ML20062H526

From kanterella
Jump to navigation Jump to search
Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Summary Disposition of Jf Doherty Contention 13 on Operation of ECCS Pump Strainer Assemblies. Excerpts of Jf Doherty Deposition Encl.Pp 97-115
ML20062H526
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 08/04/1980
From:
BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML19331C559 List:
References
ISSUANCES-CP, NUDOCS 8008190086
Download: ML20062H526 (19)
v • d • e


Text

{{#Wiki_filter:O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i In the Matter of S S HOUSTON LIGHTING & POWER S l COMPANY S Docket No. 50-466 1 S ~ (Allens Creek Nuclear S Generating Station, Unit S No. 1) S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD i (1) Each of the five ECCS pump suction lines will be provided with a strainer assembly designed to guarantee that the largest sized particles that could enter the ECCS system are not large enough to hamper ECCS performance by becoming lodged in small openings in ECCS equipment. (Affidavit, p. 2) (2) The five ECCS strainer assemblies are designed with three times the open area of the suction piping to provide a high confidence that strainer clogging will not hamper ECCS performance. This assembly design exceeds the requirements of Regulatory Guide 1.1. (Af fidavit, pp. 2-3) (3) All insulation utilized in the drywell will be of the metallic reflective type which is the least likely of all available insulation types to break into small pieces and potentially block the ECCS strainers. (Affidavit, p. 3) s008190 i. S7

(4) The location and configuration of the ECCS pump i i strainer assemblies will further reduce the possibility of blockage. There will be a very low velocity profile in the vicinity of the strainers and they will be located to avoid ingestion of sunken and/or floating debris. (Affidavit, pp. 3-4) (5) The small amount of insulation ucilized in the containment, but outside the drywell, which is not of the metallic reflective type, is extremely unlikely to cause any blockage of the ECCS pumps because the paths to the Suppres-sion Pool from the areas where other insulation will be used, are extremely tortuous. (Affidavit, p. 4) (6) Applicant has greatly minimized the possibility that paintings and coatings used inside the containment could separate from pipes and cause ECCS blockage by complying with Regulatory Guide 1.54 as described in PEAR, Appendix C. (.Af fidavit, pp. 4-5) a i i ---m I l~ S19

5 7 9 -17 4 3 A C?.,S : E AT COSTS Doherty Contention No. 13/ PAlO BY PLF. DEF. ECCS Sumps i k UNITED STATES OF AMERICA i I NUCLEAR REGULATORY COMMISSION ( NRC) BEFORE THE ATOMIC SAFETY & LICENSING BOARD l f IN THE MATTER OF HOUSTON LIGHTING & POWER COMPANY DOCKET NO. 50-466 i (ALLENS CREEK NGCLEAR GENERATING STATION UNIT 1) l CEPOSITION OF: JOHN F. DOHERTY l Y J .o9 fr ~ /26,' 1917 Bank of the Sov-hwest Building. Houston. Texas 770C2. (713) 552 5311

122 d 1 Q Have you read the PSAR sections on water level a di indicators? 2 3 A No -- I don't think so. I don't seem to have 4 any Xerox out of that anyway. 5 Q Do you usually remember when you read things? L 6 A I think so. 7 Q All right. w 8 A Sut I am not as good as I used to be. 9 Q In giving your answer to the general question 10 about the design and operatioh of water level } 11 indicators, do you believe that you did read 12 the PSAR sections? 13 A No, I don't. 14 Q John, we'll turn to one that I think we can do 15 in the short time remaining. [l 16 A All right. 17 Q Number thirteen on the Applicant's containment j 18 emergency sump pump. Will you describe for me l 19 the ICCS sump that's referenced in this l(l 20 con te n tion ? 11 21 A Well, I don't understand a lot about it. It's it's at the bottom of the dry well. 22 at the 23 Q The bottom of the dry well is an ECCS? m}: 24 A There's a way in which water drops. It's 25 collected and piped back into the ECCS for reuse 1 3 1C O

123 1 Q All right. And the sump which is. the-origi n 2 of the water for reuse is the dry well? 3 A Seneath the dry well there is a pump?.. 4 A Yes. 5 Q What pump is beneath the dry well?.. 6 A It's called a sump pump. 7 Q There's a su=p punp beneath the dry well which 8 pumps water? ~ g A Well, it drains out. 10 Q It pumps the water that's dra'ining into the well 11 out of the dry well? s t 12 A Yes. 1 i 13 Q All right-14 A It's got to get out of the dry well to a drain. 15 The dry well is not a closed place.. 2t's a 16 drain. 17 Q So it has a drain and there's a pump. connected 18 to this drain and it pumps that wate 2 19 A Up in to the ECCS, yes. 20 Q What is the ECCS? 21 A It's a large s torage water system.. -- 22 Q A big tank? 23 A It's two tanks, I th ink. L 24 Q All righ t. 25 A And maybe even more. 101 e-em mp e- -. - em V

124 1 Q And so this sump pump that you refe{ence in 2 your contention and the sump you refe ence in d 3 your contention is the dry well, a.7 a pump connected to the dry well which pumps water into 4 5 two large Eccs tanks; correct? 6 A Yes. 7 0 okay. Which you then use to recycle -- well, 8 where's the end point to the recycli.}g? 9 A The water is pumped back into the reactor. 10 0 Directly into the reactor ves'sel? 11 A Yes. It's main purpose is that and it pumps 12 at a high pressure in order to overcome the 13 pressure in the vessel itself. 14 0 What is the source of thermal shielding and 15 insulation which is the item of conceyn in 16 this contention? 17 A What is the source of it? l 18 Q Yes, sir. 19 A There 's insulation on the pipina of the valves 20 and pumps which in the event of a pipe break 21 or whatever, can plug the drain. L r 22 0 So is insulation and thermal shielding on the 1 23 pumps and pipes and valves on the dry well, that 24 can fall and plug the dry well drain? 2 25 A Yes. That would be the =ost logical place. ~ icz

a 125 1 Q Is there any other source? 2 A Let me think. Let me think. 3 Q what amount of this thermal shielding. insula-4 tion would have to come loose to cause__ the 2 5 problem that you described there?. _ 6 A I don't know the answer to that question? 7 0 You - don' t have any idea what it wou_id take? 8 Would it take the totality of all of..that to 9 plug up the drain? I 10 A I would think less than that.' t J 11 Q Half? c. 12 A Perhaps. i i t 13 0 A quarter? e t 14 A Perhaps. a 15 0 You have no idea? [ t 16 A No, I have no idea. I 17 Q You know what type of thermal shield.or insula- ) 18 tion is used in the dry well that's.s.usceptible 19 to this fragmentation ha subsecuent draininc? 20 A No. 21 Q Is all thermal shielding and insulation 22 susceptible to this process? 23 A I doubt it. ~ 24 Q Do you know what kind of thermal shialding 25 insulation is used in the Allen's creek design? 103

126 i 1 A No. 2 0 Do you know whether or not it is the type that 3 is susceptible or nonsusceptible to this type 4 of fragmentation that you described?._ 5 A I believe it is. 4 6 0 What is your basis for your belief? i 7 A The NRC annual report states that this is a rt i r 8 problem. 9 0 Does it state i t as a problem at Allen's i i 10 Creek? l 11 A No, it doesn't. ,) 12 Q Well, it says it's a problem where? t 13 A Well, it doesn't specify. It's kind of 9* I.. I 14 unspecific. It says -- it looks to be any t 15 reactor system. 16 Q Any reactor? . t. I 17 A Yes. 13 Q All right. 19 MR. NEWMAN: What are you reading 20 from? 21 THE WITNESS: An NRC annua 1 report. ? 22 MR. NEWMAN: May I see it? L. 23 THE WITNESS: Sure. Unfortunately 24 the date is not on it. It's one of the.re c en t 25 ones. 104 e,m -m --m-,-v

127 1 Q (By Mr. Biddle) That's your only sougee for assuming that thermal shielding insula, tion can 2 block the Allen's Creek drain sump or dry well 3 4 drain? 5 A well, regulatory guide -- 6 Q Excuse me. Does that regulatory gu_i_de reference I 7 Allen's Creek? 8 A No, none of them do. They never reference t 9 plants. l 10 Q And what is the relevance of the ra,t_e,, guide to a potential problem at Allen's Creek? 11 to the 12 A They are to provide methods acceptable 13 NRC regulatory staff of implementing. specific 14 parts of regulation. 15 Q Is it your contention that Allen's Creek will 16 not comply with that rate guide? ___ 17 A Not yet, no. I would have said that,-- principles 18 do not necessarily mean that they will license 19 the aspect anyway. 20 0 Are you contending that compliance with that 21 rate guide is insufficient assuranct_o_f the 22 problems you described? 23 A Yes. At this point I am. 24 Q But you have no knowledge of the type.. or, amoun t of thermal shielding insulation wh. ch. exists i at 23 Td~(15 umm I

128 1 Allen's Creek? 2 A That's right. 3 Q If it had no thermal shielding or insulation, 4 what would be the basis of your co.7, ten _ tion? 5 The presence of the rate guide alone is suf ficie::t? 6 A The rate guide seems -- it doesn't s.e.em to 7 indicate that as a possibility. 8 Q Does it reference Allen's Creek? ] 9 A No. 10 0 So in an attempt to recapitulate again, the S 11 source of your concern depends solely._on the 12 evidence of the rate guide and an NR,C_ annual 13 report which states that for all reactor types, 14 there may be a possibility of the rmal,_shie lding t ^ 5 15 and insulation blocking a dry well_d_ra.in? .I I 16 A Blockage of the dry well drain is the_ problem -- l 17 the regulatory guide speaks of debris. 18 0 Which regulatory guide? l 1 ) 19 A 1.82. i 20 MR. NEWMAN: Do you haye_1.82 with l 7 i 21 you? 22 THE WITNESS: Yes. 23 MR. NEWMAN: May I see it? 24 THE WITNESS: Yes. 25 0 (sy Mr. siddle) Am I not correct tha.t the qn_6 l k

129 1 presence of this rate guide or other rate 2 guides and the NRC annual report is_the sole actual basis for your assertion tha.t..there's a 3 4 problem at Allen's Creek in blocking _up a dry 5 Well d ^in? I 6 A I don' t know of any publications on this. It's l 7 attached in the of fices -- it's attached in the j i 8 nuclear reactor regulation number C-3_so they 1 I g have apparently th ough t it had some. bearing. I 10 Q Do they reference Allen's Cre'ek? 11 A No. 12 Q Do they reference designs similar to the Allen's i 13 Creek design? 14 A Chey don't seem to reference anything _to my 15 knowledge. 16 Q Do they' give any indication that this. test 17 applies to all reactors that encompasses Allen's ll-18 Creek withcut exception? t 19 A That would be pretty hard. l 20 0 Do they or don't they? 21 A At the moment they don't speak about. Allen's T .L. 22 Creek. l t 23 O Do they speak of reactor types? Do they speak l 24 of reactor types? 23 A Just a minute. (*~ 107

130 1 Q I'm sorry. 2 A That's okay. I don't see where they do. There's 3 nothing here. 4 0 Is it conceivable that one reactor type could 5 have a greater problem then another reactor type? 6 A

Yes, I would say so, yes.

7 Q And you don' t know which category A11en's 8 Creek belongs in? 9 A Right. 10 Q You have no facts in hand to hake that differ-11 entiation? 12 A I have no facts in hand, th a t ' s rig.)t. Could you tell me what significance the ultimate 13 Q 14 heat sink design -- could you tell me of what 15 significance the ultimate heat sink design 16 or operation has to this contention? -.. 17 A It's my understanding that if there's a 18 failure of the ECCS, there's a way that they take water directly from the ultimate heat 19 can 20 sink and use that. 21 Q All right. 22 MR. NEWMAN: What is the ultimate 23 heat sink at Allen's Creek? ~' 24 THE WITNESS: It's a small.depres-25 sion in the bottom of the coolant. .. 108 [~

131 1 MR. NEWMAN: It's your contention 2 r.h a t that would be drawn up for use as an 3 cmersencY coolins System? 4 THE WITNESS: If the recycling 5 system doesn't function, apparenti_g it's a 6 backup. 7 MR. NEWMAN: All right. 8 Q i.3y Mr. Biddle) So it really has no direct 9 relation to your intantion about the adequacy 10 of ECCS system and it's probl' ems with dry well i 11 draining? sink 12 A Well, I would assume the ultimate heat _ 13 would be considered part of the ECcs system. 14 Q Does this have any correlation in this contentic a? if 15 A It only supports the contention in that 16 the ultimate heat sink is not able_to function, (, 17 then it's more urgent to make certain that it 13 doesn't happen. l 19 0 If the ultimate heat sink is not ab l,e_to j _ l ( 20 function; correct? l ('~ 21 A Properly, yes. _j.nk in any 22 Q How is the functioning of the heat s connected to the dry well drain _o2 thermal i l 23 way ~ 24 shielding and insulation? 25 A If the water is inaccessible, then a shift has 109 i

132 1 to be made to another system to get_wa_ter. 2 O This shift you're describing is betwe_e.n ECCS 3 and the normal heat sink? 4 A Yes. 5 0 Okay. But using the ultimate he at;,s_ ink has 6 no reference to problems with the d.ry._.well drain 7 or the thermal shield; correct? t 8 A The dry well drain problems will occul inde-9 pendent of whether the ultimate hea _s. ink 10 will happen or not. 11 Q or problems with the dry well drain...wi.11 have 12 no impact on the heat sink? 13 A Yes, they will. I i 14 0 Wh a t ' s that? 15 A If one doesn't work, the other will have to be i 16 used. l 17 0 If there's a failure because of the_dr;y well 13 drain, will it impact the performance _of the I 1 19 heat sink? i i 20 A No. 21 MR. NEWMAN: John, a...f.e w m om e n t s 22 ago when I asked you to furnish to me.the 23 document th a t you were reading from, you 24 furnished to me an unidentified or.a pag.e 25 from an unidentified document. I have it here ,y;a 5 Mo t =

133 1 in my hand, and I want to be sure that this 2 document is the one that you were, rejerring to 3 as a basis for your contention. THE WITNESS: Was thag_on,this 4 5 contention? 1 MR. NEWMAN: Yes. 6 s 5 THE WITNESS: I don't have a copy 7 t 8 of it with me. f MR. NEUMAN: Excuse me.__That is 9 10 your document, just in case you forgot,. ~ THE WITNESS: This one is.mine. 11 12 All right. What is it you're saying for sure? MR. NEWMAN: Earlier -- well, let's 13 14 have that document marked for identif.i.ation. c 15 THE WITNESS: No proble.m., 16 5. 17 (The instrument ref err.ed _to was 18 marked Doherty Exhibit 1 for identif.ication.) 19 20 MR. N EW M1.3. Okay. Back.on the 21 record. 22 John, I want to show you. Exhibit 23 No. 1 in this deposition and ask you whether 24 this is the document to which you r.eferr,ed as 25 a partial basis for your contention when we 1'_1 W

134 1 spoke a few moments ago? THE WITNESS: Yes -- I me_an, I ~ 2 don't understand. I have this right here in 3 p 4 the file. I don't know anything ab.out any-i 5 Words-4 1 6 MR-NEWMAN : This is the_ document 4 i 'f 7 I thought you were relying on for par.t- - - of ycur 8 contention; correct? s THE WITNESS : Right. g MR. NEWMAN: And' s p ec i # i,c., ally, as 10 11 I recall you drew our attention to. r.eg_ula to ry 12 guide 1.82; correct? THE WITNESS: Right. l 13 14 MR. NEWMAN: So that's _a,,part of 15 your contention as well; correct? 16 THE WITNESS: Well, the._c,on te n ti on 17 is as it's worded. 18 MR. NENMAN: But as a basis for 19 your contention, you pointed to rate Suide 20 1.82 as a result of my having looked _at it; 21 correct? THE WITNESS: Right. 22 23 MR. NEWMAN: As I understand it, ~ 24 part of the basis for your contention.co.mes 25 from regulatory guide 1.82; correct? A AO 1_. 4 h

135 1 THE WITNESS: No. The contention J 2 would have ciued the basis if 1.82 were the 3 in te n tion. It may be that this backed that 4 up. ( 5 MR. NEWMAN: Why don' t you take a .il 6 look at tha t document and tell me what portions L 7 of that document provide a basis for your [ f 8 contention? { l 9 MR. cOPELAND: Off the record. 10 11 (Whereupon there was a discussion 12 held off the record.) 13 14 MR. NEWMAN: Let's go back on 15 the record. 16 For the record, I'd like to note 17 that what we just referred to as Dohe3_ty Exhibit 18 No. I has been re-numbered as Doherty Exhibit 19 No. 4 for purposes of consistency with prior 20 depositions in this matter. 21 John, when we spoke before about 22 Exhibit No. 4, you, in discussing that mentioned 0 23 the regulatory guide 1.82 which is discussed in 24 that Exhibit 4; is that correct? 25 THE WITNESS: I think so, yes. M

l 136 1 MR.-NEWMAN: All righ t.._..And i t 's 2 your contention, I take it, that regulatory 3 guide 1.32 applies to the Allen's creek plant? 4 THE WITNESS: Yes. i i MR. NEWMAN: okay.. Fan _the record, 5 6 I'd like to note that regulatory guide 1.a2 l 7 applies toward reactors. 8 THE WITNESS: 'What tima...do you 9 have? 4 1 10 MR. BIDDLE: 11:~30. Hava_we 11 arrived at end of questions at thi s..p oin t ? 12 MR. NEWMAN: There's one_ final 13 series I'd like to have. 14 off the record. 15 16 (Whe reupon there was.a _ dis cussion i f 17 held off the record. ) 18 19 0 (ay Mr. siddle) one last question, John. on 20 this ECCS sump business, you don' t have an 21 expert witness on the ECCS design.and. operation; 22 is that correct? 23 A That's correct. 24 Q And do you hold yourself out as an expemt on 25 th e ECCS sump design and operation? g_'l ? e -,e e . - emen

137 1 A lio, I don't hold myself out as an expert. 2 Q All right. Then we ' ll resu.ne again tomorrow 5 31^9 ** 9 00* 3 4 A You want to resume at 9:00? Okay. I can go 5 through the whole day. 6 Q All right. 7 (Whe reupon the proceedings were g recessed until 9:00 a.m. on g 10 P 11 12 13 14 15 16 17 18 19 t - i l 20 l ~ 21 22 23 ~ 24 25 125 m w. eese e m- =om

===w==}}

Retrieved from "https://kanterella.com/w/index.php?title=ML20062H526&oldid=4453677"