ML19290D662
| ML19290D662 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 01/25/1980 |
| From: | Clay Johnson TEXAS PUBLIC INTEREST RESEARCH GROUP |
| To: | HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8002220513 | |
| Download: ML19290D662 (18) | |
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- . . . C00xETED g
, BELATED bAhttDAbogg ustmo REF: Docket 50-466 E jg 2 9 $80 > ,-
i In the !!atter of Houston Lighting & Power Cor 1 pgdfrf 4 An Application for Construction Permit (Allen 6 yS$g&SetdCS ' Nuclear Power Plant) Exd 3 4 N O' TEX PIRG'S ANSWERS TO HI&P'S MURTH SET OF INTERROGATORIES A. (Re: Amended Add. Cont. #1)
- 1. The market is the United States, generally. The preeise=.a=ount of natural gas not comnitted to contract in this maiket is not known at this time. The average price of the gas in this market -
is not known at this time. TexPIRG would estimate an average price of $2.20 per thousand cubic feet. The basis for that i ei' estimate is the Carter. Administration's proposed controlled j price for new gas (U.S.) ini1977, which is $1.75 per thousand ' cubic feet, escalated in a range of 9-10 % per year up to 1980.
- 2. TexPIRG does not at this time have detailed technical data on b, j these techniques beyond that stated in the contention. Obviously, improved methods of analyzing the amounts of reserves below {
i 30,000 feet would increase supplies by adding more certainty [ to drilling at these depths. . 3. Tex)IRG does not have this information. .
- 4. The passage of the Natural Gas Policy Act increases estimates of -
gas production up to 1990 by 2-3 quads over the estimates used by the Federal Power Commission at the time of the FS-FES, according [ to the Environmental Protection Agency (" Comments On the Draft + Programmat.ic Environmental Impact Statement On the Fuel Use Act," Environmen~tal Protection Agency, Feb. 9, 1979, VII). ~ Other documents on availability of natural gas include: :
"Pemex Wants Dollars For A New Gas Line,". BUSINESS WEEK, May 23, 1977, p. 42.
" Energy: A Gas Bonanza," NEWSWEEK, August 1, 1977, p. 61 k "What Natural Gas Shortage?," PROGRESSIVE, April 1977, pp. 19-23. .
" Oil, Gas Seen Possible Off S. Oregon," OIL AND GAS JOURNAL, a Dec. 24, 1979, p. 119.
"Transco, Mich Wis Seek Gulf Expansion Okays," OIL AND GAS JOURNAL, i Dec. 24, 1979, p. 44.
" West U.S. Lands Cleared For Oil Activity," OIL AND GAS JOURNAL, Dec. 24, 1979.p. 134.
8002220 6/3
, 2.
" Redevelopment: A National Phenomona," PETROLEUM ENGINEER, December, 1979, p. 21.
"What to Expect on the Energy Front," U.S . NEWS AND WORLD REPORT, Dec. 31, 1979, p. 63.
" Energy Fcrecast: Lower Frenzy, Higher Prices," BUSINESS WEZK, Dec. 31, 1979, p. 104.
" Utilities," FORBES, January 7, 1980, p. 152.
- 5. TerPIRG does not know of any studies at this time which specifically _
compare a new natural gas facilities' economics to that of a nuclear unit. But the differences can be illustrated by Chart EAT-3 in Volume I of HL&P's Rate Filing Package in Docket 2676 before the PUC. The last constructed natural gas plant generates power at S76 per kw - in HL&P.ts system. South Texas Nuclear Project will come on line in 1982, according to the chart, at $895/kw; and Allens Creek is shown coming on line in 1986 at 31,081/kw. HL&P revised these figures for both nuclear projects upward by substantial factors ! several weeks later; and TexPIRG believes the revised figures are still greatly under-projected. Even utilizing these admittedly low figures above for the nuclear units, the STP unit produces . power at a 1,000 % higher cost, and Allens Creek, at a 1,300 % higher cost. Of course, eleven years and.:sirteennyears of inflation, I respectively, account for some of that differencefin cost (the . natural gas ur.it was built in 1971); but the inflation adjustment :
~ still leaves a massive difference in costs.
- 6. Applicants ' pro'jections of natural gas costs are included in _
HL&P Answers to Requests for Information from Texas Industrial Energy Consumers in Docket 2676, Public Utility Commission. Page j 14 of 20 of Braden in Volume I of the HL&P Rate Filing Package in that docket states: " Projections of future gas prices for residential ' users show a gradual decline through the 1980's... Future gas prices were projected by HL&P on an internal analysis estimding future - rates of change in the cost of gas the company will buy during ' this period as boiler fuel." ,
- 7. STATISTICAL ANALYSIS OF POWER PLANT CAPACITY FACTORS, NUREG CR 0382; !
POWER PLANT PERFORMANCE: NUCLEAR AND COAL CAPACITY FACTORS,1976, Komanoff (and UPIATE,1977) Council on Economic Priorities, N.Y.; Testimo.y of Dr. Irving Bupp, Hearings on Nuclear Power Costs,
3. U.S. House Committee on Government Operations, 1390; NUCLEAR POWER ISSUES AND CHOICES, (Spurgeon Keeney, et.al.) 1977, Mitre Corp.; Testimony of Dr. Edward Kahn, U.S. House Committee Hearings, ibid., 963. f
- 8. TexPIRG estimates a capital cost for ACNGS cf $4,500/kw.
This is based upon the following procedure. As of Mar.1979, . 93 HL&P elisted9 capital cost for ACNGS at 1.297 billion dollars 33 (Sebodule c-4, HL&P rate filing package). Dr. Irving Bupp gg has found that actual costs of nuclear power plants exceed m; projected costs by an average of 100 % during the mid- to k( late 70's (Testimony before Government Operations Committee, Hearings on Nuclear Power Costs). Escalating the HL&P pr;;ection '~ above by that percentage, the actuil capital cost is estimated at 2.594 billion dollars. Applying capacity factor of 50 % es (justified by s tudies listed above), the cost per kw becomes 34,500 !
- 9. 5,500 acres. +
This is derived as follows: 5,720 (ACNGS) minus 220. acres (natural gas plant, from Table 61, " Impacts of Coal-Fired Plants on Fish, Wildlife, and Their Habitats" U.S. Fish and Wildlife )) Service). ~.. 10. This conclusion is reached because of the numerous studies regarding the occupational hazards in the extraction of both _ U02 8 and coal. $[ p.
- Some documents on the hazards .to workers of :
uranium extraction include: " Respiratory Disease Mortality Among Uranium Miners," Archer, Z.E., k ANNALS OF THE NEW YORK ACADEMY OF SCIENCES, 271:280-93, 1976, and " Lung Cancer Among Uranium Miners EP in the U.S. , " HEALTH PHYSICS, Archer, Z.E. , 25: 350-71, 1973.
- 11. Natural gas extraction will produce damage analogous to oil f drilling.
There may be some aesthetic losses during actual drilling, *~ however. numerous mitigative measures suitable to the site are available when aesthetic needs are high ore special protections are n'eeded [7 (as in casp of wetlands). To the extent that future natural gas $ (ig exploration occurs offshore, the risk of oil spill increases (Prob- EE abilities in TECHNOLOGY REVIEW,Feb.76). Uranium mining can cause extensive destruction to large acreages of land, especially where strip mining is involved. TNA Uradium mill tailings produce health hazards to human and wildlife populations from radiohetive contamina-tion. , activity. Ground and surface water can become contaminated with radio- - f~ Solution-mining creates taxic wastes-and may result in land and we.ter becoming polluted by acids and toxic substances.
. I
4. Documents describing this damage include: " Ground and Surface Water in New Mexico: Are They Protected Against Uranium Mining and Milling," Natural Resources Journal, Townsend, K., Cet. 19, 1978;
" Uranium Mill Tailings: Congress Addresses A long-Neglected Problem,"
Science, vol. 202, Oct. 13, 1978; Unresolved: Front End of Nuclear Waste Disposal," (Sweet), Bulletin of Atomic Scientists, Vol. 35,
#5, May,1979; " Effects of Uranium Mint 2g and Milling on Groundwater in Grants Mineral Belt, N.M.," Groundwater Journal, vol. 14, Sept.- -
Oct.1976; and Transaction of the American Nuclear Societv vol. 30, 1978 Winter Meeting (symposium on environmental effects of uranium mining),
- 12. Approximately 20,000 acre ft./ year would be saved. TexPIRG _
does not have temperature values at the present time to compare ambient water temperature differences for natural gas and nuclear generation. But it is well recognized that nuclear plants lose 60 's more energy through thermal discharge than do fossil fuel ' plants (" Thermal Pollution and Aquatic Life," Scientific American, 1969, 220:3 ).
. 13. Texas Air Control Board and U.S. #PA.
- 14. All of Harris and Galveston Counties.
- 15. !
It is "non-attainment" for oxidants / ozone for all of Harris and Galveston County. It is "non-attainment" for particulates in
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relatively small areas concentrated near the ship channel and down- -b
- town Houston, as well as Texas City. Enough permits are already .
to/ i issued exceed SO 2 . standards by a factor of two, and PSD by six, ! I according to EVALUATION OF THE IMPACT OF THE FEDERAL PREVENTION OF ! SIGNIFICANT AIR QUALITY DETERIORATION REGULATIONS FOR SO .. HOUSTON, TX (Doc. P-3989, 1979, Chamber of Commerce, ERT, Inc.) "i' -
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5.
- 16. The Fish and Wildlife Service reports that natural gas generators release virtually zero S02 and particulates. Slight emissions of NOx are reported, but these are manageable because the agency notes that such levels are below the threshold for biological effects. (" Impacts of Coal-Fired Power Plants on Fish, Wildlife and their Habitats" FWS/obs-78-29; p. 155 and p. 58). i
- 17. Applicant is automaticallyeentitled to an exemption once a =
sufficient showing has been made. Judging the adequacy of the bemon- , strationi does involve discretion on the part of the Secretary - of Energy. Se' ction 10.3.5 of the Final. Environmental Impact Statement of the Puel Use Act states: " Exemptions to use oil and gas will be granted if applicable environmental requirements will be violated." 2 The Conference Committee for this legislation states that " conferees - are aware that several regulatory changes are anticipated under the Clean Air Act" including revisions of state implementation plans and revision of certain national standards, and that Conferees
" expect:and intend such new and revised regulations be counted as I
' applicable environmental requirements ' for the purposes of -
the Act." JOINT EXPLANATORY STATEMDE , Committee of Conference,. July 11, 1978, Section 103, Definitions. . Obviously, the granting of the exemption depends upon the sufficiency of evidence presented by HL&P in the application. ;
- 18. TexPIRG objects to this interrogatory on the grounds that the question is vague and overbroad, and the request essentially amounts to a production of pre-filed testimony and accompanying workpapers prior to the time they must be filed. Work-product is also sought. _
- 19. Documents referred to in Interrogatory Nos. Al through A17 .
are available for insp.ection upon appointment by the applicant, for.those documents actually in the possession of the intervenor. - The remainder of the documents are utilized by intervenor in M.D. - Anderson Library. Library at University of Houston and Rice University
- 20. Clarence Johnson p
21 and 22 (a-e). TexPIRG has not yet determined whom will be called : as a witness, either expert or non-expert. - t* l
6.
- 3. (Re: A= ended Add Cont. #2)
- 1. Paper #2, Vol. 2(Energy) of ACHIEVING GOALS OF EMPLOYMENT ACT I
- 2. f xhfNb dde@* nod'have hdat information yet.
- 3. TexPIRG does not have a quantified value yet. .
- 4. The contention refers to a broad range of options. On one level the in-state Texas grid could be interconnected in such a i
manner that Texas utilities with excess power aould sell,orn"- transmit power to other utilities on a permt rather~than an emergency basis. On a broader level, Texas could allow interconnection across state lines so that a ~similar arrangement could be made with out-of-state utilities. Moreover, a fully interconnected I national grid consisting of all utilities in th> United States - could even out the distribution of excessive margins throughout the continent. The latter program was proposed in S.1208 (by ~ Metcalf) in 1975. As Sen. Metcalf noted: "A unified power system - could arrange to meet that peak in the Nation's four time zones - p with far less capacity than would be necessary to meet each zone's peak independently." _[ (Congressional Record, 94th Congress, First Session, Mar. 17, 1975, 121:43). TexPIRG does not yet know the i costs involved with any of these plans. !
- 5. TexPIRG understands that El Paso Electric Company, City of Austin, City of San Antonio, and Texas Utilities all have excess [
capacity. : TexPIRG do es not yet have the information requested _ in sub-parts (a) (b) and (c). ,i
- 6. TexPIRG does not yet have a quantified figure. r5 ~
- 7. __
TexPIRG does not yet know of such studies, but believes the statement is a logical corro11ary of the " offset" policy contained in federal law. [
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- 8. TexPIRG objects on the same grounds stated in response
- 9. All document (s) stated in interrogataries' responses 31-B7 are availaie for inspection by the applicant. 5~*
- 10. Clarence Johnson 11.--12(a)-(e) TexPIRG has not yet determined an expert witness or witnesses with regard to this contention. ,
*/ Other.
No. 4 (Ross conservation
& Williams) andarticles Vol. 79,are No. in TECHNOLOGY79,REVIEW 7 (Widmer). .
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7. C. (Re: Amended Add. Contention 3) (1.) Task force Renort: South Texas Pro.iect (2.) Report 50-499/79-08; May 17, 1977, letter from W.C. Seidle to Houston Lighting & Power Company; Inspection Report dated : Dec. 9, 1977 (report number unknown).. : E (3.) Section 17, Paragraph 17.15A of PSAR (regarding documentation. E of construction procedures); Paragraph 3.8.1.2.1 of PSAR (regarding personnel training); the final violation concerns failure of 7 the Design Review Committee to audit design rev.tews, and TexPIRG i: does not know the exact section of the PSAR affected. s (4.) HI&P's Answers to TexPIRG's Fifth Set of Interrogatories to the Applicant. (5.) Inspection Report #50-498-08; Report 78/14 (Sept. 15, 1978); Report 50-499/78-12; Report #50-499/79-09; Report # 50-499/79-04; f. (6.) Inspection Report # 50-499/ 78-14.; Plaintiff's Original y. Petition, Dan Swayze v. Brown & Root Construction Co. and Albert D. Fraley, Jr.; " Einstein's Ghost:' Trouble at Houston Lighting & Power's Nuclear Project," Sansam & Crossley, IN BET M MAGAZINE, June 1979; " Texas Magazine Owner Accused of Suppressing A-Plant Article, " Cory, B. , Wtshingtcn Post, June 8, 1979. - (7.) TexPIRG does not know at this time whether Mr. Swayze or Mr. Fraley gave the accurate account of what occurred. in that incident. : In either case, it raises serious question regarding HI&P's QA supervision. If Swayze is correct, then Brown & Root ~ and its agents fired him because he was stringently following . the rules with respect to QC inspection. If Mr. Fraley is correct, s then Mr. Swayze told him that HIAP's QA would " stay out" of any attempts to overlook construction defects. ~ (8.) Applicant is in possession of that document. TexPIRG
l 8. Exhibit 2 in Docket 2676 of the Public Utility Commission of Texas contains a complete listing supplied by HL&P. That document is relied upon in this sub-part of the contention.
- 9. These include each of the matters described in TexPIRG Exhibit 5, Docket 2676, PUC: Mechanical Auz. Eldg. one foot too narrow, concrete voids in Unit 1 Reactor Containment Bldg., defective I structural steel connections in MEAB, RCP, and FHB of Unit 1, construction tower crane CT-044 fell and damaged, construction r crane CT-053 and tower 910 damaged, and understrength bolts _
installed in some structures. The February, 1979 inspection 3 gave a citation on rebar storage, and the April, 1979 inspection found the same problem still existed (inspection report numbers i not known). In an April 30, 1979 letter from W.C. Seidle to HL&P, tae inspector's reporte.d is quoted at p.4 (of the report) as follows: "that condition has markedly deteriorated since the problem was first identifieds4 Furthermore, TexPIRG refers
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to the more generalized complaint that HL&P's management of its construction program may net be adequatee For instance the SOUTH TEXAS ELECTRICAL GENERATION PROJECT: TASK FORCE REPORT provides a statistical analysis of likely future overrun ande finds virtually no probability of a total cost of $2.7 billion; yet testimony by Jordan before the Public Utility Commission in . docket 2676 one year later shows that the new projection of final cost has reached that figure. Public Utility Commission staff i engineer Milton Lee testified that the PUC staff was not satisfied with HL&P's construction program managment and subsequently _
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the PUC staff and HL&P agreed to an independent audit of the construction program. For instance, Lee testified: "...in' con-versation with middle management and plant operators, they seemed
' not to know the direction of HIdP's future plans and have 'little input on planning decisions and other important decisions." (Docket 2676 Transcript at 1849). HL&P Executive Vice President Oprea :
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testified in Docket 2676 that he does notDknow how the company resolved problems in supporting quality control inspections at STP, nor did,he know how his staff had dealt with allegations of harrassment against QC inspectors (Tr. at 287). Yet the Executive Vice President is expressly responsible for Quality Assurance, see South Texas Project 2 NRC 894, 910, Paragraph 48. 4
W 9. [b
- 10. It does not comply with 10 CFR 50, App. B. #
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(a) Para. I. The QA functions do not have sufficient authority M
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and freedom to see that all safety-related functions have performed correctly. 3 E (b) P II. The training is not sufficient to assure suitable 4 e proficiency of the QA employees. a (c) P III'. The design control measures are inadequate to check either the original designs or the field changes in the design. = 4 (d) P X. The inspections and process monitoring is insufficient h E to insure quality adequate for safety of the plant. (e) P XVII.The QA records planned are insufficient to be easily 8 a identified and retrieved. 4 (f) P XVIII. The audits are not sufficient in that they should
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be done as a .ouble check on all records (not just spot checks) and S should be done by truly independent persons Ti.e., the independence M should be guaranteed by incentives such as increasing pay dependent e upon the number of errors they identify).
?E N"
D. Occupational Exposure Con'tention A 1979 article in NUCLEAR ENGINEERING
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- 1. Yes, it is in error.
INTERNATIONAL (at page 36) entitled " Radiation Exposure in LWR's 4 Higher Than Predicted" shows that the exposure .for BWR's. o'f the size of Allens Creek should be about 2,050 man-rem per year after g seven years of operation and increasing after that. Daca in NUREG- h 0482 (" Occupational Radiation Exposure At Light Water Cooled Power s P e Reactors" 1977) confirms that larger sized reactors and BWR design tend to be associated with higher radiation exposure levels. The Yj data in there shows most rsactors comparable to Allens Creek to + exceed 500 man / rem per year. -
- 2. Yes we disagree. The Staff has not way of predicting what the Applicant will do (a statement confirmed by the article mentioned i
10 in #1 above). The Applicant has chosen the " dirtiest" reactor design in terms of radiation releases, and this will affect the level of performance adversely. The Staff has no. guarantees that the Appli cant will not put " profits" above the advis ed exposure levels for the year. Also, the NRC does not adequately consider the history for requiring "backfitting" work to deal ' with periodie9 resolution of the hundreds of unresolved safety issues, which increases worker and maintenance occupational - exposure.
- 3. Yes, the levels will not be as low as is reasonably achie'vable. !
Basically, it is TexPIRG's position that the past history of reactors ~ of this type is sufficient to question the predictions that have been made; and that the burden of proc'f is on the Applicant to show definitively that the radiation exposure levels will meet the law. (See #2 above).
- 4. NUREG-0482 is available feriinspection at M.D. Anderson Library at University of Houston.
5., clarence Johnson 6.-7.(a-e). Expert witnesses have not been determined at this time, nor has any other testimony been decided. E. Control Room Design: 1 We do not know every r'eason, but some are : (a) No design has been shown sufficient, and all designs involved in accidents have come up short. (b) Most accidents are due to human error, and the plant'is not designed to prevent human override of all safety systems. (c) Very little human engineering has been applied to the - design of reactor control panels. (d) The utilities get what they want, which is cheap control panels. (e)~ There are too many controls and they are not clearly marked. (f) The controls should be of unique shapes and colors to avoid confusion during emergencies. (g) The indicator lights are so small they ~can be covered up
-d by' maintenance tags.
4 4
11. (h) The controls and instruments are not grouped in a functional way. (1) Some instruments and controls are not accessible to the necessary operators in the time necessary.- (j) The controls are too large. (k) There are too many confusing annunciator warnirrgs during an accident. (1) There are too many indicators for the operators to respond to all of them within the time necessary.
- 2. It would be too big of a burden to list every defective -
instrument because it is not that each .one is defective by itself butratherthatwhenallareusedto[g'etherduringaccidentconditions l they are not sufficient to ensure safety under all conditions. ~ It is impossible to use present designs to place enough indicators to measure all necessary parameters with sufficient speed and accuracy to prevent operators from making mistakes.
- 3. We have been unable to examine more than that specified by the f applicant in the PSAR. Since this information is so out of date, vague, and incomplete, we have asked in interrogatories. that .
the applicant send complete documentation on all ACNGS instrumentation including pictures, drawings, diagrams, and documentation including the relative positions of all parts to the whole system. We hope to examine all such supplemental information. 4.. There are too many to list all of them. Neither the applicant l nor the NRC can imagine all of them. No one predicted the : secuence at TMI. I
- 5. No. All control room designs rely on the same standards of the d NRC and IEEE.
- 6. No. All post-accident display instrumentation is based on same basic standards of NRC and IEEE. j
- 7. See answer to no. 2. :
- 8. See answer to no. 7. +
- 9. Snectrum (Nov. 1979) is available from UH library. Also available is the Renort of the President's Commission on TMI, -
(for inspection upon appointment), t h-
lx
- 12. . . .
!I
+;
- 10. Clarence Johnson i 11.-12. No decision has yet been made on cestimony to be presented. [
5.:.:: d rt
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F. RE: Charcoal Filter Fire ] T All questicns: TexPIRG has not advanced sufficiently in researching 3.3 this contentim to respond to any of the questions at this time; for g the present, the response to these questions should be considered $
"do not know at the present time."
However, TexPIRG will respond to':these questions at a later ll
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date when the answers arec'known. r Nf-t -- s m ce
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13. G. Add. Cont. #32 (Re: SDVT)
- 1. No
- 2. In the answer to this contention, applicant stated it did use SDVT's.
- 3. Aug. 16, 1974 Letter from I. Stuart (GE) to E. Case (AEC)
Dockets 50-278, 298, 333, and 341. Cooper and Fitzpatrick plants also had the same problem. i i
- 4. THE NUGGET FILE, Union of Concerned Scientists, Jan. 1979, Robert Pollard, Editor, page 50.
- 5. Probably the condition can be repaired in a few minutes. We: q have no data on how long it would take to empty the scram ;j discharge volume (SDV) but we b^elieve an ATWS with highest I monitor flux for the event would occur by the time the SDi .i was evacuated.
- 6. (a) Scram for LOCA--unanalyzed accidents ATWS & LOCA generally regarded as serious. ,
(b) If- SCRAM or Turbine Trip or other. ATWS, than see the various
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analyses in the PSAR. TexPIRG contends this failure would be ATWS initiator, If float sinks, then rod block monitor (or its ! analog--rod control & information system) do hot functionfcorrectly.
- 7. The documents mentioned in responses herein will be made available for inspection.
- 8. John F. Doherty and Clarence Johnson j 9-10a-E. Witnesses have not been determined yet. '
H. Add, Cont. #34, 48 (hydrogen monitor)
- 1. Hydrogen, oxygen
- 2. We are not urging taking a sample. We are stating that under --
current plans one cannot ascertain how much hydrogen is in the building, if it is evenly distributed (uniform concentration) and that there is not sufficient way to bring to attention af operating personnel the fact of hydrogen explosion in the building.
- 3. The monitors shoulasbe placed throughnut the containment building ,
to assess local concentrations .because the gas may be forced through the safety Relief Valves and be bubbled through the s,uppression pool. Although hydrogen rises in an air environment, .the threat 11 also posed at lower elevations. (a) They are inadequate if located in a few high places.
14. (b) See above.
- 4. No. TexPIRG notes NURGEG-0578 "TMI-2 Lessons learned Task Force Report and Short Term Recommendation, page 9: " ...a minority of the Task Force recommends immediately effective rulemaking to require that changes be made in the operating plants that currently rely upon containment Bamplihg as the only method of long term post accident hydrogen removal from the containment."
Whether the building leaks or otherwise releases the hydrogen or is deliberately vented, the issue is that radioactive materials ? will leave the site.
- 5. Yes. There is no source -at this time that says they are the same.
- 6. TMI containment consists of a free standing still vessel surrounded by a concrete shield building.
ACNGS TMI-2 Internal Pressure Limit 15 PSI 60 PSIG Temperature Limit not known - 389 F. Volume See CSDR#2 2.8 million ft.3 TuxPIRG has not considered changes in the design of ACNGS shell ~ announc'ed in the Containment Structure Design Report of 12/79 by Ebasco.
- 7. No.
- 8. In the building--on p.127 of the Kemeny Commission Report: "The Need for Change--The Legacy of TMI," Oct.1979, it states:
"That there was the sound of a hydrogen explosion in the building" referring to a 1:50 p.m. noise -~
by an employee. That was 9 houre after the original SCRAM - on 3-28-79. It produced a 28 PSI force (ibid.). (a) and (b) Not known.
- 9. (.a).No (b) No
- 10. Eydrogen is liberated from H2O when the zirconium is oxidized. '
Hydrogen is explosive. Any oxygen available to mix with this
-4 hydrogen produces a more severe explosion than a volume equal to the hydrogen alone.
- 11. '.3 have not researched this item.
- 12. TexFIRG objects to this question on the grounds stated in the response to A18.
15.
- 13. All docur.ents mentioned in responses herein will be made available if within the possession of TexPIRG. In addition, the following additional' documents are available in the M.n. Anderson Library at University of Houston: SER Davis Besse Plant (NUREG 0421); "SER TMI-2 (NUREG 0107 Supp. 2).
- 14. John F. Doherty and Clarence Johnson :
15-16 (a-e). Witnesses have not been determined yet.
- I. Re: Add. Cont. 46 (relief valves)
- 1. We believe the spring loaded valve in fig. 3 of NURGEG 0462 " Technical Report on Operating Experience'in BWR Pressure Relief Systems. " is the one. See 'page 10 of NUREG 0462:" Operating
'l Experiencerof -the spring-loaded SV's has been essentially i failurn free."
- 2. NUREG 0040 V.#3 #1 " Licensee Contractor & Vendor Inspection i Status Report" indicates there are 42 valve manufacturers. TexPIRG means here that several different valve manufacturers be used.
- 3. Having reduced the number of relief valves, more pressure !
can escapecthan in a large number of valves. Dangers include ! during LOCA, PEA, or ATWS, the pressure of the reactor carb ! may stay less than the pressure in the fuel rods, leading'to ; their inflation and ballooning with consequent flow blockage ; and additional heating with consequent extrusion of molten fuel i through radial pellet cracks leading to crossing of the pellet [ clad gap and contact of molten fuel with the clad. (Source: common knowledge and NUREG CR-0500, "An Assessment of Fuel { [ Melting-, Radial Extrusion, etc." p. 13). _
- 4. For TMI: p. 2-44 NUREG 0560
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For Browns-Ferry p. B-27 NUREG-0618 (recent); B-33, NUREG-0483 For Hatch: B-103 NUREG-0483; Dresden: NUREG-0462, Table 3 . For Davis-Besse: NUREG 0040, Vol. 2, #5, p. 144. j All of these documents are av&ilab.'e in the UH Anderson Library. . w .
- 5. Tex?IRG objects to this questian on the same grounds stated in the response to A18. ,
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- 6. All documents cited in these responses are available from the ERC or can be inspected at M.D. Anderson Library (UH).
- 7. John Doherty and Chirence Johnson
- 8. - 9. (a-e) Witnesses have not been determined yet.
E. 5 J. Re: Contention 47 *
- 1. TexPIRG has not yet identified the inadequacy or deficiency.
- 2. None. a
- 3. (A-E) Witnesses not determined yet.
K. (Re: Contention 49)
- 1. Both use differential pressure transmitters to generate level measurement signals. TexPIRG is not aware of the exact design of the TMI-2 indicators.
- 2. TexPIRG objects to this question on the grounds that it is overly vague.
- 3. The " smaller bubbles" refers to the collapse of voids caused gi by increased pressure in the steam area above the water level. It is M possible.the " smaller bubbles" would be forced to the surface =
,. and hence be destroyed. " Power drop" refers to decrease in power g output at the fuel lods; it would also produce less void size. Collapse $[ of voids will decrease the water level rapidly following MSIV (i.e., ($ main steam isolation valve) closure and SCRAM. $
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- 4. The reactor coolant inventory should be kept at a high "lewe l . The operator in thls scenario believes that water level Q indicator is not stuck at low, thinking the water level is low. :
So he would increase the reactor coolant inventory.
- 5. They might be.
Tex)IRG is uncertain if (a) The feedwater pump's are " steam driven" and (b) If there is any override to prevent fE excessive. filling of the reactor core which gets its information .. {-{ m from any source other than that which supplies the water-level +1 indicator in the ACNGS control room. EN
- 6. On overfilling of the reactor With the MSIVs shut, sater would reach the level of the main steam line, that was " overflow." .
- 7. See # 6 a'bove. The introduction of water to this steam E line would cause a water hammer. See p. 1-16 (last paragraph) of NUREG-0582 and Table 3-2, ibid.
F
t r 17.
- 8. The following documents are utili. sed:
UUREG 0582 (WATER HAIGER IN NUCLEAR POWER PLANTS) 7/79 (available in U.H. library or from NRC) 44 FR 50925-8. (Federal Register available in most libraries) Letter from E.A. Turner (HL&P) to Vassallo 311-14-79 (in your i possession) I Am. #39 to OPR-16 (Oyster Creek Power Plant)
- 9. John Doherty and Clarence Johnson _
10-11 (a-e) Witnesses not determined yet. t l Certificate of Service This document has been served by deposit in the U.S. mail on thishbkayofJanuary,1980uponthefollowing: Chairman Wolfe, ~' Mr. Ch'eatum, Mr. Linenberger, Mr. Lowerre, Mr. Sohinki, M.r. Copeland, - Mr. Uewman, Ms. McCorkle, Ma, Hinderset61n#, Mr. Marrack, and Mr. Doherty, b' ( OQ (.N]g][k-}W
,] ,
s .
WHEREFORE PREMISIS CONSIDERED, These responses constitute TexFIRG's answers to said interrogatories. p ii_ b QQ \ ,, , ? James Scott, Jr. bodnsel for TexPIRG L' I - Docket 50-466 -
)
County of Harris
)
State of Texas
)
BEFORE THE UNDERSIGNED AUTHORITY Appeared Clarence L. Johnson, - who affirms that he has provided answers to the Fourth Set of Interrogatories from Houston Lighting & Power Company in hiis cauacity as Executive Director of Texas Public Interest Research Group and that said answers are true and accuratec to the best' of his knowledge and belief. - 2'i// I (l y J he L f a ,
. Clarence Johnson U "
Ob ie O .c ; nl n , Notary Public UAetENE A. SH!ELOS
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