ML20062H645

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Statement of Matl Facts as to Which There Is No Issue to Be Heard Re Summary Disposition of Tx Pirg Contention 38 on Use of Float Type Switches in Scram Discharge Vol Tank.W/ Excerpts of Johnson Deposition.Pp 470-481
ML20062H645
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 8008190320
Download: ML20062H645 (12)


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

control rods.

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

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472

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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

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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}}