ML20062H617
Text
_
O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1
In the Matter of S
S HOUSTON LIGHTING & POWER S
COMPANY Docket No. 50-466 S
(Allens Creek Nuclear S
Generating 3tation, Unit S
Mo. 1)
S Material Facts As To Which There Is No Genuine Issue To Be Heard (1)
Flow-induced vibration of reactor components including jet pumps, spargers, fuel pins, fuel rods, in-core instrumenta-tion and low range pc'..ar monitors (LPRM's) has been studied extensively by General Electric.
Information from the vibration tests and analyses and from experience at other plants has been used to improve the ACNGS design.
(Affidavit, p.
2)
For example, vibration of LPRM tubes at the Duane Arnold aad Cooper nuclear plants were traced to bypass flow holes in the design of those plants.
Bypass flow holes have been eliminated in the design of ACMGS.
(Affidavit, pp. 6-7)
Other design improve-ments of components will make them less likely to be damaged as a result of flow-induced vibration.
(Affidavit, p.
7)
(2)
The potential for vibration of ACNGS reactor internals will be further specifically assessed and remedied, if necessary, through the following sets of analyses and tests:
- a.. t.. 'g90284 358
(a)
A dynamic system analysis.
This analysis, described in 5 3.9.1.3 of GESSAR 233, analyzed flow induced vibration during normal operations, and is used in designing and testing of components, and for establishing cre-ocerational testing criteria.
(Af fidavit, p.
2)
(b)
Flow tests, forced oscillation tests, and othe-physical tests of reactor internal components.
These tests are used to verify design and are independent of the NRC testing requirements.
(Affidavit, pp. 3-4)
(c)
Prototype plant pre-operational and operational tests.
Extensive vibration testing on the prototype plant (now designated Perry Unit 1) in accordance with Regulatory Guide 1.20 will be made to detect evidence of undesirable effects due to flow-induced vit.ation.
(Affidavit, p.
4)
(d)
Pre-operational testing at ACNGS.
Testing of reactor internals of ACNGS in accordance with the provi-sions of Regulatory Guide 1.20.
(Affidavit, p.
5)
(3)
The vibration testing requiremant of Regulatory Guide 1.20 for prototype 238 BWR-6 plants is expected to occur prior to operation of ACNGS.
If another plant is the prototype plant, ACNGS will show compliance with Regulatory Guide 1.20 through pre-operaticnal, non-prototype confirmatcry tests.
(Affidavit, p.
5)
(4)
In the past, monitoring of reactor performance instrumentation has revealed vibration problems long before they are of concern. 359
(Affidavit, p.
6)
(5)
ACNGS will have a loose parts monitoring system to detect any loose parts in the reactor.
(Affidavit, p. 7)
(6)
In the past, neither a loss of plant safety nor the inability to safely shut down the plant has ever occurred be-cause of flow-induced vibration.
(Affidavit, p.
7) b !:
360
Doherty Contention No. 31/
PAID BY PLF. OEF.
Flow-Induced Vibration
(
of LPRM's 3
E I
~
1 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ( N RC)
BEFORE THE ATOMIC SAFETY & LICENSING BOARD i'
d IN THE MATTER OF HOUSTON LIGHTING & POWER COMP ANY DOCKET No. 50-466 (ALLENS CREEK NUCLEAR GENE RATING
=
STATION UNIT 1) t i
U DEPOSITION OF:
JOHN F.
DOHE RTY 5
3 3
1 e
Nes
[
w:4, wat
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s 3'
1917 Bank of :ne Southwes: Build:ng. Houston, Texas 77002 *(713) 552 5311
80 1
Q Are there any?
]
2 A
I am not certain.
3 Q
Have you retained any expert witness,or expert j
.4 consultation?
y
+
ll 5
A No.
i 6
Q Do you hold yourself out as an expert _in 7
design or installation of diesel. gen _e.ra' tors?
8 A
No.
ii 9
Q And the same answer would then hold..for the i
10 componenes of the diesel generator. system?
11 A
That's right.
12 Q
Okay.
John, I would like to now turn to your 13 contention No. 31 on flow induced vibration 14 of the LPRM's.
15 Now, would you explain _to. me wha t 16 your understanding is as to the design, function 17 of the LP RM ' s ?
18 A
It gives information as to the power being given 19 out at a certain location in the reactor core.
20 Q
How does it acquire this information?.
t 21 A
I believe it monitors or gives the amount of 22 radiation being emitted at that point._
23 Q
The amount of radiation being emitted at that 24 point?
25 A
Weli, at that locale.
i' 362
81 1
Q What's the relationship be tween the radiation 2
being emitted and the power level?...____
3 A
The more radia;..n the more power.
4 0
Is it a direct linear function?
5 A
As far as I know, yes.
that it 6
Q What radiation are you talking about_,
7 measures?
Does it measure the whole spectrum 8
of radiation inside the reactor core?
9 A
It may only measure one product or one,_-- yes, 10 but one would probably be enough.
one isotope 11 or one neutron.
+
12 O
What do you mean by one product?
f 13 A
Well,.one -- let's say one neutron. I'll be 14 more clear.
I think it measures neutron emissio n.
15 0
Now, you think it measures neutron emissions?
16 A
Yes..
17 0
How?
18 A
You got me.
I don't know yet.
19 0
What is the instrument itself?
20 A
What is the instrument itself?
the instru-21 Q
Yes.
You have any understanding of _,
t 22 ment or is it to you just a black box?
For 7
23 example, what's its shape?
J l
24 A
I don't know its shape.
I 25 Q
What's its sire?
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g-
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82 A
It would have to be fairly small in order to 2
l fit into the fuel bundles or fit between the fuel bundles.
I'm a e sure of its _yact e
3 location.
a i
5 Q
Y u d n't know where it's located?
it's 6
A Not with certainty, no.
Apparently, __
located ar the intersection of four fuel 7
g bundles.
S.
9 0
What do you mean apparently?
10 A
Fr m this drawing here that I did.
11 Q Y u did this drawing?
12 A
No.
I put some -- I placed some drawings on that drawing and that's where I though t it to 13 be.
14 15 0
Y u placed marks on the drawing and that 16 revealed --
1 i
17 A
Yes.
The blue marks a e mine.
13 Q
Do I understand you to say that you placed marks on this drawing and that revealed to you 19 20 the placement of the L?RM's?
21 A
That sounds very mystical.
At that time, I i i I
22 thought that's where they were and I put them in to remind mYSelf of them-23 24 o
You don't know where you got the inspiration 25 for~ making these marks?
I i:
364
83 1
A Not at the moment, no.
1 2
Q So is it f air to say that you re' ally don ' t have an idea about the location of the L3RM?
3 4
A No.
It's unfair.
I have some idea.
1 1
5 Q
okay.
Whe re did you get this idea from?
6 A
Apparently from reading the PSAR.
Do you know which PSAR section you read?
7 Q
g A
No, I don't remember that.
g Q
Well, let's go back to your impression _.
What is vour impression of its location?. _._
10 in a 11 A
That it would be at the intersection, _,
12 sense, of four fuel bundles, but it wouldn' t
),
13 be at an intersection where a control red 14 ra31s.
4
- 1. 2 0
Would vou describe the nature or si:,e_or shape 16 of the geometric configuration of this, inner s.
17 section where the four fuel bundles would be?
13 A
If you imagine four bcxes looking d,own on them,'
I' 19 each equally apart from each other, that would t
t
~
l 20 be it.
21 Q
Four boxes -- you mean four square be:ges?
Is 22 a reactor composed of little boxes? _
i 23 A
The fuel bundles are square when looked at it 1
24 from above, yes.
25 Q
What' do they look like when you look,at them 365
=
84 1
from a cross section?
J 2
A If you take a look at 3
Q If y u' re 1 king at the reactor core in 'a 4
cross section, what geometry is the n _r,cVe ale d?
A If you look at the reactor core?
In.. _a__.c. ro s s 6
section?
7 Q
Yes.
And in a longitudinal cross sectjon.
1 3
A All right.
That means up and down to me.
]
!'i 9
Q It does to me, too.
10 A
Then you would see, depending on where,you put i
11 your cut --
12 Q
Let's put the cut near an LPRM, since it would 13 help this discussion.
14 A
Then you would see the fuel bundles.,__
4 13 Q
What's the geometry of that?
16 A
That's enclosed by a fairly light metallic 17 sheet.
18 Q
All right.
So if you look at the core,in this 19 cross section, all you see is little. cylinders; 20 correct?
21 A
No.
22 Q
What else?
23 A
You don't see any cylinders.
If you follow this 24 out, it would look like a row, I guess.
It 23 would almost look like a fence.
It would have a i~
3/.;.6
85 1
fence post kind of look about it, except it 2
would be twelve feet in height and'hard to see 3
in detail unless you could stand back.
Between 4
each, you would see a small space.
3 0
And this small space is useful for inserting l
1' 6
the LPRM's?
7 A'
No.
Not every one.
8 Q
How many LPRM's are there?
t 9
A I believe there are f o r ty-eigh t.
10 0
Did you get this impression as to the number of 11 LPRM's from the same inspiration that led you t
12 to the marks on the diagram?
r a
13 A
No.
I don't think so, no.
la Q
Do you have a particular reference as to th a t c
+
15 piece of in f orma tion ?
16 A
Yes.
Page 7.6-27 of the PSAR.
as to the number, 17 Q
That gives you information 18 supposedly?
It gives you no information as i
J i
19 to the shape, size or structure or geonetry 20 of th e LP RM ' s ; correct?
21 A
Of what the LPRM itself looks like?
22 Q
Yes.
23 A
That page does give some description.
i 24 Q
What is your understanding of the shape, size 25 and 'geome try of the LP RM?
367 4
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86
_,ormation f
1 A
Describe shape and size from geomet5y 2
for me.
3 Q
If you prefer that they not be distinguished, 4
4 I'll ask just for the gecmetry.
5 A
They have to be small enough to fit in the 6
spaces.
7 Q
All right.
~
8 A
I don't know their length, but I would have 9
some idea of their other dimensions.
10 Q
Your only familiarity with their act3a,1 physical 11 appearance is that th,ey must be small; is that 12 the sum total of it?
13 A
They must be small at least on two dimensions.
14 Q
Is th at the sum total of your f amiliar_ity with 15 them?
16 A
I have never seen one, so I think s_e...
17 Q
Your contention has to do with the vibration 13 of these particular mechanisms.
Now, if you 19 have no familiarity with their physic,al con-20 figuration, what leads you to the conclusion 21 that they are susceptible to any vibration?
_ testimony there was 22 A
There have been several 23 in regard to vibration of the fuel. bundle 24 channels given by some engineer from _GZ in 25 February -- Tebruary 25th, 1976.
O W
t..
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87 I
1 Q
That was vibration of what?
i 2
A Of the channels as I understand it.
3 0
What are the channels ?-
4 A
Well, the channels include the sheeting around 3
each fuel bundle and, as far as I k_n o w, that 6
would be the significant material that would 7
strike an L?RM and cause any danger.__.
8 MR. NEWMAN :
Dces that testimony 9
have anything to do with the LP RM ' s,..th e 10 degradation of those L?RM's' 11 THE WITNESS:
Yes.
12 MR. NEWMAN:
What's the..date and f.
13 reference in which that testimony was given?
l 14 THE WITNESS :
The date_if 15 Pebruary 25, 1976.
16 MR. NEWMAN:
And the case?
17 TEE WITNESS:
It was testimony at 18 the U.S.
Senate.
t 19 MR. NEWMAN:
Thank you...
s 20 Q
(3y Mr. siddle) So the basis of your-. contention 21 rests solely on this testimony given_before the L~
22 Senate; correct?
s.
23 A
As far as I know, yes.
I don't have.any other 24 basis for it.
~
25 Q
All right.
G W
h_
369
. -. =.
t 88 MR. NEWMAN:
And
.t's your con-1 1
tention that that testimony deals with the 1
2 f l " - i n d "__C
- d d*9 *d^ti "
f LPRM'S C2*
3 4
vibrations; correct?
1 THE WITNESS:
Yes.
1 5
a.
MR. NEWMAN:
Chank you.
6 Q
( 3 v. Mr. Biddle) Can v.ou tell me -what the role g
of the LPRM is in preventing accidents?
4 9
A The LPRM senses deformities or whatever problems i
10 in fuel areas.
11 Q
Eow does it do that?
12 A
It picks up increased powering in a local area 1
such that an operator can react and essentially j
13 14 control that area of the core without having 15 to stop the whole contraption.
16 Q
As I understand your answer, you say that it's used for operator information.
I believe my 17 13 question was :
What role does it have in pre-19 venting accidents?
local 20 A
Unless there was some way of sensing a, t
21 area problem, the local area problem might i
4 22 simply spread so that if -- if it can be detected early and in a particular place, an 23 24 accident does not develop.
25 Q
But it centributes only to the operator
~
379
89 1
information; correct?
2 A
I think it may actually be c ap ab le. o "_..s c raming 4
I 3
the system.
i 4
Q But you're not sure?
L 5
A At the moment, I'm not sure that.that alone would 6
do it.
7 Q
If the LPRM fails, does that mean that you have i
,g removed the capacity to scram the r e.a c to r ?
9 A
No.
It means you remove the capacity _to get 10 the information in that locale.
does the. operator 1.,
Q If it fails, do you have 12 have indicated to him the fact that he has 13 lost that capacity?
14 A
I believe, yes.
15 Q
And then you -- can you indicate to_me.all the i
16 ins tances you know of where LPRM's have failed 17 and that's led to accident situations?_
13 A
No.
19 Q
You knew of no LPRM failures?
20 A
No.
~
21 Q
You know of any LPRM failures by any_cause or 22 for any reason?
23 A
I believe there have been some due to.ficw-24 induced vibration.
~
25 Q
What makes you believe that?
FC 371
90 J-1 A
The testimony by the GE engineers to
..a t
- ff*CD*
2 o
D y u know for a fact that the GE engineers 3
tes tified that flow-induced vibration has 4
C^"88d LPRM f^il" *?
5 6
A Not for a fact, no.
I am pretty certain it
~
7 h88' th "9h-g Q
Do you know of any other facts which led you to conclude that the LPRM's have failed because g
t
~
of flow-induced vibration other than by testi-
~
10 9
11 many by the GE engineers?
j 12 A
I'm sorry.
I was checking to see if I answered
'f i
t the first question correctly.
j' 13 e
t 14 0
All right.
3 1
MR. BIDDLE:
Would you read back I i 15 36 the question?
i
. - ~
17 (Whereupon the requested testimony 13 was read back by the court reporter.1 19 m.
20 L
2.,
A The answer is no.
Not at this time, no.
22 O
But if you discover any through sarendipity,
23 you will inform us?
24 A
I will inform you if I discover another situa-25 tion where flow-induced vibration --
k, I,_
ik
91 1
Q It's because of an LPRM failure?
2 A
Right.
3 0
DoeS the LP R" have any role in sitigating the 4
consequence of accidents?
s 5
A sy that question do you mean the accid.ent 6
has already happened?
3 e
1 7
0 Yes, sir-i C
A other than its information, whatever information 9
it would make available, I don' t think..so.
i of questions may seem..a bit 10 0
And my next set i
11 repetitive, but I want to clarify.som.ething.
12 Now, would you tell me what flow-i
?
13 induced vibration is?
l 14 A
The flowing material is the coolant..
It's 15 pushed with a great deal of force with.this kind of a motion (indicating).
It's pretty 16 17 much in's and out's.
~
13 0
would you describe that motion for.the record?
19 A
That would be caused by the pushing of that 20 material, that water, against fuel rod channels 21 in such a way that they start to shake.in some 22 fairly small way.
23 Q
Are you saying that the vibration is caused by i
24 the direct impingement on the water of the L.
P
~
25 reactor?
h.~. 373 w,
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92 1
A The word impingement sounds like a more direct i
2 word, but the movement of the water past these i
in te rnals.
3 4
Q And it's just the movement of the wage _ along the surfaces of the reactor internals _which j
-)
6 causes the vibration?
7 A.
As I want the contention to go, other_ things 8
such as seismic activities, seismic events or 9
vibrating external things would not be. included 10 in th is.
's j
11 Q I understand.
I' m trying to understand the 12 source of vibratory motion you're conc.erned I
i 13 with.
Am I correct that this source is the I
14 flow of the water along the externals,., along 15 the external surfaces of the reactor _ component t
16 internals?
17 A Well, on the outside and through the bundles, 18 too.
19 Q All right.
But it's just the parallel. flow u
20 that sets them vibrating; is that correct?
21 A No.
It's not entirely.true.
It's all flows 22 within that, g-23 Q All right.
['
24 A
Not all flows are parallel.
There would be 25 some hitting.
It's not all in one direction.
~
I< ~
3?4
93 f
1 Q
Is there eddying and hitting, which _I_ call 2
impringement, on the LPRM's?
j 3
A There would be some, I believe.
4 Q
How do you know that?
3 A
I believe that the shape of the LPRM is not j
6 such that it goes entirely out of the water in 7
the 8
0 Excuse me.
I thought you testified th,at you 1
9 have no idea of what the shape was.
10 A
When I get through thinking what you're asking, 11 I believe th at there was a toc and a bottom
{
within the reactor where the water wo.uld only l
12 u
l r
13 have parallel contact with the LP RM.
14 0
All right.
15 A
It would also be coming down on it._._Not a i
16 great amount, but some.
17 0
It is your belief that that is true?
t~
13 A
Yes.
19 0
Is it your belier because it happens to 20 coincide with your theory of what happens with 21 flow-induced vibration, or because..you have 22 some idea of its shape?
23 A
It's again sort of like a negative inference.
r 24 I think I would know if an LPRM were another 25 cylinder running the entire length of the fuel
~
ep a
m 9
we
94 1
bundle.
2 0
You think you would know that if it were true?
3 A
YSS-4 0
Why?
i 5
A secause I seen enough of these cross sections l
4 6
and never seen that.
4 1
7 Q
So it's your belief that it's not a cylinder i
8 running the en tire length?
t t
9 A
That's right.
And it does have relevance to 10 what I said earlier under oath.
i 11 Q
If it were a cylinder running the_, full _ length, 12 then it would not vibrate; c o r r e c t ?,,,, _
1 13 A
No.
It might vibrate.
14 0
What would cause tha*'
I le A
well, it might vibrate because the. reactor s
i 16 channels were vibrating.
In other wo.rds, it's I
l 17 an attached part so it would vibrate.
l 18 Q
It's attached to the reactor channels?,
i i
19 A
It's attached to the fuel channels.
20 MR. NEWMAN:
What's the, source of
,s'lr -
21 your information on the design of_the__LPRM's, 4.
I 22 sir?
23 THz WITN:ss:
The fact.,on the 24 design?
~
MR. NEWMAN:
What's the source of 25 376 "w e "P**W*
e m.
m mn a
t..
95 your information'concerning your testimony j
1 i
just now regarding the dimensions o#, {h e LPRM's?
2 THE WITNESS:
It's impossible to 3
,j{d so forth.
4 he specific about their appearance a
"ld 1 S C"117 h*VS i
I'V* **nti "*d "h*
- th*Y W 5
6 appeared in drawings if they were of such magni-
- tude, one of the things we discussed was that o
a if that had appeared, I feel certain, that I would have noticed.
g MR. NEWMAN:
So then you3, entire 10 11 line of argument is based on a supposition?
You don't have a reference to give t,,,u s ;
o 12 correct?
13 THE WITNESS:
That's correct.
14 MR. NEWMAN :
Y u d n't have a text 15 I
16 for us to look at?
THE WITNESS:
No, sir.
Not at this 17 18 time.
F MR. NEWXAN :
Okay.
j_
19 j
20 Q
(By Mr. Biddle) If you could, John,
_ ust once 21 more, just briefly describe for me,h_ow the f
22 flow sets the LP RM into motion.
23 A
Okay.
The flow -- it can do it in _two ways.
~'
24 To hit the monitor itself and cause it to 25
- vibrate, 3??
96 1
Q Does it do that?
2 A
I believe it does.
3 Q
All right.
sut you have no direct knowledge of 4
that; correct?
1 I
5 A
That's correct. And also hit the fuel channels 4
6 to which tne L?ax is attached.
3 7
Q If I might just interrupt you quickly there.
8 Where is it attached to the fuel chan{.al?
9 A
Several places.
10 0
Along the whole length of the LPRM?
11 A
P os sib ly.
I don ' t believe so, though.
12 Q
What is'ycur belief as to where it's attached?
13 A
W e l l,.:Mr relief is that it's not the full 14 length of the fuel channel.
My belie # is it's l'
15 attached -- I'm not certain where it's attached.
1 16 0
If it's not attached, then the vibration of your i
4 i
l 17 channel may be irrelevant to the vibration of f
I i
19 A
If HL&P introduces evidence that it's not l
20 attached then --
i l
21 Q
If HL&P indicates that they are not in contact 22 A
Not attached in some way --
23 O
Excuse me.
Let me finish.
Mechanical contact I
1 _
24 between the fuel channels and the L?R.} would s
l 25 introduce vib ra tions ; is that correct?
l i
l' 378
- * * * * ' * ~ ~ *
- = = -
e.
97 1
A Perhaps, through a spacer or a hole,,or something.
)
l 2
0 A spacer or a holder rigging the spacer and the i
r channel between the LPRM?
3 4
A Yes.
5 o
The presence of that spacer or holder. would be i
6 the path whereby vibration of the fu.el channel i
7 would be?
8 A
Yes.
g Q
All right.
MR. NEWMAN:
If that were not 10 11 true, then the contention would be es,sentially 12 moot?
THE WITNESS:
No, because of the 13 14 first part.
MR. NEWMAN :
All right.
13 16 Q
(By Mr. Biddle) Which is the impingement part I
l 17 of the flow hittin9; correct?
t i
13 A
Yes.
l 19 Q
Can you tell me how the LPRM signal is affected 20 by this vibration?
!'~
21 A
According to the GE engineer study, they make 1
I 22 it unreliable.
I don't know if it makes it i-l l
23 high or low.
24 Q
Would it make a difference?
25 A
It dould make a difference in the response to e
+
379 il'
- * * ' * * * * * ~
es enseashus e**
e*
w e.
m.
98 2
1 it.
1 2
Q.
Which would be worse?
3 A I would think if it were reading icw and it 4
was high that that would be the more dangerous i
5 of the two situations.
6 Q Are you contending that vibration will,in fact-i 7
cause an erroneous low reading?
8 A Yes.
9 o That is the basis of your contention on this signal portion?
10 11 A Yes.
_ hen there's 12 O So that if it causes a high signal, t
no portion for your contention there; correct?
13 14 A No, there is some, but I chink the more serious 4
15 problem is first.
16 Q What is the basis of your contention i,f it 17 causes the signal to read high?.
18 A If it were reading high, it would mean -- you 19 know, and believed and followed as an indicator, 20 it would mean, at least in the past,,, t would i
21 mean the closing down of certain areas of the 22 core.
I don't know -- I'll have to,visuali=e 23 a core like this.
There is a balancing that
~
24 apparently needs to be done.
In other words, 25 if one control rod is inserted down here
~
380
= - -
o 99 1
because of a problem, then the balance.over 2
here so there's the same amount of balance 4
3 all around.
I believe that if there.was 4
inadequate readings, readings being i-J gh when 3
5 they are actually low, the reactor is being led 6
the reactor crew is led into doing various i
i 7
acts that are needlessly moving theti. towa rd l
8 riskier consequences.
9 Q
How do they move you towards riskier.3.ypes of 10 things?
11 ' A They may decide to shut down, 12 Q
That poses a risk?
l 13 A
I think so.
14 Q
Why does shutting down cause a risk?__
15 A
It causes more reactions around the. reactors.
16 Q
What reactions are you talking about?--
shutting down.
Having to look 17 A
closing the 18 at whatever it is.
l__
19 Q
What risk is associated with the reactor shuttin
)i 20 down?
l 21 A
Doing reac. tor shut-down or start upr-that is.
(
I 22 O
We're not talking about stored up.
i 23 A
Well, you're going to have to start up af ter 24 you shut down.
f _.
25-Q All right.
Go ahead, then.
I 381 l
100 1
A Those are more critical rimes than general 2
operation.
3 Q
Why?
t 4
A Because that's when parts move that are normally 5
not moving.
I 6
0 What carts?
s s
7 A
B Q
control rods do not move during normal operation?
l f
9 A
Not that much.
p 10 0
What significance is the amount of traverse in 11 control rod movement?
Why does it pose more 12 of a risk depending on how far the traverse?
i r
13 A
It's like any thing e ls e.
The more operations 14 that you have to put something through, the i
4 15 more possibility there is of danger.
i 1
The basis of your contention is that _this can 16 0
17 lead to movement of reactor parts which will 18 wear them out?
19 A
Wear them out or fail, whatever you want to use.
i 4
20 Q
So that,-
~"
21 A
It's an unnecessary use.
22 Q
So that this contention leads to a further 23 contention the.t Allen's creek parts are not 24 designed with a sufficient useful life?
25 A
Th a t' s too broad.
.r -
1382 e.o, m
- wa
~.-
101 1
0 Wasn't that what you just told me aboup what 2
risks are associated with reactor start-up or Shut down?
3 4
A Things are kind of getting far afield here.
5 0
well, it's your contention, John, and I'm trying 6
to find out what you' re talking aboup.,
7 A-It's my belief that the unnecessary operation-8 of the reactor just naturally brings in more g
risk.
10 0
So if I put these pieces together, _ you contend, 11 based solely on testimony by the GE,,e,ngineers 12 before the Senate, that flow-induc.ed v,ibration will produce LPax failure, which will produce l
13 risk of unnecessary operation in the, reactor 14 a
13 clant?
16 A
Yes.
17 Q
Is that correct, sir?
And I will inform you of any other informa-18 A
Yes.
19 tion.
20 Q
All right.
Can you identify f or me any instance s 21 where signals from the LPRM have been affected 22 by a flow-induced vibration?
23 A
230 0 at the moment, no-24 Q
So you have none?
Oh 25 A
I think there are some in that te s tim,o ny.
7c. 383 D=
g,
102
~
1 Q
But outside that testimony, you have.yo impress-2 ion of there being any record of any such 3
facts?
4 A
I'm not certain.
j
]
5 Q
You know of none right now; correct?
6 A
At the moment I can't tell you any, no.
j i
you will inform us i"_you find
~
7 Q
Do you want 8
any; correct?
9 A
Right.
10 Q
What is the relevance of the radiation monitoring i
11 system listed in your contention?
12 A
.What is the relevance of it?
9r 13 Q Yes.
.I t appears to me that this radiation
(
14 monitoring system just appears in the midst i
of the contention.
It doesn't relate to 15 16 anything.
17 A I see.
This means that the LPRM's have some 18 inaccuracy and that's the list.
19 Q
Well, I understand the portion of the contention 20 that has to do with the LPRM's.
What is the 21 relevance between LPRM's and the radiation 22 monitoring sys tem --
23 Well, what is the radiation monitoring system?
24 A
The LPRM.
25 o
You 'are using radiation and LPan synonymously?
3Eh1
l 1
1 103 i
1 A
Yes.
4 e
.i 2
O There's no other radiation monitoring...sys tem 3
as farHas purposes of this contention _--
+
4 A
Yes.
For purposes of this contention,.yes.
j 5O All right.
You just decided to change the name?
l 6
A I was' kind of sloppy there, yes.
t:
i 7
Q What is the relevance of 5/4 percentierror i:
1 i
8 which you listed in your contention?--
i i
9 A
If that's to indicate -- that's to indicata --
l 10 it indicates the severity of any deviations r
4 11 caused by the flow-induced vibration that, in 4
4 12 fact, a difference may be 5.4 percent more l
t 1
13 than the error.
j l
i l'
14 Q
The difference between what is -- it may be t
I 15 more than 5.4 percent of the error?-. -
(
r I
16 A
Flow induced vibration -- if it has -caused an i
J 17 error in the reading, then that reading may, i
18 in addition, be 5.4 percent off, because of the 19 error th a t ' s involved in the normal operation i
l 20 of an LPRM.
1 i
21 Q
Why is that significant?
{~
22 A
That makes the error possibility greater.
l 23 0
aut then we ' re back into a discussion-again i
1 24 that we just went through as to whether or not f-i 23 it gives you an error on the high side or low i
385 r.,, -, -.,c.-.%
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104 i
side and that sort of thing; corregt?_
2 A
Yes.
3 Q
so you believe it to be just a reinforcement 4
of your argument on signal inaccura_cy_,and 5
that of itself has no re a l imp e r:an_c_e_;., correct?
i s
i 6
You want to take the error by flow-i.3duced i
7 vieration and add 5.4 percent; correct?
8 A
When I wrote the contention, I wanted to be --
1 I
g I was encouraging people to see that.the 10 error could be cumulative to the 5.4_ percent.
11 Q
What causes the 5.4 percent error?
12 A
I don't know.
13 Q
You have no idea whatsoever what introduced i
4 14 the 5.4 percent error?
15 A
No-At the moment I don't< no-16 Q
Are they the same sort of thing that introduced i
l 17 the error by flow-induced vibration?__
t l
l 13 A
I don't know for certain, i
)
19 0
What's your basis for asserting that these 20 in f act might be cumulative.
i 1
21 Q
If the error could be 5.4 p e rce n t. and_none of 22 the things that contribute to the.5.4. percent 23 are flow-induced vibrations, then this naximum 24 error could cecur.
s.
25 Q
The$e's a double if in there.
One has to 386
105 1
suppose that both of those if's have been true before that makes that statement correct, does
)
2 it not?
3 4
A Yes.
5 e
no you have any belief that either of those 6
if's may in f act be manifest?
7 A
'ere are no events where that has occurred to 5
8 anyone's knowledge.
9 Q
Not even in the testimony by GE engir.eers?
f 10 A
I. don't think the GE engineers talk about this t
11 error.
,2 Q
You just introduced that yourself?
4 13 A
Yes.
p i
a 14 0
Withou t any factual basis?
4 i.
15 A
Yes.
16 Q
All right.
17 A
That's in your PSAR report.
18 0
You're not certain?
19 A
It's in there.
20 0
But you're certain it's in the PSAR jtnd it 21 says that LPRM's when operating narmally are 22 within 5. 4 percent?
23 A
I think that they were meaning that the LPRM 24 gives a rough figure and that's the roughness 25 of Ehe figure.
9 387
106 1
Q So the LPRM's-are normally not in error by any i.
2 amount greater than 5.4 percent; is t. hat 3
correct?
4 A
That seems to be what that indicated.-
I believe t
5 that's correct.
i 6
Q If the LPRM's are in error by 5.4 percent, what'.;
3 3
7 the significance of it?
8 A
It simply means that they are operati.g just 9
out of design in some way.
It coul'd meaa 10 anything.
11 0
or i.e could mean nothing; correct?
You have 12 no way of knowing?
13 A
I don'.t know of the testing history or where r
J 14 they arrived at that figure,-but if it's any 15 kind of probability basing, it probably would 1
16 mean that that's some very small amount of 17 time that they would be --
13 Q
Excuse me.
You have any basis for that'if?.
19 A
No.
I 20 Q
Is it your understanding that the LPR{1--
1 1
21 have forgotten what you told me.
There was 1 s
.I
-I 22 a 20 to 40 in number?
I 23 A
No.
There are forty-eight.
i 24 Q
All right.
Forty-eight in number.
Do they 25 al1 fail together in the same method?
~
e A **
j 388 i
~.. _
k.
107 1
A Oc they all fail toget'her in the s ame __me thod?
2 Q
Yes.
If one fails, do they all fail?
3 A
No.
4 0
Can you tell me if anything signifiqan.t occurs 5
LE one falls?
6 A
If any significance occurs if one fails?
i 7
Q Yes, and you have forty-seven remain.ing.
8 A
We're back to the information about_ locale.
The 9
other forty-seven can't tell you tha.t._
10 0
What's the significance of losing information?
11 A
You lose -- you lose one of your safety factors 12 and one of the things would tell you._.- it would.tell you if there's a local overpower.
13 14 You also lose the ability to know if there's a 15 local overpower.
If you lose an L?an_for some 16 reason, that is.
17 Q
Are you contending that the possibility of a 4
18 local overpower can go undetected by._the failure 19 of one L?RM?
20 A
Yes.
21 Q
How is that?
22 A
Well, you say could go undetected?
4 23 0
Yes.
24 A
Ch, it might pick up a disturbance at.that part h
25 it would pick it up later and not be as sensitire y
ONUS
108 g
4 good 1
to it and essentially would not be,
2 information.
j 3
o Is it your contention that when an LPRM f ails,
d 4
it fails totally and renders no information?
5 A
It can.
6 Q
All right.
d 7
A It may not necessarily.
It might be better if 8
it did, that way, you'd know.
If you were 9
running at 80 percent and it said 80 percent i
t 10 and dropped to zero, you would know what 11 happened.
12 MR. NEWMAN:
What's the basis of
~
i I
~
your statement with regard to the degradation 13 1
i 14 that you just described of the LPRM's?
-Is s
i 15 that based on data?
16 THE V TNEJG:
I guess you're going 17 to have to be a little clearer.
q s
18 MR. NEWMAN:
You just described j
3 19 various failures, modes of the LPRM's,,_ and you 1
20 described how they can degrade and what the 21 significance is of degradation of various levels 22 and I'm asking yotJ what the basis is for your s
. tha mode'of degradation 23 information concerning r
b 24 and the failure of the LPRM'at each s.tep of the 25 degrading mode just as you described it.
I
~"
)
~
e
'e, 390 u
S-,
109 j
1 want to know what the basis of your,last state-2 ment was.
THE WITNESS:
I know that they 3
4 function to communicate local information in the 3
reactor core.
4 i
no basis 6
MR. NEWMAN:
But you have,
i for saying whether an LPaM can be partially i
7 8
degraded or whether as partially degraded it i
9 can still serve some useful function.
10 THE WITNESS:
If -- I supcose it t.
f 11 might be possible that someone would. learn --
12 a particular power monitor in a reactop core 13 might.also run 20 percent off --
14 MR. NEWMAN:
You're mi_ssing my t
i 15 point.
What I'm trying to get at is the basis b e f _ r e_.
You've 16 for the statement th at you made o
17 described a failure mode.
You've descpibed the l
i 13 characteristics of the LPaM failures.
I want 19 to know if that's based upon your own _observa-20 tion, a reference to which you can refer us or 21 an individual who might have told you,_about 22 that or is this a matter that's develo_ ped out 23 of your own supposition?
24 THE WITNESS:
It's just a matter 25 that's probably developed out of some reading 3-391
110 1
which I don' t know at this point whe.re; MR. NEWMAN:
You've. read _about that 2
3 subj ect matter?
4 THE WITNESS:
Yes.
MR. NEWMAN:
Can.vou.. o_r_o_mo tiv m
-2 6
furnish us a reference to the material-that 7
you've read so that we can have some, help in 8
preparing our case?
THE WITNESS:
Yes.
Let me see.
9 10 What you want here is 11
~
MR. NEWMAN:
I want the..re f erence.
12 THE WITNESS: Something.that says MR. NEWMAN:
That describes the 13 14 f ailure mode of the LPRM's due to flow-induced 15 vibration.
16 THE WITNESS:
Whoa.
W h o a..
My 17 understanding was that you wanted some. thing 13 that would -- I made the statement that they 19 might not fail totally.
20 MR. NEWMAN:
Correct..
21 THE WITNESS:
And that's what 22 you're concerned about?
23 MR. NEWMAN:
Right.
I wanu to 24 know the basis of your statement as to the 25 fai1ure mode and the impact that the failure
~
O W
392
t 111 1
mode has and the information on which.the LPRM 2
is designed.
THE WITNESS:
Okay.
3 4
Q (By Mr. Biddle) Have you read the PSA_R section 1
on flow-induced vibration?
-2 6
A I'm not certain.
t 7
Q You don' t know whether you have or h.av_e not?
8 A
I don't know.
9 Q
Then you do not know whether or not they make 10 any reference in there as to flow-induced e
_ 11 vibration and LPRM's?
i 12 A
That' s 'righ t.
I'm almost certain I haven' t flow-induced vibration in j
13 read anything about 14 the PS AR.
13 Q
All right.
16 A
It seems that I haven't.
17 o
You hold-yourself out as an expert in._this area?
13 A
No, not now.
19 0
Do you intend to become an expert between now 20 and the time of the hearing?
I 21 A
Yes.
22 O
How are you going to establish your expertise?
23 A
Just a little strategy that I'll hava_to work 24 up.
l 25 Q
Does that include reading the PSAR section on
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..-_,,-.,m,-,,---n,
, - _. - - - _,,..... ~ -
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112 1
flow-induced vibrations?
2 A
I'll attempt to do that.
I certain1y should.
3 If you assure =e there is, I will.
4 Q
All right.
5 A
I'd appreciate a refe'rence to that if you have q
d 6
one handy.
It does save searching.
j 1
7 Q-We ll, we ' ll take that up after the deposition.
I a
i 3
All right.
John, let's_{ urn to 1
9 your contentien number forty-one on water 10 level indicators, if you would.
Would you i
11 describe for me the water level indicator system 12 at 3-Mile Island?
}
13 A
At 3-Mile Island -- you know the date that I 14 sent in th a t?
It's really hard for me to fin d 15 it-16 0
It's marked as 8-10-79.
17 A
okay.
13 MR. COPELAND:
Do you want to 19 borrow mine?
20 THE WITNESS:
Yes.
I guess I 21 should.
22 0
(By Mr. Biddle) Do you have the latest question 23 in mind?
24 A
Yes.
25 No, I can't describe that right now.
394
t'
....c COST $
PAID BY PLF. OEF.
(
TexPirg Contention No. 11/
Flow-Induced Vibration 3
i 1
i i
I i
UNITED STATES NUCLEAR
)
3EFORE THE ATOMIC SAFETY REGULATORY COMIIISSIO!i
)
)
AND LICENSING BOARD IN THE MATTER OF:
)
)
NO. 50-466 HOUSTON LIGHTING AND
)
POWER CO!!PANY (ALLEN'S
)
CREEK NUCLEAR GENERATING
)
STATION, UNIT 1)
)
l
~.
i DEPOSITION OF:
CLARENCE JOHNSOT
\\/ O kU rn S ~.1.
t i
i
(
-)
afewatav aes k.'
eee mu 1917 Bank of the Southwest Building. Houston, Texas 77CO2. (713) 652 5311 j
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.t Well, a n v. witness, as soon as ue. retain 3
them, ue'll let You k n o *-' -
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P 14 the flow cf that water can cause the 15 components to vibrate and so you might lo have some fatigue of the cc=ponents, 17 and a pcssibility of damage.
o, o " ' e... ' ". * ". c a..
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A Well, the failure of the feed water e,4-o--->>g
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t
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testimony before the Joint Comrittee on
,s y
j e'
Atomic Enere.v., this could well have been i
I 1
ficw-induced vibration, even 1
due to i
~_.
o i
3 though I don't know for a fact that that's the reason thev. occurred.
-y
'O n.
You do not?
l 11 i
I do not.
l 3,
o,.
t.1. %.. 2 +- 4 *a a s O. a '- C. c _ ~.#
j It's my understandine. it's a
- r. u n o..
i
'. 3 A.
1_ t Q.
What ha00. ens when it fails?
ia 15 A.
The water flow is altered.
I'm not
, e' certain of the full ramifications and consequences.
'3 n..
Do vou know what han.n. ens when the s n. a r c. e r l
failed at these plants that you rensioned?
l __.
19
.. o.
0 A.
.4 4
21 0
Do you '.new if they toch any design steps l
22 to solve the problem?
l t
...y
. w... u
..e.
f
- 3..
_Ae..e.
- 3.,3 24 Q.
Oc you kne'.' what kind of I.N.... P lants
.,p._- n_,. f '.,. e. e ~. '. e
. e k i n,... e c - o - e d.>
i.
. w..o. 3 e t
6 h
7-Ob7
?
125 1
A What kind of 3.w.a.
plants?
3 2
G Were they 3.M.R.'s?
3 A
I don't thinP so, because there aren't
_ h 4
any 3.M.R.'s operating, as far as I know.
5 G
Do vou knew what they determined to be h
6 the cause of the flow-induced vibration 7
in these plants?
o 3
A.
Mc, I do not.
0 o,
G And v.cu don't knew what stens were taken 10 to eliminate the nroblem?
7 11 A.
Mo, I do not.
12 G
Mell, how could you possibly contend, 13 then, that it's a problem with respect l
14 to the design of the Allen's Creek plant?
15 A
Uell, it was our feeling that it should
}
16 he brought up in the licensing process, 17 and that we had brcught forth sufficient 18 evidence with sparger failures to at 19 least require the' applicant to respond
}
20 to the contention so that it can be 21 better evaluated.
22 G
Mhat if I told you it wasn't a proble.m?
)
23
?_
Mell, I would 24 G
h a t would you want te know?
2:
a.
I'd ant to P.new wh./
- v. o u s a v.
it's not a 1
4 4
t-
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Oc V.ou denV. that it '.' a s sClVOd en thO
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5 6
G You don't have anf idea, de vou?
1 A.
'J o, I don't.
l I
1
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f.5%. 1 e 3
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1 I don't know.
1 o,
i n.
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ua' 0.3 ". '.
o a
so-
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both of those are cc:".ponents
- .r i th i n 12 i
13 a reacter.
I don't knew.
a #ual o i..
- a 4 1 s '.
3.
- n..
. 5 %.. a
- w. a
,_.. a 13 A
I don't know.
16 2
Did it fail on one of these five plants?
17 A.
As far as I know, no.
, o-n.
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" ave you ever seen one, do yCu have any idea?
I 5
e O'
A.
!! c, I have never seen one.
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DC you knCW Where the je". pun?S ar3 J
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in don't kncu what any of these things look 1
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theY have a how can Ycu contend that f _ __
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y evidence that flow-induced 1
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other components may be 9
a different life-They cculd have
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, 4, Do you contend chat the jet pump is going
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a 16 to vibrate in this plant, based on e
i design of'the plant?
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The contention is that there is inadequate-i._
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I can't state that assurance on that.
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1 it yacr contention that flow-induced 2
vibration is going to occur in this plant i
because of its desion?
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Are you, a
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