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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063N7591982-10-0606 October 1982 Withdrawal of Application for CP ML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20055A7221982-07-15015 July 1982 Memorandum & Order Denying Jf Doherty 820615 Submittals, Treated as Motion to Reconsider ASLB 820602 Order.Motion Untimely Filed & Failed to Show Significance or Gravity of Issues ML20055A3551982-07-12012 July 1982 Amended Contention 59.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20053D6371982-06-0202 June 1982 Memorandum & Order Denying J Doherty 820422 Motion Re Contention 58 on Applicant Conduct on Reporting Violations. Applicant 820519 Motion to Strike Doherty 820514 Reply Granted ML20053A3961982-05-24024 May 1982 Order Extending Commission Time to Review ALAB-671 Until 820601 ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F9941982-05-12012 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention 58.Intervenor Fails to Meet Required Stds to Reopen Record & for Untimely Filings.Certificate of Svc Encl ML20052F2971982-05-10010 May 1982 Order Extending Time Until 820524 for Commission to Determine Whether to Review ALAB-671 ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20052D1221982-04-29029 April 1982 Findings of Fact on Supplemental Issues to Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20052A4541982-04-22022 April 1982 Submittal of Contention 58 Re Applicant Conduct on Reporting Violations at Plant.Certificate of Svc Encl ML20054E0561982-04-21021 April 1982 Supplemental Findings of Fact on Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20054D5251982-04-20020 April 1982 Order Incorporating ASLB Rulings at 820412 Hearing Re Tx Pirg 820405 Motion to Enter Counsel for cross-examination & to Reconsider 820128 Order.Motion Denied But Tx Pirg Permitted to Submit Written cross-examination Questions ML20054B6981982-04-14014 April 1982 Transcript of 820414 Hearing.Pp 21,787-22,027 ML20050E2181982-04-0808 April 1982 Order Ruling on Doherty Motions.Request for Production of Bechtel Quadrex Rept Review Moot Since Applicant Furnished Rept on 820316.Motion of 820315 for Subpoena of Quadrex Corp Employees Denied W/O Prejudice ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050B1141982-03-31031 March 1982 Decision ALAB-671,affirming ASLB Decision Denying R Alexander Petition to Intervene.Aslb Assessment of Untimeliness of Petition Free of Matl Error.Issue Raised No Longer Cognizable ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20042C5661982-03-30030 March 1982 Reply Opposing Tx PIRG,810315 Proposed Findings of Fact & Conclusions of Law.Proposed Findings Are Collection of Disjointed Thoughts & Facts W/No Rational Assessment of Effect on Problem or Issue Discussed.W/Certificate of Svc ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20049K0671982-03-25025 March 1982 Reply to Tx Pirg 820315 Addl Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20049J9651982-03-24024 March 1982 Testimony of Fr Allenspach & JW Gilray Per ASLB 810128 Order Re Doherty Renewed Motion for Addl Evidence on Tx Pirg Addl Contention 31.Quadrex Rept Does Not Alter Previous Conclusions That Applicant Technically Qualified ML20049J9701982-03-24024 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31.Certificate of Svc Encl ML20049J9671982-03-24024 March 1982 Response to First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31 ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20042A2721982-03-18018 March 1982 Order Scheduling 820412-16 Evidentiary Hearing to Receive Addl Evidence in Houston,Tx ML20042A2771982-03-18018 March 1982 Memorandum & Order Denying J Doherty 820310 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Ample Time to Complete Discovery Given.Personal Obligations Are No Excuse ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20041G1711982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion to Postpone 820412 Hearing on Quadrex Rept.Doherty Cannot Profit from Failure to Comply W/Aslb Order Re Completion of Discovery by Postponing Hearing.Certificate of Svc Encl 1982-07-02
[Table view] Category:TRANSCRIPTS
MONTHYEARML20054B6981982-04-14014 April 1982 Transcript of 820414 Hearing.Pp 21,787-22,027 ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20049J9651982-03-24024 March 1982 Testimony of Fr Allenspach & JW Gilray Per ASLB 810128 Order Re Doherty Renewed Motion for Addl Evidence on Tx Pirg Addl Contention 31.Quadrex Rept Does Not Alter Previous Conclusions That Applicant Technically Qualified ML20038D0461981-12-0909 December 1981 Transcript of 811209 CP Hearing in Houston,Tx. Pp 21,103-21,328 ML20038D0451981-12-0808 December 1981 Transcript of 811208 CP Hearing in Houston,Tx.Pp 20,939- 21,102 ML20038D0441981-12-0707 December 1981 Trancript of 811207 CP Hearing in Houston,Tx.Pp 20,774- 20,938 ML20033A3281981-11-20020 November 1981 Transcript of 811120 CP Hearing in Houston,Tx.Pp 20,650- 20,773.Related Documentation Encl ML20033A3471981-11-18018 November 1981 Transcript of 811118 CP Hearing in Houston,Tx.Pp 20,276- 20,407 ML20033A3571981-11-17017 November 1981 Transcript of 811117 CP Hearing in Houston,Tx.Pp 200,070- 20,145 & 20,152-20,275.Related Documentation Encl ML20033A3391981-11-16016 November 1981 Transcript of 811116 CP Hearing in Houston,Tx.Pp 19,863- 20,069.Affidavits & Related Documentation Encl ML20032B2081981-10-30030 October 1981 Testimony of Wl Brooks Re Doherty Contention 15 That Industry Std Power Excursion Theory Inadequate to Represent Increase in Heat Energy Due to Rapid Increase in Reactivity in Design Based Power Excursion Accident ML20032B2131981-10-30030 October 1981 Testimony of Wl Brooks Re Doherty Contention 24.Basis Has Been Developed for Conclusions That Potential Worth of Postulated Dropped Rod Sufficiently Small to Prevent Peak Energy Yield of 280 Cal./Gm ML20032B2021981-10-30030 October 1981 Testimony of Vth Leung Re Doherty Contention 11 on Fuel Pool Integrity Consequences When Spent Fuel Assembly Dropped on Pool Floor.Dropped Assembly Would Not Penetrate Steel Liner. Concrete Floor Below Steel Liner Would Not Be Damaged ML20032B2101981-10-30030 October 1981 Testimony of Wl Brooks Re Doherty Contention 21 on Core Power Density & Adequacy of Odyn Code to Demonstrate Reactor Scram Curve.Applicant Will Not Be Required to Perform Analyses W/Odyn Code at CP Stage ML20032B0111981-10-30030 October 1981 Transcript of 811030 Hearing in Houston,Tx.Pp 19,593-19,862. Gotchy,Litton,Gunther & Malec Testimonies,Exhibits, Affidavits & Impact of U Fuel Cycle Encl ML20032B2041981-10-30030 October 1981 Testimony of Jf Knight & Je Kennedy Re ASLB Questions on Scram Discharge Level Monitoring Sys.Transmitters Measuring Scram Discharge Vol Level Must Conform to Category I Environ Qualification Requirements ML20032A9911981-10-29029 October 1981 Transcript of 811029 Hearing in Houston,Tx.Pp 19,331-19,592. Field,Martin,Malec & Chiou Testimony,Exhibits,Topical Repts, Errata,Prof Qualifications & Other Supportive Documentation Encl ML20032B0041981-10-28028 October 1981 Transcript of 811028 CP Hearing in Houston,Tx. Pp 19,074-19,330 ML20032A9901981-10-27027 October 1981 Transcript of 811027 Hearing in Houston,Tx.Pp 18,868-19,073. Hou & Peterson Testimony,Affidavits & Prof Qualifications Encl ML20032A9881981-10-26026 October 1981 Transcript of 811026 Hearing in Houston,Tx.Pp 18,606-18,867. Urbanik & Kantor Testimony & Other Supportive Documentation Encl ML20011A6301981-10-22022 October 1981 Testimony of FB Litton Re Doherty Contention 43 on Stainless Steel Cleaning & Reg Guide 1.54.Applicant Meets All Applicable NRC Licensing Requirements Re Cleaning & Coating Matls for CP ML20031E5501981-10-14014 October 1981 Table 1 & Attachment 1,inadvertently Omitted from 811009 Testimony Re Increased Risk of Cancer & Noncancerous Effects from App I Levels of Radiation ML20031E5511981-10-14014 October 1981 Testimony of T Urbanik Re Evacuation Time Estimate Study. Prof Qualifications Encl ML20031D6951981-10-0909 October 1981 Testimony of Rl Gotchy Re Potential Public Health Impact of Rn-222 Releases Resulting from U Mining & Milling.Average Annual Dose Increase Insignificant ML20031D7111981-10-0909 October 1981 Testimony of Rl Grubb Re Core Lateral Support (Doherty Contention 45).Reactor Core Will Withstand Combined Seismic/Loca Loadings.Prof Qualifications Encl ML20031D6631981-10-0909 October 1981 Testimony of F Kantor Re Emergency Planning Issue (Schuessler Consolidated Contention 1).Applicant Info Meets App E,Part Ii,Item H Requirements.Prof Qualifications Encl ML20031D6841981-10-0909 October 1981 Testimony of Hou Re Control Rod Ejection (Doherty Contention 28).Facility Protective Measures Ensure Public Safety for Postulated Rod Ejection Accident.Prof Qualifications Encl ML20031D6741981-10-0909 October 1981 Testimony of Mb Fields Re Bypass Leakage (Mccorkle Contention 17) ML20031D6831981-10-0909 October 1981 Testimony of Hou Re Flow Induced Vibration (Tx Pirg Contention 11 & Doherty Contention 31).Applicant Info Adequate for CP Application.Prof Qualifications Encl ML20031D7161981-10-0909 October 1981 Testimony of FB Litton Re Intergranular Stress Corrosion Cracking/Water Hammer (Doherty Contention 44).Applicant Program Complies W/Nrc Recommendations to Minimize Occurrences ML20031D6701981-10-0909 October 1981 Testimony of Rl Gotchy Re Increased Risk of Cancer & Noncancerous Effects from App I Levels of Radiation (Cummings Contention 9).Health Effects Models Underestimated Health Risks ML20031D6781981-10-0909 October 1981 Testimony of Mb Fields Re Suppression Pool Swell (Doherty Contention 5) ML20031D7171981-10-0909 October 1981 Testimony of FB Litton Re Intergranular Stress Corrosion Cracking (Tx Pirg Contention 10) ML20031D8561981-10-0909 October 1981 Transcript of 811009 CP Hearing in Houston,Tx. Pp 18,450-18,605.LA Gunther & RA Frazar Testimony Re Doherty Contention 35 (Welding) & Prof Qualifications Encl ML20031D6711981-10-0909 October 1981 Testimony of Mb Fields Re Mannings Coefficient (Tx Pirg Contention 6) ML20031D8401981-10-0808 October 1981 Transcript of 811008 Hearing in Houston,Tx.Pp 18,218-18,449. F Allenspach & J Gilray Testimony & Organization & Staffing to Oversee Design & Const Encl ML20031D8541981-10-0707 October 1981 Transcript of 811007 CP Hearing in Houston,Tx.Pp 18,014- 18,217.GW Oprea & Jh Goldberg Testimony Encl ML20031D8381981-10-0606 October 1981 Transcript of 811006 Hearing in Houston,Tx.Pp 17,800-18,013. Testimony of M Mitchell,M Hodges,T Huang,C Ferrell & L Soffer Encl ML20031D8531981-10-0505 October 1981 Transcript of 811005 CP Hearing in Houston,Tx.Pp 17,574- 17,799 ML20031A3791981-09-18018 September 1981 Transcript of 810918 CP Hearing in Houston,Tx.Pp 17,391- 17,573.Prof Qualifications of El Murri,Wr Griffin & RW Lawhn Encl ML20031H4671981-09-18018 September 1981 Testimony of Mk Mitchell Re Doherty Contention 38(b) on Cold Shutdown within 24 Hours.No NRC Requirements Specify Facility Be Designed to Be Capable of Being Brought to Cold Shutdown in 24 Hours ML20031H4831981-09-18018 September 1981 Testimony of La Gunther & RA Frazer Re Doherty Contention 35 on Welding.Describes Planned Welding Program.Prof Qualifications Encl ML20031H4821981-09-18018 September 1981 Testimony of Ma Lugo Re Tx Pirg Addl Contention 6 on Mannings Coefficient & ASLB Question on Svc Level Stress Limits.Margin of Safety Above Design Pressure at 15 Psig Is 35 Psig.Prof Qualifications ML20031H3641981-09-18018 September 1981 Testimony of La Gunther & Wf Malec Re Tx Pirg Contention 10, Doherty Contentions 44 & 43 & ASLB Question on Reg Guide 1.54 ML20031H4581981-09-18018 September 1981 Testimony of RR Hobson & Jg Dunlap Re Doherty Contention 45 on Core Lateral Support.Facility Fuel Assemblies Comply W/Recommendations in NUREG/CR-1018.Prof Qualifications Encl ML20031H4791981-09-18018 September 1981 Testimony of DA Nuto Re Doherty Contention 5 Re Supression Pool Uplift.Suppression Pool Swell Effects During LOCA Will Not Cause Structural Damage to Steel Platform Supporting Hydraulic Control Units.Prof Qualifications Encl ML20031H3791981-09-18018 September 1981 Testimony of G Martin & Wf Malec Re Mccorkle Contention 17 on Bypass Leakage.Aslb Statement Correct That No Difference Exists in % by Weight & % by Vol ML20031H4731981-09-18018 September 1981 Testimony of Gm Gordon Re Tx Pirg Contention 10,Doherty Contentions 10,43 & 44 ML20031H3461981-09-18018 September 1981 Testimony of Sp Congdon Re Doherty Contention 15 on Wigle Computer Code.No Basis for Contention.Criteria Contained in Spert Rept Irrelevant to Scram Reactivity Calculations 1982-04-14
[Table view] Category:DEPOSITIONS
MONTHYEARML20054B6981982-04-14014 April 1982 Transcript of 820414 Hearing.Pp 21,787-22,027 ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20049J9651982-03-24024 March 1982 Testimony of Fr Allenspach & JW Gilray Per ASLB 810128 Order Re Doherty Renewed Motion for Addl Evidence on Tx Pirg Addl Contention 31.Quadrex Rept Does Not Alter Previous Conclusions That Applicant Technically Qualified ML20038D0461981-12-0909 December 1981 Transcript of 811209 CP Hearing in Houston,Tx. Pp 21,103-21,328 ML20038D0451981-12-0808 December 1981 Transcript of 811208 CP Hearing in Houston,Tx.Pp 20,939- 21,102 ML20038D0441981-12-0707 December 1981 Trancript of 811207 CP Hearing in Houston,Tx.Pp 20,774- 20,938 ML20033A3281981-11-20020 November 1981 Transcript of 811120 CP Hearing in Houston,Tx.Pp 20,650- 20,773.Related Documentation Encl ML20033A3471981-11-18018 November 1981 Transcript of 811118 CP Hearing in Houston,Tx.Pp 20,276- 20,407 ML20033A3571981-11-17017 November 1981 Transcript of 811117 CP Hearing in Houston,Tx.Pp 200,070- 20,145 & 20,152-20,275.Related Documentation Encl ML20033A3391981-11-16016 November 1981 Transcript of 811116 CP Hearing in Houston,Tx.Pp 19,863- 20,069.Affidavits & Related Documentation Encl ML20032B2081981-10-30030 October 1981 Testimony of Wl Brooks Re Doherty Contention 15 That Industry Std Power Excursion Theory Inadequate to Represent Increase in Heat Energy Due to Rapid Increase in Reactivity in Design Based Power Excursion Accident ML20032B2131981-10-30030 October 1981 Testimony of Wl Brooks Re Doherty Contention 24.Basis Has Been Developed for Conclusions That Potential Worth of Postulated Dropped Rod Sufficiently Small to Prevent Peak Energy Yield of 280 Cal./Gm ML20032B2021981-10-30030 October 1981 Testimony of Vth Leung Re Doherty Contention 11 on Fuel Pool Integrity Consequences When Spent Fuel Assembly Dropped on Pool Floor.Dropped Assembly Would Not Penetrate Steel Liner. Concrete Floor Below Steel Liner Would Not Be Damaged ML20032B2101981-10-30030 October 1981 Testimony of Wl Brooks Re Doherty Contention 21 on Core Power Density & Adequacy of Odyn Code to Demonstrate Reactor Scram Curve.Applicant Will Not Be Required to Perform Analyses W/Odyn Code at CP Stage ML20032B0111981-10-30030 October 1981 Transcript of 811030 Hearing in Houston,Tx.Pp 19,593-19,862. Gotchy,Litton,Gunther & Malec Testimonies,Exhibits, Affidavits & Impact of U Fuel Cycle Encl ML20032B2041981-10-30030 October 1981 Testimony of Jf Knight & Je Kennedy Re ASLB Questions on Scram Discharge Level Monitoring Sys.Transmitters Measuring Scram Discharge Vol Level Must Conform to Category I Environ Qualification Requirements ML20032A9911981-10-29029 October 1981 Transcript of 811029 Hearing in Houston,Tx.Pp 19,331-19,592. Field,Martin,Malec & Chiou Testimony,Exhibits,Topical Repts, Errata,Prof Qualifications & Other Supportive Documentation Encl ML20032B0041981-10-28028 October 1981 Transcript of 811028 CP Hearing in Houston,Tx. Pp 19,074-19,330 ML20032A9901981-10-27027 October 1981 Transcript of 811027 Hearing in Houston,Tx.Pp 18,868-19,073. Hou & Peterson Testimony,Affidavits & Prof Qualifications Encl ML20032A9881981-10-26026 October 1981 Transcript of 811026 Hearing in Houston,Tx.Pp 18,606-18,867. Urbanik & Kantor Testimony & Other Supportive Documentation Encl ML20011A6301981-10-22022 October 1981 Testimony of FB Litton Re Doherty Contention 43 on Stainless Steel Cleaning & Reg Guide 1.54.Applicant Meets All Applicable NRC Licensing Requirements Re Cleaning & Coating Matls for CP ML20031E5501981-10-14014 October 1981 Table 1 & Attachment 1,inadvertently Omitted from 811009 Testimony Re Increased Risk of Cancer & Noncancerous Effects from App I Levels of Radiation ML20031E5511981-10-14014 October 1981 Testimony of T Urbanik Re Evacuation Time Estimate Study. Prof Qualifications Encl ML20031D6951981-10-0909 October 1981 Testimony of Rl Gotchy Re Potential Public Health Impact of Rn-222 Releases Resulting from U Mining & Milling.Average Annual Dose Increase Insignificant ML20031D7111981-10-0909 October 1981 Testimony of Rl Grubb Re Core Lateral Support (Doherty Contention 45).Reactor Core Will Withstand Combined Seismic/Loca Loadings.Prof Qualifications Encl ML20031D6631981-10-0909 October 1981 Testimony of F Kantor Re Emergency Planning Issue (Schuessler Consolidated Contention 1).Applicant Info Meets App E,Part Ii,Item H Requirements.Prof Qualifications Encl ML20031D6841981-10-0909 October 1981 Testimony of Hou Re Control Rod Ejection (Doherty Contention 28).Facility Protective Measures Ensure Public Safety for Postulated Rod Ejection Accident.Prof Qualifications Encl ML20031D6741981-10-0909 October 1981 Testimony of Mb Fields Re Bypass Leakage (Mccorkle Contention 17) ML20031D6831981-10-0909 October 1981 Testimony of Hou Re Flow Induced Vibration (Tx Pirg Contention 11 & Doherty Contention 31).Applicant Info Adequate for CP Application.Prof Qualifications Encl ML20031D7161981-10-0909 October 1981 Testimony of FB Litton Re Intergranular Stress Corrosion Cracking/Water Hammer (Doherty Contention 44).Applicant Program Complies W/Nrc Recommendations to Minimize Occurrences ML20031D6701981-10-0909 October 1981 Testimony of Rl Gotchy Re Increased Risk of Cancer & Noncancerous Effects from App I Levels of Radiation (Cummings Contention 9).Health Effects Models Underestimated Health Risks ML20031D6781981-10-0909 October 1981 Testimony of Mb Fields Re Suppression Pool Swell (Doherty Contention 5) ML20031D7171981-10-0909 October 1981 Testimony of FB Litton Re Intergranular Stress Corrosion Cracking (Tx Pirg Contention 10) ML20031D8561981-10-0909 October 1981 Transcript of 811009 CP Hearing in Houston,Tx. Pp 18,450-18,605.LA Gunther & RA Frazar Testimony Re Doherty Contention 35 (Welding) & Prof Qualifications Encl ML20031D6711981-10-0909 October 1981 Testimony of Mb Fields Re Mannings Coefficient (Tx Pirg Contention 6) ML20031D8401981-10-0808 October 1981 Transcript of 811008 Hearing in Houston,Tx.Pp 18,218-18,449. F Allenspach & J Gilray Testimony & Organization & Staffing to Oversee Design & Const Encl ML20031D8541981-10-0707 October 1981 Transcript of 811007 CP Hearing in Houston,Tx.Pp 18,014- 18,217.GW Oprea & Jh Goldberg Testimony Encl ML20031D8381981-10-0606 October 1981 Transcript of 811006 Hearing in Houston,Tx.Pp 17,800-18,013. Testimony of M Mitchell,M Hodges,T Huang,C Ferrell & L Soffer Encl ML20031D8531981-10-0505 October 1981 Transcript of 811005 CP Hearing in Houston,Tx.Pp 17,574- 17,799 ML20031A3791981-09-18018 September 1981 Transcript of 810918 CP Hearing in Houston,Tx.Pp 17,391- 17,573.Prof Qualifications of El Murri,Wr Griffin & RW Lawhn Encl ML20031H4671981-09-18018 September 1981 Testimony of Mk Mitchell Re Doherty Contention 38(b) on Cold Shutdown within 24 Hours.No NRC Requirements Specify Facility Be Designed to Be Capable of Being Brought to Cold Shutdown in 24 Hours ML20031H4831981-09-18018 September 1981 Testimony of La Gunther & RA Frazer Re Doherty Contention 35 on Welding.Describes Planned Welding Program.Prof Qualifications Encl ML20031H4821981-09-18018 September 1981 Testimony of Ma Lugo Re Tx Pirg Addl Contention 6 on Mannings Coefficient & ASLB Question on Svc Level Stress Limits.Margin of Safety Above Design Pressure at 15 Psig Is 35 Psig.Prof Qualifications ML20031H3641981-09-18018 September 1981 Testimony of La Gunther & Wf Malec Re Tx Pirg Contention 10, Doherty Contentions 44 & 43 & ASLB Question on Reg Guide 1.54 ML20031H4581981-09-18018 September 1981 Testimony of RR Hobson & Jg Dunlap Re Doherty Contention 45 on Core Lateral Support.Facility Fuel Assemblies Comply W/Recommendations in NUREG/CR-1018.Prof Qualifications Encl ML20031H4791981-09-18018 September 1981 Testimony of DA Nuto Re Doherty Contention 5 Re Supression Pool Uplift.Suppression Pool Swell Effects During LOCA Will Not Cause Structural Damage to Steel Platform Supporting Hydraulic Control Units.Prof Qualifications Encl ML20031H3791981-09-18018 September 1981 Testimony of G Martin & Wf Malec Re Mccorkle Contention 17 on Bypass Leakage.Aslb Statement Correct That No Difference Exists in % by Weight & % by Vol ML20031H4731981-09-18018 September 1981 Testimony of Gm Gordon Re Tx Pirg Contention 10,Doherty Contentions 10,43 & 44 ML20031H3461981-09-18018 September 1981 Testimony of Sp Congdon Re Doherty Contention 15 on Wigle Computer Code.No Basis for Contention.Criteria Contained in Spert Rept Irrelevant to Scram Reactivity Calculations 1982-04-14
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML20054B6981982-04-14014 April 1982 Transcript of 820414 Hearing.Pp 21,787-22,027 ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20049J9651982-03-24024 March 1982 Testimony of Fr Allenspach & JW Gilray Per ASLB 810128 Order Re Doherty Renewed Motion for Addl Evidence on Tx Pirg Addl Contention 31.Quadrex Rept Does Not Alter Previous Conclusions That Applicant Technically Qualified ML20038D0461981-12-0909 December 1981 Transcript of 811209 CP Hearing in Houston,Tx. Pp 21,103-21,328 ML20038D0451981-12-0808 December 1981 Transcript of 811208 CP Hearing in Houston,Tx.Pp 20,939- 21,102 ML20038D0441981-12-0707 December 1981 Trancript of 811207 CP Hearing in Houston,Tx.Pp 20,774- 20,938 ML20033A3281981-11-20020 November 1981 Transcript of 811120 CP Hearing in Houston,Tx.Pp 20,650- 20,773.Related Documentation Encl ML20033A3471981-11-18018 November 1981 Transcript of 811118 CP Hearing in Houston,Tx.Pp 20,276- 20,407 ML20033A3571981-11-17017 November 1981 Transcript of 811117 CP Hearing in Houston,Tx.Pp 200,070- 20,145 & 20,152-20,275.Related Documentation Encl ML20033A3391981-11-16016 November 1981 Transcript of 811116 CP Hearing in Houston,Tx.Pp 19,863- 20,069.Affidavits & Related Documentation Encl ML20032B2081981-10-30030 October 1981 Testimony of Wl Brooks Re Doherty Contention 15 That Industry Std Power Excursion Theory Inadequate to Represent Increase in Heat Energy Due to Rapid Increase in Reactivity in Design Based Power Excursion Accident ML20032B2131981-10-30030 October 1981 Testimony of Wl Brooks Re Doherty Contention 24.Basis Has Been Developed for Conclusions That Potential Worth of Postulated Dropped Rod Sufficiently Small to Prevent Peak Energy Yield of 280 Cal./Gm ML20032B2021981-10-30030 October 1981 Testimony of Vth Leung Re Doherty Contention 11 on Fuel Pool Integrity Consequences When Spent Fuel Assembly Dropped on Pool Floor.Dropped Assembly Would Not Penetrate Steel Liner. Concrete Floor Below Steel Liner Would Not Be Damaged ML20032B2101981-10-30030 October 1981 Testimony of Wl Brooks Re Doherty Contention 21 on Core Power Density & Adequacy of Odyn Code to Demonstrate Reactor Scram Curve.Applicant Will Not Be Required to Perform Analyses W/Odyn Code at CP Stage ML20032B0111981-10-30030 October 1981 Transcript of 811030 Hearing in Houston,Tx.Pp 19,593-19,862. Gotchy,Litton,Gunther & Malec Testimonies,Exhibits, Affidavits & Impact of U Fuel Cycle Encl ML20032B2041981-10-30030 October 1981 Testimony of Jf Knight & Je Kennedy Re ASLB Questions on Scram Discharge Level Monitoring Sys.Transmitters Measuring Scram Discharge Vol Level Must Conform to Category I Environ Qualification Requirements ML20032A9911981-10-29029 October 1981 Transcript of 811029 Hearing in Houston,Tx.Pp 19,331-19,592. Field,Martin,Malec & Chiou Testimony,Exhibits,Topical Repts, Errata,Prof Qualifications & Other Supportive Documentation Encl ML20032B0041981-10-28028 October 1981 Transcript of 811028 CP Hearing in Houston,Tx. Pp 19,074-19,330 ML20032A9901981-10-27027 October 1981 Transcript of 811027 Hearing in Houston,Tx.Pp 18,868-19,073. Hou & Peterson Testimony,Affidavits & Prof Qualifications Encl ML20032A9881981-10-26026 October 1981 Transcript of 811026 Hearing in Houston,Tx.Pp 18,606-18,867. Urbanik & Kantor Testimony & Other Supportive Documentation Encl ML20011A6301981-10-22022 October 1981 Testimony of FB Litton Re Doherty Contention 43 on Stainless Steel Cleaning & Reg Guide 1.54.Applicant Meets All Applicable NRC Licensing Requirements Re Cleaning & Coating Matls for CP ML20031E5501981-10-14014 October 1981 Table 1 & Attachment 1,inadvertently Omitted from 811009 Testimony Re Increased Risk of Cancer & Noncancerous Effects from App I Levels of Radiation ML20031E5511981-10-14014 October 1981 Testimony of T Urbanik Re Evacuation Time Estimate Study. Prof Qualifications Encl ML20031D6951981-10-0909 October 1981 Testimony of Rl Gotchy Re Potential Public Health Impact of Rn-222 Releases Resulting from U Mining & Milling.Average Annual Dose Increase Insignificant ML20031D7111981-10-0909 October 1981 Testimony of Rl Grubb Re Core Lateral Support (Doherty Contention 45).Reactor Core Will Withstand Combined Seismic/Loca Loadings.Prof Qualifications Encl ML20031D6631981-10-0909 October 1981 Testimony of F Kantor Re Emergency Planning Issue (Schuessler Consolidated Contention 1).Applicant Info Meets App E,Part Ii,Item H Requirements.Prof Qualifications Encl ML20031D6841981-10-0909 October 1981 Testimony of Hou Re Control Rod Ejection (Doherty Contention 28).Facility Protective Measures Ensure Public Safety for Postulated Rod Ejection Accident.Prof Qualifications Encl ML20031D6741981-10-0909 October 1981 Testimony of Mb Fields Re Bypass Leakage (Mccorkle Contention 17) ML20031D6831981-10-0909 October 1981 Testimony of Hou Re Flow Induced Vibration (Tx Pirg Contention 11 & Doherty Contention 31).Applicant Info Adequate for CP Application.Prof Qualifications Encl ML20031D7161981-10-0909 October 1981 Testimony of FB Litton Re Intergranular Stress Corrosion Cracking/Water Hammer (Doherty Contention 44).Applicant Program Complies W/Nrc Recommendations to Minimize Occurrences ML20031D6701981-10-0909 October 1981 Testimony of Rl Gotchy Re Increased Risk of Cancer & Noncancerous Effects from App I Levels of Radiation (Cummings Contention 9).Health Effects Models Underestimated Health Risks ML20031D6781981-10-0909 October 1981 Testimony of Mb Fields Re Suppression Pool Swell (Doherty Contention 5) ML20031D7171981-10-0909 October 1981 Testimony of FB Litton Re Intergranular Stress Corrosion Cracking (Tx Pirg Contention 10) ML20031D8561981-10-0909 October 1981 Transcript of 811009 CP Hearing in Houston,Tx. Pp 18,450-18,605.LA Gunther & RA Frazar Testimony Re Doherty Contention 35 (Welding) & Prof Qualifications Encl ML20031D6711981-10-0909 October 1981 Testimony of Mb Fields Re Mannings Coefficient (Tx Pirg Contention 6) ML20031D8401981-10-0808 October 1981 Transcript of 811008 Hearing in Houston,Tx.Pp 18,218-18,449. F Allenspach & J Gilray Testimony & Organization & Staffing to Oversee Design & Const Encl ML20031D8541981-10-0707 October 1981 Transcript of 811007 CP Hearing in Houston,Tx.Pp 18,014- 18,217.GW Oprea & Jh Goldberg Testimony Encl ML20031D8381981-10-0606 October 1981 Transcript of 811006 Hearing in Houston,Tx.Pp 17,800-18,013. Testimony of M Mitchell,M Hodges,T Huang,C Ferrell & L Soffer Encl ML20031D8531981-10-0505 October 1981 Transcript of 811005 CP Hearing in Houston,Tx.Pp 17,574- 17,799 ML20031A3791981-09-18018 September 1981 Transcript of 810918 CP Hearing in Houston,Tx.Pp 17,391- 17,573.Prof Qualifications of El Murri,Wr Griffin & RW Lawhn Encl ML20031H4671981-09-18018 September 1981 Testimony of Mk Mitchell Re Doherty Contention 38(b) on Cold Shutdown within 24 Hours.No NRC Requirements Specify Facility Be Designed to Be Capable of Being Brought to Cold Shutdown in 24 Hours ML20031H4831981-09-18018 September 1981 Testimony of La Gunther & RA Frazer Re Doherty Contention 35 on Welding.Describes Planned Welding Program.Prof Qualifications Encl ML20031H4821981-09-18018 September 1981 Testimony of Ma Lugo Re Tx Pirg Addl Contention 6 on Mannings Coefficient & ASLB Question on Svc Level Stress Limits.Margin of Safety Above Design Pressure at 15 Psig Is 35 Psig.Prof Qualifications ML20031H3641981-09-18018 September 1981 Testimony of La Gunther & Wf Malec Re Tx Pirg Contention 10, Doherty Contentions 44 & 43 & ASLB Question on Reg Guide 1.54 ML20031H4581981-09-18018 September 1981 Testimony of RR Hobson & Jg Dunlap Re Doherty Contention 45 on Core Lateral Support.Facility Fuel Assemblies Comply W/Recommendations in NUREG/CR-1018.Prof Qualifications Encl ML20031H4791981-09-18018 September 1981 Testimony of DA Nuto Re Doherty Contention 5 Re Supression Pool Uplift.Suppression Pool Swell Effects During LOCA Will Not Cause Structural Damage to Steel Platform Supporting Hydraulic Control Units.Prof Qualifications Encl ML20031H3791981-09-18018 September 1981 Testimony of G Martin & Wf Malec Re Mccorkle Contention 17 on Bypass Leakage.Aslb Statement Correct That No Difference Exists in % by Weight & % by Vol ML20031H4731981-09-18018 September 1981 Testimony of Gm Gordon Re Tx Pirg Contention 10,Doherty Contentions 10,43 & 44 ML20031H3461981-09-18018 September 1981 Testimony of Sp Congdon Re Doherty Contention 15 on Wigle Computer Code.No Basis for Contention.Criteria Contained in Spert Rept Irrelevant to Scram Reactivity Calculations 1982-04-14
[Table view] |
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Scptemb r 18, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
In the Matter of
~S
^
S HOUSTON LIGHTING & POWER COMPANY S
Docket No. 50-466 S
I (Allens Creek Nuclear Generating S
[
Station, Unit 1)
S 3
I 4
DIRECT TESTIMONY OF DONALD L. PETERSON 3
REGARDING DOHERTY CONTENTION NO. 28 - CONTROL ROD EJECTION C
Q.
Mr. Petersd'n, have you reviewed your prior affidavit
~
10 on Doherty Contention No. 28, which affidavit is attached 11 hereto as Attachment DLP-l?
12 A.
Yes I have.
Q.
Are the statements contained thereir still true and 13, correct?
74 A.
Yes they are.
Q.
Do you believe your affidavit addresses Mr. Doherty's 16 contention as it is described at page 42 of the Board's Order 17 of September 1, 19817 s0 A.
Yes.
I have reviewed my prior affidavit in light.
13 of the statement of Doherty Contention 28 set forth in the 20 Board's Second Order Ruling Upon Motions for Summary Disposition, and I have determined that the prior affidavit adequately addresses the July 31, 1979 version of the contention.
To reiterate, there is no rod ejection accident with consequences more severe than the rod drop event.
In this regard, I l
24 l
8110270445 810918 PDR ADOCK 05000466 T
PDR
1 specifically addressed the scenario whereby tha'cntiro Control 2
Rod Drive and housing become detached from the vessel (see 8-10), which is the specific event discussed Affidavit, pp.
3 in the contention.
I have also reviewed Mr. Doherty's reply to Applicant's l
s.
[
Motion for Summary Disposition wherein Mr. Doherty alleges 5 i that the drive housing weld would fail because of bulging strains and distortions.
The two exhibits to Mr. Doherty's I
reply indicated the alleged source of bulging is a damaging 9
pressure pulse following a rod drop.
Mr. Holt claw and Dr.
/
' 10 williams have previously addressed this issue and have shown that this is no pressure pulse associated with a rod drop 33 accident (Tr. 11718-12035).
Furthermore, bulging of the reactor itself would not affect the ability of the rod 13 support structure to prevent housing ejection, as the support 14 beams are welded to the reactor pedestal.
Even if we 1
assumed failure of the drive housing weld, the rod cannot be
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16 ejected more than three inches.
17 Finally, I would note that the design of the big h
13 Rock Point reactor is not comparable to Allens Creek.
The reported cracking is in a part which has been eliminated in the gg Allens Creek design, and furthermore, does not increase the likelihood of a rod ejection.
21 l
22 1
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I 24 t
___._______.__n
Attcchmsnt DLP-1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING & POWER COMPANY
)
f Docket No. 50-466 (Allens Creek Nuclear Generating
)
Station, Unit No.1)
)
AFFIDAVIT OF DONALD L. PETERSON State o'f California County of Santa Clara I, Donald L. Peterson, Manager Control Rod Drive Line, within the Nuclear Power Systems Engineering Department of the General Electric Company, of lawful age, being first duly sworn, upon my oath certify that the state-ments contained in the attached pages and accompanying exhibits are true and correct to the best of my knowledge and belief.
Executed at San Jose, California, July 29,1980.
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SubsJp@gM86296M&cMM&fe this 29 day of July
, 1980.
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KAREN s. VOGELHUBER g(3
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NOTARY PUsuc.CAUFORNIA g S but SANTA CLARA COUNTY J
507ARYPUBLICINANDFgRSAID S
sy comminion Enim Dec. 5,1980 o COUNTY AND STATE Dmmmmmmmmmmmmmm6 My commission expires 12-5 o'f 1980 4
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Attcchm3nt DLP-1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S
S HCUSTON LIGHTING & POWER S
COMPANY S
Docket No. 50-466 5
(Allens Creek Nuclear S
Generating Station, Unit S
No. 1)
S Affidavit of Donald L. Peterson
~~
/
My name is Donald L. Peterson.
I am employed at General Electric Company as a Professional Nuclear Engineer, as I have been for 25 years.
A statement of my experience l~
and qualifications is set out in Attachment 1.
This affidavit' responds to Intervenor Doherty's Contention No. 28 which po.stulates that a control rod can be ejected by containment pressure or by the pressure in 4
i the SCRAM Discharge Volume Tank (SDVT).
Ir.tervenor contends that such a rod ejection would create a more rapid reacti-vity insertion than a rod drop, the design basis reactivity insertion accident.
As support for this assertion, Inter-venor relies on the power excursion accident at the Sta-tionary Low Power Reactor (SL-1) in January.1961.
l
I.
Introduction For gross control of reactivity in the Allens Creek reactor, cruciform control blades are inserted be-i-
tween the fuel assemblies.
These control blades, or rods, i
r.nclose smaller rods filled with boren carbide, a n6utron absorbing material.
The reactor is controlled by driving these control blades (177 for ACNGS) into the reactor core to reduce reactivity (and thus power) cnd withdrawing the a
rods to increase reactivity (and power).
The control blades are moved by, hydraulic drives which insert or re-i tract the blades in small increments and continuously drive the blades in on a shutdown signal.
II.
The Rod Drop Event As testified to by Mr. Stirn in an affidavit also filed'in this proceeding, it is possible that a rapid 1/
removal of a high worth control rod could result in a potentially significant power excursion.
The design basis accident dealing with rapid removal of a control rod is the rod drop accident.
The worst case credible control rod drop accident for the ACNGS design is described as follows:
1/
Control rod worth is the measure.of reactivity which will be added to.the nuclear reaction is the rod is re. moved.
4 i
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. _ ~.
~.
a)
A fully inserted control rod drive must sustain a complete rupture, break, or disconnection from its crucife u control blade at or nunr the coupling.
b)
The blade must stick in the fully. inserted posi-tion as the rod drive is withdrawn.
c)
The blade falls by gravity after the rod drive is i
fully withdrawn.
As explained by Mr. Stirn, the above' described I
sequence assumes that the Rod Pattern Control System (RPCS) j is operating.
This is a reasonable assumption because the Rod Pattern Control System (RPCS) is a safety related, hard-wired, dual channel system which must operate to move 2,
..? -
control _ rods and which cannot be bypassed by the operator.
The RPCS limits the amount of reactivity which may be inserted into the core by a dropped rod under the assump-tions listed above.
This is accomp.1.ished by physically preventing rod movement if the reactivity worth of the control rod chosen for movement by the operator is not in a 3/
~
proper preplanned sequence which minimi::es rod worth.
2/
For a fuller description of the RPCS, see the affidavit of Mr. Lesyna, filed in this docket concurrently.
L 3f The sequence is provided in detail on pages 7.7-8.8 of the ACNGS PSAR.
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The enforced sequence assumes that the magnitude of the maximum control rod worth will be limited such that unac-ceptable fuel damage cannot occur in the event of a rod drop.
Hence, with the RPCS operating, the peak fuel enthalpies that can result frcm the postulated drop cf i
these rods has been shown to be well below the energy 4
deposition (i.e.,
fuel peak enthalpy) design limit thereby resulting in inconsequential fuel damage.
III. The Hvpcthesized Rod Ejection Accident According to Intervenor's contention, a control rod might be removed faster than has been assumed under the assumptions used for the rod drop event.
This-could theoretically produce higher fuel enthalpies (and thus worse fuel damage) than predicted.
Intervenor hypothesizes that containment pressure and/or pressure from the SCRAM Discharge Volume Tank (SDVT) would act to drive the rod out faster than would gravity acting on a decoupled rod.
/
A.
The Rod Control System In order to understand Intervenor's conention, a simplified understanding of the Control Rod Drive (CRD)
~
Hydraulic Control Units (HCU) is helpful.
A simple illus-tration is attached as Exhibit A.
The CRD is primarily a
^
piston connected to the control rod and driven up or down by varying the pressure differential across the piston.
4 4
9
-M II.
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During a SCRAlt, water at several hundred pounds per square inch above reactor vessel pressure automatically enters the CRD below the drive piston and pushes the rod into the core.
In order to displace the water above the piston for such a rapid insertion, a special flow volume called the scram discharge volume is available.
The scram discharge volume l
consists of header piping which connects to each control rod hydraulic control unit and drains into an instrument volume.
The header piping is sized to receive and contain all the
~
water discharged by the drives during a scram, independant cf the instrument volume During normal plant operation the scram discha:ge volume is empty, and vented to atmosphere thrcugh an open vent and drain valve.
When a scram occurs a signal from the Reactor' Protection System closes these vent and drain valves i
to conserve reactor water.
Lights in the control room indi-cate the position of these valves.
During a scram, the scram discharge volume partially fills with water displaced from above the drive pistons.
4/
Folleving the scram, the control rod drive seal leakage from the reactor continues to flow into tne scram discharge 4/
There are two leakage paths across the drive seals:
one from the CRD supply pumps and another from re-actor pressure.
.,m s
w..
-_,,.--m,,
.._m
c volume until the discharge volume pressure equals the reactcr vessel pressure.
A check valve in each HCU prevents reverse flow from the scram discharge header volume to tha drive.
When the initial scram signal is cleared from the Reactor Protection System, the scram discharge volume signal is overridden witn a key lock override switch, and the scram discharge volume is drained and returned to atmospheric pressure.
3.
The Hypothetical Accident As explained above, the SDV is at atmospheric pressure at all times except after a SCRAM.
Hence, at these times the pressure from the SDV could not approach the value necessary to move any of the 177 CRD pistons.
After a SCRAM, l-as the SDV is filled by seal leakage frem the reactor, the pressure above the CRD piston is at all times equal to re-i actor pressure.
Consequently, the fact that the SDV has It pressurized to reactor pressure is of no consequence.
would add no additional pressure to drive the rod out of the core.
Furthermore, since check calves are in all 177 lines i
l leading to the SDV, any pressure helf by the SDV could not be transmitted back to the CRD unit.
Obvicusly, then, the I
pressure er lack of it in the SDV has no effect on the Con-trol Rod Drives.
-Intervenor has also suggested that containment pressure would add to or produce a rod ejection event.
Since the Control Rod Drive units as well as their associated Hydraulic Control Units are sealed, there is no way in which the drive water would see containment pressure unless the system were ruptured.
Since pressures in the CRD units are close to reactor operating pressure (several hundred psi) and contair. ment design pressure is at a maximum 15 psi, the effect of a rupture on the control rod drive would be to relieve pressure above or below the drive piston.
The re-
/
lease of pressure below the piston in discussed in detail below; the consequences are well accounted for.
The release of pressure above the piston would drive the control red into the core.
Hence, containment pressure could nct contribute to a rod ejection.
Although not covered by Intervenor's contention, one can postulate an event in which the pressure below the CRD drive piston is relieved by some incredible failure while i
reactor pressure acts above the pistons.
However, even if the pressure below the drive piston were relieved with the drive latched (as it would normally be), no control rod withdrawal would occur.
The CRD col'let latch mechanism would hold the the CRD in place because the collet is held in the latching position with a heavy re urn spring and requires at.
a
least 100 psi above reactor pressure in the area over the piston to unlatch.
If the pressure were relieved below the drive piston while the CRD was being moved (unlatched posi-tion), the hydraulic pressure which unlatches the CRD would drop and spring force would cause the collet to latch and stop rod withdrawal.
Furthermore, even if the collet were assumed to jam in the open position, the steady-state control rcd withdrawal velocity would be 2 ft/sec compared with 5 ft/sec for a rod drop event.
This number was calculated by i
an analysis of the forces and hydraulic losses in the drive 4
during this postulated event.
Since lower withdrawal velocities result in lesser reactivity insertions (and thus lower peak
[~
enthalpies and potential fuel damage), this postulated event does not produce a rod ejection accident that compares with the rod drop event.
One other event which might be postulated is the failure of the drive housing such that the entire Control Rod Drive and housing becomes detached from the vessel.
This scenario would result in the following sequence of events:
The housing would separate from the vessel.
The control rod drive and housing would be blown downward against
~
the support structure by reactor pressure acting on the l
l cross-sectional area of the housing and the drive.
The downward motion of the drive and associated parts would be H
,a.
li
_ ~._.._ _ _,_ _ __
. - - _ = -
~
determined by the gap between the bottom of the drive and the suppcrt structure and by the deflection of the support structure under impact.
The support structure is composed of a series of deep I beams located under the reactor vessel and attached to the reactor pedestal (not the reactor vessel).
Suspended from these beams are tie rods attached to support blocks placed under the individual drives.
Shock-absorbing springs at the tie rod / beam connection limit the maximum housing movement to aporoximately three inches under the loads anticipated from reactor pressure and driveline weight.
In the current design, maximum deflection of the support structure after impact by the CRD housing is approximately 3 inches.
If the collet were to remain latched, no further f-control rod ejection would occur and the housing would not I
~~
drop far enough to clear the vessel penetration.
[
If the basic housing failure were to occur while m
the control red is being withdrawn (this is a small fraction of the "otal drive operation time) and if the collet were to stay unlatched, the following sequence of events is pos-(
sible:
The housing would separate frem the vessel.
The 1
the con-drive and housing would be blown downward against trol rod drive housing support.
Since in this instance the r
i control rod is unlatched, the control rod will continue to withdraw a'fter the control rod drive housing has been 5
-9_
g
l 1
stopped by the drive housing support.
The equivalent steady-state rod withdrawal velocity for this occurrence would be 0.3 ft/sec-5/ as compared with 5 ft/sec for the rod drop event.
Clearly, this event also does not produce a rod ejection accident with consequences more adverse than the rod drop event.
The withdrawal speed for the instance where pressure below the CRD piston has been removed and the collet fails (2 ft/sec) is higher than the velocity for the case where the CRD housing has detached and the collet fails (.3 ft/sec) because in
~
nhe former case reactor pressure above the CRD drives the rod out with no pressure below the drive piston.
In the latter case pressure below the piston is not removed during the event.
There are no other credible rod ejection scenarios with more adverse consequences because the failure of all known mechanisms which could produce uncontrolled withdrawl of control rods have been reviewed and analyzed.
III.
The SL-1 Event Intervenor has used the SL-1 accident to support
/
~
the contention that a rod ejection event would produce a 5/
This withdrawal velocity was calculated by the same means used to determine the withdrawal speed for the instance where pressure is relieved below the drive pisten. _
9 O
-- A
l power excursion larger than a rod drop event.
The SL-1 was a military pressurized water reactor which used control rods inserted into the top of the reactor.
At the time of the accident, the reactor was shutdown (all controls roda in) and the control rod drives were undergoing maintenance.
Results of investigation showed that a control rod, detached from its drive, had been renoved to a point, where the reactor began a power excursion.
As a result of the power excursion, control rods were blown out of the core and the i
reactor was demolished.
"~
The SL-1 reactor and accident are in no way rele-vant to ACNGS.
First, when the ACNGS reactor is shut down l..
i (all control rods in), the complete removal of one control l-rod would not bring the reactor critical.
Secondly, rod i
ejection for ACNGS is physically prevented or the effects are bounded by the rod drop event.
The SL-1 reactor was not 1
so designed.
Hence, Intervenor's reference to the SL-1 event to support this contention is totally inappropriate.
IV.
Conclusion After thoroughly analyzing the range of events which could rapidly remove a control rod from the reactor, it is apparent that the consecuences of a design basis rod drop event are bounding.
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ATTACHMENT 1 PROFESSIONAL QUALIFICATIONS DONALD L. PETERSON CONTROL ROD DRIVE'LINE DESIGN GENERAL ELECTRIC COMPANY My name is Donald L. Peterson.
My business ad-dress is 175 Curtner Avenue, San Jose, California 95125.
I am Manager, Control Rod Drive Line Design Unit for the Boiling Water Reactor System Department of the General Electric Company.
In this position I am responsible for the design of components such as the control rod drive, control rod, hydraulic control unit and other components associated with the control rod drive system.
I have a Bachelors Degree in Mechanical Engineering i~
from the University of Washington, Seattle.
After two years of service a's a Gunnery Officer in the U.S. Navy and a snort term as an Instructor in Mechanical Engineering Department of the University of Washington, I'
joined General Electric Company.
Prior to transferring to General Electric Company's boiling water reactor operations, I worked at the Hanford operation for 7 1/2 yez My re-L sponsibilities included design of remote handling facilities, test facilities and control rod drive mechanisms.
For the past 25 years I have been responsible for the design of components for boiling water reactors, being u
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the responsible design engineer for control rod drives on early General Electric reactors.
I have continuously served as Technical Leader or Manager of the group responsible for control rod drives and associated components since that time.
I am a Professional Engineer in the State of California.
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