ML20003H802
| ML20003H802 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 04/23/1981 |
| From: | Doherty J DOHERTY, J.F. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20003H799 | List: |
| References | |
| ISSUANCES-CP, NUDOCS 8105070466 | |
| Download: ML20003H802 (3) | |
Text
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UUITED STATES OF AMERICA EUOLEAR RE3ULATORY COMMISSION APRIL 23,1981 BEFORE THE ATOMIC SAFETY & LICEUSING BOARD In the Matter of:
98 HOUSTON LIGHTING & POWER CO.
Docket No. 50-466 CP' 4' Allens Creek Nuclear Gener-ating Station, Unit 1)
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PR 2 71981 e IHTERVENOR J0FN F. DOHERTY'S CONTENTION #56 WhMcfof(*"H9, 6
r Dxku;g John F. Doherty, intervenor pro-se in the above p
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t ceedings now files the below Contention #56.
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Intervenor contends Applicant's reactor trip system is not protected againd a pipe break to the scram discharge volumis~ff6i:1'thT hy'dfaulic contiol' units.
Sudden breakage of one or more of these pipes would impair public safety because the water would continue *come out of the reactor and possibly drown out, short or otherwise stop the recir-cultion cooling pumps which are located below them, and there is no valve upstream of such break locations to per-mit stopping the loss of coolant., A plausible physical mechanism for pipe break in this part of the control rod hydraulic system would be thermal shock to the non-safety grade piping. Such thermal shock results on a reactor scram.
This Contention-is based on the results of the investi-gation of the June 28, 1980, partial scram failure at the Brown's Ferrv, Unit 3, by the NRC Office for Analysis and Evaluation of Operational Data, authored by Carlyle Michael-son.
T_he report was sent to the Commissioners on April 7, 1981, as recorted in the Washington Post, of April 8, 1981 on page A-9 (attached).
To the best of this Intervenor's knowledge the report was the first publication of discovery of the problem in the contention. IEtervenor believes the requirements of s-10 CFR 2.714 (i) and'(iv) are met by him at the threshold, that is, the timing of the report lays good cause for a late filing, and that there is indeed no other party rep-resenting his interest on this issue.
In 10 CFR 2.714 (10 Intervenor believes it cannot be shown there is available (O
s dg6d at this time other means by which his interest will be protected on this issue.
Under 10 CFR 2.714 (v), this 810 507 0 $ff
, s Intervenor would point out the final schedule for hearing sefety issues is not determined.
Indeed, discovery on issues, while others are in litigation is permissible in a multi-issue administrative hearing, although not desir-able.
In acy case it is not reasonable to deny an Inter-venor the ri-ht to hear an issue, because he won't have time to do discovery on the issue.
Under 10 CFR 2.714 (iii) this Intervenor 1ould ou urge that a record which does 7
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not cover an issue cannot be complete as one that does even if the Intervening party does not present expert Ve'stimony.
Therefore, this Intervenor requests the Board admit into controversy his Contention #56, with discovery to begin at once.
Respectfully Submitted, I
( John F. Doherty, J. D.
Intervanor
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CERTIFICATE OF SERVICE 2
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Copies of "INTERVENOR JOHN F. DOEERTY'S CONTENTION #56" were served on the below partie's'via First Class U. S Postal Service, this o23 April, 1981.
Sheldon J. Wolfe Esq., Gustave A. Linenberger, Dr. E.
Leonard Cheatum,, Administrative Judges J.- Gregory -Copeland,"Esqr and' JackTTe~wman~, Esq., Applicant Richard A. Black, Esq. Staff Jocketing & Service, URC Atomic Safety Licensing & Appeal Board The Several Intervening Parties
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nation's operaths nudear power plants and a re- ;
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reg $22..
m ct cc h3' ors'iom Boy seperctes incluces ocstel pents.
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- S13-S26.. sole 8.9918.99 comprise about two-thirds of the nation's 74 cucieg Fcnc:fulcoc.
plants. It is ponrdbie, accordir4 to Harold Denton, Entre stocx et ;rs' Stctus jecns. shorts and toos NRC's c. rector of reactor regu'ation, that socie have eom Cchnn Ke.Jorocche. Scsson cnd Son Jour.
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reg S32-S38..
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again causing a mehdom l
Foshion riercec ecrnngs wth surgicci steel studs.
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Scientists have long known that neutron radiatim oc!ucas. hoccs. reg $4-8.50...... sole 3.016.31
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from the reactor core makes the msel walls britde Wcmen's felt ncts in c venety of styies for c O.
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. ac w cy.tw buUt reactors to mix mcommg cold water with hot c
insto ed. fro-2-for-1 scie on many Wcmer brcs and body gar-:..
r-m water to cusha the impact. But Denton told reac.
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E4 sovrgs on misses' wcirm rebes for snDogie, smye ste ec Y
Ironicany, new rules in effect sina the accident at 3.
Three MUe Island two years ago could make things comfort, orig. * $24-538....... sole 9.9915.99 just 5. reg SL J-4 aorse. The rules require operators to leave high-Entre stock of ct'Jcren's cocts. trned for ecster Mcgncver 2t, M
pressure water pumps nmning if they come en au-cressrq gris 414. todd:ers cnd infcnts too, cokxleveh g Y
tornaticaty because operators at TMI turned them req 515-S62.......
...... scle 11.21-46.41 Teknikc19"c reg S400.
off and the reactor core overheated as a result. But Chacrens ecstsc esstmenystymW -.
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leaving them on, it turns out, incieses pressure on t
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the hot waUs at the worst possible moment-just MEN'S AND BOYS' WEAR cmsumpnce as the cold wa-ter hits.
RCA25 rer-F Men's necicuecr. reg 7.50-511........... scle $6 Sb goce
[_. 'Ibe bo!!!ng-water reactor problem invohes several m
6 2 pipes rarps irilla. gter from d4-mcn to 6 mer.e*
Men'slong s'eeve heavy-we+ght,hirts. ~
Gusdorf Tu-that carry _ab_o_ut 600 gaSms or water out of tif or;g
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_ reactor core to afp tang wnen taere is an au-Men',s Vcn Heusen iong s'eeve sport shirtsc z,
tomanc shutdown. ine pipes also undergo "signifi-O'O E
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FURNITUR little that, they do not fa!! under the STIC's regula.
$2 tions for routine inspection, said Stuart D. Rubin. I regS25.
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f If one' or more should break, highly radicc.cthe water would spill into the reactor buildin;; where it h.4--
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