ML19309H658
| ML19309H658 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 04/07/1980 |
| From: | Doherty J DOHERTY, J.F. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8005130624 | |
| Download: ML19309H658 (2) | |
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1 Jo'in F. Joherty, 'Intervonor in the above proceedings filed his Coatention #17 on :iny 25,1979, and in that document titled
" John F. Doherty's Adi.itional Contentions after ALAB-535", on care #6, the original and unamended to:c't occurs.
In this Motion, Intervonor wishes to insert the phrase: Antici,ated Transients
- lithout Scram (i?"S), as a cart of the series of events listed in the first sentence.
In suoport of the amendaent, this Intevenor offers t'le fo llow i.ng.
Tirst, the chrase was omitted in the oririnal filine be-cause this Intervenor thought the AT~.!S event was included among io ;er Excurision Accilents (PZAs) at the time of filing.
Uoon cusoectir; this was not the case, this Intervenor filed an InterrogatorI with Staff, (See:Interroratory '0 A of this In-tervenor's -10th 3et of Interrogatories to Staff of January 3,1983) to which the reoly was that 2egulator7 Guide 1 70, levision 3 di' not ir.clude AT'.13 among such events.
Second, where the focus of the contenti6n is.on'the relief valves and ;ATUS:is anLacknowledged possible event by Staff, its inclusion here with Power necursion events because both sub. ject the valves and suppression pool to stresses caused by reactivity:is justified.
SUPPORTIUG 3 TATE:C*T UliDE2 10 CFR 2.7'a
- i. 2he reason this accident event was not included in the series of events in the first sentence of Contention 117, is that Intervenor thou;;ht he had included it in the ori--inal filing.
ii. Save this Intervenor's Cantentio. 23 (which will be argued Y-him at the Heari.gs) there is no other no-nille means this Intervon >r's interestis will be protecte4
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iii. It would appear unwise to consider Power Escursion Events i
l (P2.Ys) without the AT'.l5 event because they both involve reactivitr effect. To exclude the AT'cl3 event uculd leave a hole in the record on the point of c =nleteness of 7rotection offered by the safet/ relief valves.
iv.
!!o other carty has raised the contention to include AT'.3.
v.
Iac'.usica of this at this time with a'3 proximately 100 4
days of discovery for other contentica is unlikely to dela: the proceedings.
Therefore, this Intervenor preys this anendment be allowed in the tent of Contentica =,i17 2esn actfull y submitted,
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.lolfo, Sse. (I!HC)
Gustave -.. Linonber:er (URC) l Dr. 3. Leonar:1 Cheatua (IIRC)
E te*/an :. Schin':i, Esc. (Staf')
Richard 1. L3'erre, 2sc. (Tenns)
R. G3rdoa G.och, Esc. ('ippl)
J. Gregory Copeland, Esq. (Appl)
The Intervoning Parties Atomic Safety Licensing & Appeal 3 card i
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