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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063N7591982-10-0606 October 1982 Withdrawal of Application for CP ML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20055A7221982-07-15015 July 1982 Memorandum & Order Denying Jf Doherty 820615 Submittals, Treated as Motion to Reconsider ASLB 820602 Order.Motion Untimely Filed & Failed to Show Significance or Gravity of Issues ML20055A3551982-07-12012 July 1982 Amended Contention 59.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20053D6371982-06-0202 June 1982 Memorandum & Order Denying J Doherty 820422 Motion Re Contention 58 on Applicant Conduct on Reporting Violations. Applicant 820519 Motion to Strike Doherty 820514 Reply Granted ML20053A3961982-05-24024 May 1982 Order Extending Commission Time to Review ALAB-671 Until 820601 ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F9941982-05-12012 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention 58.Intervenor Fails to Meet Required Stds to Reopen Record & for Untimely Filings.Certificate of Svc Encl ML20052F2971982-05-10010 May 1982 Order Extending Time Until 820524 for Commission to Determine Whether to Review ALAB-671 ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20052D1221982-04-29029 April 1982 Findings of Fact on Supplemental Issues to Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20052A4541982-04-22022 April 1982 Submittal of Contention 58 Re Applicant Conduct on Reporting Violations at Plant.Certificate of Svc Encl ML20054E0561982-04-21021 April 1982 Supplemental Findings of Fact on Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20054D5251982-04-20020 April 1982 Order Incorporating ASLB Rulings at 820412 Hearing Re Tx Pirg 820405 Motion to Enter Counsel for cross-examination & to Reconsider 820128 Order.Motion Denied But Tx Pirg Permitted to Submit Written cross-examination Questions ML20054B6981982-04-14014 April 1982 Transcript of 820414 Hearing.Pp 21,787-22,027 ML20050E2181982-04-0808 April 1982 Order Ruling on Doherty Motions.Request for Production of Bechtel Quadrex Rept Review Moot Since Applicant Furnished Rept on 820316.Motion of 820315 for Subpoena of Quadrex Corp Employees Denied W/O Prejudice ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050B1141982-03-31031 March 1982 Decision ALAB-671,affirming ASLB Decision Denying R Alexander Petition to Intervene.Aslb Assessment of Untimeliness of Petition Free of Matl Error.Issue Raised No Longer Cognizable ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20042C5661982-03-30030 March 1982 Reply Opposing Tx PIRG,810315 Proposed Findings of Fact & Conclusions of Law.Proposed Findings Are Collection of Disjointed Thoughts & Facts W/No Rational Assessment of Effect on Problem or Issue Discussed.W/Certificate of Svc ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20049K0671982-03-25025 March 1982 Reply to Tx Pirg 820315 Addl Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20049J9651982-03-24024 March 1982 Testimony of Fr Allenspach & JW Gilray Per ASLB 810128 Order Re Doherty Renewed Motion for Addl Evidence on Tx Pirg Addl Contention 31.Quadrex Rept Does Not Alter Previous Conclusions That Applicant Technically Qualified ML20049J9701982-03-24024 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31.Certificate of Svc Encl ML20049J9671982-03-24024 March 1982 Response to First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31 ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20042A2721982-03-18018 March 1982 Order Scheduling 820412-16 Evidentiary Hearing to Receive Addl Evidence in Houston,Tx ML20042A2771982-03-18018 March 1982 Memorandum & Order Denying J Doherty 820310 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Ample Time to Complete Discovery Given.Personal Obligations Are No Excuse ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20041G1711982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion to Postpone 820412 Hearing on Quadrex Rept.Doherty Cannot Profit from Failure to Comply W/Aslb Order Re Completion of Discovery by Postponing Hearing.Certificate of Svc Encl 1982-07-02
[Table view] Category:PLEADINGS
MONTHYEARML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F9941982-05-12012 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention 58.Intervenor Fails to Meet Required Stds to Reopen Record & for Untimely Filings.Certificate of Svc Encl ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20041G1711982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion to Postpone 820412 Hearing on Quadrex Rept.Doherty Cannot Profit from Failure to Comply W/Aslb Order Re Completion of Discovery by Postponing Hearing.Certificate of Svc Encl ML20041F0871982-03-10010 March 1982 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Addl Time Needed to Complete Discovery.Certificate of Svc Encl ML20041E1541982-03-0808 March 1982 Response Opposing D Marrack 820218 Motion for Review of Dates for Reopening Hearing & Continuance.Aslb Lacks Authority to Order Continuance Until Util Irrevocable Commitment Made.Certificate of Svc Encl ML20041E1741982-03-0505 March 1982 Brief Opposing R Alexander Appeal from ASLB 820112 Order Denying Petition to Intervene.Aslb Did Not Abuse Discretion in Denying Petition.Certificate of Svc Encl ML20041E1201982-03-0505 March 1982 Motion for Order Directing Applicant to Provide Forthcoming Bechtel Quadrex Rept Review.Rept Pertinent to Remaining Issue.Certificate of Svc Encl.Related Correspondence ML20049H8881982-03-0101 March 1982 Response Opposing D Marrack 820213 Motion for Review of Dates for Reopening Hearings & Continuance.No Commission Regulations or Atomic Energy Act Provisions Require Applicant Irrevocable Commitment.Certificate of Svc Encl ML20041C0671982-02-22022 February 1982 Response Opposing Tx Pirg 820209 Motion for Addl Time to File Proposed Findings of Fact & Conclusion of Law.Motion Mooted by Tx Pirg Filing Proposed Findings on 820212. Certificate of Svc Encl ML20041B4821982-02-22022 February 1982 Response Opposing Tx Pirg 820209 Motion for Addl Time to File Proposed Findings of Fact & Conclusions of Law.Schedule Already Extended in Consideration of Length of Record.No New Development Set Forth.Certificate of Svc Encl ML20041B5901982-02-13013 February 1982 Motion for Postponement of All Action on CP Application Until Applicant States That Util Irrevocably Committed to Building Plant If CP Received.Certificate of Svc Encl ML20040H0761982-02-0909 February 1982 Motion for 30 Addl Days to File Proposed Findings of Fact & Conclusions of Law.Length of Record Necessitates Extension. Decision Would Not Be Delayed Since Addl Hearings to Be Held in Apr 1982 ML20040E2781982-01-29029 January 1982 Requests for Clarification Re R Alexander 811130 Petition to Intervene.J Silberg Indicates That Order Denying Petition Issued,But No Order Has Been Served.Certificate of Svc Encl ML20039B7481981-12-17017 December 1981 Response Opposing Tx Pirg 811207 Motions for Addl Testimony, Further Development of Record & Admission of New Contention. Motion Superficial Attempt to Delay Proceeding & Totally Devoid of Merit.Certificate of Svc Encl ML20062M6441981-12-14014 December 1981 Response Opposing Doherty 811015 Renewed Motion for Addl Evidence on Tx Pirg Contention 31.Doherty Failed to Comply W/Aslb 811110 Order.Motion Is W/O Merit & Would Cause Unnecessary Delay.Certificate of Svc Encl ML20039B0771981-12-0707 December 1981 Renewed Motion for Addl Evidence on Tx Pirg Addl Contention 31 Re Applicant Technical Qualifications.Specifies Portions of Quadrex Rept,Indicating Organizational Changes That Should Be Made.Certificate of Svc Encl ML20062M6241981-12-0707 December 1981 Motion for Tx Pirg to Present Addl Evidence,To Order Applicant to Serve Tx Pirg W/Quadrex Rept & to Rule That Need for Power Is Tx Pirg Contention.Alternatively,Requests Admittance as Tx Pirg Contention.W/Certificate of Svc ML20033B3381981-11-27027 November 1981 Response Opposing Doherty 811106 Motion to Require Applicant to Submit Addl Testimony on Need for Power.Motion Should Be Considered as Motion to Reopen Record.Issue Not Significant to Warrant Reopening.W/Certificate of Svc ML20033C0201981-11-25025 November 1981 Response Opposing Applicant 811120 Response to Doherty Motion for Addl Testimony.Motion Was Not Motion to Reopen Record Since Motion Filed Prior to Hearing Closing.Burdens Cited Under Motion to Reopen Inapplicable ML20033C0091981-11-25025 November 1981 Request for Leave to File Response to Applicant 811120 Response to Doherty Motion for Addl Testimony on Need for Power.Applicant Response Is Erroneous & Time for Completion of Evidentiary Hearing Short.Certificate of Svc Encl ML20038A8841981-11-20020 November 1981 Response Opposing Doherty 811106 Motion for Addl Testimony on Need for Power.Pleading Construed as Motion to Reopen Record.Burden of Explaining Why ASLB Would Reach Different Result Not Met.W/Certificate of Svc.Related Correspondence ML20032C1801981-11-0505 November 1981 Motion to File NRC Responses to Doherty Motion for Addl Evidence on Tx Pirg Addl Contention 31 One Day Late ML20032B3721981-10-30030 October 1981 Reply Opposing Doherty 811015 Motion to Reopen Record on Tx Pirg Addl Contention 31.Doherty Failed to Establish That Rept Controverts Specific Testimony & That Issues Are Beyond Scope of Contention.W/Certificate of Svc ML20032B3411981-10-30030 October 1981 Joint Motion to Establish Schedule to File Proposed Findings of Fact & Conclusions of Law.Parties Should Be Put on Notice of Schedule for Planning Purposes.Certificate of Svc Encl ML20031H0991981-10-15015 October 1981 Motion for Addl Evidence on Tx Pirg Addl Contention 31 Re Applicant Technical Qualifications.Addl Testimony Sought Due to Recently Released Rept on Design Deficiencies at South Tx Project ML20031A9381981-09-18018 September 1981 Request That ASLB Issue Order Re Mccorkle Contentions 14 & 17,TX Pirg Addl Contentions 6 & 40 & Doherty Contentions 5, 15,38-B,43 & 44,that Applicant & NRC Statements of Matl Facts Will Not Be Subj to Litigation.W/Certificate of Svc ML20010G1101981-09-0303 September 1981 Response to ASLB Request Re Positions on ALAB-640.Radon Emissions Determined by ALAB-640 Constitute Significant Addl Environ Impact.Certificate of Svc Encl ML20010F4791981-09-0303 September 1981 Response Opposing Further Consideration of Radon Releases. NRC Analysis of Radon Releases in Final Suppl to Fes Satisfies NEPA Requirements,Complies W/Commission 780414 Order & Supplies Sufficient Info.Certificate of Svc Encl ML20010C3341981-08-13013 August 1981 Response in Support of Applicant 810805 Motion to Strike Substantial Portion of D Marrack Supplemental Testimony. Statements Are Arguments & Not Testimony.Certificate of Svc Encl ML20010A1171981-08-0505 August 1981 Motion to Strike Marrack Prefiled Testimony.Testimony Is Not Specifically Responsive to F Sanders 810205-06 Testimony. Certificate of Svc Encl.Related Correspondence ML20009B2001981-07-13013 July 1981 Response Opposing Doherty 810622 Motion to File Contention 57 Re Vulnerability of Control Sys in Nuclear Power Plants to Electromagnetic Pulses Per Nuclear Detonations.Issue Does Not Warrant License Revisions.Certificate of Svc Encl ML20009B2031981-07-0707 July 1981 Response in Opposition to Intervenor Doherty 810622 Request for Leave to File Contention 57.No Good Cause Shown for Late Filing & No Specificity Provided.W/Science News Article & Certificate of Svc ML20005B3801981-06-22022 June 1981 Request for Leave to File & Submission of Contention 57 Re Vulnerability of Control Sys to Electromagnetic Pulses. Issue Has Not Been Made Public Until Recently.W/Certificate of Svc ML20004B6091981-05-27027 May 1981 Response Opposing Doherty 810423 Motion to Add Late Filed Contention 56.Postulated Accident Only Applicable to B&W Design Facility & Allens Creek Has Mark III Containment Design.Certificate of Svc Encl ML19347F4941981-05-0808 May 1981 Reply Opposing Doherty 810423 Filing Re Contention 56, If Filing Is Motion to Add Late Filed Contention. Contention Refs Alleged Problem at Browns Ferry Which Is Not Applicable to Mark III Containments.W/Certificate of Svc ML20008F7671981-05-0808 May 1981 Response Supporting Applicant 810422 Motion to Preclude Jm Scott Testimony.Aslb 810407 Order Forbids Scott to Serve as Counsel & Expert Witness.Certificate of Svc Encl ML19347F4661981-05-0808 May 1981 Response Opposing Doherty 810423 Motion to Reopen Record on Need for Power Contention.Aslb Should Issue Order That Motion Is Moot & Direct Applicant to Update Testimony on Need for Power Testimony Later.Certificate of Svc Encl ML20003H9551981-04-29029 April 1981 Motion for Order Adopting Specific Procedures to Govern Conduct of cross-examination During Health & Safety Phase of Proceeding.Procedures Will Ensure cross-examination Not Cumulative.W/Proposed Order & Certificate of Svc 1982-07-02
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0/79 UNITED STATES OF AfiERICA NUCLEAR REGULATORY C0fiMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING & POWER COMPANY
)
Docket No. 50-466
)
(Allens Creek Nuclear Generating
)
Station, Unit 1)
)
NRC STAFF'S RESPONSE TO JOHN F. DOHERTY'S CONTENTION #45, NEED FOR ADDITIONAL LATERAL SUPPORT IN THE REACTOR CORF The NRC Staff opposes what is, in effect, the December 3,1979 motion to admit a new contention (#45) filed by John F. Doherty in the captioned pro-ceeding. The newly proffered contention concerns an alleged insufficiency in the lateral support of the Allens Creek reactor core resulting in an inability of the core to withstand the lateral force due to flashing "which occurs near the end of the subcooled blowdown portion of the LOCA transient."
The contention is based upon Mr. Doherty's review of NUREG/CR-1018 and the recomendations contained therein.
However, Mr. Doherty has, we believe, misread the cited report.
In using NUREG/
CR-1018 as the basis for his contention, he has relied upon the analysis and recommendations specified for a PWR (Allens Creek is, of course, a BWR).
Appendix A of the report (p. A-2), in the section " Crossflow Velocity Force Calculation,"specifically indicates that:
Differential flashing may cause lateral fluid velocities in the core region of a pressurized water reactor during a postulated loss-of-coolant accident near the end of the subcooled blowdown region.
l 7@l0 t =s'=5
This calculation is used to determine the additional margin for lateral loads as stated:
(a) 30% for an SSE impact load or (b) a factor of 1.3 for the LOCA or combined SSE-LOCA analyses. The report indicates (p.14) that:
Additional margin, such as discussed above for lateral LOCA forces is not applicable if a linear bounding analysis can be justified.
Linear response analysis techniques are well defined.
For the Allens Creek facility, such a linear analysis has been approved by the Staff after its review of the GE topical report NEDE-21175-P, "BWR 6 Fuel Assembly Evaluation of Combined SSE and LOCA loadings."
In the Staff's evaluation of that report (see attached letter from 0.D. Parr to G.G. Sherwood, dated May 17, 1978), we state:
Unlike in a PWR, the blowdown load due to pipe rupture in a BWR is expected to be small. Consequently, the analysis revealed no lateral impacting between the fuel assemblies.
This makes the fuel assembly response independent of gap size between the assemblies and permits a relatively simple linear analysis.
Since the analysis and recommendations on which Mr. Doherty bases his contention relate solely to PWRs, the Staf f urges the Board to deny the motion to admit contention #45.
Respectfully submitted,
~k k-
[} L.
l l Stephen M. Schinki Counsel for NRC Staff Dated at Bethesda, Maryland, this 20th day of December,1979.
UNITED STATES OF AMERICA NUCLEAR REGULATURY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING & POWER COMPANY Docket No. 50-466 (Allens Creek Nuclear Generating
)
Station, Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S RESPONSE TO JOHN F. D0HERTY'S CONTENTION #45, NEED FOR ADDITIONAL LATERAL SUPPORT IN THE REACTOR CORE" in the above-captioned proceeding have been served on th'e following by deposit in the United States mail, first class, or, as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal mail system, this 20th day of December,1979:
Sheldon J. Wolfe, Esq., Chairman
Atomic Safety and Licensing Board Panel Asst. Attorney General for the U.S. Nuclear Regulatory Commission State of Texas Washington, DC 20555 P.O. Box 12548 Capitol Station Dr. E. Leonard Cheatum Austin, Texas 78711 Route 3, Box 350A Watkinsville, Georgia 30677 Hon. Jerry Sliva, Mayor City of Wallis, Texas 77485 Mr. Gustave A. Linenberger
- Atomic Safety and Licensing Board Panel Hon. John R. Mikeska U.S. Nuclear Regulatory Commission Austin County Judge Washington, DC 20555 P.O. Box 310 Bellville, Texas 77418 R. Gordon Gooch, Esq.
Baker & Botts Mr. John F. Doherty 1701 Pennsylvania Avenue, N.W.
4327 Alconbury Street Washington, DC 20U06 Houston, Texas 77021 J. Gregory Copeland, Esq.
Mr. and Mrs. Robert S. Framson Baker & Botts 4822 Waynesboro Drive One Shell Plaza Houston, Texas 77035 Houston, Texas 77002 Mr. F. H. Potthoff, III Jack Newman, Esq.
1814 Pine Village Lowenstein, Reis, Newman & Axelrad Houston, Texas 77080 1025 Connecticut Avenue, N.W.
Washington, DC 20037 D. Marrack 420 Mulberry Lane Carro Hinderstein Bellaire, Texas 77401 8739 Link Terrace Houston, Texas 77025 1661 280
=e-o e--
Margaret Bishop Texas Public Interest 11418 Oak Spring Research Group, Inc.
Houston, Texas 77043 c/o James Scott, Jr., Esq.
8302 Albacore Glen Van Slyke Hot!ston, Texas 77074 1739 Marsnall Houston, Texas 77098 Brenda A. McCorkle 6140 Darnell J. Morgan Bishop Houston, Texas 770/4 a
11418 Oak Spring Houston, Texas 77043 Mr. Wayne Rentfro P.O. Box 1335 Stephen.A. Doggett, Esq.
Rosenberg, Texas 77471 Pollan, Nicholson & Doggett P.O. Box 592 Rosemary N. Lemmer Rosenberg, Texas 77471 11423 Oak Spring Houston, Texas 77043 Bryan L. Baker Charles Andrew Perez
,1118 Montrose Houston, Texas 77019 1014 Montrose Blvd.
Houston, Texas 77019 Robin Griffith 1034 Sally Ann Leotis Johnston Rosenberg, Texas 77471 1407 Scenic Ridge Houston, Texas 77043 Elinore P. Cummings 926 Horace Mann Atomic Safety and Licensing
- Rosenberg, Texas 77471 Appeal Board U.S. Nuclear Regulatory Comnission Mrs. Connie Wilson Washington, DC 20555 11427 Oak Spring Houston, Texas 77043 Atomic Safety and Licensing
- Board Panel Patricia L. Streilein U.S. Nuclear Regulatory Commission Route 2, Box 398-C Pashington, DC 20555 Richmon, Texas 77469 Docketing and Service Section
- Carolina Conn Office of the Secretary 1414 Scenic Ridge U.S. Nuclear Regulatory Co rnission Houston, Texas 77043 Washington, DC 20555 Mr. Robert Alexander Mr. William J. Schuessler 10925 Briar Forest #1056 5810 Darnell Houston, TX 77042 Houston, Texas 77074 b
/
w Stepherf M. Schinki Counsel for NRC Staff 1661 281
.a Distribution w/ enclosure -
Central File u M. Rushbrook S.Kim NRC PDR P.. Capra LWR #3 File R. Boyd BCC:
JBuchanan D. Crutchfield TAbernathy R. Diggs ACRS (16)
S. Hanauer Central Files - Topical Reports Dr. G. G. Shemood Manaaer - Safety and Licensing General Electric Company 175 Curtner Avenue San Jose, California 95114
Dear Dr. Sherwood:
SUBJECT:
STAFF EVALUATION OF TOPICAL REPORT tlEDE-21175-P Al:D !!ED0-21175 We have completed our review, through Amendment 2, of General Electric topical report llEDE-21175-P (proprietary) and llEDD-21175 (non-proprietary version), " BUR /6 Fuel Assembly Evaluation of Conbined SSE and LOCA Loadings." This report describes: (1) seismic and blowdown loadings, (2) analytical methods used to determine fuel assembly structural response to the loads, and (3) design limits used to detennine the a4quacy of BUR /6 fuel assemblies.
Based on our review, we conclude that the analytical methods described in this report are acceptable for reference in license applications as discussed in the enclosed staff evaluation. We have not reviewed the generic fuel assembly design limits since we have not yet completed developing general acceptance criteria for the design limits. The seismic and blowdown loads were not reviewed and must be considered on a plant-by-plant basis.
In addition, the analysis of the potential fuel bundle liftoff from the core plate for a postulated steam line break will be evaluated seaarately and a report will be issued on the subject at a later time.
The staff does not intend to repeat its review of this report when it is referenced in specific license applications, except to assure that the report is applicable to the specific plant involved. When the proprietary report is used as a reference, both the proprietary and the non-proprietary version of the report must be referenced.
In accordance with established procedure, it is requested that General Electric issue a revised version of this report to include: Amendments 1 and 2, an supplementary information provided acceptance letter, and the staf f e DUPLICATE DOCUMENT
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