bfb $ $/l )

MOTARY PUBLIC IN AND FOR HARRIS COUNTY, T E X A S Cheryl A. Southworth My Commission Expires 8/19/81 1810 090 -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY 5 Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Applicant's Response to John F. Doherty's Tenth Set of Interrogto'ies r in the above-captioned proceeding were served on tne following by deposit in the United States mail, postage prepaid, or by hand-delivery this /lYk day of Juous llA , 1980.

J Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq.

Atomic Safety and Licensing Assistant Attorney General Board Pt.nel for the State of Texas U.S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D. C. 20555 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. Charles J. Dusek Watkinsville, Georgia 30677 Mayor, City of Wallis P. O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 Atomic Safety and Licensing Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission County Judge, Austin County Washington, D. C. 20555 P. O. Box 99 Bellville, Texas 77418 Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of the Appeal Board Commission U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 R. Gordon Gooch, Esq. Atomic Safety and Licensing Baker & Botts Board Panel 1701 Pennsylvania Avenue, N. W. U.S. Nuclear Regulatory Washington, D. C. 20006 Commission Nashington, D. C. 20555 1810 091

Steve Schinki, Esq. Carolina Conn Staff Counsel 1414 Scenic Ridge U.S. Nuc1 car Regulatory Commission Houston, Texas 77043 Washington, D. C. 20555 Elinore P. Cumings Jchn F. Doherty Route 1, Box 138V 4327 Alconbury Street Rosenberg, Texas 77471 Houston, Texas 77021 Stephen A. Doggett, Esq.

Robert S. Framson P. O. Box 592 Madeline Bass Framson Rosenberg, Texas 77471 4822 Waynesboro Drive Houston, Texas 77035 Robin Griffith 1034 Sally Ann Carro Hinderstein Rosenberg, Texas 77471 8739 Link Terrace Houston, Texas 77025 Leotis Johnston 1407 Scenic Ridge D. Marrack Houston, Texas 77043 420 Mulberry Lane Bellaire, Texas 77401 Rosemary N. Lemmer 11423 Oak Spring Brenda McCorkle Houston, Texas 77043 6140 Darnell Houston, Texas 77074 Kathryn Otto Route 2, Box 62L F. H. Potthoff, III Richmond, Texas 77469 7200 Shady Villa, #110 Houston, Texas 77055 Frances Pavlovic 111 Datonia Wayne E. Rentfro Bellaire, Texas 77401 P. O. Box 1335 Rosenberg, Texas 77471 Charles Perez 1014 Montrose James M. Scott, Jr. Houston, Texas 77019 8302 Albacore Houston, Texas 77074 William Schuessler 5810 Darnell Bryan L. Baker Houston, Texas 77074 1118 Montrose Houston, Texas 77019 Patricia L. Strelein Route 2, Box 395C Dorothy F. Carrick Richmond, Texas Box 409, Wagon Rd. Rfd. #1 Wallis, Texas 77485 1810 092

Glenn Van Slyke Donald D. Weaver 1739 Marshall P. O. Drawer V Houston, Texas 77098 Simonton, Texas 77476 Connie Wilson J. Morgan Bishop 11427 Oak Spring 11418 Oak Spring Houston, Texas 77043 Houston, Texas 77043 b

C. Thomas Biddle, Jr#

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