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Category:INTERVENTION PETITIONS
MONTHYEARML20055A3551982-07-12012 July 1982 Amended Contention 59.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 ML20039B5721981-12-15015 December 1981 Response Opposing R Alexander 811130 Untimely Petition to Intervene.Strong Grounds Necessary to Reopen Record on Financial Qualifications Not Shown & Requirements for Untimely Intervention Not Met.Certificate of Svc Encl ML20003H8021981-04-23023 April 1981 Intervenor Jf Doherty Contention 56,stating That Reactor Trip Sys Unprotected Against Pipe Break to Scram Discharge Vols from Hydraulic Control Units.Certificate of Svc Encl ML20003A5581981-01-26026 January 1981 Contentions 50 & 55 in Response to NUREG-0470,Suppl 2, Draft Suppl to Fes Re Const of Allens Creek Nuclear Generating Station,Unit 1. Site Je-3 Superior to Applicant Choice W/Less Environ Impact ML20062L2941981-01-15015 January 1981 Contention 51 Re Designation of Site Li-3 as Superior Site, Contention 52 Re Ability of Govt to Decide Issues of Wildlife Habitat & Contentions 53 & 54 Re NUREG-470,Suppl 2. Certificate of Svc Encl ML19336A7361980-10-27027 October 1980 Response in Opposition to Jf Doherty Untimely Contention 50. Intervenor Failed to Establish Connection Between Design & Alleged Safety Concern of Coolant Circulation Degradation. Certificate of Svc Encl ML19331D9241980-08-28028 August 1980 Response in Opposition to W Schuessler,S Doggett & Tx Pirg 800813 Reworded Contention Except Portion Re Capability of Plan W/Location.Remaining Portions Do Not Comply W/Aslb 800724 Order.Certificate of Svc Encl ML19338C3861980-08-15015 August 1980 Consolidation of Contentions Re Emergency Evacuation Plans. Alleges Failure of Environ Rept,Psar,Fes & SER to Comply W/ Regulations Re Evacuation During Class 9 Accidents. Designates Wj Schuessler as Lead Party ML19323D7621980-04-22022 April 1980 Response in Opposition to Jf Doherty Contentions 48 & 49. Intervenor Failed to Justify Untimeliness & to State Good Basis for Conteniton 48.Contention 49 Is Inappropriate for Consideration Due to Class 9 Policy.W/Certificate of Svc ML19323B6961980-04-0707 April 1980 Contentions 48 & 49 Alleging That Facility Should Be Designed W/Control Rod Drive Return as Addl Safeguard & That Containment Should Have Core Ladle as Described in NUREG- 0054 ML19309G1181980-04-0707 April 1980 Brief in Response & Opposition to Fh Potthoff Appeal of ASLB 800310 Order Rejecting Contention 6 Re Biomass Farm Alternative.Intervenor Failed to Include Sufficient Bases for Allegation.Certificate of Svc Encl ML19309H6581980-04-0707 April 1980 Amend to 790525 Contention 17,adding ATWS for Consideration W/Power Excursion Accidents Re Reactivity Effect ML19305E1481980-03-31031 March 1980 Response in Support of R Potthoff Appeal Re Denial of Petition to Intervene.Potthoff Contention Should Be Regarded as Allegation That EIS Did Not Address Biomass Conversion. W/Certificate of Svc ML19309E4101980-03-27027 March 1980 Response in Opposition to Intervenor Jf Doherty 800312 Untimely Contention 47.Good Cause Re Relationship of New Info to Analyses of Turbine Missile Generation Probability & Damage to Equipment,Not Met.W/Certificate of Svc ML19294B0971980-02-10010 February 1980 Response to Applicant & NRC Briefs Re R Alexander 800206 Appeal.Restates Interests as Affected Family & Urges Aslab to Grant Intervention ML20148C9071978-10-11011 October 1978 Petition for Leave to Intervene by Houston Chapter of Natl Lawyers Guild,Inc ML20148B7651978-10-11011 October 1978 Petition to Intervene in CP Proceedings.Accident at Facility Could Cause Tremendous Loss of Life.Even Low Levels of Radiation Can Cause Cancer or Genetic Damage ML20147C6961978-09-29029 September 1978 Response to Amended Petition for Leave to Intervene Filed by W. E.Rentfro.Holds That Amended Petition Fails to Meet the Requirements of I0CFR2.7J4(b) & ASLB Order of 780814 & Should Be Denied 1982-07-12
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20055A3551982-07-12012 July 1982 Amended Contention 59.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 ML20039B5721981-12-15015 December 1981 Response Opposing R Alexander 811130 Untimely Petition to Intervene.Strong Grounds Necessary to Reopen Record on Financial Qualifications Not Shown & Requirements for Untimely Intervention Not Met.Certificate of Svc Encl ML20003H8021981-04-23023 April 1981 Intervenor Jf Doherty Contention 56,stating That Reactor Trip Sys Unprotected Against Pipe Break to Scram Discharge Vols from Hydraulic Control Units.Certificate of Svc Encl ML20003A5581981-01-26026 January 1981 Contentions 50 & 55 in Response to NUREG-0470,Suppl 2, Draft Suppl to Fes Re Const of Allens Creek Nuclear Generating Station,Unit 1. Site Je-3 Superior to Applicant Choice W/Less Environ Impact ML20062L2941981-01-15015 January 1981 Contention 51 Re Designation of Site Li-3 as Superior Site, Contention 52 Re Ability of Govt to Decide Issues of Wildlife Habitat & Contentions 53 & 54 Re NUREG-470,Suppl 2. Certificate of Svc Encl ML19336A7361980-10-27027 October 1980 Response in Opposition to Jf Doherty Untimely Contention 50. Intervenor Failed to Establish Connection Between Design & Alleged Safety Concern of Coolant Circulation Degradation. Certificate of Svc Encl ML19331D9241980-08-28028 August 1980 Response in Opposition to W Schuessler,S Doggett & Tx Pirg 800813 Reworded Contention Except Portion Re Capability of Plan W/Location.Remaining Portions Do Not Comply W/Aslb 800724 Order.Certificate of Svc Encl ML19338C3861980-08-15015 August 1980 Consolidation of Contentions Re Emergency Evacuation Plans. Alleges Failure of Environ Rept,Psar,Fes & SER to Comply W/ Regulations Re Evacuation During Class 9 Accidents. Designates Wj Schuessler as Lead Party ML19323D7621980-04-22022 April 1980 Response in Opposition to Jf Doherty Contentions 48 & 49. Intervenor Failed to Justify Untimeliness & to State Good Basis for Conteniton 48.Contention 49 Is Inappropriate for Consideration Due to Class 9 Policy.W/Certificate of Svc ML19323B6961980-04-0707 April 1980 Contentions 48 & 49 Alleging That Facility Should Be Designed W/Control Rod Drive Return as Addl Safeguard & That Containment Should Have Core Ladle as Described in NUREG- 0054 ML19309G1181980-04-0707 April 1980 Brief in Response & Opposition to Fh Potthoff Appeal of ASLB 800310 Order Rejecting Contention 6 Re Biomass Farm Alternative.Intervenor Failed to Include Sufficient Bases for Allegation.Certificate of Svc Encl ML19309H6581980-04-0707 April 1980 Amend to 790525 Contention 17,adding ATWS for Consideration W/Power Excursion Accidents Re Reactivity Effect ML19305E1481980-03-31031 March 1980 Response in Support of R Potthoff Appeal Re Denial of Petition to Intervene.Potthoff Contention Should Be Regarded as Allegation That EIS Did Not Address Biomass Conversion. W/Certificate of Svc ML19309E4101980-03-27027 March 1980 Response in Opposition to Intervenor Jf Doherty 800312 Untimely Contention 47.Good Cause Re Relationship of New Info to Analyses of Turbine Missile Generation Probability & Damage to Equipment,Not Met.W/Certificate of Svc ML19294B0971980-02-10010 February 1980 Response to Applicant & NRC Briefs Re R Alexander 800206 Appeal.Restates Interests as Affected Family & Urges Aslab to Grant Intervention ML20148C9071978-10-11011 October 1978 Petition for Leave to Intervene by Houston Chapter of Natl Lawyers Guild,Inc ML20148B7651978-10-11011 October 1978 Petition to Intervene in CP Proceedings.Accident at Facility Could Cause Tremendous Loss of Life.Even Low Levels of Radiation Can Cause Cancer or Genetic Damage ML20147C6961978-09-29029 September 1978 Response to Amended Petition for Leave to Intervene Filed by W. E.Rentfro.Holds That Amended Petition Fails to Meet the Requirements of I0CFR2.7J4(b) & ASLB Order of 780814 & Should Be Denied 1982-07-12
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20063N7591982-10-0606 October 1982 Withdrawal of Application for CP 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 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 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 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 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 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 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 ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.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 ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence 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 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 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 ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl 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 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 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 ML20049K0671982-03-25025 March 1982 Reply to Tx Pirg 820315 Addl Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to 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 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 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 ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042B2381982-03-15015 March 1982 Sixth Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20042B2451982-03-15015 March 1982 Motion for Subpoena of Quadrex Corp Employees.Testimony Necessary for Clear Understanding of Brown & Root Deficiencies Despite Util Supervision & Specific Steps Needed to Correct & Prevent Problems.W/Certificate of Svc ML20041F0761982-03-10010 March 1982 Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence ML20041F0871982-03-10010 March 1982 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Addl Time Needed to Complete Discovery.Certificate of Svc Encl ML20049J6571982-03-0808 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl ML20041E1001982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20041E1071982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl ML20041E1181982-03-0505 March 1982 Third Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept Matters.Related Correspondence ML20041E1201982-03-0505 March 1982 Motion for Order Directing Applicant to Provide Forthcoming Bechtel Quadrex Rept Review.Rept Pertinent to Remaining Issue.Certificate of Svc Encl.Related Correspondence ML20041E1741982-03-0505 March 1982 Brief Opposing R Alexander Appeal from ASLB 820112 Order Denying Petition to Intervene.Aslb Did Not Abuse Discretion in Denying Petition.Certificate of Svc Encl ML20041E0711982-03-0404 March 1982 Second Set of Interrogatories Re Tx Pirg Contention 21 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20049H8881982-03-0101 March 1982 Response Opposing D Marrack 820213 Motion for Review of Dates for Reopening Hearings & Continuance.No Commission Regulations or Atomic Energy Act Provisions Require Applicant Irrevocable Commitment.Certificate of Svc Encl ML20041B5381982-02-22022 February 1982 Reply to Intervenors Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20041C0671982-02-22022 February 1982 Response Opposing Tx Pirg 820209 Motion for Addl Time to File Proposed Findings of Fact & Conclusion of Law.Motion Mooted by Tx Pirg Filing Proposed Findings on 820212. Certificate of Svc Encl ML20041B5421982-02-17017 February 1982 First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl.Related Correspondence 1982-07-02
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION"'
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July /1, 1982 BEFORE THE ATOMIC SAFETY AND LICENSING $0lRD.?.15 f.0:35 f
I In the Matter of: ) (-
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HOUSTON LIGHTING & POWER CO.
(Allens Creek Nuclear Generating ) Docket No. 50-466 CP Station, Unit 1) ) ;
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INTERVENOR DOHERTY'S AMENDED CONTENTION 59 l
On July 1, 1932 and July 6, 1982, this Intervenor received responses to his Motion to Re-open the Record of June 15, 19.82, from Auplicant and Staff respectively. On July 6, this Inter-venor received in the same filing, a response to his Contention 59, which asserts in its first part that the Applicant is un-oualified to recieve a license fron the Comnission because it failed to. report numbr
)roblems with the South Texas Nuclear
/ Project which were recurted in the Quadrex Report, a report on the design work for that plant by the Brown & Root Company.
The amendment below applies only to Contention 59, part (a). i l
It is sugeested that parties use this Intervenor's June 15, 1982 $
filing to follow the anendments which largely are intended to state the consequences of each of the findings and their relevance to safety. '
AME!iDED CONTENTION 59(a)
Interveaor contends , Applicant has not demonstrated it is able to conoly wi13h NRC re -uld; ions, specifically 10 CFR .50 55(e) and hence should not be granted a construction permit for the proposed ACNGS. This contention is based on Applicant's failure to report under this re5ulation several deficiencies found by the Quadrex Corporation in its report on design work by-- the Brown
& Root Corporation it the South Texas Nuclear Project (STNP) in
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May 1981. Intervenor asserts that Absfollowing deficiencies u should have been reported under 10 CFR 50.55(eX1Xi-iv):
8207160202 820712 PDR ADOCK 05000466 O PDR
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. Under 10 CFR 50.55 (e)fb(i),'the following should have been recorted: j,/
(1) Based on Quadrex Mport Item 3.1(b)(3), inconsistenTre- I e
veiw mf vendor subtd,tted reports. As pointed out in the .'
+
e Quadrex Report,'valvc.s were involved in this. The proper function of valves,is significant to , shutdown of the plant. Part
. M-49 of the rpor!: indicates butterf1,1 valves, and 30 inch ;
and 18 inch valves were a' part of this deficiericy. Question ,
M h1 indicates the same problem effected the tank for con- ,
taining ECCS water, an oovious safety system component which
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if it failed could effact plant safety. ,
(2) Based on Quadrex :teport Item 4.5.2.1(e) there was no docu-mentation for definin's separation barrirrs. This could have effected clant safety becauEe various senaration barriers
( i could have been used, some of ,which would not be capable ol' ; ,
preventing common mode failure in event,of fire. Question ,
H-3 of the Report inicates an unacceptable material uns used as a fire barrier, a (3) Based on the Quadrex Reoort item 4 3 2.1(j) vendors '
were allowed to appl .- IIRC requirecents instead of archi- ,
tect engineers. Question E-8 of tb Report indicates (Quadrex Assessment) that acceptance criteria for the i reliability of the essential services features (ESF) sequencer were left to suppliers. This lack couYd.
have effected plant safety, because the E3F secuencer-signals the diesel generators to commence operation.
In event of locs of off-site power. combined with a =
design based ac :ident, the unit would be denendant [
on the reliability of the ESF .to.Drovide's signal for l heat removal from the core following scram. Hen ce ,
allowing vender to apply these criteria effected plant safety.
( j) Based on the Quadrex Report item 3.1(j)(2) the AFW l (auxilliary feed-water) pumps may not be qualified for" $
costulated accident envi'ronments. Were this deficiency f
to have been uncorrected, any accident which relies on g these pumps for make up water to the pressure vessel would have been less controled, and possibly gone un- .
controlled. Therefore the deficiency could have had an effect on safe operation of the plant. An example .
I J
d of an accident where AFW pumps are required is the
. large break LOCA.
( 5 ) Based on the Quadrex Report item 3.1(e) there were no
- written guidelines for conduct of failure modes and effects analysis. This means that these analysis were done (if at all) by idiosyncratic process of enineering groups or individuals. This means there were no ways nonlicant could know what the failure effects were for the STNF as so far constructed. With such a large deficiency in knowledge ofthe effects of LOCA, or any ;
other accident tyne or design based accident, the failure
.to recort under 10 CFR 50 55(e) was a serious omission.
(G) Based on the Quadrex Report item 4.4.2.1(d) separation requireacnts against common mode faEures were not iden-tified with re5ard to HVAC. Question H-6 of the re, ort states this would apoly to the 6ffects of high energy line breaks or fire. The common mode failure of filter trains for the containment or the scent fuel building systeos for the redundant containment ventilation ore, redundant spent fuel ventilation w6uld adversely effect saf e operation of the plant because of over heating of each which would cause leakage of any gases in either structure to move outward since the usual negative pres-sure to the environment would be lost. In an accident situation, the effect would be to aggrivate unwanted exit of any radioactivity, going beyond technical spec-ifications and perhaps 10 CFR 50 Ap'endix I limits. ,
7 ) Based on Quadrex Report item 4.1.2.1(b) there is no evidence of evaluation of reasonableness of pos'tulatrd.. internal ~ missiles
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j and Question C-9 of the Report indicates criteria for pro- {
l , tection a5ainstmissiles were never implemented. Therefore /
An,licant should have reported this deficiency on discovery under this section of 10 CFR 50 55 because vulnerability to missiles is recognized by the Commission as a possible danger to plant safety; and is a safety research subject of the Commission as well, item A-32, (See: STAFF Exhibit 19, Fg C-7.) .
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e Under 10 CFR So.55(e)(1)(ii), the following should have been '
renorted:
I (6) 3aspd on Quadrex Reoort Item'4.3.2.1(b) no top level document (Technical Reference Document (TRD)') existed that specified slant-wide senaration reouirements 'for the Mechanical and Instrument &. Controls engineerinC for the STNP after much construction. sence for all work the plant safety may well ,
have been comoromised because if instruments were not properly f ;
i separated they could simultaneously be damaged by fire:or envir-onmental conditions (i.e. post-accident pressure, tenperature and radiation) Plant safety
- systems rely on the instumentation i and controls and thesetare expected to operat'e'in a planned' man- ,
n'er based (in part)'on their separation.
- I (9) Based on Quadrex Reoort Item 4.3 2.1(n) there w'as no design document on circuit application of isolation devices. This lack could have adversely effected clant safety and should have been re7erted because impropei isolation (for example containment isolation) could result in release of radioactive
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materials in event of an accident such as a small or large ;
break LOCA. ,
(10) Based on Quadrex Report item 4.4.2.1(c), there are no calculations for hydrogen mixin5 and the potential for pocket accumulations in the containment after LOCA de-spite the fact much of the STNP-I containment building is now constructed. Accumulations of hydrogen in con-tainment buildings should be addressed according to Question H-3 of the Quadrex Report, and represent a serious problem for plant safety because explosions of hydrogen may exceed the ultimate yield strength of the containment oermitting radioactive gases to escape and reach members of the public.
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(B) Based on Quadrex Report Item 4 5 2.1(b), loads used as basis foreplant design were unverified or not revi'ewed l . for certain pipe rupture loadings (Question C-4, 2nd page, and. Question M-8 ENS). The failure to verify uipe rupture loads is a serious Plant design deficiency that effects plant safety, because in the event of pipe f ruuture, pipe whip may damage safety components, and pressure and beat may have similar effects on safety systems. In addition these effects may damage struc-
)
tural steel inside containment further comoromi' sipg plant safety.
(IL) Based on Quadrex Report Item 4.6.2.1(a) temperature values were not controlled by designers for ecuipment design.
The use of saturation temperatures rather than actual temperatures inside containment is not conservative in all cases (according to Quadrex Report item 4.6.2.1(a)) ,
as there has been no analysis performed to support the implied assu=ption that equipment will not respond to actual temperatures. Therefore, plant safety =ay be adversely effected because safety equipment inside con-tainment is not correctly environmentally qualified.
(13) Based on Quadrex Report Item 4.6.2.1(b) insufficient .
6nvironmentsi analysis was . done by two contractors at the DTMP. In Question N-3 of the Quadrex Report it states " failure to perform these analyses has the notect ial of causing plant retrofits and compromise of the maintainance and access aspects of the plant desigg"thus indicating some of these failures to pro-vide analysis must have effected the final design as approved andc ' onstruction' tad. started before the finding.
In particular high energy lines in the mechanical auxilliary building (MAB) would effect plant safety
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in event of a main steam line break in the MAB, which houses much of the motor driven safety equipment, were hot analyzed, a failure regarded as untimely in a.6.2.1(b) of the Quadrex Report.
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.Q) Based on Quadrex Report item 3 1(d)(5) idenftified supoort systems and other systems were improperly identified with re5ard to safety related versus non-safety related class- ,
ification. Question E-3 indicates misidentification occured f
in the instrumentation.& controls systems of the plant. Ord-ered or installed-instrumentati6n and controls would adversely j effect olant safety if they were non-safety related where
{
they should have'been safety-related and violate General Desian Criteria 21 (15) Based on Quadrex Report item 4.8.2.2(k), there is no documented basis for locating breathing connections.
In event of clant accidents, it may become necessary
{
to send personnel to areas of the olant to assist in mitigating the accident. Without adequate breathing connections, this may be impossible or possible only with delay. Delay or failure to perform certain acts may effect uublic safety because many accidents can -
be mitigated with prompt attention. Since STNP-I is more than 40% completed, the optimal placement of breath- .
ing lines may now be impossible, or violate' Commission criteria on the placement of breathing lines.
Under 10 CPR 50 55(e)(1)(iii)the following should have been reported:
(IG ) Based on quadrex ne ort item li.6.2.1(e), Applicant use of the RELAP3 code for annulus nressurization analvsis was inap,ropriate. Question U-2 of the report indicates use of appropriate codes will be untimely. "This-then*-
will mean major structural changes to at least STUP-I.
Failure of the annulus under pressurization effects plant
. safe operation because of the escape of products in gas-eous forms, which are radioactive. Failure cannot be precluded unless the correct code is applied and defic-iencies corrected. .
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(M) Based on Quadrex Raport item 4.1.2.1(c) tho turbino buil-ding had not been analyzed for safe shutdown earthquake ,
although by February, 1979 the turbine-generator foundation mat had been completely installed, and installation of the "Condensor and Turbine Generator" had been 10% complete with expected completion by February of 1980, according t to NUREG-0030, Vol. 2, No. 1, Feb. 1979, p. 2-74, (STNP, Unit 1 only). Failure to correctly construct against the safe shutdown earthquake has numerous safety impli- l cations which effect safety: failur'e of the turbine building f might result in turbine missiles, a turbine rotation block l with disabling of the stop valve would clearly cause a i fission flux increase which would possibly bring an over-power transient. Hence, this meets the standard of 10 CFR .
50 55(e)(1).
Uhder 10 CFR 50.55(e)(1)(iv)-the followine should have been recorted: ,
(18 ) Based on Quadrex deport item 4.6.2.1(a), temperature values for equipment design have not been pronerly con-trolled. Question U-15 of the Reoort states some of the eeuipment has been purchased relying on the'se (uncontrolled) values. The same ;,uestion shows that the enuipment is safety related and to be installed in the IVC or MAB por-tions of the plant. Safety related ec,uitment in the MAB is use* to mitigate accidents, so the item could re-late to nlant safety adversely.
I (19) Based on Quadrex Report item 4.6.2.2(m), different i values of the essential cooling pond (ECP) initial tempor-ature assumptions were used by Nuclear Analysis and Heavy Civil disciplines.- This deficiency permits an operating x
condition in the two unit plant which will e'ceed the tech-
.nical snecifications for the ECP. Further, Question N-17 of the Quadrex Report states that reanalysis of the problem is "not timely". According to NUREG-0030,.Vol.2 Ho., Feb.
1979, " Reservoir and Make,up Water Facilities"for the STNP were more than 55% completed at that date. Therefore the ECP calculation problem should have been reported under 10 CPR 50.55(e)(1)(ii) at the time of the report'.s 1
annearance. ~
. . .' s !
(RO) Based on Quadrex Reoort item 4.6.2.1(b), there was a lack l of environmental analysis outside containment whin could' !
result in either retrofit in the MAB or incorrectly designed i
equipment in the isolation valve. cubicle (IVC). In par- l
~
ticular, high energy lines in the MAB would effect plant safety in event of a main steam line break in the MAB,
, where much of the motor driven safety equipment is located.
Intervenor asserts that failure to report these findings demonstrate ~ inability to comply with URC regulations on the part of the Applicant and that i this inability would endanSer the public and this Intervenor were Applicant granted the sought license.
Respectfully, j lJu hhnF.Doherty /
CERTIFICATE OF SERVICE I certify that cocies of "INTERVEROR DOHERTY'S AMENDED COUTENTION 59" were served on the parties balow via First Class U. S. Postal Service, this /l dt of July, 1982, from Houston, Texas.
Sheldon J. '1olfe, Esq. .s~
- Administrative Judge Dr. E. Leonard Cheatum Administrative Judge Gustave A. Linenberger Administrative Judge '
Richard A. Black, Esq., Staff Counsel J. Gregory Copeland, Esq. Applicant Counsel Jack R. Newman, Esq. Applicant Counsel -
The Several Intervening Parties l Docketinr; & Service Branch Atomic Safety Licensing & Appeal Board r w /x ]
ohn F. Doherty' me