ML20042B235
| ML20042B235 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 03/17/1982 |
| From: | Doherty J DOHERTY, J.F. |
| To: | HOUSTON LIGHTING & POWER CO. |
| References | |
| ISSUANCES-CP, NUDOCS 8203250123 | |
| Download: ML20042B235 (10) | |
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UNITED 3TATES OF AMERICA HUCLEAR REGULATORY COMMISSION "',;T, March 17, 1982 BEFORE THE ATOMIC SAFETY & LICENSING BOARD d
'82 122 22 P153 In the Matter of:
Docket No. 50-4D6 CP HOUSTON LIGHTING & POWER CO.
(Allens Creek Nuclear Generating Station, Unit 1 INTERVENOR DOHERTI'S SEVENTH SET OF INTERROGATORIES.TO APPLICANT WITH REGARD TO TEIPIRG ADDITIONAL CONTENTION 31 AND QUADREX REPORT MATTERS John F. Doherty, Intervenor in the above construction license-proceeding, and acting under the Board Order of January 28, 1982, now files the below Interrogatories pur-suant to 10 CFR 2.740b and 10 CFR 2.741.
Please answer each question fully.
Please identify-all documents, memos,<
studies, reports, letters, or other similar papers relied upon by Applicant which support the answer, and make avail-able such documents to this Intervenor.
Identify expert witnesses who answer the questions and give their relation-t ship to Applicant.
Identify any expertwitnesses who Appli-cant inten'ds to have testify on the subject matter questioned and state the expert's qualifications.
Thank you.
1.
Referring to Attachment-A, did B&R or Applicant perform the large break ECCS analysis for the South Texas Project (SD P)?
(a) If B&R, when was Applicant first aware of the error?
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(b) Please make available, any reports or letters, etc., that show this, and identify them in your reply.
2.
With regard to the Quadrex Report on Allens Creek work by EBASCO Servic'es, Approximately what % (percent) of the EBASCO engineering l
P sponse was sampled in each of the four areas (Civil /
BGCEWS ructural; Mechanical; Nuclear; Pipe Support? (See:
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(interog. 2, Continued)
(b) What is menat by " insight regarding the current status of the technical werk performed by each disciplinet,( Sec. 1.0, Report)
(c) Did Quadrex use any kind of Guide for making com-parisons with " normal industry practice", or was this concept merely experience-based and without written criteria?
(d) Why was ISI (in-service inspection) not included-in this design review, in view of the difficulties with this for ACNGS design work? (See this Inter-venor's Sixth Set of Interogatories, Question #9, and Attachment B)
(e) Why did Applicant cause the Quadrex Report on EBASCO to be done?
(f) Were there any signs to Applicant that EBASCO Services was not working properly on the project at the time the report was started?
If "yes",
ylease indicate what these were, and indicate the date and identify the first Applicant report on each sign that EBASCO Services was not working properly, and make them available, (g) What investigations of battery room hydrogen con-centration, and heating and ventilation were done by Quadrex? (See: p. 3-8, Report)
(h) Has EBASCO Services reviewed any vendor submitted reports in any area or discipline other than civil / structural?
If so, which disciplines have done this for ACNGS?
(i) Was any conscious effort made to choose items for the Quadrez Report on EBASCO which were similar to items in which the Quadrex Report on Brown & Root (B&R) revealed deficiencies or other difficulties?
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(Interog 2, Continued)
(j) Prior to the Quadfex-EBASCO Services Report, had Applicant questioned EBASCO if its civil /struc-tural department maintained a guide to computer-programs?
If "yes", when?
Identify any report showing this in your reply, please, and make it available.
'(k) What did EBASCO engineers state that gives Quadrex confidence computer programs have been used properly?
(Report, Question C-104)
How many programs are included in this statement?
(1) How many hours total were spent in reviewing:
(1) Civil /Structur'al (2) Mechanical (3) Nuclear (4) Pipe Support; for the Quadrex-EBASCO Report by Quadrex?
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(m) Referring to Question C-111 of the Report, what is non-participatin6 mass? Is the effect on safety l
negative.when this is too great a magnitude when l
used in the PIPESTRESS 2010 Pro 5 ram?
(n) Is the Corporate MNE Pipe Rupture Analysis Manual noted in Question M-102, being done by EBASC07 If "yes" why is this necessary, since they have built other plants?
(o) Referring co Question M-103 of the Report, did EBASCO state it would evaluate all potential-targets?
If not, what does the last sentenc,e of "Quadrex Assessment" for M-103mean?
(That is, isn't Quadrex in error?)
(p) In Question N-101 of the Report, what does "Approp-riate" mean in the "Quadrex Assessment"?
(q) Referring to Question N-101.of the Report, what is Applicant's understanding of the meaning Quadrex applied to the "EBASCO Response" with regard to flow models and acceptance on Waterford (PWR) and St. Lucie (PWR) plants?
l (1) Flow of what is' involved?
l (2) What was the concern addressed about NRC requiring 0.6 times model flow?
(3) What is the flow from and to?
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(Interos 2, Continued) nt@j (4) Is the NRC requiring a 0.6 times model flow, placing a greater requirement than the Homo-g geneous Equilibriun Critical Flow Model with h
a multiplier 1.0?
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- 3. Did Mr. Sas of EBASCO Services, (Identified as an Eppert Witness who will testify) attend any of the formal review meetings in Sectomber, 1981 with Quadrex Corp.?
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- 4. Why did Acolicant's witnesses Mr. Oprea and Mr. Goldberg f
5 not mention the Quadrex Report on EBASCO in their testimony d
on. TexPIRG Additional Contention 31, Technical Qualifica-g tions, in the October 1981 hearings, or at least alude f
to the Quadrex work if it was in progress?
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- 5. Did Mr. Oprea direct that Mr. Goldberg would not mention the Quadrex Report on EBASCO Services in the October hearings g
on ACNGS on TexPIRG Additional Contention 31?
- 6. Did Mr. Oprea direct that Mr. Goldberg would not mention the Quadrex Report on Brown & Root desi n work at STNP 6
in the October 1981 hearings on ACNGS on TexPIRG Additional Contention 31?
- 7. Had Quadrex Corp performed a review of BWR design engineering prior to its report on EBASCO Services at ACNGS?
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- 8. Had Quadrex Crop. performed a review of nuclear power plant design work, at as early a stage as that of ACNGS',at any prev-B ious time?
- 9. In Section 4.1.2 of the Quadrex Report on STNP (hereinafter:
Reoort) what are the " number of studies mentioned in the first sentence?
Who is doing them other than Applicant?
- 10. Referring to Sec. 4.1.2 of the Reoort and sp9cifically on the statement, " Based solely on the current iindings of this review, a determination of current adequacy cannot be made.":
(a) Did Quadrex indicate to Applicant the statement meant B&R Civil / Structural Work was technically inadequate?
(b) If "no", what did the statement mean?
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11 Refering to Sec. 4.1.2 of the Reoort, what generally did Quadrex indicate'was " evident", as a result in the design process caused by lack of experience and consistency in implementing appropriate Code inter-cretations and industry practice?
12.
Refering to' Question C-1, "Quadrex Assessment" item (e),
did Apolicant prior to Quadrex have any doubts that the B&R structural (group) checked the reasonableness of that input data or that the group acknowledged its
. receipt?
(a) If "yes", please give the date of any memo, report, etc. where doubt is shown, identify it, and make it available to this Intervenor.
(b)Does Applicant believe B&R did check for reasonable-ness of input data?
For what reasons?
13.
Refering to Question C-1, "Quadrex Assessment" item (f),
was Applicant aware BLR did not require that receipt of the "really important" data transmitted to a discipline be acknowledged back to the originating discipline?
(a) If "yes", please give the date of any memo, report, etc. where this is shown, identify it, and make it available to this Intervenor.
(b) Did Quadrex (perhaps through Reviewer Hossain) explain what "really important" meant?
If so, please give the explaination.
14.
Refering to Question C-1, "Quadrex Assesment item *(g),
it states B&R procedures called for a final design verification at a time when final data became available
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and probably (emphasis added) when the structures had been erected.
(a) Was Applicant aware of these procedures prior to to the Quadrex report?
(b).If "yes", please give the date of any memo, report, etc. where this' awareness is shown, identify it, and make it available to this Intervenor.
(c) Did Applicant attempt to change B&R's procedure?
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. 15 Refering to Question C-4 of the Reoort, "Quadrex As essment",
what is the secondary shield wall in a PWR?
(a) Is it in containment building?
(b) What is the NRC margin mentioned in this part afC-4?
(c) Which factor,1.2 or 1.4 wasi actually employed?
(d) Was this secondary shield wall actually constructed in STNP-I, or STNP-II?
16.
Refering to Question H 12 of the Reoort, has the pres-surizer support skirt been constructed?
(a)WhenconstructedwasHL&Pawaretheconsequegesof n
loss of off-site power were yet to be assessVwith regard to cressurizer cooling requirements?
(b) If "yes" to (a) please,ive the date of any memo, report, etc. which shows this, identify it, and make it available.
17 Refering to Question C-4 ei the Recort, in the "B&R Response" at the #, is Quadrex saying here B&R was designing prematurely such that it had to make changes due to new input information?
(a) Is Applicant aware of any instances where a structure had been constructed, then had to be redesigned because of new environmental loadings?
16.
Refering to Question H-3 of the Report, was Applicant aware that heat load calcuations for the HVAC did not consider i
off-normal system conditions, prior toQuadrex?
(a) If "yes", give the date of any pacers, reports, memos,etc.
that reveal this, identify them, and make them available please.
19 Referring to Question H-3 of the Reoort, was Applicant aware l
no criteria existed at the STNP for the HVAC design of air flows in radioactive areas?
(a) Had Apolicant suggested to B&R that they get this?
(b) Refering to (a) above, when was this first suggested, and what is the identity of any memo, letter etc. doing I
this?
20.
Which came first? The release to the HRC of a copy cf the Quadrex Report, or the termination of B&R as architect engineer at the STNP site?
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_7-21.
Referring to H-3, did Applicant understand the "Qa.-
rex Assessment" statement: "... [a] n evaluation of the effect of some of these openin6s being in the expected plant operating open position was not performed",
meant that in normal operation.some of the openings would be open?
(a) Is it correct to say that B&R had not established the normal operating air flow conditions at STNP?
(b) If so, please identify and give the date of any memo, report, etc. of Applicant,which shows Applicant noticed this prior to Quadrex.
22.
Referring to B-3, was Applicant aware if B&R had the proper information it needed on NRC rules with regard to hydro-gen in the containment building to perform # calculations for hydrogen mixing and the potential for pocket accum-ulations in the containment after a LOCA"?
(a) Did B&R ever request any such information of Aoplicant?
(b) Does Applicant know if these calculations are deficient at this time?
23 Does Applicant' believe any heat loads from pipes would be great enough to affect the HVAC design basis? (Question H-3)
If so, give a single example of a normal operating load and an accident condition load, please.
24 Refering to Sec. 4.4.2, was Applicant aware B&R had no procedurs for an engineering discipline to be sure its i
requirements (outputs) were properly used by HVAC,other than "the usual document cycle"?
(a) If "yes" did HL&P think that sctisfactory?
(b) If not did Applicant ever try to get B&R to do something to change this?
25 Refering to H-5 of the Reoort, "Quadrex Assessment", when did Applicant first become aware B&R was determining the safety classification of the HVAC systems using their en-gineering experience, knowledge, ANSI N18.2, and Reg. Guide l
1.26, instead of, " documented requirements of interfacing systems"?
(a)'Pl' ease give the identity of any letter, memo, etc. that shows Applicant was aware of this, and make it available.
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26.
Refering to Question M-3 (B&R) of the Reoort, hcd 3%R in its pipe rupture studies up to its termination, analyzed whether identified targets of pipe whip cr water suray were necessary fcr safe shutdown for that break?
(a) Had Applicant asked them to do make such an iden-tification in any study?
(b) Please provide the date of any such request, and identify the letter, memo, etc. where the request is made, as well as make it cvailable.
27.
Refering to Question M-10 (B&R) was Applicant aware the problem of pipe support failures caused by impact from a whipping pipe had not been considered?
(a) Please give the date and identity of any memo, report, etc. which shows applicant was aware of this prior to the "Quadrex Assessment" finding?
28.
Refering again to M-10 (B&R),was Applicant aware thet a group identified as "B&R Stress" had not prepared a TRD for identifying essential components for consideration in the unrestrained oipe whip analysis?
(a) Please give the date and identity of any memo, report, etc. which shows Applicant aware of this prior to the "Quadrer Assessmeat" finding?
29, Refering to Question M-50, i'Quadrex Assessment" item 2, and Sec. 4.5 5.1(a)(1) of the Report, has the finding that, "All active pumps were demonstrated operable by analysis.",
raised concern because the active pumps were not demon-strated operable by testing?
(a) Was Applicant aware of this deficiency prior to Quadrex mentioning it?
(b) If Applicant was, please give the date, identity and make available any memo, report or other paper that shows this awareness.
30.
Refering to Question M-51 of the Recort, when had loplicant first noticed B&R was uncertain as to the definition of passive numps and valves, versus active pumps and valves?
(a) Give the date, identify and make available any report, memo, etc. showing when Applicant first' nook notice of this, please.
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-g-31.
Refering to Question P-20 of the Reoort, prior to Quadrex, was lpplicant aware B&R had not developed criteria for jet impingement protection on unbroken piping systems?
(a) Does Applican a54,ee with Quadrex that this finding could be exce ted4 seriously impact plant licensability?
(b) If Applicant was aware, when did it expect 3&R to develope the criteria?
(c) When did Applicant first become aware of this?
(d) Identify and nake available any memo etc. that shows (c), please.
32.
.If the Quadrex Report on B&R had never got ont of Appli-cant's possession, and hence remained secret, does Applicant believe it would have terminated BaR as architect-engineer when it did?
33.
Did Quadrex Corp's representatives indicate to Applicant that current construction work done at the STNP plants suffered from inadequate separation of HVAC? (Refering to Question H-6, Reo:rt) 34.
When did Applicant first becone aware there were no written criteria for physical separation of HVAC components at STNP, to protect against postulated fires and high energy line breaks? (Refering to Question H-6, Renort)
(a) Please give the date and identity of any memo, report, etc. that shows this, and make it available.
35 Refering to Question H-6 of the Recort, who was the con-tractor for the fire hazards analhsis for STNP?
(a) Was Applicant aware there was no control document gov-erning plant design on the topic of fire hazards?
(b) If "yes", please idicate the date, identity, and make available any document, memo, etc. showing this.
- 36. Refering to Questica H-23, "Quadrex Assessment", was Apoli-cant aware that the B&R design used the floor drainage system for leak detection, and would have to meet the requirements of Standard Review Plan 9.3.3 of the NRC?
(a) Did Applicant approve of this detection olan?
(b) If "yes" to (a), when was the approval?
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i g: c TH (Question 36, Continued) in (c) To what grade would the system have to be upgraded,
?.i if the final design uses floor drainage.as the only y) means for leakage detection?
37 Refering to Question H-11 of the Renort, Did Quadrex indi-
.g cate to Applicant at post-meetin5s, that any of the dif-g/
ferences in " Exhibit-II" of Question H-11, represented a serious differeace between the FSAR statement and the
}-f Reactor Containment Fan Cooler (RCFC) saecifications?
(a) If "yes", which one or ones are significantly different?
hp 38.
Refering to Question H-17 of the Reoort, was Applicant f
aware crior to Quadrex there was no criteris for selection
[i_r of the person to verify the HVAC design?
(a) Did HL&P Q/A take note of the selection of design h
5 verifiers by no criteria?
(b) If the answer to (a) is "yes" what did Applicant do?
Ej (c) Did HL&P Q/A approve the choice of a design verifier f
outside of HVAC for HVAC design?
espect 11 CERTIFICATE OF SERVICE John 'F.
Doherty I certify that copies of INTERVENOR DOHERTY'S SEVENTH SET OF f
INTEROGATORIES TO APPLICANT WITH REGARD TO TEZPIRG ADDITIONAL l
CONTfNTION 31 AND QUADREX REPORT MATTERS were served this
/7
- of March,1982, via First Class U. S. Postal Service from Houston, Texas,on the parties below:
Sheldon J. Wolfe, Esq.
Administrative Judge Gustave A. Linenberger, Jr.
Administrative Judge Dr. E. Leonard Cheatum Administrative Judge Richard A. Black, Esq.
Staff Counsel J. Gregory Copeland, Esq.
Applicant Counsel Jack R. Newman, Esq.
Applicant Counsel
}
Parties The Several Intervening & Appeal Board Atomic Safety Licensing U. S. Nuclear Regulatory Commission,
- Docketing al.d Service Branch
}
John F. Doherty l
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ATTACH MENT
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A The Light
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Company anus.on tighting & roser e.o. sox i7oo souston. Texas 77ooi <7is)ees 92ii r
January 8, 1982 ST-HL-AE-776
. M'Og SFN: V-0530
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[D.N' Mr. Darrel G. Eisenhut 4 W ;2'
- Division of Licensing e
Nuclear Regulatory Connission j
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Washington, D.C.
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Dear Mr. Eisenhut:
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South Texas Project
'Q; f g Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Larce Break ECCS Analysis On December 22, 1981, HL&P received notification from Westinghouse Elec-
,3 tric Corporation that an error had been discovered in the large break ECCS analysis for the South Texis Troject (STP).
According to Westinghouse, a s
meeting was held with the NRC staff on December 17, 1981 to discuss this issue.
Westinghouse has determined that tne single failure of emergency safe-guard equipment assumed in the large break ECCS analysis does not represent the most limiting assumption possible.
In fact, it has been detennined that it is more conservative to assume no failure in the emergency safeguards equipment for the ECCS analysis.
In the case of STP, Westinghouse has determined that this error results g
in a 19 F penalty in Peak Clad Temperature (PCT).
The STP FSAR ECCS analysis results indicate 144 F margin to the 10CFR50.46 ECCS acceptance criteria.
Since sufficient margin to the 10CFR50.46 limits is available, and no peaking factor (F ). reduction is required due to the correction of the single failure assumptic, i the error was determined not to be a safety issue.
It is HL&P's
- nnie'rstanding that NRC concurred with Westinghouse on this determination.
In the December 17, 1981 meeting with the NRC staff, Westinghouse agreed to request affected utilities to describe to the NRC how this problem affected their unit (s).
This letter is intended to satisfy the above request.
If there are any questions, please contact Mr. Michael E. Powell at (713) 676-8592.
Very t,rul yours, K//,d*]/
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J.,/ Gol g
Vice President Nuclear Engineering and Construction McS/blt ND 1 1.: Q4 W NO