ML20055A355

Amended Contention 59.Certificate of Svc Encl

ML20055A355
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	07/12/1982
From:	Doherty J DOHERTY, J.F.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-CP, NUDOCS 8207160202
Download: ML20055A355 (8)

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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

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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):

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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 .'

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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 .

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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-

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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

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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

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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

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(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

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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