ML20004B609
| ML20004B609 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 05/27/1981 |
| From: | Black R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8105290165 | |
| Download: ML20004B609 (5) | |
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May 27, 1981 66k[
UNITED STATES OF AMERICA I'I/IP 2d T9 NUCLEAR REGULATORY COMMISSION A;
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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HOUSTON LIGHTING & POWER COMPANY Docket No. 50-466
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(Allens Creek Nuclear Generating
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Station, Unit 1)
)
NRC STAFF'S RESPONSE TO INTERVEN0R DOHERTY'S CONTENTION NO. 56 On April 23, 1981, Intervenor Doherty filed a document entitled "Intervenor John F. Doherty's Contention #56." Although this document is not entitled as a motion to add a late-filed contention, it is clear that Intervenor Doherty wishes the document to be treated as such since, particularly, he has addressed the four " good cause" factors of 10 C.F.R. 6 2.714. The NRC Staff opposes the motion to add this contention for the reasons set forth below.
The concern expressed in Doherty Contention No. 56 stems from the NRC's investigation of the partial scram failure that occurred at the Browns Ferry, Unit 3 on June 28, 1980. That investigation resulted in a March,1981, NRC report--the so-called Michaelson Report referenced by Mr. Doherty. The report addresses a potential concern regarding the effects of a postulated scram discharge volume (SDV) rupture.
The report postulates that a normal scram causes a rupture in the SDV, resulting in leakage flows from all control rod drives.
It is further postulated that the rupture could lead to an uncontrolled 810529o
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-2 blowdown outside the primary containment, thereby flooding the equipment roon and resulting in failure of the ECCS pumps. Mr. Doherty, based on his interpretation of the Michaelson Report, therefore concludes that the above postulated accident sequence could jeopardize the public health and safety.
Mr. Doherty's interpretation of the Michaelson Report is void of facts, in error, and is incorrectly used as basis for this contention.
Tne above accident sequence was postulated for review and analysis after the Browns Ferry accident.
In BWR designs such as Browns Ferry, the control rod drive units, the SDV, and the ECCS pumps are all located outside of the primary containment. Therefore, it was postulated that water released from an SDV rupture could flood out or in some other way threaten the ECCS pumps which are located at a lower elevation than the SDV outside containment.
In a liark III containment design such as Allens Creek, the control rod drive units and the SDV are located within the primary containment, while the ECCS pumps are located outside the primary containment.
In the event of a SDV rupture, the water will return directly to the suppression pool and not threaten the ECCS pumps.M y
Mr. Doherty's contention refers to flooding of the " recirculation cooling pumps." Mr. Doherty appears to be confused between the recirculation pumps which are located within the drywell and the ECCS pumps which are located in the auxiliary building outside containment and were the subject of concern in the Michaelson Report.
In any event, pipe breaks inside containment (including pipe breaks inside the drywell) have already been analyzed for the Allens Creek facility.
See PSAR 6 15.1.39.
. l As indicated above, Mr. Doherty's concern regarding the flooding of ECCS pumps from a SDV rupture has no b -is in fact for the Allens Creek facility. Accordingly, this contention should be rejected because it does not meet the " basis" and " specificity" requirements of 10 C.F.R. 9 2.714. Since this contention does not meet this threshold showing, it is not necessary to address the " good cause" requirements of 10 C.F.R. 9 2.714.
It should be sufficient to note that since this contention has no basis, there can be no good cause for its acceptance into the 1
proceeding at this late juncture.
Based on the foregoing, this motion for the admission of Doherty Contention No. 56 should be denied.
Respectfully submitted, kg C
Richard L. Black Counsel for NRC Staff Dated at Bethesda, Maryland, this 27th day of May, 1981.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTO:1 LIGHTING AND POWER COMPAtt'f i Docket No. 50-466 (Allens Creek Nuclear Generating Station, Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S RESPONSE TO INTERVENOR-D0HERTY'S CONTEt4 TION NO. 56" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal mail system, this 27th day of May,1981:
Sheldon J. Wolfe, Esq., Chairman
- Susan Plettman, Esq.
Atomic Safety and Licensing David Preister, Esq.
Board Panel Texas Attorney General's Office U.S. Nuclear Regulatory Commission P.O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711 Dr. E. Leonard Cheatum Hon. Jerry Sliva, Mayor Route 3, Box 350A City of Wallis, TX 77485 l
Watkinsville, Georgia 30677 Hon. John R. Mikeska Mr. Gustave A. Linenberger*
Austin County Judge Atomic Safety and Licensing P.O. Box 310 l
Board Panel Bellville, TX 77418 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. John F. Doherty 4327 Alconbury Street The Honorable Ron Waters Houston, TX 77021 i
State Representative, District 79 3620 Washington Avenue, No. 362 Mr. Willian J. Schuessler Houston, TX 77007 5810 Darnell Houston, TX 77074 J. Gregory Copeland, Esq.
Baker & Botts One Shell Plaza Houston, TX 77002
Jack Newman, Esq.
D. Marrack Lowenstein, Reis, Newman &
420 Mulberry Lane Axelrad Bellaire, TX 77401 1025 Connecticut Avenue, N.W.
Washington, DC 20037 Texas Public Interest Research Group Inc.
Brenda A. McCorkle c/o James Scott, Jr., Esq.
G140 Darnell 13935 Ivymount Houston, TX 77074 Sugarland, TX 77478 Mr. Wayne Rentfro Rosemary N. Lemmer P.O. Box 1335 11423 Oak Spring Rosenberg, TX 77471 Houston, TX 77043 Carro Hinderstein Leotis Johnston 8739 Link Terrace 1407 Scenic Ridge Houston, TX 77025 Houston, TX 77043 Margaret Bishop U.S. Nuclear Regulatory Commission J. Morgan Bishop Region IV, I&E 11418 Dak Spring 611 Ryan Plaza Drive, Suite 1000 Houston, TX 77043 Arlington, TX 76011 Stephen A. Doggett, Esq.
Bryan L. Baker Pollan, Nicholson & Doggett 1923 Hawthorne P.O. Box 532 Houston, TX 77098 Rosenberg, TX 77471 Robin Griffith Carolina Conn 1034 Sally Ann 1414 Scenic Ridge Rosenberg, TX 77471 Houston, TX 77043 Mr. William Perrenod Atomic Safety and Licensing 4070 Merrick Board Panel
- Houston, TX 77025 U.S. Nuclear Regulatory Commission Washington, DC 20555 Docketing and Service Section*
Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Panel
- Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 k-Rictard L. BJ1 ck Counsel for NRC Staff l
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