ML20062H641

Motion for Summary Disposition of Tx Pirg Contention 38 Re Use of Float Type Switches in Scram Discharge Vol Tank. Facility Will Use Differential Pressure Level Transmitter Sys to Eliminate Float Sinking.Pp 468-469

ML20062H641
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: ML19331C558 ML20062H463 ML20062H470 ML20062H473 ML20062H479 ML20062H485 ML20062H489 ML20062H504 ML20062H514 ML20062H526 ML20062H534 ML20062H539 ML20062H543 ML20062H547 ML20062H549 ML20062H556 ML20062H558 ML20062H561 ML20062H565 ML20062H570 ML20062H572 ML20062H576 ML20062H580 ML20062H583 ML20062H586 ML20062H589 ML20062H593 ML20062H597 ML20062H602 ML20062H605 ML20062H609 ML20062H614 ML20062H617 ML20062H620 ML20062H625 ML20062H630 ML20062H638 ML20062H641 ML20062H645 ML20062H651 ML20062H656 ML20062H658 ML20062H662 ML20062H665
References
ISSUANCES-CP, NUDOCS 8008190311
Download: ML20062H641 (2)

Text

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nV UNITED STATES OF AMERICA NRLEAR 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 f

APPLICANT 'S MOTION FOR SUICIARY DISPOSITION CN INTERVENOR TEXPIRG'S CONTENTION NO. 33 Applicant moves the Board under 10 CFR S 2.749 to grant summary disposition with respect to Intervenor TexPirg's l

Contention No. 38 relating to use of float type switches in the SCRAM discharge volume tank.

As shown in the accompanying i

statement of material facts as to which there is no genuine i

issue to be heard, and affidavit of James D. Heidt, there

}

is no issue to try in this proceeding and Applicant is entitled under S 2.749 to have the contention summarily dismissed as a matter of law.

The Contention TexPirg's Contention No. 38 states:

Petitioner contends the ACNGS control rod drive system is a hazard to public (and its members) safety because General Electric designed control rod systems have had defective float switches which failed to 468 8008190311 t

function in their SCRAM discharge volume tanks (SDVT).

These switches activate the outflow of these tanks.

If they fail to float, the SDVT will not empty.

In the event of SCRAM, while the SDVT is filled with water, water from the hydraulic CRD system cannot escape and permit the control rod to be driven into the core as designed, because the rod's progress is slowed.

From 1972 to 1974 this failure was noted at Hatch I, Peach Sottom III, Duane Arnold Energy Center and Fermi 2.

Argument Intervenor Tex?irg alleges that ACNGS will use i

defective float switches in the SCRAM Discharge Instrument Volume (SDIV) which will cause the SDIV not to drain, thereby causing the control rod drive system not to function properly.

i Contrary to Intervenor's assertion'in this contention, ACNGS will not use the type of float switches referred to by r

Intervenor.

Instead of a float type level switch, ACMGS will use a differential pressure level transmitter system to transmit i

~

information on water level in the SDIV.

This system will eliminate the problem which Intervenor raises, namely, float

(

t sinking.

Since there is no genuine issue of material fact to be litigated on this issue, Applicant is entitled to su= mary disposition as a matter of law. -

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