ML20052F289
| ML20052F289 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/06/1982 |
| From: | Jeffrey Riley CAROLINA ENVIRONMENTAL STUDY GROUP |
| To: | DUKE POWER CO. |
| References | |
| NUDOCS 8205120317 | |
| Download: ML20052F289 (14) | |
Text
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- BELiTED CORRESPONDENO!!
UNITED STATES OF AMERICR NUCLEAR REGULATORY COMMISSION t ycqv-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) '22 I"# 13 21
)
DUKE POWER COMPANY, et al.
) Docket Nos. 50-413
) 50-414 (Catawba Nuclear Station, )
Units 1 and 2) )
CESG'S RESPONSE TO APPLICANT'S FIRST SET OF INTERROGATORIES CESG herewith responds to Applicant's first set of interrog-atories and requests to produce, dated April 9, 1982, and c ned p
r with CESG contentions 13 and 17
$E Specific Interrogatories _ g, {T ,
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- A4 -9 CESG - Contention 13 U
- l. What do you mean by the term " irregularities"? N 6 m
Depositing metal in a weld before the specified preheat temperature had been reached, or the specified interpass temperature.
- 2. Identify each and every " irregularity" which is the subject of this question.
This is the only irregularity.
- 3. For each " irregularity" identiEIed in your response to l .
Interrogatory 2, please specify the location, t,ime of occurrence and person or persons who were involved. '
L :
I do not have specific dates, times, nor identities of persons.
- 4. When do you contend such "irregulari'.ies" occurred?
During the period in which safety related welds were being made on unit 1.
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- 5. What do you contend was the cause of such " irregularities"?
The supervisor 8s insistence that the welder not wait until the specified preheat temperature was reached.
6.
What are your bases for your responses to Interrogator-ies 1-57 Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.
A conversation with a colleague who is an engineer.
The conversation took place, approximately, in November, 1981.
- 7. What " welding practices" are the subject of this Contention.
and what person or persons do you contend engaged in such " welding practices"?
See answers to 1 and 5 foregoing. The welder and his supervisor were involved in the practices.
- 8. Specify when such " welding practices" occurred.
Over an appreciable period of time during the constrution of unit 1.
- 9. Where are the proper " welding practices" established?
The proper practices are established in the NRC mandated ASME Boiler and Pressure Vessel Code,Section IX, titled Welding Qualifications; and ANSI B31 7, " Nuclear Power Piping".
- 10. Are the welding practices which are the subject of this Contention set forth in particular procedures?
Those having to do with preheat temperature and minimum interpass temperature.
- 11. If your response to Interrogatory 10 is in the affirma-tive, please specify the particular procedures which govern the " welding practices" which are the subject of this Contention.
I am not as yet in possession of sufficient facts to reply.
- 12. For each of the procedures identified in your response to Interrogatory 11, set forth the specific problems which you contend occurred.
I contend that the welding practices referred to fail to meet the relevant standards, that being the judgment of the welder involved.
- 13. Do you contend that the " welding practices" which are the subject of this Contention fail te comply with certain standards?
Yes 14.
If your response to Interrogatory 13 is in the,affirma-tive, please identify the particular standards which are the subject of this Contention.
The standard is a temperature. I do not presently know the specified temperature.
- 15. For each of the standards identified in your response to Interrogatory 14, please specify the particular concern which you have concerning " welding practices".
If the standards are not met the weld will presumably be deficient in some functional characteristic or character-istics. This would include, but not be limited to, tensile minumum properties as listed in the ASME B&PV Code,Section IX, Table Q-ll.l.
- 16. What are your bases for your responses to Interrogator-ies 7 through 15? Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position. .
The bases for response are ident:.fied in responses 7 through 15 foregoing.
_4 17.
Identify each specific " safety related system" which is the subject of this Contention.
I am not able at related systems. present to identify the specific safety 18.
Specify the particular " welding practices" which you contend were performed on each of the " safety related systems" identified in your response to Interrogatory 17
- . _ The answer is apparent from foregoing responses 19.
)
Specify for each of the " welding practices" associ .
ated with i the " safety related systems" identified in your response to i
[:
Interrogatory 18 the particular concerns which you hav e regarding the adequacy of such practices. f
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See response to-15. =
- 20. i For each of the concerns identified in your response to h Interrogatory 19, E specify the time at which such concerns E
_ (i.e., problem) occurred. ?;
A See response to 8. -
21.
For each concern identified in your response E E
. gatory 19, to Interro- E identify the person or persons who were E E
involved and the situation giving rise to your concern. 7
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See response to 7. =i
- 22. -
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For each concern identified in your response tg In t erro- ?
gatory 19, ((
specify the cause which you attribute to m:
such concerns. ((
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55 The "cause to [ sic) which" I attribute my concerns is 51 the failure to carry out the relevant specified proced ure. 55 55 5E E
EE 5
-5 23.
What are your bases for your resp nses to Interrogatories 15 through 22?
Identify all documents, testimony or oral statements by any person and !
legal requirements on which you rely in support of your position.
~
_ _ _ . See response to 16.
- 24. Do you contend that the Applicants have not identified all
" irregularities" in~ " welding practices" pursuant t o their
- own inspection procedures? .
Yes. .
25.
If your response to Interrogatory 24 is in the affirmative, please specify the
" irregularities" which you contend Applicants have not identified.
and interpass temperature requirements. e eat Superviso
- 26. :
For each of the
" irregularities" identified in your res-pense to Interrogatory 25, d answer each of the Interro-gatories 1-5 above if you have not already done g m
so. E E
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No further reponse is required. 5..
- 27. -
9 IE; If your response to Interrogatory 24 is in th FE e negative, please specify precisely what your concern is withrespect {=
to " welding practices". (
Repetitive. !!E See response to 15. fZi.
- 28. Do you contend that the NRC Staff has not identified the ff p
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particular " welding practices" with which this Cont ention lilii is concerned? ((
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pattern of practices.To the best of my knowledge sthe NRC islitu lie
@l Emu Eff
- 29. If your response to Interrogatory 28 is in the af firna-tive, please identify those instances of " welding practices" which you contend the NRC Staff does not identify.
Those instances in which a supervisor instructed a weld'er to begin the weld before the specified preheat or minimum interpass temperature was reached.
- 30. For each of those instances " welding practices" id enti-fied in your response to Interrogatory 29, please answer Interrogatories 7 through 15 if you have not already done so for those particular practices.
- No further response required.
31.
If your response to Interrogatory 28 is in the negative, please explain exactly what your concern is with respect to " welding practices".
See response to 15
- 32. Do you contend that Applicants have not corrected all
" irregularities" in welding practices"? If so, please explain, identifying the areas of the plant here such welds remain uncorrected.
Applicant's have not corrected these irregularities.
Applicant's supervisory employee was the immed'. ate cause.
The defect is not likely to be revealed by nondestructive tests, but rather by tensile tests which cannot be performed without destruction of the work product.
33.
What are your bases for your responses to Interrogater-les 24 through 327 Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.
See response to 6. The last sentense in the response to 32 is based on the writer's experience with testing.
34.
.- What do you mean by the term " endanger"?
A weld which fails at a stress less than design basis or which corrodes increases the probability of a LOCA.
The TMI experience involved a sequence of unanticipated events which led to serious consequences including appreciable releases of I-131 and Kryptons. Such ~
radioactive releases as a consequence of equipment failure endanger the health and safety of the public.
35.
Specify the consequences which you allege will follow ,
from each " irregularity" in " welding practices" which are the subject of this Contention. '
See response to 34 It is not possible to be rigidly specific absent a knowledge of the particular welds <*
involved and absent a prescience which would indicate the combination of conditions and concatenation of events in which failure play a determinative of the particular welds would role. What can be said with certaintyand relevant is that if the temperature specifications are significant, reflecting cumulative engineering judgment and experience, and have been made an' NRC requirement, departure from them increases the likelihood of an accidental failure. The potential serinusness of the consequences does not require argument in this foru=. _
36.
For each of the consequences identified in your response to Interrogatory 35, specify the particular
" safety related system" involved in such a scenario.
See response to 35.
- 37. .
Do you contend that the procedures applicable"to Y welding at the Catawba facility are not in compliance E with applicable NRC regulations?
Yes il
'f 38.
If your response to any of the Interrogatory 37 is in de the affirmative, please specify for your particular concern and specify the particular NRC requirecents E
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which you contend have not been satisfied.
E See responses to 9, 15, 34 and 35.- d.
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.n hat are your - ,,
ba'ses'for your . responses to Interrogator-
[ ' iss 34 t.hrough ,38Y *s Identify all documents, testimony
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- ' . s or orrt statements by an person and' legal requirements
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on which you rely in support of your position.
. ; .. See response to 39 The list of. documents, testimonies, and oral statements on which those judgments are based is extensive and acquired over a decade. It is beyond my capacity to recall all'such. As to legal requirements,
, see response to 9.
,N -
CESG - Contentionil7 ,
'l . What ic the bacis forkth'ic, contention?
\ '
Dorbicula Ire known to beepresent in the waters of Lake s
s Wylie, to proliferate in moving streams, and to clog water pausa89 ways.' There is, to my knowledge, no s s-
' discussion of the effects. of Corbicula on the performance of t,he Catawba water cooling eystem, secondary consequences (s\ of an. infestation, nor means.of preventing such infestation.
identify aYJ 2 ., Please documents, testimony or oral statements by jny.'person and legal requirements on
' , ys which yob rely in support 02,your response to Inter-J; rogattry~1., '"
. , , [
Tne EIS' irr the discussion ~ of aquatic ecology, refers to Corbicula;'ci ting
- Applicant's list of benthic species i
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(Eh, Tables 4,1-12 and 4 1-13). The effects of condenser
, , tube clogging at o maduracturing plant downstream from s
Catawba are known ,tto me through discussions with persons T having first hand involvement. Shutdowns to deal with Corbicula infestations will adversely affect the cost /
benefit belance of;the' plant, vis-a-vis NEPA considerations.
An increased pate in thermal cycling of the plant, and s possible uforendsshutdowns have safety significance.
- 3. What are the " effects" bf Corbicula which you contend
-" ~ swill occur? , ,' _
'The primary effect 41s discussed in the EIS: " . . .the Asiatic clam (Corbicula manilensis) is the largest componentwof the biomass both in the lake [Wylie] as a whole and'.at-the site. Corbicula is a filter feeder, removing plankton and detritus from the water mass.
It is a major fouligg organism .throughout the world, settling in and clogging water 31ntake pipes, especially '
during its larval stage." ,
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4.
What do you contend are the consequences of the " effects"?
Unless growth of the organism is inhibited I would expect these primary consequences among others: clogging of cooled with water action of pipes, pumps,clo5eing of condenser tubes, intebference nozzles, clogging of tower drains. clogging of cooling tower spray In turn slowed flow rates and reduced heat transfer in reduce the cooling capacity of the condenser.the condenser will reduce the design capacity of accepting 40% ofThis will full core heat on turbi..e bypass and can lead to overpressurization j of both the secondary and primary systems with an increased potential for system failure and coolant loss. This i increases the likelihood of TMI type and related failures,
- 5. How do you contend such "ef fects" will a ffect "perfor- i mance of the cooling tower system"?
heat exchange rate in the condenser,As with pump performance.
in, decrease and may interfere 4, foregoi$
6.
f g
What do you contend are the components of the " cooling tower system" which will be affected by Corbicula?
See responses to 4 and 5.
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For each of the components identified in your respon se E to Interrogatory 6, .
specify the particular "effect" 5 which you contend Corbicula will have. .
See response to 4 )
- 8. What are your bases h n
i for your responses to Interrogator-les 3 through 7? k Identify all documents, testimony or k oral statements by any person and legal requirements on
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- h which you rely in support of your position. a clogging effects.The EIS, response 3, provides the basis for the foulin b l
y FSAR water 10 4 5, provides a description of the tower cool system. E
- r The FSAnto10.h.1.1 condensers are designed condenseindicates up to 40that thethe
% of main pn full load main steam flow bypassed directly to the con-denser by the turbine bypass system.
W of the turbine bypass system is described in 10 4 4.1.The dumping cap [1 p.
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. . l A safety evaluation is given in 10 4 4 3 However the draft SER notes that Applicant has not provided the l capability to operate the power-operated atmospheric relief valves remotely from the control room on a loss of offsite power condition (3rd unnumbered page under
.10 3). Staff concludes in the draft SER "that the requirements of General Design Criterion 34 and the guidelines of Branch Technical Position RSB 5-1 are [not]
met until satisfactory resolution of our concern for loss of control room operability of the power operated atmospheric relief valves ~during a loss of offsite power and SSE. . . " (id. 4th unnumbered page) .
- 9. Do you contend there are any " effects" which have an adverse impact on the environment?
The failure to be able to vent sufficient steam, 8 foregoing, will lead to temperature and pressure rises in both the primary and the secondary systems. Such an event will increase the likelihood of a LOCA or, because the pressure differential is increased, a steam generator tube rupture.
- 10. If your response to Interrogatory 9 is in the affirma-tive, please specify all such " effects."
It is not possible to specify the precise effect of a LOCA but rather to note that there is possible, depending on interacting circumstances such as a loss of offsite power, a spectrum of possible effects ranging from a release which is completely contained to a core exposure with the possible consequences of hydrogen release, i combustion, containment rupture, meltdown. On the secondary side steam generator tube failure combined with atmospheric venting would see the release of coolant system rrdloactive volatiles including iodine, noble gases, and tritium. The magnitude of this release j is not predictable. The effect would, of course, be, in part, determined by the amount of radioactive material
- released.
P
- 11. Do you contend that any " effects" identified in your k
response to Interrogatory 10 tip the cost-benefit
[ balance against licensing?
Unless the Commission's SECY-82-8A is reversed by a higher jurisdiction it appears that NEPA balance consider-ations would not be at issue in this proceeding. This would appear to be the case because cost-benefit is considred in the context of alternatives, Board's Memorandum and Order of March 5, 1982, re rejection of CESG 1, 5 , 6, and 12.
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l 12.
If your response to Interrogatory 11 is in the affirma-tive, please specify precisely what the " costs" which i I
you contend tip the environmental cost-benefit balance
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against operation.
See reponse to 11.
13.
What are your bases for your responses to Interroga- t tories 8 through 127 Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.
See responses 8, 9 and 10.
- 14. What is the extent of such infestation which you con-g tend exists? 4 4
it is not operative.No infestation exists in the Catawba cooling syst .
at the site, EIS 2-36 and, based on the rapidity ofHowever I proliferation of Corbicula and its worldwide distribution ,
in theit. system unless effective measures were ta prevent c-
- 15. p Do you contend such infestation is likely to extend t o .
the Catawba site? %
See response to 14 r 16.
g Do you contend that such y-
" effects" will be detectable?
Yes.
M
- 17. Do you contend that the {
" effects" of Corbicula are irreversible once they are detected? k No.
But a qualification must be added. [.
I:r without cost or the expenditure of time. Cleanup is not U-
- 18. 5; If your response to Interrogatory 17 is in the a f firma- . .:
tive, [h how do you explain that other facilities have lf..
g, adequately dealt with ,Corbicula? UZ I
^
We do not contend that the effects of Corbicula are I irreversible, response 17. We do not know or concede that other plants have dealt with Corbicula without significant cost.
- 19. If your response to Interrogatory 17 is in the nega-tive, what concerns can you have for "the performance of the cooling tower system."
~~-
~ihere is no assurance afforded by the ER or the FSAR that Applicant is aware of the problem or has made appropriate provisions for dealing with it, Board's M&O, p.27. We have been told that the calcareous shells of Corbicula adhere strongly to condenser tubes.
We have seen no evidence as to the effect on heat flux through tubes once infested and then cleaned. The description of the vertical disposition of the condenser tubes in a shell in which vapor flow is horizontal raises questions about accessibility to mechanical cleanout and vulnerability to a chemical procedure if, indeed, there is a satisfactory chemical-procedure.
The question of the possibility of cleanout does not address the question of the downtime it requires.
- 20. What are your bases for your responses to Interroga-tories 13 through 187 Identify all docu'ents, m testimony or oral statements by any person and legal require-ments on which you rely in support of your position.
We have seen no testimony. The bases for responses have been provided in earlier responses, viz. 2, and drawing conclusions from straightforward premises as in 3, 4, 6, and 19.
Respectfully provided, 9%
Jepse L. Riley ]
CESG [d 854 Henley Place Charlotte, NC 28207 704-375-4342 May.6, 1982
r ;
C: r-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .g2 C 10 P1 :15 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD (J . .
DC _ ,.
In the Matter of )
)
DUKE POWER COMPANY; et al. ) Docket No.40-413
)40-414 (Catawba Nuclear Station, )
Units 1 and 2) )
AFFIRMATION OF SERVICE I hereby affirm that copies of "CESG'S RESPONSE TO APPLICANT'S FIRST SET OF INTERROGATORIES" in the above captioned matter have been served on the following by deposit in the United States mail this sixth day of May, 1982:
James L. Kelly, Chairman George E. Johnson, Esq.
Atomic Safety and Licensing Office of the Executive Legal Board Panel Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Comission Washington, D.C. 20555 Washington, D.C. 20555 Dr. A. Dixon Callihan William L. Porter, Esq.
Union Carbide Corporation Albert V. Carr, Jr. , Esq.
P.O. Box Y Ellen T. Ruff, Esq.
Oak Ridge, Tennessee 37830 Duke Power Company P.O. Box 33189 Dr. Richard F. Foster Charlotte, North Carolina 28242 P.O. Box 4263 Sunriver, Oregon 97701 Richard P. Wilson, Esq.
Assistant Attorney General Chainnan State of South Carolina Atomic Safety and Licensing P.O. Box 11549 Board Panel Columbia, South Carolina 29211 U.S. Nuclear Regulatory Commission Robert Guild, Esq.
Washington, D.C. 20555 314 Pall Mall Columbia, South Carolina 29201 Chainnan Atomic Safety and Licensing Scott Stucky Appeal Board Docketing and Service Station U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555
Henry A. Presler Executive Director for Charlotte-Mecklenburg Operations Environmental Coalition U.S. Nuclear Regulatory 943 Henley Place . Comission Charlotte, North Carolina 28207 Washington, D.C. 20555 f f Jesse L. Riley f8r CESG f' i
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