ML19331B907
| ML19331B907 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 08/06/1980 |
| From: | Fields M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19331B836 | List: |
| References | |
| ISSUANCES-CP, NUDOCS 8008130513 | |
| Download: ML19331B907 (38) | |
Text
-
O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
HOUSTON LIGHTING & POWER COMPANY Docket No. 50-466 L
(Allens Creek Nuclear Generating
)
i Station, Unit 1)
)
AFFIDAVIT OF M. B. FIELDS CONCERNING CONTENTION TP A-6 i
My name is M. B. Fields.
I am currently employed by the Nuclear Regulatory Commission as a Containment Systems Engineer in the Containment Systems Branch. My qualifications are listed on the attached qualification sheet.
The purpose of my affidavit is to address TEXPIRG Contention A-6 which reads as follows:
p Petitioner contends that the drywell planned for Allens Creek Unit I will not withstand the pressure generated in a LOCA. The water within the weir wall will not clear the first row of vents before the differential pressure exceeds 28 psi.
This is due to failure to properly account for. the Mannings roughness factor within the weir wall and the vent pipe.
By delaying the time to clear the first row of vents by only 0.5 second the drywell will be damaged allowing the escape of high pressure steam into the containment without being condensed. This will lead to the con-tainment vessel pressure exceeding 15 psig so that it will crack allowing the escape of radioactive gases above the limits allowed by 10 CFR 100.
l Intervenors contend that the Mannings roughness factor within the weir wall
[
and vent pipe is not properly accounted for in calculating vent clearing 8008130g g o
times and, therefore, the drywell will not withstand the pressure generated during a LOCA.
It appears that the concern has arisen because simplified calculations by the Intervenors were performed assuming that the flow results from a potential energy drop rather than by a drop in pressure. Although the concern using simplified calculations does not exist when flow caused by a drop in pressure is calculated, there may be an implied concern as to whether the Applicant's assumption of negligible wall friction is appropriate.
The Manning formula (Fluid Mechanics, Victor L. Streeter, E. Benjamin Wylie, Seventh Edition) is depicted as:
V = Cm R(2/3) 3(1/2) or Q = VA = Cjl AR(2/3)S(1/2) n In the above formula, n is the Manning roughness factor for various boundary a
j materials.
It is derived from a formula for steady uniform flow through an open channel with no pressure differential or for the non-pressure flow of water through closed conduits.
By use of the Manning formula, the Inter-venors determined a vent clearing time of 1.99 seconds with the roughness factor for cast iron.
However, use of the Manning equation is incorrect for determining the vent clearing time.
For the Manning equation to be correctly used, the channel (or closed conduit) must have a constant slope and flow must be steady and 6
d
, aniform with no pressure differential at either end of the conduit. The situation that exists inside the vents of a Mark III containment during the vent clearing phase of a LOCA is completely different. The vents have no slope, the flow is not constant, and the pressure differential across the drywell wall is the force that creates the fluid flow through the conduit (vents).
The Applicant's vent clearing model is developed in Section 4 of a General Electric Licensing Topical Report, "The General Electric Mark III Pressure Suppression Containment System Analytical Model," NED0-20533, June 1974.
The model includes a control volume for each vent and three control volumes for the weir area. One of the assumptions is that friction is negligible.
The assumptions of negligible friction was based on earlier studies reported in another Licensing Topical Report, "The General Electric Pressure Suppres-i
..l sion Containment Analytical Model," NED0-10320.
In Section 4.1 the results 1
of calculations of irreversible friction losses for the Limerick Units are reported.
Figures 4.1 and 4.2 from that report are attached. As noted in Section 4.1, the irreversible friction losses are in the order of 1% of the pressure difference being applied to the vent water. Additional work at the Idaho Nuclear Corporation with the CONTEMPT-PS Code showed that the vent clearing transient is not affected by friction losses for reasonable values of vent roughness factors (November 1970 Monthly Report of the Nuclear Safety Division of the Idaho Nuclear Corporation Hai-436-70, Page 16).
~
. In addition to calculations of vent clearing times, the Applicant, in Sec-tion 4.2 of NED0-10320, reports on the results of vent clearing times meas-ured during the Humboldt Bay series of pressure suppression tests.
Compari-sons with calculations are shown in Figure 4.4 which is enclosed. Additional comparisons with experimental data are reported in Section 4.1 of Supplement No. I to NED0-10320, May 1971.
Several comparisons with experimental data from General Electric Company's Pressure Suppression Test Facility (PSTF) are reported in Appendix A to NED0-20533. Two of those comparisons, Figures A-12 and A-13 are attached, illustrate measured vent clearance earlier than calculated at a lower dry-well pressure than calculated.
i In summary, the role of friction in models for calculating vent clearing time has been actively considered by the reactor vendor for almost a decade.
The assumption of negligible friction in the vent clearing model has been accepted by the Staff based on comparative calculations with and wit'hout friction and comparisons of experimental results with calculations.
General Electric has determined, and the Staff agrees, that the analytical model conservatively predicts vent clearing times.
It is the Staff's opinion that TEXPIRG incorrectly applieo the Manning equation by its inadvertent omission of imposed pressure drops across the length of a closed conduit. Appropriate fonnulas would measure flow throu'gh closed conduits when subjected to pressure difference (e.g., the Darcy-L.
13-
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, Weisback equation--Streeter (5.8.7) as rewritten on page 233 of Streeter's, Fluid Mechanics, Seventh Edition). The reference relied upon by the Inter-venor (Fluid Mechanics-Streeter) is an authoritative reference that clearly includes information that supports a conclusion that friction would be expected to be negligibly small as was sub:>equently demonstrated.
I certify that I prepared the foregoing affidavit and hereby swear that it is true and correct to the best of my knowledge, information and belief.
h.
/ 9' M. B. Fisids Subscribed and sworn to before me this 6th day of August,1980
$k' ff b iM Notaryfublic
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My Cor.nission expires: July 1, 1980 i.
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5' Professional Qualifications Mel B. Fields s
I am a Systems Engineer in the Containment Systems Branch of the Office of Nuclear Reactor Regulation.
In this position I am responsible for the review and technical evaluation of safety aspects of containment systens.
I graduated from the University of Arizona with a Bachelor of Science Degree in Nuclear Engineering in 1974.
I am currently enrolled as a part-time graduate student in the Mechanical Engineering Department of the Catholic University of America in Washington, D. C.
In 1975 I accepted a position as a Reactor Engineer (Intern) in the
's Containment Systems Branch, Division of Systems Safety, Nuclear Regulatory
- Commission. My responsibilities included the review and technical In this position, evaluation of the safety aspects of containment systems.
I have been responsible for the evaluation of the health and safety aspects related to containment systems for the following nuclear power plants:
Black Fox Station, Units Nos.1 & 2, Grand Gulf Nuclear Station, Units Nos.1 & 2, North Anna Power Station, Units Nos.1 & 2, Jamesport Nuclear Station, Units Nos.1 & 2 and Cherokee and Perkins Nuclear Station Units For the Black Fox Station, I was responsible for Nos. 1, 2 & 3.
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r reviewing the staff positions and writing the section of the Safety l
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Evaluation Report on the Mark III containment systen.
In early 1977, I was transferred to another branch, the Power Systems Branch, in the same division where I remained for approximately 1-1/2 years before returning recently to the Containment Systems Branch.
I am currently involved in the review of the Mark III Containment Test Program being conducted by Ger.eral Electric.
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3 UNITED STATES NUCLEAR
)
BEFORE THE ATOMIC SAFETY k-REGULATORY COM?tISSION
)
b
)
AND LICENSING BOARD MATTER OF:
)
IN THE 4
)
NO. 50-466 5
HOUSTON LIGHTING AND
)
POWER COMPANY (ALLEN'S
)
o-CREEK NUCLEAR GENERATING
)
[,-
STATION, UNIT 1)
)
l T
L DEPOSITION OF:
F CLARENCE JOHNSON Vol-U ni S 1 p
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26 1
directly to the contentions, and I would 2
like'to start with TexPIRG additional i
3 contention'6 on drywell integrity.
4 Do you have the contention in front
)
5 of you there?
i L
6 A
It's 7
G Contention 6, additional 6.
Are you ready?
8 A
Yes.
f[l 9
G What is the Manning's factor?
10' A
As I understand it, it's a formula for i
11 deriving the pressure generated by the 12 roughness of the surface upon which a 13 fluid might be moving.
14 C
Would you agree that the roughness factor 15 is t'he "n" value in the Manning's formula?
r 3
16 A
I believe so.
Let me see.
17 G
Are you referring to your interrogatory 18 answers?
.r-19-A Yes.
20 G
Reference is made in that interrogatory 21 answer number 34 to a book written by r-22 Professor Streeter.
Do you see that in
[
23-the very first paragraph?
- (...
24 A
Yes.
25 G.
Is that the source of your knowledge about i
4
~
27 1
the Manning's roughness factor?
2 A.
No.
3 G
It is not?
4 A
Not the source of necessarily of my 5
knowledge, but 6
0 Is that the text that you rely upon for r-7 the formula that you've used in answering l
.8 this question?
l.
.}
9 A
I believe so.
t-10 0
Have you ever read Streeter's book or
'f 11 looked at it?
~
p 12 A.
No, I haven't.
.1.
13 G
Did you answer that question?
14 A
I accepted it as ny answer.
15 G
Did you answer it?
Did you physically 16 write the answer?
h{
_ 17, A No, I didn't.
l 18 G
Who did?
t-19 A
Jim Scott.
20 G
But you. swore that the answer is true and 2
21 correct; did you,not?
22 A
Yes.
23 G
All right, well, assuming that Mr. scott 24~
used Professor Streeter's book for purposes 25' of answering this question,'do you have l
i i
l I*
h :.
28 t'
l-about that in your own mind that that's 2
what he used?
3 A
I don't have any significant doubt.
I
{
4 don't know of any reason why Professor 5
Streeter's definition of what the formula 6
is would be any different from what
{
7 Mr. Scott's formula is.
I wouldn't think I
8 so.
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I 9
g All right, sir, I want you to look, then,
[
10 at Professor Streeter's book, at page 229, 11 and at page 229, Professor Streeter sets
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12 forth what he describes as the Manning's
.{s 13 formula or equation at the bottom of page 14 229.
15 A.
Yes, I see it.
[
16 0
Have you ever seen it.'before?
I t 17 A.
I haven't seen it, no, not in that form.
18 The only form I've seen it in is the 19 interrogatory res'ponse.
20 g
"Do you quarrel with that statement there,
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21 that that is the Manning's formula?
22 A
If he states it is, I' don't sne any
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23 reason to disagree with it, no.
x-24 G
And if Professor Streeter took the position 25 -
that the formula is used in calculating i
I
l 29 2"
1 incompressible steady flow at cons, tant 2
depth in a priscatic, open channel, 3
would you disagree with that?
L-~
4 A
I think that's accurate, that Manning's 5
formula is widely used i n-t h a t regard.
. c-1, 6
G All right, well, let's talk, then, about F
7 the flow paths that you are concerned I
8 with in your contentions, and what I
}I I'm going 9
would like to get you to do 10 to 'ncve marked as an exhibit, Johnson 11 Exhibit 1, a diagram of the reactor F
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12 building.
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13 14 (The instrunent referred to r-l 15 was marked for identification " Johnson
(
16 Exhibit No.
1.")
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17 18 G
I'd like to show you this,.At r. Johnson.
j 19 You don't have td accept the accuracy of u
20 "the representations there, it's just a i
l 21 draseing for purposes of talking about the 22 subject here, and uhat I want you to tell I
{,.
23 me now is which flow path and which 24 surface we're talking about in your con-25 tention.
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4 I
i 1.
I 30 1
specifically, I want to know the 2
surface where you contend that the 3
friction will occur for which we need
~
4 to give it an "n" value for purposes of 5
applying the Manning's equation.
- [
6 A
I believe that the surface would be the 9
m 7
surface in the horizontal vent.
8 G
The surface in the horizontal vent?
g..
g 9
A Yes.
e t';~
10 0
All right, and then, if you would, sir, 1
11 turn to Frofessor Streeter's book and
!F-12 look at page 230, and at the top of that kl r--
13 page, there is a listing of various "n" 14 values, and what I would like for you to U
15 do is tell me what the "n" value is for
- 16 the materials used in the horizontal 17 vent.
l'
.I 18 A
.015.
ff 19 G
All right, and what is that number in his 20
' book?
What did you look at in his book L
21 to get that number?
22 A
Approximation taken from cast iron.
23 0
from cast iron?
Is it your understanding 24 that these horizontal vents will be con-u 25 strurted o r cast iron?
l i
I t
~-
31 1
A No, it isn't.
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2 O
Mhat are they going to be constructed of?
3 A
I would presume a steel alloy.
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4 G
What kind of steel alloy?
Stainless steel?
5 A
I'm not certain.
I would presume that 6
would be the case.
{'
7 Presuming that it is stainless steel, 8
what is the "n" factor for stainless
- k. ;1 i
,9 steel in Professor Streeter's book?
10 A
I don't see that he listed one.
The "n" 11 value for riveted steel is.018.
II 12 g
Well, do you know if there is an "n"-
13 value for stainless steel?
14 A
I'm sure there must be.
15 g
You are sure there cust be?
t__
16 A
I suppose an "n"
factor can be obtained 17 for any substance.
I don't knew..what f.
' ~ -
18 the figure would be, though.
1-19 0
nell, looking at'the interrogatory answers, 1
,6 l
20
- in the paragraph before paragraph E.
n I
21 There is a sentence that says, "It should 22 not'be inferred that the simple calcula-23 tion done here is the final or best calcu-9 24 lation of the actual differential drywell n
25 pressure-generated during a LocA, but it
(
I i
32
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i 1
is instead the mini..u.
pressure that would
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i 2
be reached".
3 A
Right.
4 0
Is anybody at TexPIRG doing another calcu-5 lation at this time?
6 A
No, not at this time.
I' 7
4 All right.
Have you searched any text-8 books looking for an "n" factor for stain-r' 9
less steel?
e 10 A
1 have not.
i 11 G
Do you know if there is, in fact, any 12 riveted steel in this plant?
/
13 A
I would doubt that that's the case, 14 it's possible.
15 G
Well, how can you justify using the "n" 16 value for riveted steel for purposes of g.
jg 17 your calculation if there is not going 18 to be any riveted steel in this plant?
19 A
We didn't use thd "n" value for riveted 9
20
" steel, we used the "n" value for cast 21 iron.
22 0
, Is there going to be cast iron at this
'\\
23 plant?
24 L
no.
25 G
How can you --
l I
.V' i
33
~
1 A
I think that the presur.ption was that the 2
"n" value will be somewhere between that 3
of cast iron and riveted steel.
t 4
G It will be somewhere between those two?
c 5
A Yes.
~
6 6
G In other words, stainless steel has a f~
7 roughness factor that is higher than 8
cast iron?
'l
,9 A
I think that's the presumption, yes.
10 0
You think that's a reasonable presumption?
11 A
I would say at the present time, yes, a},'
12 I'd say that my knowledge at the present a
N-13 time.
14 0
Eave you ever seen a piece of stainless 15 steel?
16 A
Yes.
17 G-Have you ever seen a piece of cast iron?
I 18 A
Yes.
19 G
Which.one of thoie is smoother?
20 A
I suppose it depends upon the treatment 21 that's been given to the metal.
22 G
Have you ever seen a piece of cast iron 23 thst's smoother than a piece of stainless l
24 steel?
25 A
I can't say that, I can't ansver that one c'
i i
L
I s
L 34 f'
(
l way or the other because I don't normally 2
go around making those comparisons.
3 o
would you look again at your interrogatories
~
[-
4 and in the sar.e answer, and in the same 5
parasraph that I was reading, further down, 6
you say, "No accounting of th e frictional
(
7 force is caused by the flow of water 8
between the weir wall and the drywell
'l 9
was made".
could you tell me what the
['
10 frictional force is there that you are 11 speaking of?
r
~
s 12 A
Can I see your diagram?
I would 13 I think that's the frictional force 14 caused by the two surfaces between the t
15 weir wall and the drywell wall.
16 g
And do you know what those surfaces are 17 constructed of?
't 18 A
Mo, I don't.
j 19 4
So you don't know what the "n"
value' 20 would be for those surfaces?
21 A
That's correct.
l 22 o
there does the resistance occur?
Does it
(
23 occur on the weir wall or does it occur I'
24 u
on the drywell wall?
25 A
I'm certain it occurs between both walls.
1 I
I t,
z,.
s-l-
35 1
0 It occurs between the walls?
l 2
A I mean'it occurs I'm sure there is
[
3 resistance for each surface.
l-4 0
All right, but you don't know what the 5
"n" factor would be for e-ither surface?
6 A
No.
~
1
[
7 G
Mor what the materials are made of?
8 A
No, I don't.
-l
,,,9 0
Do you know what the turning losses r
lo -
for the calculation of the flow are 11 through the horizontal vents and out 12 through the space between the weir 13 wall and the drywell?
14 A
No, I don'.t.
r 15 0
Do you know which is greater, the turning 16 losses or the friction losses for the 17 flows going through that flow path?
18 A
I'm not certain.
I presume the turning 19 losses are greate'r.
20 0
'All right.
Is it your understanding 21 that H.L.sP has calculated the turning 22 losses through that flow path?
(
23 A
I'm not certain.
I'd have to go through 24 and look at the P.S.A.R.
25 g
But you haven't done that?
I l
36 1
A I,
personally, haven't, no.
2 O
All right, so you have no way of knowing 1
'~
3 whether the turning losses are more or 4
less than what you claim to be the 5
frictional losses?
F 6
A I have no way of certainty, certainty' a
7 of knowledge on that.
[...
8-4 And as I understood you earlier, you said 2
I' 9
you had no idea of what the "n" factor 10 is for stainless steel; is that correct?
I
- 11 A
Ho, I don't.
12 O
And you would have no idea, then, whether l1(-
13 the "n" factor varies over the years?
14 p.
In other words, is it higher or lower z}
15 after 40 years, for example?
l 16 A
My presumption would be that it would be l
5
[g, 17 higher.
18 0
And why is that?
r-19 A
Just due to the f'a c t that after time 20 the frictional loss may tend to roughen 9
21 the surface, the frictional force on the t~
22 surface would tend to" roughen it.
g 23 0
How do you calculate the reduction in
.. s. -
24 flow volume that would be attributable e-25 to the change in the surface characteristics I
I f
P"
F 37
/
j, 1
of stainless steel over this 40-year 2
period of time?
F 3
A I don't know the answer to that.
f 4
G All right, looking back at your inter-5 rogatory answers again, Mr. Johnson, in 6
the third paragraph of your answer you i
7 indicate that there will be 40 sets of 8
three vents placed on the drywell wall 1 I 9
at a distance of 5.65 feet; do you see l'
10 that?
11 A
Yes.
~12 G
Okay, and you further state the second
^
13 vent is placed a,pproximately 12 feet 14 underwater?
r 15 A
Ycs.
' ' r-
}
16 G
( -
Do you know how you obtained the value
{r' 17 of 5.65 feet?
1 18 A
I believe that came from either a diagram
)
r*
1 29 or a statement in' the*S.E.R.
c-20 0
Well, did you calculate it, that value?
)
21 A
No, I didn't.
u-
- 22 G
All right, did you 23 A
I talked to a person who did calculate 24 it, told me how they came up with the l
25 figures they did.
l H:
i kh
F i
38
(
1 G
That was Mr. Scott?
2 A
Yes.
.g-fl 3
0*
But you don't know how he calculated it?
. f' k
L Mo.
5 o.
And you don't know where the value is 6
measured from?
7 A
As I say, it's my understanding that it 1
f 8
came from either a diagram or a statement h
l s'
t'
,9 in the S.E.R.
I believe it came from a 10 diagram within the S.E.R.,
and either
- )
11 the statement that that's the distance
. r' p-12 or a calculation of distance, using 13 scale.
14 4
Well, is it your understanding that this 15 is the distance from vent to vent along
~h 16 the circumference along the drywell 17 inside wall?
p 18 A
okay, sir, let me see.
Yes.
3, i,-
~
19 G
Eut you don't know the figure, where i
20 this.was obtained from, but you think 21 it was some figure in the P.S.A.R.?
22 A
Not the P.S.A.R.,
the S.E.R.
23 4
The S.E.R.,
you don't know the page?
24 A
2:o t right offhand.
25 If I gave you a copy of the S.E.R.,
do j
a
?
r-j 6
39 1
you think you could find it?
.g 2
A I'm not certain.
It might take me awhile.
3 I would prefer, you know, it's depending 4
on what you would like, I would prefer 4
k 5
to agree to make a written response to e-6
.that.
I 7
0 Answered by !*r.
scott?
I 8
A Answered with true and correct answers 9
of how we obtained 10 4
Well, he is the only one that could answer 11 that question as to how that is calculated, 12 is it not, because he's the one that did 13 the calculation?
e 14 A
Yes, probably, or else he could tell ne 15 how he did it and I could --
j 16 0
You could say, right.
But in any event,
!t 17 he has to be the ultimate source of the 18 answer?
19 A
I'll say that's a'n accurate statement.
20 g
All right, is it your understanding that 21 two drywell vents have to be uncovered 22 before the pressure in the drywell can 23 be reduced?
24 A
Is that in the interrogatory?
l 25 G
- 'o, I'm just asking.
E e
f-
m (0
(l 1
A.
I don't know.
2 S
You don't know, okay.
So you have no 3
position on that.
'~
4 Is it your understanding that flow l.
5 through the drywell vents is caused by 6
forces other than pressure within the i '.
7 drywell?
=1 8
A.
The pressure that may be outside the dry-il
,9 well, I'm sure has an effect.
t ii 10 C.
Outside the drvwell?
.il 11 A.
If there is any pressure outside, I mean e\\
12 that may -- that always affects the U
g 13 flod in terms of what the pressure is 14 outside as well as inside, but I think
(
n 15 generally speaking, the way you're 16 I think the caestion you're asking is
.a 17 the pressure we're referring to here in 18 terms of overpressurization, we're cr-g 19 referring to pres'sure within the drywell,
~
20 yes.
8 21 O
All right, fine.. That's what I'm trying 22 to find out.
You're talking about forces I
(L/
- 23 gasses through the horizontal vents, and 24 all I'm asking you is whether there is 25 any force other than pressure within the l
1 y
i
?
b.
41
,.~.
(
1 drywell that causes that to occur, to your 2
knowledge?
3 A
Not to my knowledge.
O All right.
s.
5 A
My. answer is just referring to the fact o
6 that if, for some reason, there happened for some reason, there happened 7
to be a I
}.-
8 to be a high pressure outside the drywell I
,9 within the containment, then that would 10 have an effect, but a
11 O
It's your belief that a pressure could
(,
12 occur inside the containment but outside
(' '
13 the drywell which would cause a gas to 14 flow through the horizontal vents in 15 the weir wall or in.the drywell?
I
' 16 A
It wouldn't cause it to flow through the
{
17 vents, it would have the opposite effect, 18 if would have a tendency to flow down l
19 flow.
I'm quarre'lling over something 20 that's probably not very important.
I'm
.i 21 just saying that that's 22 O
I'm just trying to get at your under-
- 23 standing of how a reactor works.
~
24 A
Yes, generally speaking, it's my -- to 25
,the best of my' knowledge that the force i
i 4
l 42
(
1 that would cause the flow to go through 2-the vents and outside the drywell structure 3
would have to come from inside the drywell.
~
4 Well, if you would look at Professor 5
Streeter's book there, or your own answers 6
to interrogatories where you set forth'
'~
7 your calculation of the Manning's formula, 8
would you identify for me in that calcula-
,9 tion or in the equation the term which
~,. -
l 10 accounts for drywell pressure?
t 11 A
I don't believe there is a variable in F
'12 there for flow caused by pressure within g
-i
[A '
13 the drywell.
It's my understanding, any-a 14 way.
ep
- I 15 G.
All right, looking at your answers to 16 interrogatories, in the third paragraph
[
17 under part C, can you tell me what the
- i 18 value is that you used for -- to define 19 the term " slope of flow"?
20 See those words in the second line 21 of that paragraph?
It's in the third 22 paragraph under C, in the second line f
\\./,
23 of that paragraph.
i 24 A
ch, youLmean in the equation?
~
25 0
Yes, there is a phrase there called " slope t
I g,
43
~
1 of flow".
2 A
The value is 1.1 over 7.
3 G
Where do you obtain that value?
~
A I'm not certain.
5 G
Do you know what the numbers 1.1 and 1
6 7 stand for, what they represent?
['
7 A
Mo, I don't.
Individually taken, as 8
an individual component, no, I don't.
l
,9 As I say, it's placed as a value of I'
10 slope of flow, obviously, in the equation.
11 Well, I understand that.
.I 12 Well, is it your understanding that 13 the horizontal vents are not, in fact, a
14 horizontal?
I 15 A
I'n not certain on that.
I don't know.
I
.j 16 0
You think there is some doubt as to
't:..
17 whether, in fact, they are horizontal?
18
-A I just don't know whether this is the 19 case or not, I pfesume there could be i
i _
20
'a-natural slope to the land on which 21 the reaetor is sitting, as far as it's 22 sitting -- as far as I know.
23 G.
Speaking in terms of design, are they i
24 designed to be horizontal insofar as 25 you know?
l i
{..
lc S.*
~
.i 44 i
1 A
I don't know.
2 You don't know.
Well, if they were 3
horizontal, how would you calculate a
~
r 4
slope of flow for a horizontal vent?
5 A
I presume this -- the slope would be
[
6
[
7 4
It would be flat, wouldn't it?
8 A
Right, I was trying to get the value.
d 9
Yes.
,j" 10 G
All 'right, sir, looking bach at the 11 Manning's forrula, then, what is the
.'s 12 motive force for flow in the Manning's
}
13 factor?
14 Is it your understanding that you 15 always have to have a slope for the i'
j 16 Manning's factor to apply?
I' 17 A
Yes, that's right.
That is, in fact,
)
l 1
18 for the use of the Manning's factor,
{
11 9 that's the force 'that's -- now that I 20 think about it, that does answer your L.
21 question to some degree, as to where
{
22 the force came from.
'It's the force
/ 'T
. (j 23 generated by the slope, by gravity.
24 g
And therefore, would you not agree that 25 the Manning's' factor has nothing to do I
i i
[?
N -
I
}.
45 1
with that calculation?
2 A
I think the purpose of this formula was 3
not necessarily to say that the Manning's j'
4 formula is the -- you know, the perfect c
5 means of neasuring this.
This was meant i
6
'.to be a rough calculation of it, and we T
7 attempted to, you know, -- generally, i
I 8
the principle of the.* tanning 's formula 9
still applies, you know, the general 10 principle of the Manning's formula still 11 applies to the situation.
12 G
How does the general principle still
-.)
13 apply if we have agreed that you have 14 no slope to cause a flow?
15 A
sut you have something to cause a flow I'
16 and --
.}":-
17 G
Eut specifically --
18 A
That would be analagous to the slope.
19 G
It's analagous to' the slope?
20 A
'Yes.
t.
21 O
could you show me somewhere in Professor 22 Streeter's book where it says that?
i 23 A
well, I doubt that he's had the occasion q_!
24 to deal in this book with this particular 25 problem.
I j
i i
46
. L.
1 0
Sir, if you'll look back at your conten-2 tion, you claim that we have improperly 3
calculated the pressure that would be
[
4 generated during a LOCA, L-O-C-A, because 1
5 we have failed to properly account for i
6 the maximum roughness factor within the 7
weir wall and vent pipe.
.i 8
A Well, we were talking about -- you failed
,9 to account for the frictional stress, 10 frictional resistance.'
.i 11 G
All right, sir, what I want you to tell r
i 12 me now is a calculation in Professor
^-
l' 13 Streeter's book or any other book on 14 engineering that uses c Manning's rough-5 15 ness factor in some calculation other 16 than the fianning 's equation; do you 17 know of any such calculation?
18 A
I don't know of any, it would have to be it's my unders'tanding it would have 19 20
'to be an extremely complex model because 21 of the different. variables that would 22 enter into it.
- 23 If you were to make or.e that was l~
24 specifically suited to'this particular t
25 problen --
l 5
r l
i
47 1
.g Mell, is it your belief, then, that the 2
!!anning's equation would not be suited 3
for making that calculation?
~
4 A.
As I say, I think it's suited to -- it's 3
possible to use it for a rough approxima-6 tion.
The attempt in this interrogatory
['
7 was to make -- or this response, was to 8
make a calculation, i't was conservative
.9 to our viewpoint, certainly you have the 10 right to disagree that that's not the 11 case, but that was our attempt in,this 12 interrogatory, and the reason we used
('
[
13 the formula, we attempted to use values
.k 14 and figures that we felt would be con-1 15 servative to our viewpoint to show that
-e-16 yes, it's true there may be more Y
17 it may be true a more complex mod.el would 18 give a more accurate figure or would come 19 closer to giving a more accurate figure, 20
'but our intent was to show what we thought 21 would be a minimum figure.
22 O
All right, what I want to know, then, is L
23 how you came up with the motive force l~~
24 for purposes of your calculation if you 25 agree that there is no slope, and therefore, i
e B
?
48 1
the Manning's equation can't possibiy 2
apply?
t 3
How did you calculate the motive
~
4 force?
5 A
Right offhand, I don't know, That's ahother 6
case where I prefer to perhaps make a 7
written response to it.
8 G
That's because Mr. Scott knows the answer?
9 A
'Yes, I'd say that's the case.
It's my 10 assumption that slope of flow probably
'l 11 has that -- contains that value.
/
12 G
Slope of flow contains what value?
.(
13 A
The force.
14 G
The motive force, but yeu don't knew 15 where those numbers came from in your
-[
16 definition of your value given to slope g
17 of flow?
18 A
no, I don't know how they were computed.
r-19 G
You don't know what 1.1 stands for or 20 what the 7 stands for?
.s 21 A.
.No.
t 22 O
Did you ash Mr. Scott when you signed 23 these interrogatories?
24-A Mo, I trust him.
25 G
And you don't know of any calculation other i
V i
s
~
48 st 1
than Manning's equation which uses an
- ~
t 2
"n" factor, do you?
lr 3
A That uses an "n" factor?
~
4 0
A roughness factor in the calculation.
t 5
A I don't have knowledge of it.
f 6
g And you haven't looked at our P.S.A.R.
..I 7
to de'termine if the calculation in there
.l 8
of the time which it would take to d
9 clear the vents properly accounts for
! [~
10 frictional losses and turning lesses?
I i
11 I haven't looked at the P.S.A.R.
on
'12 that point.
I have looked at the
.i
.13 S.E.R.
on that point.
4 14 4
All rightr sir, would you show me where 15 in the s.E.R.
that you looked to calculate
. i e-l 16 or do your calculation of the time it 17 would take to clear the horizontal vents?
18 A
Do you have the S.E.R.'s there?
f 19 G
Yes, I do.
'Ca n ' t' find it?
20 A
Well, I haven't looked through the last 1
1 21 one yet.
8 22 g
Well, let's go on, then.
- k.,
_ 23 A
There is a chart in here.that graphically 24 shows the number of seconds and so forth.
25 g
The number of seeonds that it takes?
I
\\
i 1
50 1
Okay, maybe we coulf. have somebody look 2
that up and see if that's what you are 3
talking about while we go on.
.~
4 A
I can't remember which of the supplements 5
it's in.
r 6
4 Let me just ask you this for clarification:
7 Is it your understanding that since pres-
)
8 sure is the motive force in this case
,9 for the fluid flow, that any formula to do this calculation must have a component 10 11 in it for pressure and the change in pres-12 sure?
t('
13 A
Yes.
14 G
All right..
Can you tell me just briefly, 15 then, where this contention came from, 16 whose concern it was.and how it came 17 about?
Was this something that you brought 18 up yourself or some, body else?
19 A
No, I'd -- it came about through discus-i
~
- ion with Mr. Scott.
20 s
21 0
So he's the one that basically said, "This i..
22 is a problem or sonething that ought to 23 be explored"?
L.
24 A
Brought it to our attention, yes.
25 All right, looking at page 6 - 9 of the l
I i
51 1
Safety Evaluation Report, dated Hovember 2
1974, is that the table that you were 3
speaking of?
4 A
Yes.
5 0
And that's the table that'you've used as 6
the source of your understanding for the i
7 time it would take for the pressure to 1
1 I.
8 clear the vents?
'9 A
Or at least of the M.R.C.'s scatement of t-10 what they believe it would be.
And what 11 we are claiming is th5.t those figures 4
t 12 did not adequately take into account a
~
13 roughness.
{.,_
14 G
They don't adequately take into account
'I
- I 15 the roughness on the weir wall?
r-Al 16 L
Yes.
- \\
17 G
Backing up a minute to something we dis-r.
I
[
18 cussed earlier, I want to show you a 19 document entitled Texas Public Interest
~
20 Research Group Amendments and Replies to 21 Applicant and Staff to Contentions sub-22' mitted pursuant to ALAD 535.
It's dated
(,
- 23 June 15, 1979.
These are amendments to 24 contentions submitted by TexPIRG earlier, 25
.and I'd like to ask you 15 you were the i
I
$NC
=.
52 8
1 one who prepared those ame nde.en t s ?
2 A
Mo.
3 o
Do you know who prepared then?
4 A
Mo, I wasn't with TexPIRG at the time
~
5 this occurred.
I would presume that it 6
was a Mr. Doherty, and I believe it was 7
Mr. Doherty.
These ar.endments
~
8 0
All right, referring you, Mr. Johnson, to i'
,9 a deposition taken of Mr. Doherty 10 tiovember 19, 1979, in this proceeding, 11 Mr. Doherty said at page 19 that he I-12 worked on the anendments,-- excuse ne.
13 tie ll, reading the whole thing, he o
14 was asked:
15
" Question:
who prepared any other I
16 contentions that have
-l 17 been present in this pro-18 oeeding?
j 1
19 Answer:
'Yes, I prepared some for 20 TexPIRG while I was employed 21
.for them.
22 Question:
Did you prepare any for
,.. ~
23 them while you vere not 24 enployed f or Te:: PIP.G?
25 Answer:.
I did the amendren'ts to l
i
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~