ML20062L384
| ML20062L384 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 01/19/1981 |
| From: | Doherty J AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-CP, NUDOCS 8101280325 | |
| Download: ML20062L384 (3) | |
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UNITED STATES OF AMERICA Jan. M, %81 MUCLEAR REGULATORY COMMICSION BEFORE THE ATOMIC SAFETY & LICEUSING E0ARD In the Matter of:
HOUSTCN LIGHfING & PC'JER CO.
Docket No. 50-466 CP
( Allens Creek Nuclear Genernt.ing Station, Unit 1) l l
INTERVINOR DOHERTY'S MOTION FOR THE BOA 2D TO CALL AS A SITNESS,
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DEMETRIOS BASDEKAS F0E HIS CONTENTIONS S (in cart),12,17, 2%
l 28, 41, and 42.
This motion is filed i.n order to use a possible avenue for an expert witness to appear-in behalf of these Contentions.
In its decision ALAB-382 (Consumere Power Co.,
(Midland Plant, Units 1 and P) 5 NRC 603-608, 1977) the Appeal Bonrd in that proceeding stated (at 607):
N Nothing...orecludes a Board from calling wit-(s nesses where it finds a genuine need for their UCCKE7t WN;c I,
testimony or from utilising Commission payments 9
of the usual witness fees and expenses when it OYpg r
y I A 'Y Off;4#l does so.
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[Tlhe subjects which the witness may address i 3'Me4
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testimony would be controlled by the Board an cros examination b*r any party would be restrictad to mat-r s
covered in the witness's direct presentation.
W (T]he Board's authorit7 in this respect should be exercised with circumspection where the ;itaess it de-sires to hear would have been sponsored by one of the parties but for financial considerations.
A motion setting forth the reasons for it$ making ap.
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the areas of testimony for the witness, while nerhansg s
asaporonriateasarequest,hasbeenfiledhereinoktb Intervenor's susricion Anplicant and Staff may well Siish,ANg gISBN a
v input and the motion form clearly gives them notice.--
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G The 'ditness
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Demetrios Basdekas is an emoloree of the Commission / %
8 in a orofession capacity, with responsibilities to the p$Of
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Instrumentation, Contro'. & ?ower Systems Branch, as of g
October, 4980. He had previouslr (or is concurrently) also with responsibilities to the Experimental Fast Breeder Reactor Safety Research Branch.
He was the sub. ject of Boari Notification 10-15 which was titled: "Dif f arini: Pro-Nati fir tion * ( 3" 30 15), dated:
fessional Oointon 3:ard
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November 29, 1980.
This Intervenor received this notification no earlier than mid-December, however.
After careful co nsid-erntion, this Intervenor requests throuch this motion that Demetrios Basdekas testify as a Board witness.
Board Motification 80-15, by enclosure of a memorandum from Mr. Basdeka to James R. Tourtellotte, Esq., of the Coc-mission's Le.'nl Gtaf f, of October 10, 1910, setc forth in Mr. Easdekas' words, "The basic disagreement stems from the assumntion made 57 the Staf', and still hel1 'ce'ite the T.'lI-2 accident,. hat " safety s7 stems will mitigate control system failures at any pouer."
Contentions for Uhich the Witness is Saucht The contentions listed beluw are those this Intervenor believes are relevant to the differing professional opi..lon expressed by the proposed uitness.
CoEtention 8 (in nart) - Several transients involve control system failures.
These include: loss of feedwater heater, uncontroled rod withdrawal, prossure regulator fails (ocen),
pressure regulator fails (closed), loss of feedwater control, at any power.
Contention 12 - Failure of the Rod Control and Information S-stem.
Contention 24 - Control rod drop at full power.
Content'Yhn 28 - Control rod ejection at full nower.
Contention 41 - Failure of water level indicators in the RPV at full power.
Contention ap - Loss of reactor control throumh misinformation on the position of the Safety-Relief valves.at full power.
Contention 17 - Lo,ss of reactor control through unreliable operation of the safety relief valves (SRVs) through an operating transient:at full power.
Intervonor currently has no export witness for each of these contentions.
But even were he to locate such a witness, the par-ticular faciliarity with control systems, as the orofessional nos-ition of Mr. Basdekas recommend his 'resence at the forthcoming Safety hearings strongly.
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_3 Certificate of Service Cooies of "IUTCRVCMOR D0iLETY'S MOTION FOR THE BOARD TO CALL A3 1 'JIT"2SS DEMETRICS BASZEKAS FOR HIS COUTENTIONS S (in part), 12, 17, 24, 23, 41, and 42." were p rved on the -narties -below in Houston, Texas, this /4 of Janusry,
'081 Sheldon J. Wolfe, Esq. (Chair); Dr. E. Le3 nard Cheatum; Gustavo A. Linenberaer, Alainistrative Judzes.
Black, Ecq(. (Staff) Applicant)
Richard A.
Jack R. Newman, Esq.
J. Gre;; cry Cooeland, Esq(. ( Applicant)
Susan R. Plettaan, Esq.
The several intervening parties.
Atcric Safety Licensing & Appeal Board Docketing a 3ervice Branch, URO Respectfully Submitted, chn F. Doherty (Intervenor)
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