ML20062H589

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 43 on Use of Certain Coating & Cleaning Compounds.Excerpts of Jf Doherty Deposition Encl.Pp 264-275
ML20062H589
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 8008190236
Download: ML20062H589 (12)
v • d • e


Text

,.m U

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S

S HOUSTON LIGHTING & POWER S

COMPANY S

Docket No. 50-466 S

(Allens Creek Nuclear S

Generating Station, Unit S

No. 1)

S Material Facts As To Which There Is No Genuine Issue To Be Heard (1)

Several nuclear steam supply systems at ACNGS e

employ stainless steel piping and/or components for various reasons.

These systems are:

recirculation loop, control rod drive, hydraulic control units, fuel pool cooling systems, standby liquid control system lines, and reactor pressure vessel head ventline.

(2)

None of these systems will employ a protective coating of any kind.

(Affidavit, p. 2)

(3)

All of the stainless steel components used at ACNGS will be cleaned after installation but prior to operation of the plant in complete accordance with the provisions of Regulatory Guide 1.37, " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants."

(Affidavit, p.

2) 264 B 0 0819 0 o 36

)

)

(4)

General Electric does not take exception to any provision in Regulatory Guide 1.54 ("Cuality Assurance Requirements for Protective Coatings Applied to Nuclear s

Power Plants") which pertains to the cleaning or coating of

-i stainless steel.

(Affidavit, p. 2).

e 1

S h

k i

?

f L

E i

l f

'. ~

465 n

79-1743C DSH COST S Doherty Contention No. 43/

PAID BY PLF. CEF.

Stainless Steel Cleaning T

r UNITED STATES OF AMERICA i

NUCLEAR REGULATORY COMMISSION i

i BEFORE THE ATOMIC SAFETY AND LICENSING SOARD i

I IN THE MATTER OF:

HOUSTON LIGHTING AND POWER COMPANY, (ALLENS Docket No. 50-466 CREEK NUCLEAR GENERATING STATION, UNIT 1) f, i

I l

k i

a DEPOSITION OF:

i t

JOHN F.

DOHERTY 4'

.3 y'

nismat&<

28a

<a#

+2ters a

a w

1917 Bank of the scutnwest Buildin;. Houston, Texas 77002. (713] 652 5911

}

32G I

1 A.

There are some parts where it could, but.

I 2

some parts it couldn't.

It would'be impossible f

3 MR. NEWMAN: _

i i

4 to duplicate that accident?

l 5

A.

If you nean duplicate in the sense of I

l 6

xerox it, you're right.

7 Q.

(BY MR. BIDDLE):

Would you turn to your 8

contention number 43 on coatings and cleaning?

9 Which of the compounds prohibited by reg. guide

)

10 1.54 will be used at Allens Creek to coat

]

k 11 stainless steel components?

^

12 A.

I don't know the names of any of these r

13 materials right now.

i 14 Q.

You listed a number of compound 6-15 components in your contention, did you not?

T 16 A.

Yes.

[,.

17 Q.

You contend that all of those compounds 18 were used in the coatings for stainless steel at 19 Allens Creek?

c 20 A.

Apparently they had been used before in w

L 21 coatings or they wouldn't have been mentioned as t'

6 22 not good to use.

u 23 Q.

Would you answer my question, please?

24 A.

Yes, what is that question again.

O L,

25 MR.

BIDDLE: Would you read it, 267 1

.-e moir enno" cron=?r49 TNC.

u m --

329 3

e 1

please7 t

L 2

i 3

(The question was read back by the 6

4 r e po r te r.)

i 5

6 A.

Well, all this is future.

What I'm t

7 contending is that if the compounds do in fact 8

contain these materials, that they have this J

1 J

9 hazard.

l 10 Q.

I don't think anyone will argue with you

[

l 11 about that, Mr. Doherty.

The question is:

Which 12 of these prohibited elements do you contend will

.9 13 be used to coat stainless steel at Allens. Creek?

[

A.

Well, I filed the contention, I filed it

{

14 l

y 15 under rather late conditions, September 14th and 16 was not able at that time to find out which of r

s 17 these materials indeed would be.

I have a letter 18 from GE dated February 8th, 1977 which indicates 19 GE will provide by April 29th, 1977, additional u

20 information regarding the quantity of unqualified

/

'l coating materials for NSSS equipment located 22 within the containment.

a 23 Q.

What does that have to do with your

.m i

24 contention?

25 A.

Tnat indicates to me that GE at that m

268 1

1--mu c n i, o u.goarsas, we.

BMPJ e

i 4

r 1

time had unqualified coating materials.

2 Q.

What is an unqualified coating material?

i v

.,7

..i 3

A.

Evidently, it is materials listed in c

4 three sections of regulatory guide 1.54.

.t 5

0 What three sections of reg. guide 1.547

?

r T

6 A.

All right.

If I've understood this

]

3 es 7

right, apparently that's not true..

I have here

{

s.\\

8 three sections without it saying in this letrer

.t f

9 what those sections are.

11 o w, they may be the f

10 Standard Review Plan yes, they are the Standard 4

i 1

eyi 11 Review Plan, the three sections arc 1.2.4, 6.3 I

IL 12 and 6.6.

~

)g 13 Q.

Those are sections of what publication?

J 14 A.

It's referred to as the Standard Review

.]

f 15 Plan by the NRC.

l l

16 Q.

If we can return to my original question.

yy L

17 A.

That indicates to me that there are 18 materials that don't meet Standard Review Plan or f

19 there were at that time.

4 20 Q.

What does that have to do with your m(k 21 contention?

T.

22 A.

Allens Creek would be a GE plant, so e

23 that unless these materials whichever they are 24 specifically are out of the NSSS, then there is l

(

$3 25 some problem.

l

s

~

269

]

i INTERNATIONAL COURT REPORTERS, INC.

t

w-N 331 1

Q.

But you haven't indicated any s

2 correlation between that Standard Review Plan or J

3 reg. guide 1.54 and your contention.

4 A.

Yes, that's right.

5 Q.

Can you establish that connection?

i 6

A.

I'll have to try, otherwise, there's no t

7 contention.

t h

8 Q.

I would agree with you, sir.

l 9

A.

That's right.

Do you have a question?

)

10 Q.

Yes.

Is there any correlation between i

i 11 the Standard Review Plan you made reference.to, j

l 12 sections of reg. guide 1.54, you made reference 13 to and this contention?

14 A.

Well, I don't think thero should be any.

b 15 misunderstanding.

I don't think I made any l

16 reference to in the regulatory guide other than 17 to mention it.

The Gessar listed two documents f

18 which indicated th a t GE took exception to i

4 19 regulatory guide 1.54.

20-Q.

Do you have a document which states that 21 General Electric takes exception to the entirety 22 of reg. guide 1.54?

23 A.

Apparently just the sections.

24 Q.

Which sections of reg. guide 1.54 did GE 25 take exception to?

?:

270 iN.r < s a r 1 0,4 A i. couar n:. von;

.u,

2 :4 c.

f ses l

1 A.

I don't know at this time.

The reg.

2 guide is a page and a half in length, b

3 Q.

Are you familiar with reg. guide 1.547 f

4 A.

I have it in my hands here.

)

5 Q.

Are you familiar witn reg. guide 1.547 a

6 A.

No, I wouldn't say I was, but why don't 7

you ask a question.

g J

B Q.

Is reg. guide 1.54 concerned with 9

j 9

matters other than those expressed in your 10 contention?

q J

11 A.

It may be.

Well, it is concerned about s

12

.m a t t e r s expressed in the contention.

13 Q.

Has GE taken exception to that portion

(

-)

14 of reg. guide 1.54 whien may relate to the

.I l

15 subject matter of this contention?

l

.y l

16 A.

On page A-5 of the Gessar NUREG 0152, it l

17 indicates that GE has taken exception to the t -

1 13 provisions of the guide without saying which j e 2

l 19 provisions.

l 20 Q.

Does it say that GE has taken exception w

i

) -9 21 to each part and parcel of NUREG 1.54?

l 22 A.

Regulatory guide 1.54, it says that i

23 General Electric's position is to take exception l

l

_C 24 to the provisions of the regulatory guide.

l 25 Q.

So it is your conclusion that GE nas I

271 In t da:U, T I G :; n :

C O 'J d T REP 0kTih5, 1:JC.

f

...,s.

. m..

s.

.. g 333 r

Pi 1

taken exception to every part of reg. guide 1.54 2

and that's the basis of your concention?

i 1

)

3 A.

You're putting words in my mouth.

l l

4 Q.

That's because there are no words coming i

a 5

out of your mouth that help us to understand this p

T 6

contention.

l i

7 7

A.

Well, please refrain froc doing tnat.

I j

y

\\

i I've j

8 didn't say all sections.

I don't have 9

d 9

done very little analysis on the contention, but 4

10 Q.

What is the basis of your contention?

).

i 11 A.

Page A-5 of,NUREG 0152.

e I

L 12 Q.

That's the sole basis?

13 A.

If I had not seen that, I would not have i

.r i

i 14 framed the contention.

r'

,i L

15 Q.

Therefore, it is the sole basis of your r

9 p.

lo contention?

!n 17 A.

I think that defines the basis, r'

18 Q.

What is the title of reg. guide 1.54?

t-19 A.

Quality assurance requirements for iw 20 protective coatings applied to water cooled 21 nuclear power plants.

22 Q.

Which of the elements prohibited by reg.

23 quide 1.37 do you contend will be used to clean 3a 24 stainless steel at Allens Creek?

25 A.

I don't know that there is any of those ya f~

272

muss:

334

.l 1

in reg. guide 1.38.

I 2

Q.

Did you say that you know of none?

The n

]

3 question was, which of the elements prohibited by 4

reg. guide 1.37 vill be used to clean stainless

.i 5

steel at Allens Creek?

6 A.

And I've not postulated anything about t

7 reg. guide 1.37.

u 8

Q.

You did postulate something about J

9 cleaning of stainless steel, did you not?

10 A.

Yes.

11 Q.

This list of prohibited compounds that 12 are in your contention, did you mean to contend 13 that these are also prohibited from use in q

w 14 cleaning compounds?

15 A.

I believe they are prohibited from use 16 in cleaning compounds.

e, 17 Q.

Are you familiar with reg. guide 1.377 N

m

,3 13 A.

No, I'm not familiar with reg, guide m

19 1.37.

%l 20 Q.

Then, where did you derive your 21 contention on what should or should not be used 22 in the composition of cleaning compounds?

23 A.

From reg. guide 1.54.

.m

  • b 24 Q.

Does reg. guide 1.54 have anything to do 25 with cleaning compounds?

273

aaa M1 a

1 A.

It has to do about protective coatings.

st 2

Q.

Then it doesn't have a n y t h '. n g to do with 0

m 1

3 cleaning co mpo u nd s?

4 A.

1.54 is about protective coatings.

I I

l w

l 5

don't see anything here about t

n 6

Q.

Is the, basis for your contention as 7

regards cleaning compounds, the same as the basis m

1 i

si 3

of your contention as regards coatings, which is

]

9 the supposed exception GE has made to that reg.

i 10 guide?

1 p

o l

11 A.

Reg. guide 1.54 does apply to cleaning 12 materials as well as coatings in page, on the 13 back page, Section C,

Part Four.. Coatings and

<=

b 14 cleaning materials used with stainless steel

+

c 15 should not be compounded from or treated with i

m 16 chemical compounds containing elements that that

)

m l

17 could contribute to corrosion, intergranular

'+

l,1 13 cracking or stress corrosion cracking.

And'it

  • t 19 lists a series of elements.

l 20 Q.

Are those the same elements you've

.e L,

21 listed in your contention?

.m 22 A.

Yes.

v.L i 23 Q.

So, is it correct that the sole basis e

C 24 for your contention as it concerns cleaning and

+

25 coating compounds is the supposed exception 1

274

,$l Isrsanartosat cauar azeaarsas, ruc.

,,o 1

General Electric took to reg. guide 1.547 a

2 A.

Yes, and that was stated in the earlier I

3 reference that I gave you, i

4 MR.

NEWMAN:

If it were to be s

5 established that none of the compounds identified i

?

6 in your contention 43 are used to clean or coat 7

stainless steel components at Allens Creek, would t

f

)

8 that then moot your contention?

i 9

A.

Well, the contention lists some elements J

10 and some, I've forgotten the term for that, some

}

11

salts, I guess, but Mr. ti e w = a n, if those were i

12 removed, yes, that would remove the basis.

e

)

13 Q.

(BY MR.

BIDDLE):

Would you turn to your 1

14 contention 44?

15 A.

Incidentally, I'm not an expert on

)

n 16 cleaning compounds.

447 1

17 Q.

Yes.

What is water hammer?

l),

la A.

My understanding of it is that it's a l]

19 force that emerges when steam condenses in piping lJ l

20 that normally carries steam and then in some way l'

I 21 is moved.

In other words, water sitting in a 22 pipe and the pipe is meant to carry steam and it I

'.\\

23 can move as water in the event tne system starts i

24 operating, that pipe starts in use.

s 25 If the pipe were sitting idle, for t

27I5 I

1 J

INTERNATIONAL COURT REPORTERS, INC.

,

Retrieved from "https://kanterella.com/w/index.php?title=ML20062H589&oldid=4453632"