ML19262C070
| ML19262C070 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 01/10/1980 |
| From: | Biddle C, Copeland J, Jason White BAKER & BOTTS, HOUSTON LIGHTING & POWER CO. |
| To: | Doherty J DOHERTY, J.F. |
| References | |
| NUDOCS 8001280232 | |
| Download: ML19262C070 (12) | |
Text
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 S
Docket No. 50-466 S
(Allens Creek Nuclear S
Generating Station, Unit S
No. 1)
APPLICANT'S RESPONSE TO JOHN F.
DOHERTY'S NINTH SET OF INTERROGATORIES In response to the interrogatories propounded by John F.
Doherty, Houston Lighting & Power Company (Applicant) answers as follows:
INTERROGATORY NO. 9-1:
What is the number of "studbolts" on the ACNGS reactor vessel?
RESPONSE :
There are 72 studs on the ACNGS reactor vessel.
INTERROGATORY NO. 9-2:
Who is the manufacturer of the s.and-by emergency diesel engines, if selected?
RESPONSE
General Motors has been selected for the HPCS diesels.
The manufacturer of other diesels has not been selected.
1816 027 8001280 ME
INTERROGATORY NO. 9-3:
Is Applicant's emergency stand-by diesel engine of such.new design that there is no history of start-up failure, and hence that unreliability of start-up cannot be contended?
RESPONSE :
The ACNGS diesel engine system is of a relatively new design.
During reliability testing in compliance with NRC requirements, there has been a history of no failures.
INTERROGATORY NO. 9-4:
Does Applicant take the position that it has made so many changes from all other designs reported in NUREG-0660 that allegations of unreliability are without basis?
RESPONSE :
Yes.
INTERROGATORY NO. 9-5:
What is the source of power or fuel for the starter or start-up system of Applicant's emergency diesel generators?
RESPONSE :
An air system.
INTERROGATORY NO. 9-6:
Will the ACNGS have redundant SCRAM air heater exhaust valves?
RESPONSE
Yes. '
1816 028'
INTERROGATORY NO. 9-7:
Does Applicant at this time maintain that the water level sensing and indicator devices in the reactor core differ from those at:
(a)
Three Mile Island Unit II, immediately prior to March 28, 19 ', 9 ?
(b)
The Oyster Creek Nuclear Plant in Neu Jersey?
RESPONSE :
(a)
TMI-2 and ACNGS use differential pressure transm:Ltters to generate lev ^1 measurement signals.
Applicant is presently unaware of the exact design and manufacture of the devices used at TMI-2.
(b)
The Oyster Creek water level sensing and indicator devices are not the same as those to be used in Allens Creek.
However, the devices at ':)oth plants measure differential pressure.
INTERROGATORY NO. 9-8:
Will ACNGS dif f ar from other GESSAR-238 referenced nuclear plants with regard to water level indicators in the reactor core?
RESPONSE
The Allens Creek RPV water level indicators are the same as the other " referenced GESSAR-238" RPV water level indicators.
INTERROGATORY NO. 9-9:
If the answer to 9-9 above is "yes", please list those differences.
, 1816 029
RESPONSE
Not applicable.
INTERROGATORY NO. 9-10:
Will ACNGS use the same sensing mode or modes as those of other GESSAR-238, referenced plants?
RESPONSE :
Assuming the " mode" here means method, ACNGS uses the same water level sensing method as the other " referenced GESSAR-238 BWR 6" plants.
INTERROGATORY NO. 9-11:
If ACNGS will use different modes, please indicate what these modes are.
RESPONSE :
Not applicable.
INTERROGATORY NO. 9-12:
Does Applicant's planned water level sensing and indicating system have a history of "no failures"?
RESPONSE :
To the best of Applicant's knowledge, the planned ACNGS water level sensing and indicating system has no recurring failure history.
INTERROGATORY 'iO.
9-13:
Has Applicant's water level sensing system ever been used in any nuclear facility before?
RESPONSE
The sensing principle of electronic differential pressure transmitters in measuring water levels in the 1816 030 RPV has already been used in many BWR plants.
INTERROGATORY NO. 9-14:
If so, indicate please where the sensi4g system has its longest usage (that is:
which power plant).
RESPONSE
The principle of electronic differential pressure transmitters for measuring water levels in the RPV has been used in plants as early as Dresden 2.
Dresden 2 went critical on 1/1/70.
INTERROGATORY NO. 9-15:
Has Applicant's water level indicating system ever been used in a nuclear facility?
RESPONSE
See response to Interrogatory No. 9-13.
INTERROGATORY NO. 9-16:
If so, indicate please where the indicating system has its longest usage (that is:
which power plant).
RESPONSE
See response to Interrogatory No. 9-14.
INTERROGATORY NO. 9-17:
Does Applicant maintain there is not enough thermal shielding and insulation in its design for ACNGS to loosen during a LOCA and block the drywell drain in the manner described in Contention #13?
RESPONSE :
Yes.
1816 031
-s_
INTERROGATORY NO. 9-18:
Does Applicant maintain the thermal shielding and insulation is of a type not susceptible to blocking the drywell drain as described in Contention #13?
RESPONSE :
Yes.
INTERROGATORY NO. 9-19:
Dces Applicant contend the ACNGS has one-of-a-kind design features which will prevent blockage of the drywell drain as described in Contention #13?
RESPONSE :
No.
INTERROGATORY NO. 9-20:
Does Applicant maintain the ACNGS has design features that differ from GESSAR-238" plants that would mitigate [ sic] the event postulated in Contention #13?
RESPONSE :
No.
INTERROGATORY NO. 9-21:
Does Applicant maintain its Main Cteam Line Radiation Monitoring system differs from the GESSAR-?38 system?
RESPONSE
No.
INTERROGATORY NO. 9-22:
Does Applicant maintain its MSLRM system can detect rapid fuel failure as rapidly as systems in the 1816 032
_e_
most recently constructured PWRs?
RESPONSE
Based on the information contained in NUREG-0401, Applicant believes that the MSLRM system can detect gross "apid fuel failure as rapidly 3s presently installed PWR radiation monitoring systems.
INTERROGATORY NO. 9-23:
Does Applicant plan to construcc a system of MSLRM capable of detecting fuel failure in less than a minute?
RESPONSE :
The ACNGS MSLRM system is designed to detect gross fuel failure in less than one minute.
INTERROGATORY NO. 9-24:
If the answer to 9-23 is "yes", please explain the system or provide explan: cory material.
RESPONSE :
See ACNGS PSAR Section 11.4.2.2.
INTERROGATORY NO. 9-25:
Does Applicant know at this tima of any MSLRM system capable of detecting fuel failure in less than a minute?
RESPONSE :
All current MSLRM systems designed by GE are capable of detecting gross fuel failure in less than one minute.
INTERROGATORY NO. 9-26:
If the answer to 9-25 is "yes", please explain the system or provide explanatory material.
}0\\h Ob 7-
4
RESPONSE
See ACNGS PSAR Section 11.4.2.2.
INTERROGATORY NO. 9-27:
Is Applicant's planned MSLBM system in use in any current operating nuclear power plant?
RESPONSE
Yes.
INTERROGATORY NO. 9-28:
If the answer to 9-27 is "yes", indicate to the best of your knowledge which power plant and.hcw long it has been in use.
RESPONSE
Similar MSLRM designs have been used in many BWR plants beginning as early as Dresden 2.
Dresden 2 went critical on 1/7/70.
Respectfully submitted, 7S 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.N.
Washington, D.C.
20036 Washington, D.C.
ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY 1816 034 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 Ninth 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.
g/
Jon G.
White SUBSCRIBED AND SWORN TO BEFORE ME on thin the
((
day of January, 1980.
0}/W$N//Ab//Ut/,
NOTARY PUBLIC IN AND FOR HARRIS COUNTY, T E X A S Cheryl A.
Southworth My Commission Expires 8/19/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S
S HOUSTON LIGHTING & POWER COMPANY S
Docket No. 50-466 S
(Allens Creek Nuclear Generating S
Station, Unit 1)
S CERTIFICATE r? SERVICE I hereby certify that copies of the foregoing Applicant's Response to John F. Doherty's Ninth Set of Interrogatories in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this
/0 4L day of t howr/u 1980.
I Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel for the State of Texas U.S. Nuclear Regulatory Commission P.
O.
Fax 12548 Washington, D.
C.
20555 Capitol Station Austin, Te:<as 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 Washington, D.
C.
20555 1816 036
Steve Schinki, Esq.
Carolina Conn Staff Counsel 1414 Scenic Ridge U.S. Nuclear Regulatory Commission Houston, Texas 77043 Washington, D. C.
20555 Elinore P. Cumings John 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 Dar ell 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 c
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 1816 037 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 'pring 11418 Oak Spring Houston, Texas 77043 Houston, Texas 77043 O'
A0 h
C. Thomas Biddle, Jr./
1816 038