ML20062H656
Text
,m(-)
UNITED STATES CF 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 5
?
(Allens Creek Nuclear S
Generating Station, Unit S
No. 1) 5
/
Material Facts As To Which There Is No Genuine Issue To Be Heard 1.
Fuel hydriding is caused by hydrogenous contamina-tion (primarily noisture) introduced inside the Zircaloy fuel h
rod during manufacture.
(Affidavit, pp. 1-2) 2.
Hot vacuum outgassing (drying) techniques used P
during manufacture, just before and during plug welding, and the presence of a hydrogen getter inside the fuel rod, have proven effective in eliminating hydriding as a fuel failure mechanism.
There have been no hydride-induced failures in fuel manufacturing using the outgassing techniques and the hydrogen getter.
(Affidavit, pp. 2-3) 3.
Fuel densification has been studied since 1972.
Quality control tests during manufacture will assure that the fuel is of such an initial density that further densification during irradiation does not adversely affect fuel performance.
Conservative limits on Linear Heat Generation Rate (LHGR) 99 R O D B. q' n S 3 $
494
r f
assures that actual LHGR remains within design limits if maximum theoretical densification occurs.
(Affidavit, pp.
l 3-4).
4 4.
No fuel cladding collapses or failures that can be attributed to densification have been experienced in any BWR fuel.
(Affidavit, p.
- 5).
5.
In the unlikely event that hydriding or densification-induced fuel failures occur, no safety concern exists since (1) operation of reactor coolant and the off-gas system can be controlled by regulating the power level I
of the reactor and (2) the failed fuel can be replaced if necessary.
(Affidavit, p.
- 5). 495
m 0 - 3 "i 2,
-" ~n "
- s costs McCorkle Contention No. 14/
PAID BY PLF. OEF.
Fuel Hydriding f
3 i
t i
UNITED STATES OF A'IFRICA NUCLEAR REGULATORY COM:1IS S ION
~
BEFORE.THE ATO11IC SAFETY & LICENSING BOARD i
i IN THE MATTER OF:
)
)
HOUSTON LIGIITING & POWER CO?tPANY )
DOCRET NO. 50-466 (ALLENS CREEK NUCLEAR GENERATING )
STATION, UNIT 1)
)
A-i r
i 4
DEPOSITION OF:
DREMDA !!cCORKLE
(
)
I
~
N fM
%g
$f, N8d O
-~~
w 191/ Back of :ne S:u:hwes: Su;ld:ng. Hous:en, Texas 77002 1713) 552 5311
4 BREMDA McCORKLE, 1
3 called as a witness by Houston Lightinc & Power 3
company under the adverse party rule, having been 4
first dulv sworn, testified as follows:
D-6 CROSS EXA"IMATION 7
QUESTIONS BY ?tR. BIDDLE:
8 O
Mould you state your nane and address for the g
record?
10 A
My nane is Brenda McCorkle, and ny address is P
Texas 77074.
11 6140 Darnell, H o u s,t o n,
i 12 0
Me have asked you here today to conple te 13 disc very n the subject matter covered in i
14 anolicant's second interrogatories, specifically r
15 dealing with fuel hydriding densification, 16 and leakage bynassing filtration systems, is 17 that your understanding as well?
18 A
Yes, but I have a problen with it.
19 Q
All right.
20 A
The croblen I have with it is that I thoucht 21 the hydriding contention had been dropned out.
22 O
You say now you want to refern it 23 A
No, I'm savine that in the Board order of April 24
- 12th,
'79, in Paragranh 9,
they said ny 25 contentions 914 and 17 were adnitted.
t 497 i
4
5 1
Mou, accordinc to my calculations 2
on the contentions I submitted, the one on a
3 hydriding is Mo. 16.
4 Q
Well, we have your Contention No. 14 which reads as follows.
And I quote here and you can o
+
6 correct any portion y,cu want.
The way we have i b 7
reading n owr is that, "The fuel rods to be used
[
8 are not safe because of clad failures in off e
9 gas activities caused by hydriding and the effect 10 of fuel densifications which increases the power 11 snikes and heat ge,neration."
,i 12 A
I have that listed as Mo. 16 under nine.
13 o
which contention de you have listed under 14?
l 14 A
Under 14 I have a dry well and containneht k
15 issue contention.
16 MR. BIDDLE:
Go off the record 17 for a nonent, i
13 j
19 (Discussion off the record.)
20 21 O
Mow, the Board renunbered contentions, did 22 thev not?
In other words, your No. 14 nay 23 not be the '70 12 that the Board assicned 24 that number.
25 A
Chay.
What I did ras I caragraohed these, and I
i
__ 498 I
a
6 it started out this uas -- has a one on it.
1 This would have been Contention No.
1.
2 contention 2 is actually no. 3 on nine, 3
c 4
Contention 3,
and the reason I sav this, 9
hack on the Board order of April 12th,
'79, 5
4 6
it said with regard to her contention 3 which 7
contends that the construction of the plant 3
nay he excessive.
That corresponds with what I put l
9 10 as No.
3.
By their number, then I just went 11 on down.
And I ended un with -- and I oniv did s
12 this today, because I was just going alonc 1
13 with whatever you said.
And I ended un with i
14 the one on the fuel rods being Mo. 16.
And 4
d
,5 then I couldn't understand --
t 16 Q
Let's see if this will correct it.
We asked 17 a set of interrocatories on fuel hydriding, 18 densification and leahane, hypassing filtration 19 systens.
20 A
Right.
21 Q
And in a Board order you were asked to nore 22 fully resnoond to those.
27 A
Richt.
24 Q
And then the Board alloued us until a later 25 date to follow un discoverv.
That was a Board's 6
7 1
1 order of --
A Right, I remenber.
2 January ath, so this deposition is in 3
0 I"
4 accordance with the January 8th order saying 5
that we can follow up.on your further responses.
E 6
A Okay.
Well, my only cuestion on that was 7
if I did'not -- if they just sunnarily dropped g
the -- see, I got real confusion on'this_because
]
g I don't know what's in and what's out.
I_
10 am perfectly villine to respond as best I can.
i 11 Q
I understand.
t
-o j
l' 12 A
But when I did this this morning and I came out 1
f 13 -
with Mo. 16 on that and nowhere in the Board 14 order does it say that 16 ends.
I don't know j
15 what you're pursuing.
1 1
l 16 o
Well, I don't know where the confusion lies, but y
17 I guess the best course for us is to go ahead I
18 and connlete our questions and answers on 19 these three subject areas regardless of what 20 contention is attached to them, and then 21 afterwards we'll try --
t 22 A
We need to clarify something for the Board.
to ascertain ourselves which are in and 23 0
24 which are out and nahe use of the infornation 25 in this deoosition accordingly without nakinc 500 1
1 a
j' 1
any reference:to whether it's admitted or i,;--
2 what number pertains to to the admitted 2
-contentions.
Okay?
If that's acceptable i
s f;
4 with you.
1
-5 A
That is fine.
t 9
$ 1 6
Q All right.
Let me ask you first if you are i
t i
7 an excert either in fuel hydriding, densification 8
or in the subject area concerning leakace j,!
9 bypassing filtration systems?
i i
)
10 A
No.
- (
1
)
11 Q
Have you retained an expert witness for any I
k 12 of the contentions dealina'with this subject 13 -
matter?
t t
t t
)
14 A
Mo, I havent.
,'l-15 0
nid you then formulate the answers th..e you-i, 16 subnitted on February 1st, which was your last
\\
l.
17 set of responses, by yourself without assistance?
.r 13 A
Yes.
- (
19 0
In resnonse to the Board's order of December T
l 20 5th of 1979, you stated that you had delayed 21 in ansvering a set of interrogatories because 22 you lacked the technical knowledge to answer i.
23 many of these questions and were searchin:
24 for an exnert uitness to ansuer them.
You 1
25 then stated, and I cuote, If I cannot locate I
,s.-
i 501
_m-
,,.%n:._u
,,..e.,
..m
.,,f....
.__m.-----3_.-
,.,,,.,,...-r
,w..,
.-~_-----r-
9 s
1 an expert witness, then I will withdrau these 2
latest contenti~ons."
s IC that representation you made'to q
3 the Board no longer valid?
4 5
A I d n't understand what you are asking.
,i t
6 Q
All right.
In'a Board order of Decenber the o
5th, they' asked you to answer four questions,
~
i 8
I an sure you remenber those.
i 9
A Right.
10 0
One of those was what were your re a son s for i
11 not connlyino with the Board's order to you i
i 12 compelling.you to resocnd to discovery, and i
l 13 you resocnded that, and I quote, "I complied 14 with the Board's August 27th order to concel.
i 15 I ha"e not conol-ied with the October 5th order
~
3 I
16 because at that time I was working on the third i
17 set of interrogatories f:'on applicant.
I 18 receiv.2d this order (October 5th) two days N
I 19 before the'due date for aqswers.
I also lach t
20 the technical knowledge to answer nany of these 21 questians, and an searching for an exnert 1
22 witness to annuer then.
If I cannot locate 23 an.xnert uitness, than I will withdrav i
24 these later contentions."
9-Those answers are exactly the
-)
- s..
i i
f W M 502 6
'*'s
\\
10 1
subject natter that we are here to discuss t
2 today.
And I an askinc whether or not this r*"rS5*"t ti " ? " ""d" t
th* 3 3rd th^t 3
4 you nould withdraw these contentions if you did i
not locate an excert uitness is still valid, 5
or do you intend to testify at the hearing 7
yourself on these matters?
8 A
I don't know right now.
I an still looking for
[
t 9
an exnert.
10 Q
And is it still true that if you do not find an 11 expert that you will withdraw those conten-12 tions?
13 A
I e n't know.
i 14 0
Well, do you intend to advise the Board if you 3-change your reoresentation you nade in this
-p 16 subnission of 17 A
ch, yes, sure.
31 Decenber?
13 0
1 A
Richt.
20 0
So right now --
21 A
I'll put it this way:
Most likely I will 22 withdraw them if I can't find someone that knous a lot more than I do.
I an not real big 23 24 in nakinc a oublic fool of nyself.
25 0
e ne he forthricht in the nroblen we are 503 l
11 1
having, these contentions are uhat we call 2
the oldest contentions or the ones 3
originally admitted.
You were in that group 4
of original intervenor 5
A These are the ones adnitted when we appealed.
6 Q
We lumned those all together.
In any event, 7
the discovery on these contentions as 8
ended Decenher the 5th, so if things were neatly i
9 organized, there would be no further discovery 10 on this.
He are right now in a position cf 11 not knowina where your case is,that you s
12 intended to withdraw if you don't find an expert
[
13 witness.
And you haven't identified an expert 14 witness, and we have no one to denose to close 15 discovery.
l 16 A
Me are also in a double hind, not j'ust because 17 of ny doin ~g but also on what is in and what is 18 out.
19 o
well, but for present purposes 20 A
If I do not find an exnert witness, ! will 21 uithdraw these contentions.
22 0
And you ui
'et us knor as soon as you identify 23 hin so that we can request discovery, aernissior i
24 to denose hin because right neu the discovery i
25 on thin nortion of the case is indeterninate?
504 I
12 1
A The day I get hin wired in.
2 Q
Do you have any prospects right now or is that 3
just an --
4 A
No.
5 o
until that eine, we-will ask you for your 6
best knowledge of the contentions, even though you 7
state that it's unlikely and extrene that you 8
will testify, I think for efficiency purposes 9
we'll work on the supposition that you might 10 testify or at least you night cross-examine 11 and ue'd like to know what you know about the 12 contentions, if that is all right?
13 A
That is fine.
14 Q
It is true that you do not intend to testify 15 yourself?
m 16 A
As an expert in this area?
17 o
yes.
18 A
Absolutely not.
19 0
Maybe the best way to anproach this new is to 20 ask you hov did you fernulate the contentions t'
21 on these subject natters originally?
Did 22 someons or something identify the concern to vou s
23 that we can look at and better understand the 3 '.,
basis of your concern?
25 A
Nell, I read the naterial.
s.
505 l
1
13 1
O Which material?
2 A
!!y contentions were fornulated fron reading 3
the -- I don't know whether --
4 O
The safety Evaluation Report?
5 A
SER-7 so all these subjects matters we :2 8
gleaned from the SER?
i g
A I don't knou uhether thov cane all from that.
1 t
(
10 I read so much of thin material, ! can't tell 11 you where anything cane from.
1 12 Q
So, yau cannot point out to us -- to anythina, i
13 particular reference?
t 14 A
Mo, not to any particular reference, but it i
15 did cone fron the material that has been I
16 publishedithis.
I have read the final I
i 17 environnental report and this naterial and we i
i 13 cane un here one day and ?tr. copeland let us 19 go through scne of the naterial that was availab le 20 hero.
(
21 O
But you have no snecific quotation to a page 22 or chapter or number or anything like that?
23 A
Mo-1 24 Q
And have no recollection of uhere you oricinally e-viewed the concern?
~3 506 i
i,
14 A
Let ne look at this.
1 P41 to 49 Is that the safety 3
rep rt
- is that the e ndensed safety renort?
1 l
4 0
This book here is the original Safety Evaluation 5
RS9 rt-ThSr0 "SrS t"
5"991SC"nt3-P393 45
'i discusses hydriding protection, is that the source of vour concern on the first subject t
8 natter?
i 9
A Chat was probably --
10 Q
Have you identified any concern other than 1
11 that identified in those sections of the SCR?
i 12 A
Well, I have one -- I didn't bring it with ne but I have an ther n
that came fron uhe PsAR.
13 14 It was just a small paragranh on the -- what r
i I
15 is it called, on the --
,6 Q
Could you -- if you find that piece or 17 reference, uould you let ne know which --
13 A
I have it clinped to a stack of naterials.
iust call ne and let ne know Uhat
,o O
If vou vould 20 section of the PSAR you were referrine to.
i.
21
!io u, outside of OSat section of 22 the PSAR and these sections of the SCR dealing 23 "ith h7dridin?r You kno" of no other source 24 of your concern cresently?
25 A
!!o.
t W
t
15 1
0
'1ould you describe for nn what vou helisve 2
is the problen uith hydriding, brief1v?
3
?.
Hvdriding is when the hydroge, cets into the I
4 fuel and can cause, I guess, eladding breakdown.
i' 5
This has been a long tire sin. c I've looked P
6 at this.
7 Q
So, claddine Sreakdoun is the source of your 8
concern in hydriding?
9 A
Yea.
P 10 0
Do von knen when this probler was originally 11 discovered?
12 7-No.
13 q
no vou know hon it was originally discovered?
s 14 A
Mo.
(
15 o
no vou know of any stens that have been innle-16 nented to alleviate this nroblen, uhatever I
17 it's nature?
t arn von saving do I kno" of any renedial 13 A
I 19 naasuroc?
20 0
Yes.
21
^
Yes.
I don't knou, it's not this one, it's l
'nou whether that's 22 the P S A P., and ! don't 23 heen ahnted or not, but it talks about thev 24 have develoned a zirconiun alloy nach, or it's 25 nade of circoniun.
" hey uere nacked loosely s
i oCMS l
g l
lA 1
around the fuel rods sort o# as a hydrogen 2
cetter t keen the hydrogen auay from the 3
Cl^ddin4 f"S1 r d3-
^
4 0
Is it vour contention that that renedial neasure 5
is inadequate?
6 A
I have no notion tihether that is adecuate or 7
not-g n
You have no oninion an to its adecuacy?
9 A
Mo.
'O O
can you tell ne of every instance that you are 11 aware o# uhere fuel nanufactured hv General 12 Electric for BMn failed due to hvdriding or j
13 SuffSrSd h"dridinG "VSn SinCS MCVSNher' 1"7^r 14
'rhich was the issue date of the SER?
15 A
I don't know.
16 0
Dc "ou know o# any instance where it was?
17 A
I think I have read sonathing about it somewhere, 13 but I don't kno" uhere it was.
0 But von have no knottledge of any instance of 19 20 fuel failine after ?iovenher, 1974?
21 A
'? o -
22 Fone o# these cuestions are crenised on ansvers n
23 vou cave in nrevious interrocatories, so if 24 "ou don't understand the cuestion, just say 25 so and I will identify #cr vou the crenise.
g
~
i I
17 A
All riebt.
1 2
0 I would say in general if I ask any cuestion that vcu don't understand because of ny 3
4 structure er uhatever, just niease interruct and I'll tr" to restate it for you, rather 3
than haua you try to ansucr sonething you are not #ully aware o." what the questien is.
I 8
Let ne ask you ho" long the hydrogen cetter material nust he used to get a g
10 satisfactorv histor" as to its effectiveness?
1,.
In a crevious interroc.ator" answer v.ou indicated 12 that there wasn't adequate history.
13
'A I d n't %" "-
f
\\
0 You don't have any coinien about how 1cnq we 14 I
1-have to use it hefore vou can sav uhether
-9 r
16 it's vorhing correctly?
17 A
'I O -
13 0
DO "ou knew of an" instances "here hvdrecen this renedial neasure, has been cetter naterial, 20 denleted before t ',. e end of the life of the o,
fuel?
2 1
?Io.
o n
.1.1 _1
_4cw..
2o 24 A
"co, I did read in the last, I think it was 25 t"*
"" " l*Fent to th'S, it Cane 0"t I h*'ieve t
WA t
%U.'_
I e
i
13 in 'tarch of
'70 1
2 0
'7
A
'To, not that.
s 0
This is the last sunnienent.
3 Oh' I'"
8 " ' ' ' thi" i" th*
5 6
that has the wrong date on it.
'iarch
'70 was the issue date.
This one has the wrong I
g date.
A It does talP about the cladding in there and 9
it talks about the current cladding structure 4.
10 is sunnosed to before it begins to give way, 11 it has sonetSine like a five, I think it's 12
^ fi"*-""*r
^"d I did " t "* h -- I h^V*
13 14 of these but I did not nark the olace where it
.is.
15 It indicated to me that the
,O I don't le cladding structure or the h'rdrocen 13 kncu whether it uas hydrogen getter -- is sunnesed to last longer than the fual rods 19
' ' ' "ld 'isually he in use, which, if that is true, 20 u1 ther= is no oroblen, 3
O If that is true, then there is then vou have 22 no 5trther concern?
23 24 I"
the hvdrogen c a t t e r o r th -, claddinn structure S:
is as th4 9 indicated, and I do not renenh er l
-s i
O_
i i
19 exactiv i# that did include the h"drocen getter material, but if the claddinc structure is desicned to last longer than the fuel, t
hou could vc't object?
O Or i' tha getter natorial is designed te last longer?
A Yes, if its nrojected life is longer than
~
t t e fuel.
3 Q
Do vou agree it is possible te calculate and to nrovide an ancunt of getrer sufficient to canture all of the hydrogen exnected over the life of the fuel?
In other words, it is 12 t
ncasihie to sunnly enough zircoloid chins i,s to service the fuel cver the 11# 2 cf the e u o l o.
15 A
It should he.
O Yoti nade sono reference in "our interrogatory 1~
-t ansuers about a ccncern that tSe getter nateri.al night becone contaninated.
Could "ou identif" for ne the source of vcur concern 20 and hou the cetter natnrial nic*it become 21 contaninated?
22 A
I don't kno', I sunnese it's theoretically ncnsible that the getter naterial could 2 4, beccne saturated and l o c. e its usefulness, but n-)
4 D._ o
-y i
N I
i i
2n 3
I don't knee r encuch ahcut that to connent
[
2 on it and I do not know hat else is in thare, in the #uel racks and rods and claddinc 2s 4
naterial that could contanina".e it.
5 0
You have in nind no specific instance of getter contanination?
A No.
I a
n mhis is more of a -heoretical arcunent?
e A
Yes.
~
9 0
Let's turn our attention new to the densificatic7 10
(
11 of that sane ceneral coa.tention.
12 Again, I'll just start by asking v u to describe briefly what you visualise 13 14 as the problen uith fuel densification.
5 1
A Nell, the fuel becones connacted and I don't d
^
16 know hou it a'fects it to nake it nore or less 17 deficient than it uas before or because the I do not renenher.
I uas 13
'C"er sniken l
readina this this norninn in the sane hoo? and 19 a
- c u '-
'bc "ua7--
k n'-a
~
- w o,e
.., n o u,, t. i - c-20 t
e, arrangenent no" is such that it's nininized 22 fuel densification oroblens.
n re u n o.
4, : 0... p. u. 4 e r.
. m. u. a 4.. o g.
- u. w.. 4 y
.g r..
2.2 24 sunnienant is correct, t k. e "nc staff's evaluaticp.
25 of fuel densification nroblens crincipally,
-f l
t i
- 9..,
1 that in correct, does that rerove the source of vour concern?
2 A
Probably.
I have to get a lot nore education 3
i e
on this he#cre I can give you an educated
- anseer, 5
n But you understand our nrchlen in trying to g
rebut v.our c.uestions?
g 3
A Mhat vou are tr"ing te do is blev ne out of the water an.d vou and I hoth kncu it.
m we are tr"inc to understard the basis of your 10 concern, uhat we h, ave nov is none generalized 12
' s tatenen ts like k naification is a orchlen and
[
13 the starting places 14 A
I will sav that the !! arch ' 7.0 supnlenent to
,e
' k.. a_
%'. _# a_ &_ v. a ". M.
- 7.. ". m' 7 " a '_ _4c n.
- a_ n, c. '. s a v s ' b.. a ".
, o-thev. have taken care of the fuel densification s
7 nrchlens bv creatinc a neu nellet structure t
,3 or thev are using snaller sized pellets.
19 0
I understand.
The Genoral F,l e c t r i c n. r o n. c s e d o0 and inn.lenented a renedial neasure for the
.o,
fuel densification c.henonenon and the NRC
-'a"#
- o r.n ' ' k.. a "...a... a. d..; u' '_ _= w '. _io ".. a w-
'.. '. a b l =_
22 a.
w_
23 2nd no" I an nronnted to ask you uhether or t
23 not vou also find it accentable or if vcu have t
25 a continuinq c 'm j e c t i c n, and 1 vou Fc hava t.
1 D _.L1 i
99
~~
1 a continuing chjection, can 'rou identify it for ne specific enouch so tre can attenpt 2
e rebut it?
3 4
A
'To, I can't identify specific objection.
This naterial on the new pellet shane and cladding
-3
,1 6
is on Page A3.
O 4-3 of the SER Supnlenent?
~
I
~
8 A
Yes.
I 9
0 But vou have no particular opinion or reason 10 to object or agree with the staff's evaluation 11 here?
a 12 A
'7 0.
But the staff says it's gcing to ucrk, 13 it's an exercise in futility for ne to 14 object to it anyt r av.
If it's acceptable to 15
'R C -
i 16 0
Well, the way I read this section of th= SER, 1 ~l that is what they say.
~
1 A
That's the t'au.
I read it, too.
19 Q
They said it's acceotable, so presently the 20 only nerson objectinc to it, to our knc'71 edge, 21 is " ourself, and us need to hnce r.rh a t your 22 objections are.
23 A
If it's ccina to be accentahle to then, I have 24 no objection, I dcn't care.
I 3:
O So
~<
W D
l; l
t
23 1
A I just read this this norning, just sat down.
0 So y u have no continuing objection concerning 2
the problen of fuel densification?
3 4
A Say that again.
0
"*ll -- I dO"'t "*"t t '" t " rd" i" " "" ' "th-5 6
A If this is correct, how unusual for you and Mr. Copeland to t rv. to constantiv. ~aut words g
in ny mouth.
If this is correct, I have no 9
further objecticn.
.0 o
okav.
I have renaining a series of questions 11 I
t i
L based on nrior in'terrogatory answers that 12 13 y u gave us dealing with fissi n rates and 14 the sine or the substantiality o.# nower snikes 1-and so " orth and so on.
I assune that these
-3 16 answers vere written before you rev?.ewed this 17 naterial in the SnR.
I an wonderinc i" I need 13 to ask you these questiens based on those 19 prior answers or is your positicn n o' r centered 29 solely around the adequacy of tha evaluation 21 of the SER sunnlenent, in that you don't have 22 necessarily take an" encention to that?
t A
I don't take anv excention to the naterial 23 24 in that.
25
- don't see an" reason to ask an" nore on 0
D_.6
~4
24 O
that, then.
1-Okay.
"urning to the last area 2
2 that has to do with excessive leahage hypassing s
4 filtration systens, and I have again an 5
introductory very broad question that I an 6
forced to ash really.,
Mhat leakage bynassing 7
filtration systen are vou talking about?
I a
Me can't pinpoint the structure or systens that g
you have reference to.
,.0 A
Mhich interroc>ator" are v.ou talhina. about?
11 0
That would he v. cur,. interrogator.v., the wa" 12 I have it numberdd, 17 I will read it the 13 -
wav I have it rec rded.
It says the containnent 14 as designed will allow excessive leakage to
/
15 hypass the filtration systen, power conpany 1
admits that 20 percent of the leakage would 17 not.even he filtered and also the filter 13 absorber, I think neant adsorber, may start
, c, a fire h v.
auto ignition, if there is no 20 water supnlied by such auto ignition as recuired 21 by the ?IRC regulation guide 1.5?.
That is the 22 contention.
23 A
I have that one d o'in as ny nunher 19.
24 0
'4e l l, we'll straichten the nunhering out later.
25 nut could you describe for ne now what leahace
~4 m D_(
I.