ML20062H645
Text
O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD J
In the Matter of S
S HOUSTON LIGHTING & POWER 3
COMPANY S
Docket No. 50-466 S
(Allens Creek Nuclear S
4 Generating Station, Unit S
\\
No. 1)
S a
I l
Statement of Mate-rial Facts As To Which There Is No Genuine Issue To Be Heard (1)
The SCRAM discharge instrumant volume (SDIV) is designed to receive the water displaced above a pisten connected to the control rod at the time of a SCRAM.
The venting of this water to the SDIV allows the rapid insertion of the t
If the SDIV is not drained at the time of a SCRAM, the control rods cannot be fully inserted.
(Af fidavit,
pp. 1-2)
(2).
Problems were encountered in designs which used a float-type switch to indicate that the SDIV was drained.
Incidents occurred where the float-type switch would sink indicating that the SDIV was drained when in fact it was not.
The ACNGS design will not incorporate float-type level switches in the SDIV.
(Af fidavit, p.
5) 8008190320 4.70
(3)
The ACNGS design will use a differential pressure level transmitter system which eliminates the possibility that the system will not perform its function because of a defective float.
(Affidavit, p.
5)
T D
5 e
t L.
471
f L
EAF/ COMP COST S80-278 t,
TexPirg Contention No. 38/
PAID BY PLF. DEF.
(
SDVT Float Switch f
3 e
L 9
5 d
i IN THE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.
W 4
4 IN THE MATTER OF:
)
)
y HOUSTON LIGHTIMG AND
)
A POWER COMPANY,
)
DOCKET NO. 50-466 (Allens Creek Nuclear
)
1 Generating Station, Unit
)
d No.
1, )
)
41
- d L 75 y
DEPOSITION OF:
4 CLARENCE LEE JOHNSON e
?*
- J 1
M Nl s
4
~
~
472
+
ggy x'
4 i
_y n
42O L
M,
/Z6:
v 1917 San ( of the Southaes: Swicing. Hous:en, Texas 77002. (713) 652 5911
i 9,
12
}]p 1
A.
Yes.
a 2
Q.
And water sprays to extinguish the fire?
3 A.
Yes.
]%
4 Q.
I think th a t 's all the questions I have 5
on that one.
If you'll supply us with your i
6 interrogatory answers on that one as soon as you 9
t
. w 7
can.
i
?
8 A.
Yes.
?
P' 9
i G.
We can tu r n to number 32 which has to do I
10 with the SCRAM discharge volume tank float rg 11 swithes.
4 MTi I
3" "
12 Would you tell me what a SDVT float 379 13 switch is?
i
.u D 1
14 A.
It's a switch that is in the SCRAM f
I by the manner of-1 15 discharge volume tank, and it 1
J 1,
s--
m 4-16 floating, it indicates to the operators of the L,
w 17 plant the level of water in the SCRAM discharge 3
,8 18 volume tank.
1 19 Q.
All right.
Does it have a safety j
20 function?
'2 d
21 A.
Yes.
a
[-
22 Q.
What is that?
23 A.
Well, the SCRAM discharge volume tank 24 receives water during the SCRAM, and if these I
~~[
25 SCRAM discharge volume tanks were to be full of I
473 INTERNATIONAL COURT REPORTERS, INC.
~
HOUSTON. TEXAS (713) 652-5911
.s s
1 water, then, of course, _ it would result _in a 2
slowing of tne SCRAM of the - entrance of the 4
3 control rods into the reactor.
4 Q.
Well, that describes it's importance.
5 But what is its actual safety function?
You 6
indicated th a t it had, perhaps, a function to 7
inforn the operators of the tank's water level.
8
- Now, is it an indicator only, or does i t 9
have other functions?
?
10 A.
It's my understanding that i.t's both a 4
11 indicator and also allows the rod control 34 12 information system to eng a g e -the control rod s.
3 13 In other words, it acts as
- a. step on the
=
14 control rods.
1 4
15 0
Under what circumstances would it act as j
y 16 a block from latching the control rods or 4
17 whatever?
m E
IS A.
If it'were possible to lower the control
~f 19 rods prior to emptying the SCRAM discharge tank.
.k
'20 g.
I didn't understand your answer.
Let me w
t 21 r eph r a se the question.
s 22 You indicated that the float switch,
}
23 besides giving direct i n d i c a t i'o.y o f the level, 24 operated in a safety function cahacity to block
~'I 25 latching of control rods; right?
~}
T I
070 INTERNATIONAL COURT REPORTERS, INC.
w_--_____.
56 lJ s
2 1
A.
Yes.
e 2
Q.
Okay.
Under what circumstances would it 3
do that?
I 4
A.
If the SCRAM discharge volume tank was 5
above the water level required to allow the SCRAM.
?
i 4
6 Q.
All right.
How does the float sw i t c h l
?
7 itself operate?
3 I am not knowledgeable as to l
B A.
I'm not T
1 2
9 the complete details and the mechanical way it
[
10 operates.
In general, it operates, as I said, by 11 floating and indicating the water level.
Beyond T
12 that I can't tell you.
13 Q.
You have no knowledge of its design or
]
14 how it's constructed?
15 A.
That's correct.
Other than the fact 16 that I'm aware th a t it has a hole in terms of the 17 description of the switch itself. It has a hole 18 in the float. Tl 19 Q. Why does the have a hole? m 20 A. I don't know. -T Y 21 Q. Where did you get th e impression that it J 22 had a hole? 23 A. From a letter that was cited in the from Stuart to Case 24 contention from the case 25 in which he indicated th a t the floats sa nk )) 475 50 Tu?conATTnMAr. COURT REPORTERS. INC. i
{! 57 when the water-level reached 1 because the bole 2 a certain level, at times th e water entered the i 1 3 switch through that hole. 4 Q. You say there was a letter referenced in i S the. contention 6 A. Yes. or in answers to interrogatories? 7 Q. 8 A. I mean in answers to interrogatories, fy 9 yes. It's number th r e e. p 10 Q. Based on that letter, you then believe 11 that the SDVT float sw i t ch e s have a hole in the 12 float? 13 A. I don't know. i .) f 14 Q. You make no inference from the contents 3 i 4 .i 15 A. Yes, that.is the case. i i r 16 Q. But you don't have personal knowledge? i i 17 A. No. 18 Q. What is the importance of the hole in i i i r 19 the float? 20 A. The importance to us in our contention l r it's ) A 21 is apparently that's the manner in which '5 22 important in th e manner in which the float sinks. A 23 Q. I understand. If the float does not ? strike th a t. A 14 have a hole 25 Let's assume that the float does nort (r?6 5 e m T '
- e n 9 s t T n g s t.
r3URT RSPORTERS, INC. s
7 n 1 have this hole which lead to it's sinking, does ] 2 that re mo ve the source of your concern? w -0 3 A. I don't know. I couldn't say that at 4 the present ti me, because it would depend to what ] the float would still have a tendency 5 extent i ~J 6 to sink. I'm not sure what th a t would be. i s 72 7 Q. Well, what are the possibilities that _q S would cause the float to sink? 1 1 i 9 A. All right ?) 10 Q. I understand th e one th a t would have a ) J ~% 11 hole in it. I assume it would fill up with water T. "N 12 and cause it to sink. What are the other "1 13 possibilities? 4 14 A. At the present tine, I can't give you an -g-e j "F 15 answer. I don't know. I ?! 16 Q. If TexPirg finds th e re 's no other W 17 possibilities, then does that remove the source m J 18 of your concern? 7 19 A. Yes. We'd have to consider it. I can't
- if 20 say for certain, we would want to have some n
1 5N 21 assurance th a t in our mind the swithes are going ~7 3 22 to work and they are going to be very reliable. 2 4 23 Q. All right. And exactly what evidentiary -, n y, 24 standard would give you the necessary assurance 25 that they would work and be reliable? ~ Ed~ 4?7 n,. N INTERNATIONAL COURT REPORTERS, INC. ,,i,s .;3_qc11 }
59 ? c, .m. 7 1 A. Operating experience. That indicates L 2 that to be the case. - ? i 5 3 Q. All right. 7 1 4 A. Or testing. That indicates th a t to be J S the case. 6 Q. Okay. And if th e re were operating l s 7 experiences and sufficient testing to show that a .s 9 float switch without a hole was operative and ~ r 4 9 reliable, that would be sufficient for TexPirg's t 10 purposes? v 11 A. Yes, probably. You know, it's ha rd, to r' t ? 12 predict these. You've given a lot of conditions, i M i f 13 and assuming th o s e conditions you sa id, yes. ~ 14 Q. I wasn't fabricating conditions. I was T + 15 trying to elicit th e conditions from you as to 9 16 what would be acceptable to TexPirg. And I AJ 17 assume th e re mo val of the hole is fundemental? { J 18 A. Well, there could be a different type of T 19 switch which, I believe, there are different + 20 types of swithes besides float swithes. 21 Q. But we're only here discussing float 7 22 switches. A 23 A. Okay. i* 24 Q. And I was trying to elicit all the 1 7 25 sources of your concern, and thus far I believe 478 1 1 I 1 ~ INTERNATIONAL COURT REPORTERS, INC.
1 1 we have identified a known failure mechanism, the 2 hole in the float; right? 3 A. Yes. 4 Q. And once that is remedied, you would b 5 require adequate operating history and testing or .4 6 probably th e other way around. Is there any v. 7 other source of your concern with regard to this lI ik.' 3 contention? J 9 A. No. let ne go 10 Q. I think I f ailed to ask you 11 back. 12 You have the technical knowledge to f } 13 speak for TexPIRG; correct? g i .I J 4 14 A. Yes. 15 Q. And you wrote the answers to the 16 interrogatories? c 17 A. Yes. IS Q. Without assistance? 19 A. I had assistance fron John Doherty. ]. 20 Q. What portions of the answers or the f 21 frame of the contention did John Doherty 22 contribute to? 23 A. There is no specific part attributable 24 to it. Basically, he and I discussed in general i l 1 25 what issues were involved in this contention. He J 479 INTERMATIONAL COURT REPORTERS, INC. -c, en,3
'.Al ID .1 assisted me in collecting my own thoughts. .a 2 Q. All right. Can you _ rec all exactly what ?O i 3 facts or information he related to you? 4 A. For instance, the letter from I-. Stuart }{3 5 to E. Case, and the information from the Nugget TP i 6 file. i, 778 7 Q. So he acted in a capacity of really d 8 relating information to you? i ~ys M 9 A. Yes. a ?f' 10 Q. Have you conducted any written studies .!A 11 or other wo rk papers?
- ~a 12 A.
No. "T' 13 Q. All right. Do you have a witness?- -e i 14 A. No. ".,l 'j 15 Q. Does John Doherty intend to testify for 7 16 TexPIRG .as l 17 A. I don't know. i-5d on this? la Q. .] 19 A. I don't know. I can say we have a. 20 discusse'd that question, and we" haven't come to 21 any agreement yet on it. That's b.o t certain yet. ~ l 22 Q. Well, do you anticipate that Mr. Doherty -u l_ 23 will continue to assist you in the prosecution of 24 this contention? nt I 25 A. I'm not sure of th a t. It depends to -x ~ 480 i ~, -.sm INTERNATIONAL COURT RE?ORTERS, INC. u n st e a n u mevsc 1711g cc7_qo11
1 ~ l what extent he might be of help to us. i 2 Q. All right. Let me ask you the same sort r ?A 3 of questions with regard to your contention 4 number 15 on occupational exposure. 4 5 A. Okay. 4,, 4 6 Q. Your the person with particular T 7 technical knowledge to answer for TexPIRG? 4 8 A. Yes. f 1 4 9 Q. Did you compose the answers to i T 10 interrogatories without assistance? 4 11 A. Yes. Other than the assistance of M 12 receiving help in collecting some of the 3 13 documents. --e 14 Q. All right. I think th a t 's in line with ].i 15 'that. 16 A. Yes. 17 Q. All right. Do you have any written work M 18 papers or studies or other documents that you 19 rely on th a t have not been given to us yet? } for yes. There's a recent 20 A. That .,a 21 one th i n g, I would mention th a t in th e we 22 mentioned a document here identified as NUREG } 23 0482. Subsequent to th e s e interrogatories, the M& 24 library received a copy of NUREG 0594 which 25 merely updates by one year the occupational } 481 INTERNATIONAL COURT REPORTERS, INC. en,, a}}