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Certification by Emile Julian Providing a Certified Copy of the Transcript of 11/12/1975 Aslbp Hearing in South Texas Project Adjudicatory Proceeding (Docket Nos. 50-498 & 50-499-OL)
	ML18235A041
Person / Time
Site:	South Texas
Issue date:	07/18/1989
From:	Julian E; NRC/SECY
To:	;
	SECY/RAS
References
	50-498-OL, 50-499-OL
	Download: ML18235A041 (283)
	v • d • e

{{#Wiki_filter:OFFICE OF THE SECRETARY UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 CERTIFICATION I hereby certify that I am employed by the United States Nuclear Regulatory Commission (NRC), that I am the Acting Chief of the Docketing and Service Branch of the Office of the Secretary and as such I am the official custodian of the adjudicatory docket maintained by the Secretary of the Commission in the discharge of his responsibilities under 10 CFR Sec. 2.702. The official NRC adjudicatory docket includes the document described below, a copy of which is attached. I further certify that the attached document is a true and correct copy and is kept by the Docketing and Service Branch of the Office of the Secretary in the regular course of business. Transcript of hearing before the Atomic Safety and Licensing Board, including attachments, dated November 12, 1975, docketed November 14, 1975 and containing pages 462-575. The transcript covers a portion of the hearing held by the Licensing Board in the South Texas proceeding (Docket No. STN 50-498/499-0L) in Bay City, Texas on Wednesday, November 12, 1975. Emile L . .:i:ifi_ian Date I hereby certify that the person whose signature appears above is the official custodian of this information on file in the Office of the Secretary to which certifica

on is made and was official custodian at the time of executing th above certificate.

Attachment:

As stated L_ Assistant Secretary Secretary of the If Date" \ "-:-. < ./~?~ *\"~ . ,"'* ,, .. " . ,.. ....... NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: HOUSTON LIGHTING AND POWER CO., et al. .STN STN 50-498 50-499 462. -* .. 575 ' *~,! ?]*-... '*' , l~, 6 191 :..N K: ro NR ,; UN I TED STAT2 S OF A..'-1ER ICA NUCLEAR REGULATORY COMMISSION

* In t~e M atter of: HOUSTON LIGHTING AND POWER CO., et al. Docket Nos. STN 50-498 STN 50-499 (South Texas Project, Units 1 and 2} ------------------X Oasis Motor Hotel Highway 35 West Bay City, Texas Wednesday, 12 November 1975 Hearing in the above-entitled matter was convened, 'i 14 .. pursuant to notice, at 10:00 a.m. i 15 '.; BEFORE.: I! 1'. 16 ;j 1, 17 i i I I i i 18 !' I MRS. ELIZABETH S. BOWERS, Chairperson Atomic Safety and Licensing Board--FREDERICK J. SHON, Member DR. CADET H. HAND, Member 19 1 i i APPEARANCES:

20 1 1 I 21 I I 22 1 23 MELBERT SCHWARZ and GREGORY COPELAND, Esqs., Baker and Botts, 3000 One Shell Plaza, Houston, Texas 77002; and JACK R*. NEWMA:N, MAURICE AXELRAD and " J. A. BOu"KNIGHT, JR., .. Esqs., Lowenstein, Newman, Reis and Axelrad, 1025 Connecticut Avenue, N. W., Washington, D. C. 20036; on behalf of the Applicant, Houston Lighting & Power. 24 1, 11 Ace-Federal Reporters, Inc. II 25 ROBERT L. PENDERGRAFT and PAUL G. GOSSELINK, Esqs., Office of the Attorney General, Supreme Court Building, Austin, Texas 78711; on behalf of the State of Texas. ,1 i I ! r o Ace-Federal Reporters i ., *1 ] I i' .I II 2 1 1 I 11 3 i i 1, 4*;1 . 11 :1 1 11 d 8 ii I* 9 11 10 , , 11 II IJ q 12 11 , 1 !1 13 i i ;1 i! 14 1: '1 !I !i 15 i 1 1 \! 16 Ii I i !l 17 j\ 18 !! 19 1 20 i j 21 I I 22 I I 2~ 24 I nc. 25 , I 4 63 APPE ARA:':-JCES: (con tinu ed) I VE R S TR I D I RON and ALBERT V. CARR , Esq s., Of f ic e of the Executi ve L e gal Director, N ucl ea r Re gulat ory Corrunission, Washi n gton, D. C.; on behalf of th e Nuclear Regulator y Staff. .. I ' ro 21 221 23 241 ~ce-Federal Reporters, Inc. I 251 WITNESS George W. Oprea, Jr. James R. Sumpter Douglas W. Peacock Howard Freeman David G. Barker R. D. Gauny Richard J. Klapper D. R. Betterton Dr. Walton A. Rodger John T. Mooney C O i"i T E N T S Gordon L. Chipman, Jr. and Marvin Dunenfeld, and Ronald Gamble and Dr. Jai Raj Rajan Alex W. Dromerick J. S. Boegli Robert L. Waterfield E X H I B I T S DIRECT 485 494 and 497

492 509 519 523 527 512 530 539 544 549 551 506 NUMBER FOR IDENTIFICATION Applicant's No. 7 -Application as amended by amendments 1 thru 3 485 Applicant's No. 8 -Preliminary Safety Analysis Report as amended by amend-ment 1 thru 33 485 Applicant's No. 9 -RESAR-14 reference safety analysis report as amended by amendments 1 thru 19 485 Staff's No. 5 -Safety Evaluation Report related to construction of t h e South Texas Project. Staff's No. 6 -Safety Evaluation Report related to construction of the South Texas Project, Supplement

-No. 1 540 540 4 G~ RECEIVED 491 496 501 548 548 C R6 1 91 FP: bw l Sl \ 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ,!.,:~ .Jerol Reporters , Inc. 25 P P O C E E D I N G S MRS. BOhTER S: O n Jul y 19 , 19 7 4 , the C ornmis si o n pub lis hed i n the F ederal ?egi s ter 39 F R 26472 , a No tice of Hea ri ng o n a n a pp l icat i o n f o r a cons t r uct i o n pe r mit. A p r eheari ng confer ence wa s h e l d o n F e b rua r y 6 , 1975, and an e v identiar y hearin g on en v ironmental issu e s and safet y issues related to site suitability was held on April 22 : and 1975. After the hearing the Regulatory Staff requested that the Board defer its decision until the Sta ff could issue its position on the applicability to the South Texas Project, a new Commission regulation on "as low as practicable' radiological releases. The record was later reopened to receive the new information and the decision was issued on August 7, 1975. That partial initial decision authorized the issuance of a limited work authorization to the applicant. This meant that the Applicant could proceed at its own risk to perform certain preliminary work at the site. On October 24, 1~75, the Board issued the notice for the evidentiary -hearing on health and safety issues. I read those issues at the prehearinq conference on February~' 1975, but since some time ha~ passed, I will repeat them quickly now: We must determinine, one, whether,in accordance with A-:ce I I bw2 1i l I 2 J 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 _ Jerol Reporters, Inc. 25 4 ( -have described the p r opos ed design of the f2.cllitie.'-', .i.:1cluc:(;: but not limited to the principal architectur a l and engineering crit er ia for the design, and hav e identi fied the major features or components incorporated therein for the protection of the health and safety of th e public; b, such further technical or design information as may be required to complete the safety analysis and which can reasonable be left for later consideration, will be supplied in the Final Safety Analysis Report; c, safety features or components, if any, which require research and development have been described by the Applicants and the Applicants have identified and there will be conducted a research* and development progra~ recently designed to solve any safety questions associated with such features or components; and, d, on the basis of . the fore.going there is reasonable assurance;that, (1) such safety questions will be satisfactorily resolved at or before the latest date stated

in the application for *completion of constr\1ction of the proposed facilities; and (2), taking into consideration the criteria contained in 10 CFR Part 100, the proposed facility can be constructed and_ operated at the proposed location without undue risk to the health and safety of the public. Number 2, whether the Applicants are technically qualified to design ad construct the proposed facility.

b'.-i3 II lj I I I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace-, .,derol Reporters, Inc. 25 Number 3 , whether th o Applicants are f inancially qualified t o designilld construct the proposed facility; and Last, number 4, whether the issuance of permits for construction of the facility will be inimical to the co mmon advantage and security or to the health and safety of the public. The notice stated that the public is invited and the limited appearance statements will be accepted. And oral presentations will be limited to five minutes, but written statements without limitation on length, may be inserted in the docket. We will call for limited appearances shortly. I have introduced the Board on two prior occasions, but some of you may be *attending for the first time today. I amElizabeth Bowers .. I am a lawyer. I am a member of the Kansas Bar and for the last 24 years I have beeninvolved in federal administrative hearings. The first 15 years as a trial attorney, and since then as a presiding officer under various titles. On my left is Mr. *Frederick J. Shon. His education and experience has beenin the field of nuclear reactors. Prior to joining this panel on a ful~-time basis, he was the Assistant Director for Nuclear ~acilities, Division of Operation Savety, U.S~ Atomic Energy Commission. I think I failed to mention that his background, his bw4 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace-r.,derol Reporters, Inc. 25 educa ti onal b a ck g r ound , is bo t h in phy s i cs a nd i,1 e ng ineerin g. On my right is Dr. C a det H. H an d, wh o is t he Director of the Bode ga Bay M.~rine Labor a tor y for ,t he University of California at Berkeley. I am going to tell a little secret that I was able to find out from Dr. Hand that I think you might be interested in. One of the reasons that Emperor Hirohito wanted, to visit America was to meet Dr. Hand, who he has been corresponding with for many years in the area of marine biology. So the Emperor invited Dr. Hand to San Francisco and they exchanged qifts and had an hour's discussion through an interpreter on marine biology, which I think is a very interesting thing. DR. HAND: We didn't say a word about nuclear reactors or bombs. MRS. BOWERS~ I would ~ike to now call for appearances of the parties. Is the Applicant present? MR. SCHWARZ: Yes, Mrs. Bowers. With the Board's permission, I would suggest I remain seated with reference to the use of the microphone. MRS. BOWERS: Fine. MR. SCHWARZ: Mrs.* Bowers and Members of the Board, my name is Melbert D. Schwarz ..

I am appearing on behalf of the Applicant, Housten Lighting and Power Company, Project I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A:e-rt:Xlerol Reporters, Inc. 25 -l ( ') Manage r for the South Texas Pr oject. The ~artic ip~nts in the project are the Public Servic e Board of San Anto,1io , Central Texas Po w er and Light C ompa ny, Ci ty of A us tin, Te xas , and the Applicant.

I am with the Houston firm of Baker & Botts, located at 3000 One Shell Plaza, Houston, Texas. Telephone 713 229-1234. Appearing with me today are Gregory Copeland. His telephone number is 713 229-1301. Same address. Also appearing on behalf of the Applicant are Mr. Jack R. Newman, Mr. !vl.aurice Axelrad and Mr. J.A. Bouknight, Jr., of the Washington firm of Lowenstein, Newman, Reis and Axelrad. Messrs. Newman, Axelrad and Bouknight have as their address, 1025 Connecticut Avenue, Northwest, Washington, D. C. 20036 and their telephone number is 202 833-8371. Each of us have filed a formal appearance in this proceeding. MRS. BOWERS: Thank you, Mr. Schwarz. Is the State of Texas represented today? MR. PENDERGRAFT:

May it please the Board, Mrs. Bowers, my name is Robert L. Pendergraft.

To my left ' ' is my co-counsel, Mr. J;>aul G~ Gosselink. We are from the Office of the Attorney General, State of Texas, Supreme Court Building, Austin, Texas 78711. Area Code 512 475-4143. MRS. BOWER8: Thank you, Mr. Pendergraft. b w6 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A c~* ~erol Reporters, Inc. 25 Is the Nuclear ReguLd.:ory C or ,:-:-1 issic;, :=,:. .. :, C" present? MR. STRIDIRO N: Yes. I am Iver Stri diron. On my l eft is Al b e rt C a rr. Toge t her we r epre se nt the S t aff ' . .. of th e N ucl e ar Regul at or y Co mm i ssi on. MRS. BOWERS: The A p plicant distributed a propo se d agenda just prior to the comrnence m tn of this proc e eding. The Board has reviewed it andfinds it satisfactory. Mr. Pendergraft, have you had a chance to look over it? MR. PENDERGRAFT: Yes, we have. It is satisfactory with the State. MRS. BOWERS: Mr. Stridiron? MR. STRIDIRON: It is also satisfactory with the Staff. MRS. BOWERS: Number 3.on the agenda: opening statements. Mr. Schwarz, do you have an opening statement? MR. SCHWARZ: Yes. We do, Mrs. Bowers. On behalf of the participants in the South Texas Project, we would like to welcome the Board to South Texas again. My opening statement is directed at some suggested procedures for conduct of the hearing, and a general overview of the direct case which will be presented by the Applic~nt. ii ii I, I I I, I I i I 2 I i b w 7 J I 4 .. 5 6 7 8 9 10 l l 12 13 14 15 16 17 18 19 20 21 22 23 24 .l.~e-rederol Reporlcrs, Inc. 25 Our dir e ct case will es~cr tially be in wr i tt e n form , as required by t he Commission's rule s, the testim o ny co m prisi ng the A pp licant's direct cas e h as be en f urnis hed previousl y.in writin g to the .B oard and to the p a~t ies., On November 4th, the Board issued nine quesitons to the Applicant and to the Staff, advising that the Board would expect the parties to present.witnesses who would be responsive to these questions. ~71 Applicant transmitted under cover of a letter dated November 5, 1975, to the Board and parties, a book of prepared testimony. The book included the qualifications of each of Applicant's primary witnesses, including those witnesses who will sit on the panel of technical experts presented by the Applicant for responses to the questions previously submitted by the Board and other questions that the Board may have. It shall rely on these materials and these witnesses in the presentation of our direct case. As a matter of procedure, subject to the Board's approval, of course, we propose the identification, swearing and qualification of each of Applicant's primary witnesses. At that time, we propose to identify. Applicant's exhibits. As I have already indicated, the primary testimony in support of the Applicant's direct case has been submitted to the Board and the parties in writing. In the interest of providing a better overall I; ti I fl bh'8 ii I I 2 I 3 4 .. 5 6 7 al 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace*, -.ieral Reporters, Inc. 25 under s tanc1 ir-; g fo r tL c,~ -~, of c<. *, ~n:Ji c, ! , an oppo rt u!1ity .to r c2d thec.;c' n;2,i>::'] ~ic::J,*.1 of ou r witnesses to provide u brief oral su mrn.ary of his prepared, substanti ve t e sti mony. In conjunction wit h this su~nary , the appropriate witness will provide the Applicant's r espon se to the questions submitted by the Board on November 4. Our direct case will begin with the testimony of Mr. George W. Oprea, Jr., Executive Vice-President of Houston Lighting and power Company, Project Manager. Mr. Oprea will testify generally concerning the background of the South Texas Project, financial qualifications of the participants, national security considerations, the organization of the Applicant itself, and the undertaking of the four participants in the project and o~ the Applicant, as project manager. Mr. Oprea will also sponsor. the Application. Mr. Oprea will not be a rart of our technical panel, and we suggest that the Board may care to ask questions of Mr. Oprea concerning his testimony and perhaps the parties cross-examine Mr. Oprea, if they have any cross-examination, at the conclusion of his. testimony.. That is. the discretion of the Board and the parties. It is our intention to present a panel of witnesses, then, comprised of Dr. J. R. Sumpter, Mr. D. G. Barker,* bv: S 2 3 4 5 6 7 8 9 10 1 l 12 13 14 15 16 17 18 19 20 21 22 23 24 t..-:e *rol Reporters, Inc. 25 ii 1, Ii I, I: Ii 1: I :1 i 473 all of !Ioust on Lightin<:; and Power Company , 2nd Dr. Douglas W. Peacock of We stinghouse E l ectric Co r por atio n , Dr. Walte r A. Rodge r of App li cant's co nsu ltants , Nuclear S afety Asso ci ates , M r. J o hn T. Mooney of th e a rch itect-engineers and constructors, Bro w n and Root, In c., and Mr. E. Douglas Schwantes, Jr., of Applicant's consul ta nts, Woodward-Clyde. Dr. Sumpter, who is man a ger for Houston Lighting and Power Company will address the safety anal y sis for the South Texas project and the technical qualific_ations of the Applicant and architect-engineer and constructor. Dr. Sumpter will also sponsor the Preliminar y Safety Analysis Report. Dr. Peacock, who is Manager, Reacto~ Protection in the Pressurized Water Reactor* Systems Division in the Westinghouse Electric Corporation, will discuss the RESAR-41 design and will sponsor t_he RESAR-41 Safety Analysis Report. Dr. Peacock will also' provide the Applicant's response to the first five written questions submitted by the Board. That is, through 5-A. Mr. Barker, Manager. of Quality ~ssurarice Department or Houston Lighting and power Company, will present testimony on the quality assurance programs of the Applicant and the architect-engineering and constructor. bwlO 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A:e*. _ ..,erol Reporters, In:. 25 174 Dr. Rod ge r of Nucl ea r Safely ~ssoci~l0s , A9plicant' s concultant , will address the issu e o:F co:-: l; ,,!1c::-with Appendix I. W hi le we pe rcei ve tha t th e l as t of the wr i tten .. qu es ti ons s u bmitt ed b y the Bo ard is e s sent i a ll y dir ec t ed to the Staff, Dr. Rodger also will provide Applic a nt's response to this written question. Mr. Gauny, Physicist for Rousting Lighting and Power Company,*will present testimony on occupational exposure at the South Texas Project plant. Mr. Klapper, supervising engineer of Nuclear Safeguards and Licensing fbr Houston Lighting and Power Company, will address the matters concerning interface between the South Texas Project and the RESAR-41 reference design. Mr. Betterton, Manager-of the Environmental tection Department for Houston Lighting and Power Company, will provide testimony concerning the monitoring program established to measure the settlement of £ability structures and to measure regional ground surface subsidence. Finally, Mr. Mooney, Engineering Project Manager assigned to the South Texas Project by the architect-engineer, Brown and Root, will verbally submit the Applicant's response to Question 5-B, 6 and 7, submitted by the Board . ... Each of these witnesses, along with Mr. Schwantes, b.11 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A:e*. ~erol Reporters, Inc. 2j i i 1: ,1 ' --....; /:: of our co r:sc1ltant , \'.'O,:>dw:ird -Clyc: 2 Cons1-.;lt a nls , ,*.1ill s c2-: v2 0:1 a panel of experts wh ich we s hall pres e:-it to resp ond to s u c h questi on s as th e Bo ard or p arti e s may h ave d uri ng t he ~o u r s e of the hearing. .. Mr. Mooney will also b e available to ans w er questions on plant design and engineering, while M r. Schwantes will be available to cover matters covering geotectonic evaluation of the site. Mr. Klapper will act as moderator of this panel. We believe that collectively our panel will be able to respond to all of the Board's questions. on heal th and safety issues. And at that time provide a reasonably balanced representation of the discipline and organizations whose work is reflected in the Preliminary Safety Analysis Report and in RESAR-41. As such*, we believe that they will be in a position to respond to the Board's questions. Nevertheless, these pa_nel members are backed by additional witnessesin our audiences, should the questions require supplemental information not readily available from the primary panel. We would suggest, however, that.prior to the presentation of this panel of technical experts for the purpose of responding to questions or cross-examination, the Staff's direct case be placed in evidence, reserving the b\'.'12 ESl 11 Ii " 1: Ji 11 'I 2 If 11 1, 3 ' I 4 5 6 7 0 9 10 11 12 15 16 17 18 19 20 21 22 23 24 Ace-.. J erol Reporters, Inc. 25 ,~ 7 E quest ions i :l c: re_., s s-e):a r1-i .. n:1 t i o n un dc-r both c1 in .. : cl c c.L c:3e s on heal th o;-i d sa fety m a tters , w hi ch h:, ve been r eceived i n evid en c e. It i s o u r t h ou g ht b y follow i ng this proc edu r e , th e Board w ill be in th e pos iti o n t o address q u e st ions t o th o s e me m b e rs o f e it her the Ap p lic an t or St aff's pa ne l best able to supply* the information sought b y the Boa r d. Finally, I note that we recognize the importance of limited appearances. We shall be prepared to respond to such appearances with sworn testimony on a schedule established by the Board, with due regard for the conveneince of those people who have taken the time and e f fort to appear. On behalf of the South Texas Project participants, I wish to state that we welcome this opportunity to provide information to this Board and to assist this Board in developing the sound record necessary to execution of the responsibilityes which have been assigned to it by the Nuclear Regulatory Commis.sion. Thank you. l! 'I I, i C ": J j 1 0 .:._ i! l! f 2 Ii I' fr ,-mk 1 1 11 ;!W d 1 I! 2 ,, II 3 II 4 I 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A.,:e-rt:derol Reporters, I nc. 25 4 7,, MR. PE N DE:XG RAFT: Only to say that on behalt of t h e Attorn e y General I welcom e all of y o u a ll back to Texas aga i n. lt's goo d to s ee you a gai n. Other th a n that , w e will w aive our op~ning st a te m ent. MRS. BOWERS: M r. Pen d ergratt, y ou look d if f e r ent. You lost your beard. Didn't you ha v e a beard? MR. P E N DERGRAFT: It's still there. It's just a lot shorter. MRS. BOWERS: Mr. Stridiron? MR. STRIDIRON: Yes, Mrs. Bowers, we do have an opening statement. The NRC ~tatf proposes to present our evidence through a panel of witnesies as we did earlier during the earlier evidentiary hearing. The panel we propose to offer is seated at my left and I would ask each member to rise as I introduce him. Alexander Dromerick. Joe Boegli. . Robert Waterfield. These gentlemeri already participated during the environmental part of the statement and their statement of qualifications are part of the record. The following members have not been sworn and at the appropriate time I will move they be sworn. Gordon Chipman, Marvin Dunenfeld, konald Gamble, and Jai Rajan. Thank you, gentlemen. We will also introduce two c rr r.-: l. 4 5 6 7 8 9 10 l l 12 13 14 15 16 17 18 19 20 21 22 23 24 .t..:e-~ed~rol Reporters , Inc. 25 p ie c es of documents will be sponsorec'i by J v ir. Dro n,-:c rick , the lice n~j_ng , manag e r_ for tt1is Commission. .. Testimon y in response to lU CFu Pa rt 50 will be sponsored in p~rt by Mr. Boegli and Mr. Wat erfield. Mr. Fairobent, who sponsors this docu ment , cannot be he re today because of a pre v ious appointment in anoth er proceeding. Therefore, with lea~e of the Board, Mr. uro me ric. again in his capacity as project manager, will sponsor Mr. Fairobent;s testimony as well as his statement of professional qualifications. In addition, the Staff prepared responses to written questions from this Board and Mr. Dromerick will sponsor these responses as one document. We also have availab-le today witnesses who can respond to any further questions by the Board or questions from the other parties. Each of the documents I mentioned earlier have been served ori the Board and the other parties, and the reporter has been supplied with the appropriate number of these docu-ments. That concludes my opening statement. MRS. BOWERS: Thank you, Mr. Stridiron. The next item on the agenda is to call for limited c r.r.-.' 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23 24 Ace-Federal R e porters, Inc. 25 ,, ii u.r 1 1.:cara:--1.ce s 1-*.a.te1: 1, 2r1 '.:.s. April , because there were several peopJe who hod written the Board r equesting perm i ssio n to make li m i ted app e arance state-.. **

i.-' m e n t s, w ho d i d n o t a ppea r at t ha t en v ir onmen t a l and s afe~y-related and sit e suit a bility h ea ring. ~o let me first start by calling thos e nam es. Susie Novosad. Arthur L. Guess. Roy H. Roussel. H. W. Stickland.

John H. Wilson. Bert C. Steves. Is she here, please? Well, then~ are there people here today who would be interested in making a limited appearance statement? If so, please raise your hand. The record will show no hands raised. I think I saw the Mayor of Bay City come in a few minutes ago. Isn't he the one that told us he had a tempo-rary job for 28 years? MAYOR GUSMAN: Got two more to add to that now. MRS. BOWERS:. Mr*. Schwa.r z I would yo1:1 like to proceed of would you like a brief recess? MR. SCHWARZ: We are ready to proceed, Mrs. Bowers. Mrs. Bowers, I as*k that the following persons be 11 11 1: 'I c: . .** -~1 i! I I I I 2 I j 3 4 5 6 7 8 9 10 11 I 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace-r .,0erol Reporters, Inc. 25 S',:orn as App lic ant's \*.ri tncs:..e:-::: :Ln th i,; D rocc cec; :J. be wel l i f eac li st and as his n0 r.12 i"' ca.Lled. 'f i 1i s rc:.ig:,:... . l :** i n i dentifying each w i tne s s. Mr. G eo r ge W. Op;ea , Jr. D r. J ames p. Sum~t er. M r. D. G. B a r k er. Mr. l{. D. Gau n y. M r. R. J. Clapper. Mr. D. R. B e tterton. All of th e se gentl e m e n are of Houston Li g htin g and Power Company. Dr. Douglas W. Peacock of Westinghouse Corpor a tion. Dr. Walton A. Rodger of Nuclear Safety Associates. Mr. J. T. Mooney of Brown & Root, .and Mr. E. Schwantes of Woodward Line. Mrs. Bowers, some of these witnesses were sworn before and their qualifications were placed in evidence. However, with the thought of having a complete record, both of the prior hearing and at this hearing, we hav submitted their qualifications again, in the booklet that was furnished. sworn? MRS. HOWERS: You are asking now that they be Is that right? MR. SCHWARZ: Yes. I' H ' c:*;,,.,-'.i i, ii l ; Ii 2 1 3 4 5 6 7 8 9 10 11 12 xxxxxx 13 14 15 16 17 18 19 20 21 22 23 24 /.(e*, ,verol Reporters, Irie. 25 lih ere u;x) .1 , GE OI-<.G E 1 11. 01-'REc*, , JE. J A.MEb R. SUMPTER , R. D. GA.UNY, R. J. KLAPPER D. R. BE T'I'ERTON, . DOUGL AS .. W. PEACOCK, WAL'I'ON A. RODGER, J. T. MOO NEY ._, and .. E. DOUGLAS SCHWANTES, JR. were called as witnesses and, having been first duly sworn, were examined and testified as follows: BY MR. SCHWAkZ: Q. Have each of you prepared a statement of your education and professional qualifications for introduction in this evidence? (Chorus of jeses.) M~. SCHWARZ: Statements of education and sional qualifications for each of these witnesses were included in the book of prepared testiomny submitted to the Board on September S. Mr. Oprea's qualifications are set forth on tab 4. Dr. Peacock's under tab 6, Mr .. Barkeris under tab y, Dr. Rodger under tab 8, Mr. Gaunyis under tab 9, C. ] I 2 ;I 3 11 11 I 5 6 71 8 9 10 l l 12 13 14 15 16 17 18 19 20 21 22 23 24 A:e-, ed<?rol Reporter~. Inc. 251 -~' .--, -,--.. -~. ..:...... g I a sk each of y ou, wore each r espe ctive st a te men t of e d u c a ti on a l a n d profe ssion a l qualific a tions pre pa r e d by you or und e r y our supe r vision? (Chorus of yeses.) Do any of you have any corrections or modifications or additions to those statements? (No response.) Are each of these statements correct and true to the knowledge ot your belief? (Chorus of yeses.) Do each of _you adopt your statement and qualifi-cations (Chorus of yeses.) M!{. SCHWARZ: I ask that George W. Oprea, Jr., James R. Sumpter, D. G. Barker, R. D. Gauny, R. J. Clapper, D.R. Betterton, Douglas W. Peacock, Walton A. Rodger, J. ~. Mooney, and E. Douglas Schwantes, Jr., appearing under tabs 4 through 13 of the prepared testimony submitted to the Board *, I be incorporated into the record as though read. I have furnished sufficient copies to the reporter. MRS. BOWERS: Thank you. Mr. Pendergraft, any objection? 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace-. _Jer o l R e p o r!ers , I n c. 25 : s no '----I.-:., *** MR. STR1D IK ON: No oh j c c t i o n. MRS. B OWEHS: ~he qual ific a t i o ns i den t ified wil~ be .. p hys i ca ll y in se rt ed i n the t ran scrip t as if re a d. i i l 2 3 4 5 6 7 8 9 10 E DUCAT I ON AL A ND PR OF ESSI ONAL QUAL I F I CATIONS George W. Op r e a , Jr. E xec utive Vic e P r es i den t Houston Lighting & Po w er Comp a n y My name is George W. Oprea, Jr. I am Ex ective Vice President of Houston Lighting & Power Compan y. In this capacity I am responsible for overall tion of the Engineering Department , Transmission & Distribution Department, Energy Production Department, Power Plant Engi ne ering & Construction Department, Energy Control and Dispatching Department, Quality Assurance Department, and Environmental and Utility Affairs Department. I am a 1952 graduate of Rice University and 11 hold a Bachelor of Arts and Bachelor of Science degree 12 in Electrical Engineering. I joined Houston Lighting & 13 Power Company that year in the Distribution Planning 14 Section of the Engineering Department. I later worked 15 in Computer Applications Engineering for System Planning, 16 and in March, 1965, was named Superintendent of the 17 Engineering Planning Division. I became the Energy 18 Control Center Project Manager in March, 1967, Manager, 19 Energy Control & Dispatching Department in June, 1970, 20 and Manager, Energy Control and Nuclear Program in 21 April, 1971. In November, 1971, I was elected Vice 22 President-Operations, and in January, 1973, I was 23 elected a Group Vice President. In December, 1974, I 24 was elected Executive Vice President and assumed my 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 present duties. I am a registered professional engineer in Texas, a senior member of the Institute of Electrical and Electronic Engineers and former member of the Computer Applications Subcommittee, a past Director and Past President of the Engineers Council of Houston, a member of the Association of Computing Machinery and of the Society of Information Display, a past member and Vice Chairman of Edison Electric Institute Computer Task Force, a member of the Houston Chamber of Commerce, the Atomic Industrial Forum, the American Nuclear Society, the Edison Electric Institute Executive Advisory Committee on Nuclear Power and the Texas A&M Research Foundation. I am a retired Captain in the Naval Reserve. My responsibilities in connection with the South Texas Project include general supervision of the project management team which reports to me through the General Manager, Power Plant Engineering & Construction Department, thus assuring planned coordination of related support activities including environmental planning. The corporate quality assurance department reports directly to me. I have also been a member or alternate member of the South Texas Project Management Committee and the forerunners of that committee since 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 the conunencement of studies on the feasibility of this Project in 1971. In th2se capacities I have been involved in the overall planning for the Project. I 1 2 3 4 5 SD[.:C,;TI c~;J .... L A~JD PR OF ESS I O~J.Z\i., QT.'l-.I...IF' IC,1.T I0'.';S James R. Sumpter Manager-Nuclea r Divisio n , Power Plan~ Engineer ing and Construction D epartment Houston Ligh ting & Pow e r Co m pany My name is James R. Sumpter. My business address is 611 Walker, Houston, Texas 77001. I am Manager -Nuclear Division of the Power Plant ing and Construction Department for Houston Lighting & Power Company. I joined the Company in August, 1972, 6 and am responsible for the nuclear system design, 7 engineering, safety analysis, licensing, and fuel 8 management for all Houston Lighting & Power Company's 9 nuclear power plants including the South Texas Project 10 Nuclear Generating Station, for which that Company acts 11 as Project Manager. I was also involved in the decisions 12 concerning fuel supply for that Project. 13 I received a Bachelor of Science degree in 14 Engineering Science from the Pennsylvania State Univer-15 sity in 1965, a Master of Science degree in Nuclear 16 Engineering from the University of Michigan in 1967 and 17 a Ph.D. in Nuclear Engineering from Texas A & M Univer-18 sity in 1970. My dissertation was concerned with the 19 study of xenon oscillations during power reactor tran-20 sient operation. 21 In the summers of 1964 and 1965 I was employed 22 at the Bettis Atomic Power Laboratory in the mechanical 23 and nuclear design of naval reactors. In the summer of 24 1967, I was employed at the Los Alamos Scientific 1 2 3 4 5 6 7 8 9 I I 10 I I 11 I 12 I i 13 I ,. 14 I I ! 1s 'I 16 I 17 il 18 ,! 19 1: 20 21 22 23 24 Laboratory as a research physicist concerned with the theoretical and experimental study of critical assembly designs. Intermittently from 1968-1972, I was employed part-time teaching radioisotope laboratory and matics courses at local high schools and colleges. From 1970-1972 I was employed as a Nuclear Analyst with Sargent & Lundy Engineers. I had sibilities involving radwaste systems design, health physics, shielding, radiation monitoring system design, equipment procurement, overall plant engineering design and the associated licensing for several nuclear power stations. I am a member of the American Nuclear Society, Sigma Pi Sigma, the Sierra Club and am Secretary of ANSI/N45-8.l, a subcommittee of ANSI/N45-8, Nuclear Power Plant Air Cleaning Components and Units. 1 2 E DUC ATI O NAL AND PROFESSIO~AL Q[JAL I?I C ATI ON S D. G. Barker Manager, Quality Assurance Department Houston Lighting & Po we r Company My name is D. G. Barker. My business address is 611 Walker, Houston, Texas 77001. I am the Manager, 3 Quality Assurance Department, responsible for the 4 development, implementation, management, and surveillance 5 of the Corporate Quality Assurance Program and the 6 South Texas Project Quality Assurance Plan. I report 7 directly to Mr. G. W. Oprea, Jr., Executive Vice 8 President. 9 I graduated from Texas A & M University in 10 1967 with a Bachelor of Science degree in Mechanical 11 Engineering and in 1968 received a Masters of Engineering 12 degree in Nuclear Engineering. While working on a BS 13 degree, I was employed by Union Carbide Corporation, 14 from 1965 to 1966, as a Mechanical Engineer in the 15 Engineering Machinery Group. My responsibilities were 16 in the areas of maintenance design, vibration analysis, 17 and economic analysis on process equipment. 18 From 1966 to 1968, I was employed as a Research 19 Assistant and later as a Coordinating Engineer at the 20 Nuclear Science Center under the Texas Engineering 21 Experiment Station of the Texas A & M University System. 22 There I performed work in the analysis, design, fabrica-23 tion and testing of equipment used in the Triga Reactor 24 Conversion. I also performed work in licensing, flux 1 measurements, activation analysis, health physics, 2 programming, gamma ray spectroscopy, and high energy 3 gamma ray attenuation. 4 In 1968, I joined the Nuclear Division of 5 Todd Shipyards Corporation as a Nuclear Engineer. In 6 this position, I performed analysis and calculations in 7 reactor physics, shielding, thermal hydraulics, mechan-8 ical design and vibrations in support of the N. S. 9 SAVANNAH Program. Other duties performed included 10 material evaluation, design review, physics testing, 11 refueling and operations technical support. Later I 12 was assigned as Project Engineer for the N. S. SAVANNAH 13 Core II where I was responsible for the supervision and 14 coordination of the efforts of engineers, technicians, 15 subcontractors and vendors involved in the evaluation 16 of the nuclear and mechanical adequacy of the N. S. 17 SAVANNAH Core II which included the redesign of the 18 fuel assembly, material procurement, the design of 19 modification fixtures, writing of procedures and test 20 specifications, establishing quality assurance require-21 ments, design and operation of fuel assembly testing 22 facilities and administrative and management functions. 23 From 1971 to 1972, I worked at the H. B. 24 Zachry Company as a Quality Assurance Supervisor assisting 1 2 3 4 5 6 7 8 9 10 11 12 in the establishment of the compan y's Q ualit y A ssurance Program. In this capacit y , I wrote sections of the H. B. Zachry Company Quality Assurance Manual, performed vendor audits and construction planning. Other duties in the office and in the field on power plant projects included estimating, job planning, engineering, cost accounting, welding engineering and preparation of job progress reports. In 1972, I joined Houston Lighting & Power Company as a Nuclear Engineer and in 1973, I was ap-pointed Manager of the Quality Assurance Department. 13 Texas. I am a registered Professional Engineer in I am a member of the American Nuclear Society 14 and the American Society of Mechanical Engineers. 15 16 17 18 19 20 21 22 23 24 1 Ej~2ational an d Professional Quali f ications R. D. Gauny H e alth Ph y sicist -N ucl ear Div ision, Houston Lighting & Power Company My name is R. D. Gauny. My business address 2 is 611 Walker, Houston, Texas 77001. I am the Health 3 Physicist in the Nuclear Division of the Power Plant 4 Engineering and Construction Department of Houston 5 Lighting & Power Company. I joined the Company in 6 June, 1974, and am responsible for health physics and 7 security for the South Texas Project Nuclear Generating 8 Station, for which Houston Lighting & Power Company 9 acts as Project Manager. 10 I graduated in 1967 from San Antonio College, 11 San Antonio, Texas, with an Associate of Science Degree 12 in Physics and Mathematics. From 1967 to 1969, I 13 worked for the National Science Foundation in an effort 14 to find and identify new sub-atomic particles. During 15 this same period, I conducted a Physics Laboratory for 16 Our Lady of the Lake College in San Antonio, Texas. In 17 1969, I obtained my Bachelor of Science in Physics and 18 Mathematics from Trinity University, San Antonio, 19 Texas. In 1971, I graduated with my Master of Science 20 Degree in Bio-physics (Health Physics specialization) 21 at Texas A & M University under a United States Public 22 Health Service Traineeship. Under this traineeship 2 3 extensive experience was obtained in the use of the 24 Texas A & M Nuclear Reactors, Cyclotron and Cobalt-60 1 irradiation facilities. In-depth studies w e re conducted 2 in radiation theory, instrumentation, shielding, isotop e 3 technolog y , radiation biology, radiation chemistry, and 4 federal and state regulations. 5 During 1971 and 1972, I managed the Instrumen-6 tation and Material Account a bility Branch at Charleston 7 Naval Shipyard. As Branch Head, I assumed the responsi-8 bility for the proper accountability and disposition of 9 radioactive material related to the Navy Nuclear Propul-10 sion Program. In this capacity, I developed standard 11 operating procedures to control the functions of the 12 group and assure compliance with naval rules and 13 regulations. 14 I joined Stone & Webster Engineering Corpo-15 ration in July 1972 as an Engineer in the Materials 16 Engineering Division. In October 1972, I was made the 17 Assistant Radiological Safety Officer for the 18 corporation. In May 1973 I was appointed Corporate 19 Radiological Safety Officer for U.S. operations. I 2 o organized the record keeping, training and auditing 21 practices of the Radiological Safety Office and developed 22 field work practices and procedures to protect the 23 personnel and to assure compliance with state and 24 federal regulations. I developed a three-volume Radio-1 logical Safety Manual detailing corporate policy, work 2 practices, record keeping procedures, and equipment 3 specifications. I also organized the Radiological 4 Safety Office system to utilize the computer for record 5 ma nagement. 6 In June of 1974, I joined Houston Lighting & 7 Power Company in the capacity of Health Physicist. I 8 have visited the sites and/or worked with twenty-seven 9 planned or operating commerical nuclear reactors at 10 fifteen sites, four navy nuclear plants, two test 11 reactors, and the navy training facility at Knolls 12 Atomic Power Laboratory. I am a member of the Health 13 Physics Society, the American Nuclear Society and the 14 National Physics Honor Society. 15 16 17 18 19 20 21 22 23 24 1 EDUCATIONA L AND PROFESSIONA L QUALIF ICATIONS R. J. Klapper S upervising Engin ee r, Nuc l ear S afegua r ds & Licensing Houston Lighting & Power C ompan y M y ~ame is R. J. Klapper. My business address 2 is 611 Walker, Houston, Texas 77001. I am the Super-3 vising Engineer of Nuclear Safeguards and Licensing in 4 Houston Lighting & Power Company. 5 I graduated from Texas A&M University in 1971 6 with a Bachelor of Science degree in Nuclear Engineering 7 and in 1972 received a Master of Engineering in Nuclear 8 Engineering. 9 During the summer of 1970, I worked for the 10 Tennessee Valley Authority in their Nuclear Engineering 11 Branch. There I worked on nuclear steam supply system 12 evaluations and off-gas systems. 13 In August of 1972, I joined Houston Lighting 14 & Power Company and worked in the engineering design 15 section of the Nuclear Program. During this period, I 16 worked on bid evaluations and engineering design review. 17 In February of 1973, I was transferred to the 18 Nuclear Safeguards and Licensing Section of the Nuclear 19 Department. In this position, I was responsible for 20 the licensing of the Allens Creek Nuclear Generating 21 Station. During this time I attended the General 22 Electric BWR Design Orientation course. 23 In August of 1974, I was promoted to Project 24 Engineer working on the South Texas Project. In this 1 position I was primaril y r e sponsible f o r the coordina-2 tion of the Engineering review in the areas of civil 3 engineering, mechanical/nuclear en g ineering and licensing. 4 I was also a member of the South Texas Project group 5 responsible for the coordination of site activities. 6 In March 1975, I was promoted to Supervising 7 Engineer -Nuclear Safeguards and Licensing. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 I I ' ll I I I ! i I I ,: I ; i EDUCAT I ONA L & PROFESSI ONA L QU~LIFICA~IONS Donald R. Betterton Manager, En vironmen tal Protection Department Houston Lighting & Power Company My name is Donald R. Betterton. I am Manager of the Environmental Protection Department of Houston Lighting & Power Company. In this capacity I am sponsible for collection and evaluation of the various technical considerations associated with the environment. These considerations involve the areas of site selection criteria, radioactive dispersion, thermal effects, air and water quality considerations and environmental surveillance, including meteorological monitoring, geophysical testing, hydrological evaluations, and all offsite operational effects of the nuclear power plant. In connection with the South Texas Project, I had managerial responsibility on the Project Manager's Staff for the preparation of the Environmental Report and environmental considerations required in support of its Safety Analysis Report. My responsibility also includes acquisition of all local, state and federal permits and approvals exclusive of NRC licensing. I report to the Vice President, Environmental and Utility Affairs of Houston Lighting & Power Company. I graduated from the University of Houston in 1970 with a BS in Civil Engineering. In 1958 I joined Houston Lighting & Power Company as an Engineering Assistant in the Surveying Section of the Engineering 1 2 3 4 5 6 7 8 a J 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 I I I' I I I I I I I I I I ! ,. 11 II ' *l l1 I'. ji Department. In this capacity I performed various calculations required for horizontal and vertical control in connection with design and construction of roads, railroads, canals, substations, power plants, etc. I utilized computers to solve multiple three-point problems for control of the Houston Lighting & Power planimetric mapping system and least squares adjustment of Houston Lighting & Power Company mental traverses in the Houston area. In February of 1963, I was transferred to the Civil Engineering Division where I became involved in the design of transmission towers and foundations. During this period I assisted in the analysis and design of several 138 kv transmission line structures. I also worked on foundation analysis and design cluding straight shaft, underrearn, multiplier, and pile foundations required for transmission structures. In 1966 I was assigned to the Design ing Division and became responsible for design of paving and drainage facilities for all Houston Lighting & Power Company substations. I was also responsible for the Standards Section where I designed substation structures and components to be utilized as standard structures. 1 In 1968 I was given special assignment in the 2 envi ronmental area which included hydraulic, biological, 3 and thermal effects of power plant cooling water dis-4 charges. I was appointed Supervisor of Environmental 5 Protection in 1970 and Manager of Environmental Protec-6 tion in 1972. 7 I am a member of the Texas Society of Profes-s sional Engineers, Houston Engineering and Scientific 9 Society, and Texas Water Pollution Control Association. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 Douglas W. Peacoc k Pressur i z e d W3t er Reactor S y s t~ms D i vi sion We sti nghouse E l ec tri c Cor;o r a tion My name is D o ugl as W. Pe a cock. M y bus ine ss 2 address is P. O. Box 355, Pittsbur g h, Penns y lvania 3 15230. I am employed by Westingho use as Manager, Reactor 4 Protection in the Pressurized Wat e r Rea ctor Systems 5 Division and I have served in this c a pacity since 1972. 6 I am responsible for the functional adequacy of reactor 7 protection systems. In this capacity I have been 8 active in the regulatory review process for the RESAR-9 41 Preliminary Design Approval, the South Texas Project 10 Nuclear Generating Station, and other RESAR-41 projects. 11 I graduated from Washington State University 12 with a B.S. degree in Chemical Engineering in 1962, and 13 graduated from the University of Ill i nois with a Ph.D. 14 degree in Physical Chemistry in 1966. 15 Followin9 my academic training, I joined 16 Douglas United Nuclear Company, a prime contractor to 17 the Atomic Energy Commission responsible for the opera-18 tion of the Hanford reactors and fuel fabrication 19 facilities. Between 1966 and 1969, I held various 20 engineering assignments involving analysis of reactor 21 operation and special materials production programs. 22 During 1969 and 1970, I assumed technical management 23 positions with responsibility for fuel development 24 programs, safety analysis and licensing studies, and 1 safety research and development acti v ities related to 2 the Hanford N Reactor. In 1971, as M anager, Process 3 Technology, I had an overall responsibility for process 4 technical support functions and operational safety 5 aspects of the Hanford N Reactor and Fuel Fabrication 6 facilities. Since 1972, I have been employed by 7 Westinghouse in various safety and licensing management 8 positions. In this capacity I have been responsible 9 for establishing safety criteria, conducting safety 10 evaluations of system and component design, preparing 11 documentation for safety analysis reports, providing 12 safety system performance requirements, developing 13 analytical methods for safety analysis, and repre-14 senting Westinghouse before regulatory organizations in 15 the licensing process of numerous power reactors and 16 regulatory review of generic technical matters. 17 I have made contributions to public and in-18 dustry discussions on nuclear power technology and I 19 have lectured in the Nuclear Power Reactor Safety Pro-20 gram at Massachusetts Institute of Technology. 21 member of the American Nuclear Society. 22 23 24 I am a 1 EDUCATIONAL AND PROFES S IONAL QUAL IFICATI ON S Wal t on A. Rodger N u c lear Safet y A ss oc i a t e s My name is Walton A. Rodger. I am a partner 2 in the nuclear consulting firm Nuclear Safety Associates, 3 Bethesda, Maryland, and have held this position for the 4 past ten years. The four years prior to that I was 5 Vice President of Nuclear Fuel Services, Inc., serving 6 as its Technical Director and later as General Manager 7 of its West Valley plant. In the latter position I was 8 responsible for the construction, startup, and licensing 9 of the world's first privately owned nuclear fuel 10 reprocessing plant. 11 From 1960 to 1962, I was a partner in the 12 nuclear consulting firm of McLain Rodger Associates. 13 Before entering the consulting field, I spent 13 years 14 at Argonne National Laboratory, four at Oak Ridge 15 National Laboratory, and one at the Metallurgical 16 Laboratory of the University of Chicago. At all three 17 I was active in the development of all of the various l8 processes which have been considered for use in repro-19 cessing of nuclear fuel. I also did a great deal of 20 work in the field of radioactive waste management. At 21 Argonne I was Associate Director of the Chemical Engi-22 neering Division. My total experience in the nuclear 23 field has covered 33 years. 24 I was graduated in both Chemical and Metallurgi-I 1 2 3 4 5 6 7 8 9 I 10 I 11 I I 12 ! I 13 ,I J; 14 I 15 i 161 17 ! 1a II I'. 19 jl 20 21 22 23 24 cal Engineering from the University of Michigan in 1939. I obtained my Master's Degree in Chemical neering from the same institution in 1940. My Doctorate in Chemical Engineering was awarded by the Illinois Institute of Technology in 1956. I am the author of sections of several nuclear handbooks and have published more than two dozen papers in the nuclear field, largely on reprocessing and waste disposal. I am a member of AICHE, and in 1960 was Chairman of the Nuclear Engineering Division of the Institute. I am also a member of American Nuclear Society and Atomic Industrial Forum. I am past man of the ANSI Committee N-48 which is developing standards for the disposal of solid nuclear waste. In 1959, I served as Technical Consultant to the Joint Committee on Atomic Energy of the 86th Congress at the Hearings on Industrial Radioactive Waste Disposal. For the past two years I have served as a principal witness for the Consolidated Utility Group in the As Low As Practicable Rule Making Hearing (RM-50-2). In this capacity I have done extensive cost-benefit studies on LWR radwaste systems. 1 2 3 4 ED~CATIONA L & PR OFE SSI ONAL QU~LIFICAT IONS J o hn T. Mooney Enginee r ing Pr ojec t Manager Brown & Root, I nc. My name is John T. Moone y. My bus in ess address is 5100 Clinton Dr i ve, Houston, Texas. I am employed by Brown & Root, Inc. and serve as the Engi-neering Project Manager assigned to the South Texas 5 Project. In this position I am responsible at Brown & 6 Root for the overall engineering and design of the 7 South Texas Project Nuclear Generating Station, including 8 plant structures, systems, site development and cooling 9 facilities. 10 In 1953 I received my Bachelor's degree in 11 12 chemical engineering from Villanova University. After graduation, I was employed by Goodyear Atomic Corporation 13 in connection with the start-up and operation of the , , ' 14 i I ! 15 I 16 I ' 11 I 18 ll I'. 19 H 20 21 22 23 24 I gaseous diffusion enrichment facility at Portsmouth, Ohio. Previously, I have had responsible engineering assignments for another architect-engineer firm in the design of the Indian Point Units 2 and 3 of Consolidated Edison Company and Brunswick Units 1 and 2 of Carolina Power and Light Company. My previous experience also includes seven years at Bettis Atomic Power Laboratory in the design of power plant mechanical apparatus and plant start-up activities for the Naval Nuclear sion Program. 1 I am a registered Professional Engineer in 2 Pennsylvania, North Carolina and Tennessee. 3 4 5 6 7 I s I I 9 : I 10 I 11 I I 12 I 13 ! ,: 1411 15 11 16 17 1! 18 I'. ** 19 p I 20 21 22 23 I 24 I 1 EDUCAT I ONA L AND P R OF E SSIONAL QChLIFICATIO~S E. Douglas Schwan t es, Jr. Senior Project Engin ee r Woodward-Clyde Consultants My name is E. Douglas Schwa n tes, Jr. I am 2 emplo y ed by Woodward-Clyde Consultants of Oakland, 3 California, as Senior Project Engineer. I joined 4 Woodward-Clyde Consultants in 1972, and I am their 5 project m anager for the South Texas Project, responsible 6 for coordinating all aspects of the geotechnic investi-7 gation in connection with the licensing and design of 8 that nuclear generating facility. In this capacity I 9 have assisted in the preparation of the geotechnical 10 sections of the Preliminary Safety Analysis Report and 11 other documents. 12 In 1960 I received a Bachelor of Science 13 degree in Civil Engineering from the University of 14 Illinois, and, following a period of employment, I 15 received the Master of Science degree in Civil Engineer-16 ing from the same university in 1965. 17 From 1960 to 1962 I served as a Lieutenant, 18 junior grade, with the U.S. Coast and Geodetic Survey 19 in Washington, D.C. In 1963 I was employed as a Civil 20 Engineer by Slope Indicator Company, Division of Shannon 21 & Wilson, Inc., Seattle, Washington. In 1965 I worked 22 as a Soils Engineer for Harza Engineering Company, 23 Chicago, Illinois, and from 1965 through 1972 I was 24 employed as Project Engineer by Shannon & Wilson, Inc. 1 in Seattle, Washington. 2 I am a Registered Professional Engineer in 3 the states of California, Illinois and Washington and 4 hold membership in the American Society of Civil Engi-5 neers and the Association of Engineering Geologists. 6 My publications include the following: 7 "Features of construction in landslide areas," 8 Proceedings, Northwest Road and Street Conference, 9 University of Washington, 1967. 10 "Landslide stabilization with slit-trench 11 buttresses" with R. A. Adolfson, paper presented at the 12 17th Annual Conference on Soil Mechanics and Foundation 13 Engineering, University of Minnesota, Minneapolis, 14 1970. 15 "The Baldwin Hills Reservoir failure in 16 retrospect," with A. Casagrande and S. D. Wilson, Pro-17 ceedings of the ASCE Specialty Conference on the Perf o r-18 rnance of Earth and Earth-Supported Structures, Purdue 19 University, June, 1972. 20 In my professional experience I have been 21 associated with many foundation engineering projects 22 for industrial, commercial and residential sites, 23 retaining structures, waterfront development, highway 24 construction, darns, and landslide stabilization. 1 ., 2 I the 3 Ii No. ,. 41 1 the s ,I for Some of the more significant of these includ e: soil and foundation investigations for the Hanford 2 Nuclear Power Station near Richland, Washington; foundation investigation and initial s h oring studies the SO-story Seattle First National Bank Building; 6 the 24-story Pacific Northwest Bell Telephone Building 7 in Seattle; a post-failure study of the soil conditions a and design of the Baldwin Hills Reservoir in Los 9 Angeles; design of remedial work to stabilize landslides 10 in the Tukwila Interchange in Seattle; and stabilization 11 of a major landslide in a confined area of Minneapolis, 12 Minnesota, by use of an unusual system of slit-trench 13 buttresses. 14 15 16 17 18 19 20 21 22 23 24 c .. :.' :_* 7 81 9 10 11 12 131 14 15 16 17 18 19 20 21 22 23 24 Ace-~ 'erol Reporters, Ire. I 25 -, .-,j i ---' **-. r r* ....

t.1!cl t t:.~: -, M ,"7.S. B0 i')I:.: 1z::,: Fi n e. i'-lR. SCt l1/.0.~.zZ: M rs. Bowers , we h a.v e b~en in, contact with t he re p orter _and our exhib i t s have be e n delivered to him. I would ask that the Board approve the marking of the exhibits at this tim e. For ease of refer ence , tent at ive id enti fication numbers consistent with those proposed in our sub mit tal to the Board on November 4 have been placed on each exhibit. '!'hat is, the app lication as amended by amendments 1 through 3, as Applicant;s Exhibit No. 7. The preliminary safety analysis report, as amended by amendment l through 33, Applicant's Exhibit No. 8, and the RESAR-14 reference safety analysis report as amended by amendment 1 through 9 --one t~rough 19. I beg your pardon, Applicarit's Exhibit No. 9. If it is agreeable we would like to have those exhibits marked --excuse me one second. I would like to correct that. The preliminary safety analysis report which we have for introduction as Applicant's Exhibit No. 8 includes amendments 1 through 34. MRS. BOWERS: 'l'l?,e proposed exhibits will be marked for identification a~ you indicated, 7, 8, and 9. MR. SCHWARZ: Thank you.

4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A:e-!"ed~rol Reporters , Inc. 25 i! '! Exhibits 7 , ~. a nd 9 t or identitication .) < MR. S CHWAHZ: We would now call Mr. George W. Opr ea , Jr., execu ti ve vice pres i den t o f Housto n L i ghting an d Powe r C ompany. he h a s b ee n prev iou s l y swo rn. BY M R. SCH WARZ: Q. Do you ha ve before y ou a doc umen t entitl ed T e sti mon of George W. Oprea, Jr., reopen i n g state m ent on beh a l f o f t he South Te x as Project P a rticipants? A. (Witn e ss Opr e a.) Y es. Q. This document w ill be found under tab 14.

Was this docu m ent prepared by you or und e r y our supervision?

A. Yes, it was. Q. ls this document true and correct to the best of your knowledge and belief? A. It is. Q. Do you adopt the document entitled Testimony of George W. Oprea, Jr., reopening statement on behalf of the South Texas Project Participants and the Project Manager as your testimony in this proceeding? A. I do. MR. SCHWARZ: Mrs. Bowers, I ask that the lOpage CIT'.\! l U e 2 i. I: 'i 1 II 2 3 4 5 6 7 8 9 10 l l 12 13 14 15 16 17 18 19 20 21 22 23 24 'I 1* Ac-:!*. _,fora I Reporters , Inc. 25 f.lr. C*;_,.._ea_ bc. ., ,*, " record a:_; lLoug n rc,::.d. Co pi ,_: s hCTve lo t. 1** r epo rt e r. MRS. B Ol'i'ER.S: Any co rmne n t, M r. Pend erg raft*? < MR. PE NDEJ:<.GRA FT: The St ate has no objec ti on. MRS. BO W ERS: Mr. Stridiron? MR. STR~DI 1:<.0N: Th e Staff has no obj e ction. MRS. BOWERS: .The prepared testimony will be physically incorporated into the transcript as if read. (The testimony follows.) 1 I. 2 Re: Opening Statement on 3e~alf o f the South T exas Pr e ~ct Participants and the Project Manager Introduction. My name is George W. Oprea, Jr. I am Execu-3 tive Vice President of Houston Lighting & Power Company, 4 and I am responsible for that Compa ny's nuclear program. 5 A resume of my educational and professional qualifica-6 tions has previously been received in evidence. 7 I wish to take this opportunity to welcome 8 you again to South Texas. 9 The purpose of my testimony is to describe 10 briefly the background for the South Texas Project and, 11 in a general way, the undertakings of the Participants 12 in support of the Project. These Participants are the 13 City Public Service Board of the City of San Antonio, 14 Central Power and Light Company, the City of Austin and 15 Houston Lighting & fower Company. I shall also address 16 the undertakings of Houston Lighting & Power Company, 17 as Project Manager, in establishing its own capability 18 to support the design, construction and safe operation 19 of the South Texas Project Nuclear Generating Station. 20 In addition, I shall sponsor the formal Application. 21 II. Application. 22 The Application for Construction Permits and 23 Operating Licenses, as amended by Amendments 1 through 24 3, Applicant's Exhibit No. 7, was prepared under my 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 supervision by representatives of all Participants. The statements contained in the Application, as so amended, are true and correct to the best of my knowledgE and belief. Amendments 2 and 3 to the Application, which were filed on October 20, 1975, and October 30, 1975, respectively, brought up to date the information previously contained in the Application. They provided the current cost estimates for the South Texas Project Units 1 and 2, more current information as to the financial qualifications of the Participants, the currently planned net generating capability of the Participants, and miscellaneous information, such as memberships of Boards of Directors and principal officers The Application, as amended, fully documents the financia qualification of the Participants to design and construct South Texas Projects Units 1 and 2. III. Background for the South Texas Project. The areas served by the four Participants in 20 the Project encompass about the southern one-third of 2 1 the State. According to the last census, these areas 22 include four of the eight largest metropolitan areas in 23 the State. It is each Participant's responsibility to 2 4 provide the electricity which is needed to support the 1 2 3 4 5 6 growth and the living standards of the c itizens of the area it serves. Moreov e r, the Partic i pants are respon-sible for providing this electricity at a reasonable cost and in a manner that protects the environment as well as the health and safety of those persons in the vicinity of the proposed facility. I believe that each 7 of the Participants has been successful in meeting its 8 customers' needs and in being a good neighbor to those 9 who live in the vicinity of its generating facilities. 10 We are proud of this record and intend to perpetuate 11 it. 12 The currently planned net generating capability 13 of the four Participants in the Project through the 14 year 1984, is shown in graphic form in amended Exhibit 15 III to the Application. By comparing this projected 16 capability with that included in the Application as 17 originally filed in 1974, one notes certain reduction 18 in the facilities planned by each of the Participants. 19 Since the hearing on environmental and site 20 suitability matters the only significant reduction 21 results from Houston Lighting & Power Company's recent 22 decision to postpone indefinitely the construction of 23 its Allens Creek Nuclear Generating Station, planned 24 for a site in Austin County, Texas. None of the . 1 Participants in the South Texas Project, other than 2 Hou ston Lighting & Power Company is involved in the 3 Allens Creek project. Therefore, the deferral of that 4 project does not affect the plans of the other s ipants in the South Texas Project. 6 From Houston Lighting & Power Company's 7 standpoint, deferral of the Allens Creek project h as 8 made timely construction of the South Texas Project all 9 the more important. This action further assures our 10 ability to finance the remainder of our construction 11 program, including Houston Lighting & Power Company's 12 30.8% share of the South Texas Project. As of December 13 31, 1974, Houston Lighting & Power Company's assets had 14 a book value of $1,692,088,000. The Company's 1974 15 revenues were $486,837,000, all attributable to electric 16 operations. The bonds of Houston Lighting & Power 17 Company are rated AA by both Standard & Poor's Corpora-18 tion and Moody's Investor Service, Inc. 19 The other Participants in the South Texas 20 Project are likewise financially qualified to undertake 21 their responsibilities with respect to the South Texas 22 Project. Central Power and Light Company's assets were 23 valued at $603,972,000 as of December 31, 1974, and 24 Central's 1974 operating revenues were $223,595,000. 1 Central's bonds are also rated AA by both Standard & 2 Poor's Corporation and Moody's Investor Service, Inc. 3 Central is a wholly owned subsidiary of Central and 4 South West Corporation. As of December 31, 1974 the 5 consolidated balance sheet of Central and South West 6 and its subsidiaries reflected assets of $1,788,708,000. 7 The City Public Service Board of San Antonio 8 and the City of Austin are both municipally owned 9 electric systems, serving metropolitan populations of 10 about 1,300,000 and 335,000, respectively. In the 11 fiscal year ended January 31, 1975 the City Public 12 Service Board of San Antonio had electric system revenues 13 of over $137,000,000. Its electric and gas system 14 bonds are rated AA by both Moody's Investor Service, 15 Inc. and Standard & Poor's Corporation. During the 16 fiscal year ending September 30, 1974, the City of 17 Austin had revenues from sales of electricity of over 18 $57,000,000. Austin's revenue bonds enjoy a AA rating 19 by both of those investment services. 20 Each of the Participants is mindful of its 21 responsibility to provide adequate financial support to 22 the Project. Each will finance its proportionate share 23 of the Project, and, while the sources of funds will 24 vary among the Participants, they will include funds on -s-1 hand, retained revenues, short term lo a ns and commercial 2 paper, and the sale of securities as required. 3 Less than one half of one percent of the 4 common stock of Houston Lighting & Power Company and of 5 Central and South West Corporation is owned by non-6 residents of the United States. 7 IV. Undertakings of the Participants. 8 As I indicated to this Board last April 9 during the portion of this proceeding involving environ-10 mental and site suitability matters, the Participants 11 in the Project approached this joint undertaking in a 12 deliberate manner. In the latter part of 1971 a feasi-13 bility study was undertaken to determine the desirability 14 of constructing and operating a jointly owned generating 15 facility. 16 By the end of 1973 these Participants had 17 entered into a formal agreement providing for a jointly 18 owned and operated nuclear generating facility. Houston 19 Lighting & Power Company was selected as Project Manager 20 and charged with designing, licensing, constructing, 21 maintaining and operating the Project facilities for 22 the benefit of itself and the other Participants. 23 V. 24 Undertaking of Project Manager. Houston Lighting & Power Company fully I* 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 recognizes that as Project Manager it has the ultimate responsibility for the safe design, construction and operation of the South Texas Project Nuclear Generating Station. In order to discharge this responsbility, we commenced developing our in house nuclear capability in 1971. This involved additional training for some of our existing personnel and the hiring of a number of new employees who already had experience in the nuclear phase of the electric industry. I participated directly in assembling and organizing this in house capability which continues to report to me. The Project Manager's Staff is complemented by a strong support team comprised of Brown & Root, Inc., the Architect-Engineer and Constructor for the Project, and Westinghouse Electric Corporation, the supplier of the nuclear steam supply systems and the fabricator of the *fuel for each of Units 1 and 2. Brown & Root is known favorably to the Project ipants as a result of its experience as a designer and constructor of fossil fuel facilities and through its reputation in the engineering and construction of other large and complex facilities. Brown & Root brings to this Project substantial nuclear experience, both from the addition of personnel within its organization and 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 11 the use of experienced subcontractors such as NUS Corporation, Woodward-Clyde, Consultants and others. Westinghouse Electric Corporation needs no introduction to the nuclear power industry. It is a recognized leader in this field. Dr. Sumpter will present a more detailed discussion of the technical qualifications of Houston Lighting & Power Company, Brown & Root and Westinghouse. For many years, Houston Lighting & Power Company has recognized the need for, and has maintained, an extensive quality assurance program. In conjunction with the establishment of its nuclear program, the Company reorganized its quality assurance procedures. Mr. D. G. Barker, who joined the Company in 1972, now heads the Company's quality assurance program. He is also responsible for, and in charge of, the South Texas Project quality assurance plan. Mr. Barker will testify in more detail as to the quality assurance plan for the South Texas Project. Mr. Barker reports directly to me. I am a member of the Board of Directors of Houston Lighting & Power Company and have direct access at all times to the Chief Executive Officer of the Company, Mr. J. G. Reese, who is also the Chairman of 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 11 our Board, and to the Chief Administrative Officer of the Company, Mr. D. D. Jordan, who is also our President. I am a member of the *.1anagement Committee for the South Texas Project. The Management Committee was established under the provisions of the Participation Agreement which is set forth in Exhibit I to the cation. Houston Lighting & Power Company, as Project Manager, advises the Management Committee of activities and developments concerning the Project and consults with that Committee on a regular basis. On the other hand, the Participation Agreement charges Houston Lighting & Power Company with the safe design, tion and operation of the South Texas Project Nuclear Generating Station, and Houston Lighting & Power Company has accepted and is carrying out this responsibility. VI. Conclusion. In summary, we have established a team of the necessary talents to design, build and operate this plant in a manner that is environmentally acceptable and safe. I am proud of this team. Further, I assure you that not only I, but the entire management of Houston Lighting & Power Company, clearly recognize and accept the responsibility of designing, constructing and operating the South Texas Project Nuclear Generating 1 Station in a manner consistent with the health and 2 safety of both the workers in the plant and those 3 persons living or working in the vicinity of the plant. 4 In carrying out these goals, we h av e received, and 5 continue to receive, the full cooperation and support 6 of all of the Participants in the Project. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 2 3 4 5 6 7 8 9 10 TESTI~ONY OF J. R. SUMPTER Re: South Texas Project Pr e liminary Safety A~alysis R e port My name is J. R. Sumpter. I am Manager-Nuclear Division of the Power Plant Engineering and Construction Department of Houston Lighting & Power Company. A resume of my educational and professional qualifications has previously been received in evidence. My responsibilities in connection with the South Texas Project include the design, engineering and fuel ment of the nuclear system, radiation protection, licensing and safety analysis. 11 The Preliminary Safety Analysis Report, as 12 amended by Amendments 1 through 34, and including 13 Appendices A through F, Applicant's Exhibit No. 8 (PSAR), 14 was compiled under my supervision and direction. Some 15 of this material was prepared by Houston Lighting & 16 Power Company employees; however, the major portion of 17 the basic data was initiated and supplied by our 18 Architect-Engineer and Constructor, Brown & Root, Inc., 19 or by one or more of a number of consultants, including 20 NUS Corporation, and Woodward-Clyde, Consultants, and 21 EDS Nuclear, Incorporated. In all instances-either I 22 or one of the Houston Lighting & Power Company personnel 23 in the Nuclear Division reviewed and approved this 24 material prior to its incorporation into the PSAR. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 I am familiar with the contents of the PSAR, a s amended, and the statements contain e d therein are true and correct to the best of my knowledge and belief. C 9 1 6 11 12 I I 13 14 15 16 17 18 19 20 21 I 22 23 24 I , dera l Reporters , Inc. ' 25 "'1) S C ~-I'. .. : _ * !'. : pared tes t: .10 n y no w? A (Witness Oprea) Thc1nk you. My name is Georg e \'ii. Oprea , Jr. Do I n e e d the m i crophone? MRS. B OWERS: W e can h ea r you , b ut I don't k n ow w het h e r p eo p l e in th e bac k can hea r y ou or n o t. WIT NE SS O PREA. My n ame is G eorge W. Op r ea , Jr, exec uti v e vice presid e nt of Houst o n Lighting & Po w er Com p an y. I am responsible for th e nucl e ar p rogram. A resume of my educati o n and professional quali-fications have been r e cei v ed in evidence pr e viously. I, too on behalf of the South Texas particip a nts, ta k e this opportunity to welcome you to sunny south Texas. My prepared testimony, which has been introduced in writtenform, describes the background and planning for the South Texas Projeqt, by each of the four pa r .c ipants, . The City Public Service Board of San Antonio, Central Power & Light Company, the City of Austin, and Houston Lighting & Power Company. All of the participants participated in the preparation of the formal application for construction permits and operating license for the two units at the project site. This application and three amendments were compiled under my supervision~ It reflects the currently 2 ; i! 3 :1 4 1 I : 1 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 "' i deral Reporters , I n c. i 25 qualif i ed to fi n ance the d c si0n and construction of its i n t e r e s t i n t he S outh Texas 1~rojec t faci l ity , t he fac t that t h e bo n ds of each pa rtici pant c urr enlty e n joy a d ou bl e " A" ra ti ng by bo t h S ta ndard & Poo r's and M o ody's In ve stors' Serv i ce and t h e f act that th e gove rn ing bod i es or boards , an d th e of f i ce rs o f a ll of th e p artici pa nts, ar e ci t i ze n s of th e Unit ed Stat e s, wit h l es s than o ne-h a lf of 1 pe r cen t o f th e comm o n stoc k of H ous to n Light & P owe r, an d C e ntral & Sou t hwest Cor p ora t i o n, th e par e nt co mpany of C e ntral P owe r an d Light Com p any, b e in g own ed b y non-r e sid e nts of the Unit e d Stat e s. As project man a ger, Houston Lighting and Po we r Company recoganize that it had the ultim a t e responsibilit y for the safe design, construction and operation of the South Texas Project, nuclear generating station. Houston Lighting and Power Company conunenced developing its in-house nuclear capability in 1971. I personally partici-pated directly in assembling and organizing this capabilit y , which continues to report to me. Our own capabilit y is complemented by a strong support team comprised of Brown and Root, our architect engineer and constructor. Westinghouse Electric tion, our nuclear steam supply system vendor and several 2 ii 3 :I J I *5 11 6 1 I 7 8 9 11 t* 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ederal Reporters, Inc. 25 c on:-;u l tc..11 ts. D r. S umpL~Lc r , I i i Company's nuclear divisi.on~ wilJ provide more det a.il e d t c sti-! many a~ t o the technicla qua li f i c a tions of the . I ;::)rOJect mana g er; -r that is Houston Lightin g & Power Company, Brown and Root and Westinghouse. the need junction also in Hon,:;t-_on T.i rrl-1ting and Power Company ahs r eco gnized for quality assur ance program, not only in con-with the establishment of our nuclear program, but conjunction with its fossil fuel facilities. Mr. Parker, who heads our quality assurance department,will provide more detailed testimony as to the project qualit y assurance program. I might add, Mr. Parker reports directly to me. I am a member of the board of directors of Houston Lighting & Power Company , and have direct access at all times to Mr. J. G. Reese, the Chairman of our board and chief executive officer and Mr. Don D. Jcrson, president and chief administrative officer. I am also manager of the management committee for the Texas Project, which committee is established under the project participation agreement. In conclusion, let me assure you that we have established a team of the necessary talents to design, construct and operate this facility, in a manner that is safe, and environmentally acceptable. Not only I, but I i I I 6 7 8 9 10 11 14 15 16 17 18 19 20 21 22

23 24 1 deral Reporte r s , Inc. 25 Project i n a manner co nsis t c r1t with the healt~ and safety of both the ,-1ork e rs in the plant and thos e persons , 1 i ving a:-1d Hark ing in th e v i cinity of t he plant. I n carryi n g out these goals, we have rec e iv ed and cont i nue to rece i ve the f u l l cooperation and support of all o f th e pa r t ici p ant s i n th e proje ct. Th a n k yo u. BY MR. SC HWA RTZ: Q Mr. Opr e a, yo ur p r ep ar e d t e sti mony i nd ic ate s th at t he a pp lic a tion for construction p e rmits and o pe rati ng li ce ns e s, as a m end e d b y a m en dme nts 1, 2 an d 3, w a s p r epa r ed un de r your s u p ervision.

Is that correct? A (Witness Oprea. ) That is correct. Q Is it, as so amend e d, true and correct to the best of your knowledge? A Yes, it is. MR. SCHWARTZ: Mrs. Bowers, I ask the application, so amended, Applicant's Exhibit N umber 7, be recei v ed into evidence at this point. MRS. BOWERS. : 1r. Pendergraft? MR. PENDERGRAFT: No objection. MRS. BOWERS: Mr. Stridiron? MR. STRIDIRON: No objection, Mrs. Bowers. f m5 2 Ii ') *i 0 'I J 1 /i* .x x xx 5 11 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 I 24 I I , derol Repo rt ers , Inc. I '25 ",_ .... t L MR. SCHWAR T Z: I'

l:n 1. s t_j_;n<?. 1 ,. -.-, (Th e docume n t , llen~to f ore marked A psl\can t~s E~~ibi t Num~er 7 for i de ntif i cati o n , was rece i ve d in e v i dence.) 'I'hank you. Mr. O p r e a wil l n o t be a m e mb e r of our t e chnica l pan e l, accordi n l gy the b oa r d o r pa rti e s may h ave qu e stion s, which th e y would car e to p r e sent to Mr. Opr e a at th is time with resp e ct t? his t e stim o ny. or th e p arti e s? Is that th e w ish of t he b oar d tions? Mr. Oprea. MRS. BOWERS: M r. Pendergraft, do y ou ha ve que s-MR. PENDERGRAFT:

No questions. MRS. BO W ERS: Mr. Stridiron? MR. STRIDIRON: The staff has no questions of MRS. BOWERS: Mr. Shon is modest. He says he has one minor thing. MR. SHON: It is modest. Minor. Perhaps the ques-tion really should be addressed to the staff. I notice in one very small detail your testimony does not agree with a thing given to us by the staff. That is, the one detail is, the credit rating of the City Public Service Board of I i ! I I I f m(, 2 ' say i::, *c.riplc "1\." 3 '., not taking cr edit for eve1.-y thing you nGed? !J 4 !: WI TN}_::Ss O~RET,: Vhy don' L you c, c , k I!or a.rd f'H.'C-i: 11 s 1: man. 11 6 1 7 8 I I 9 14 15 16 17 18 19 20 21 22 23 24 MR. SCHW A RTZ: I th i nk Mr. How ard F r e eman of t he Publ i c S ervice Boa r d could best answer th at qu estion if that is a cc ep ta b l e to th e bo ar d. MRS. BOWE RS: I think he s ho uld be sw orn. Wh e r eup on, HOWARD FREEMA N was called as a witness an d , havin g b ee n first d ul y s worn , w as e xam in ed and t e stifi e d as follo w s: MRS. BOWERS: Please fully id e ntify y ours e l f. MR. SCHWARTZ: He has a statement of qualif i c at ions along with the statement to present to the board. MR. FREEMAN: My name is Howard Fre em an, se c retar y-treaurer of the City Public Service Board of San Antonio, Texas. I hold a bachelor of business administration degre e , from St. Mary's, San Antonio,as well as a master of business administration from St. Mary's. I have worked with the City Public Service Board since 1959 and have held various posi-tions including superintendent of customer accounting, chief accountant and my current position of controller and secre-~derol Reporters , Inc. 25 tary-treasurer. C ni -, ,., I 6 7 8 9 10 1 l l I 12 I 13 1 14 1 I 15 I 16 11 I 17 18 19 20 21 22 23 24 iderol Reporters, Inc. 25 l ri ( .. .. .. , .... tripl e II A II to doub l e " A, wh en \vC: recently is s ucd s uhord i-nat e lo a n bonds. Our most recent issu e is a subordinate l oan bond and was changed at this time. All the prior i ssues did~ : k w i th first lo an bonds and were graded as triple " A." MR. SCHWART Z: Mr. Fr eema n, th e bonds that were origi na lly iss ued as tri ple "A" bonds are st ill tripl e " A"? Is that correct? MR. FREE MAN: Correct. MR. SCHWARTZ: However, the last issue which was not a first loan bond, is rated double "A." MR. FP~EMAN. Correct. MRS. BOWERS: Th e board has no further questions of this witness. MR. SCHWARTZ: Thank you. MR. STRIDIRON: I did have one question. Do you ha v e a date when this change in rating came about, and was it subsequent to the submittal to the staff? MR. SCHWARTZ: It was shown in amendment 2 of the application, I believe, which was --Mr. Freeman can ans w er it. MR. FREEMA N: It was included in amendment

2. I 1 -. (;': . l' \: ..:_ : :2 \ *c., ...*. ') ; J 9 10 11 12 13 14 15 I 16 17 18 19 20 21 22 23 24 1 *e derol Reporters, Inc. 25 ME. ;:::;*, ?~IHRo::: L'c have no further que st ions. MR S. 9/.-.'r:Rs

no yo u h ave anythjng furth er , Mr. .. St ri d.ir on'? MR. S TRI DIRO N: No furth er questions.

MR S. BOWCRS: Th e board has no further questions of thi s witness. MR. SC HWARTZ: I now call Dr. J. R. Sumpter, manager, nuclear divis ion for Houstong Lightin g & Power Company. Dr. Sumpter, do you have before you a two-pag e documetn entitled "T e stimony of J. R. Sumpter, Re: South Texas Proj e ct Preliminary Safety Analysis Report"? DR. SUMPT E R: I do. DIRECT EXA.MINATION BY MR. SCHWARTZ: Q This document will be found under tab 15. Was this document prepared by you or under your supervision? A. (Witness Sumpter.) Yes. It was. A Is the document true and correct to the best of your knowledge and belief? A Yes. It is. Q Do you adopt the document entitled "Testimony of J. R. Sumpter, Re: Wouth Texas Project, Preliminary I I A ,. f r. _j 2 3 ! I 4 ,I , 1

Ii , , " I i -1: 6 1 7 a I I 9 1 I, 10 I[ 11 11 12 13 1 14 I 15 16 17 18 19 20 end 3 21 22 23 24 ~deral Reporters, Inc. 25 -.... l *-L-l_ A MR. SCHWA RTZ: I ask th~ tv 10-pc1g c do cu uent ti fi e d by Dr. Sumpter be inc orpora ted in the recor d as t hough read. MRS. BOWERS: Mr. Pend e rgraft? MR. PENDERGRAFT:

Stat e has no objection. MRS. BOWERS: Mr. STridiron? MR. STRIDIRON: No objection, Mrs. Bowers. i den--MRS. BOWERS: While I am checking .the gentl ema n on this ~oint, I am not sure I checked with each of you when it was proposed that the qualifications stateme nt s of the applicant's witnesses be physically inserted in the record. Any objection, Mr. Pendergraft? MR. PENDERGRAFT: None. MR. STRIDIRON: No objection. MRS. BOWERS: The written testimony that you have fully identified will be physically inserted in the transcript as if read. 1 2 3 4 5 6 7 8 9 10 TES~IMONY OF J. R. S~~PTER Re: South Texas Project Pre liminary Safety Analysis Repor t M y name is J. R. Sumpter. I am Manager-Nuclear Division of the Power Plant Engineering and Construction Department of Houston Lighting & Power Company. A resume of my educational and professional qualifications has previously been received in evidence. My responsibilities in connection with the South Texas Project include the design, engineering and fuel ment of the nuclear system, radiation protection, licensing and safety analysis. 11 The Preliminary Safety Analysis Report, as 12 amended by Amendments 1 through 34, and including 13 Appendices A through F, Applicant's Exhibit No. 8 (PSAR), 14 was compiled under my supervision a nd direction. Some 15 of this material was prepared by Houston Lighting & 16 Power Company employees; however, the major portion of 17 the basic data was initiated and supplied by our 18 Architect-Engineer and Constructor, Brown & Root, Inc., 19 or by one or more of a number of consultants, including 20 NUS Corporation, and Woodward-Clyde, Consultants, and 21 EDS Nuclear, Incorporated. In all instances either I 22 or one of the Houston Lighting & Power Company personnel 23 in the Nuclear Division reviewed and approved this 24 material prior to its incorporation into the PSAR. I ' / L-. }) ] ' 4 L' " I, ,.) I i' ,I 1' ,1 I + I 5 :, '! !! 6 !i 'I I. 7 ii 8 9 10 ii ,I l l : ! II 12 II 13 11 I 14 15 16 17 18 19 20 21 22 23 I xxxxxx 24 1 /, , derol Reporters, Inc. ?.5 I *J L.1 1 . '-(,'. .* r-. . '-, 1 r _1_ *: J_ *, ;J j_-* .~..: '*; ::~ '* 34 wa s p:ccpo.rc c1 under your superv i sion by i:cr'.\)loy e r: **~ of Houston Lig~ting & Pow er Company, arch it ect eng in eGr , Brown and Roo t and by a number of cons ulLants inclu ding NUS Corporation, Woodward-Clyde and EDS Nuclear; is that correct? A. Yes. Is the preliminary safety analysis re port as so amended true aQd correct to the best of your know led ge and belief? Yes, it is. MR. SCHWARZ: Mrs. Bowers, I ask that the liminary safety analysis report for the South Texas Project, as so amended, Applicant's Exhibit No. 8, be received into evidence at this point. MRS. BOWERS: Mr. Pendergraft? MR. PENDERGRAFT: No objection. MRS. BOWERS: Mr. Stridiron? MR. STRIDIRON: No objection, Mrs. Bowers. MRS. BOWERS: Applicant's Exhibit No. B'is received in evidence. (The document heretofore marked as Applicant's xxxx 2 ,, Ii , 1 3 1 1 I I , 4 1: I! i ,. 5 6 I I 7 1 a II 9 11 10 1 1 l l 12 13 14 15 11 16 17 18 19 20 21 22 23 I I )deral Reporters , 7n~. I 25 MR. SCII\17;\RZ: Tlwnk, y~u. E ): h i Li l , : o . evidence.) .. () " Next I cal l Dr. Do ug l as W. Pea cock , Manager of React or Protec ti on , Nu cle ar Safe ty D epar t me n t , Uest i nghouse El ec tric Cor po r a ti o n. W h e reupon, DR. DOU G L A S W. PE AC OC K was called as a witn e ss and, h av ing b ee n previousl y duly s w orn, was e x a~ined and testified as follows: DIRECT EX AM INATIO N BY MR. scm ,1 ARZ: Dr. Peacock, do you hav e before you a six-page document entitled, "Testimony of Douglas 1v. Peacock, re: RESAR-41"~ to which is attached a two-page attachm e nt? A. Yes, I do. MR. SCHWARZ: Mrs. Bowers, this document will be found under tab 16. BY MR. SCHWARZ: Q. Dr. Peacock, was this document prepared by you or under your supervision? A. It was. Q. Is the document true and correct to the best of your knowledge and belief? 1-'--, L.-l) _, 2 I, ' 3 1! 4 11 ii 5 Ii 6 Ii 7 11 s l! I! 9 fl ) I 11 1 1 12 I 13 I 14 15 16 17 xxxx 18 19 20 21 22 23 24 " i derol Reporters , Inc. ' 25 l\. It ls o f D o u g l as IL Peacock , r e: R.CSAR-41" as y our testimony in this proc eed ing? A. I do. MR. scm*JA RZ: Mrs. Bowe rs, I ask that the six-Da.ae document with an attachment, id e ntifi ed by Dr. P e acock, be incor p ora ted into the record as if read. MRS. BOW ERS: Mr. Pendergraft? MR. PE NDERGRAF T: No objection. MRS. Brn*m Rs: Mr. Stridiron? ' MR. STRIDIRO N: No objection. MRS. BOWERS: The testimony which you have id entified will be physically incorporated into the transcript as if read. MR. SCHWARZ: Thank you. We have furnished such copies to the Reporter. (Document follows.) 1 TESTIMONY OF DOUGLAS W. PEACOCK ~e: RESAR-41 M y name is Douglas W. Peacock. I am Manager of 2 Reactor Protection, Nuclear Safety Department, Westing-3 house Electric Corporation. A sununary of my professional 4 qualifications has been received previously in evidence. 5 The purpose of my testimony is to provide an 6 explanation of what the RESAR-41 reference design 7 involves and an explanation of how it evolved from 8 earlier Westinghouse designs. I shall also sponsor the 9 RESAR-41 Reference Safety Analysis Report, as amended 10 by Amendments 1 through 19 (RESAR-41), Applicant's 11 Exhibit No. 9. 12 I have participated in the over-all safety review 13 of the Westinghouse design described in RESAR-41. 14 Portions of RESAR-41 were prepared under my direction. 15 I participated in the review and approval of those 16 portions of RESAR-41 which were not prepared under my 17 supervision, and for these reasons, I am familiar with 18 RESAR-41 in its entirety. The statements contained in 19 RESAR-41 are true and correct to the best of my knowledge 20 and belief. 21 RESAR-41 is a standard safety analysis report for 22 a Westinghouse nuclear steam supply system (NSSS) 23 design which was filed on December 3, 1973, and docketed 24 on March 11, 1974, by the Atomic Energy Commission, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 predecessor to the Nuclear Regulator y Commission (NRC). This submittal was in the form of an application for a Preliminary Design Approval (PDA) to the NR C pursuant to Appendix O of 10 CFR Part 50. The issuance of a PDA is contingent upon successful completion of a safety review by the NRC Regulatory Staff and the Advisory Committee on Reactor Safeguards, and is similar to the review given to conventional custom plant construction permit applications. A standard design receiving a PDA may then be referenced by utility applicants for construction permits without re-review by the NRC Staff with the exception of items not resolved during the PDA review phase, site related areas and interfaces, significant safety issues arising subsequent to the PDA, any proposed modifications of the standard design, or requirements arising from NRC rules or directives promulgated after the PDA. RESAR-41, as supplemented through Amendment 19, describes the Westinghouse standard four-loop NSSS for a 3817 MW (thermal) pressurized water reactor. Its scope, as incorporated by the South Texas Project Preliminary Safety Analysis Report (PSAR), includes the Reactor, Reactor Coolant System, Emergency Core Cooling System, Emergency Boration System, and various other 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 s af et y and ass oc i ate d s y s t ems incl uding in s t rumentatio n an d controls for the v ariou s s y s tem s. T he ba lance of plant structures, systems, components and power bution systems are described in th e Applicant's PSAR. While the Sout h T exas Project license application is the first applica t ion for a construction permit to reference RESAR-41, the standard plant described in RESAR-41 is similar in many respects to the RESAR-3 design [3425 MW (thermal)] which has been reviewed by the Commission on license applications for the Catawba plant (Docket Nos. 50-413 and 414), the Vogtle plant (Docket No. 50-424 through 427), the Millstone 3 plant (Docket No. 50-423), the Comanche Peak plant (Docket Nos. 50-445 and 446), the Seabrook plant (Docket Nos. 50-443 and 444), and the SNUPPS projects (Docket Nos. 50-482 through 487). The RESAR-41 design is an lutionary step from the RESAR-3 plant design and sents design evolution of the Westinghouse nuclear technology. The principal design differences and similarities are summarized below. The RESAR-41 reactor is similar to the RESAR-3 design except for an increase in active fuel length from 12 to 14 feet providing approximately a 15% increase 24 in fuel loading and heat transfer area. In addition, r 1 correspondingly longer control rods have been provided 2 and the lower internals, of a design similar to the 3 basic RESAR-3 design, have been modified to accommodate 4 the longer fuel assemblies. The fuel design is also 5 similar except that it incorporates nine grids per 6 assembly rather than the eight grids in the RESAR-3 7 design. Similarly with the exceptions necessary to a accommodate the differences relating to the increased 9 system capacity and to accommodate the rapid refueling 10 concept, the RESAR-41 Reactor Coolant System is basically 11 similar to the RESAR-3 system. The reactor vessel is 12 of the design used on RESAR-3 applications with the 13 sole exception that the reactor vessel closure system 14 has been changed to facilitate rapid refueling. The 15 reactor coolant pump design is similar to the RESAR-3 16 pump but will have an increased capacity. To transfer 17 the additional heat.generated in the RESAR-41 reactor, 18 the steam generators will have longer and a greater 19 number of tubes thereby increasing the total heat 20 transfer area. The RESAR-41 Residual Heat Removal 21 System (RHRS), in providing greater flexibility and 2 2 operability, utilizes three cooling trains with inde-23 pendent pumps not shared with the Emergency Core Cooling 24 System (ECCS). The RHR pumps employed will be of the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 vertical type rather than the horizontal pumps used in previous designs; however the components of the modified RHRS are of a proven technology. The new Emergency Boration System (EBS), and the redesigned Safety Injection System (SIS) are the only fundamental modifications of the Engineered Safety Features. The SIS design utilizes three independent trains with complete separation from any function other than emergency core cooling. The system components are similar to previous designs with the exception that vertical pumps are employed rather than horizontal. The EBS, replacing the Boron Injection tank in the SIS used on RESAR-3 design, is provided to mitigate the quences of steamline break accidents. Although a number of the EBS components differ from those utilized in the RESAR-3 design, all are of proven technology. The strumentation and Control Systems for the Engineered Safety Features and other systems are substantially the same as previous designs with differences principally to accommodate various system modifications. A Spent Fuel Pool Cooling and Cleanup System is provided in the scope of RESAR-41. The remainder of the Auxiliary Systems, with the exception of the Fuel Handling System and the Chemical and Volume Control I . 1 System (CVCS) are substantially the same as the RESAR-3 2 designs. The Fuel Handling System has been modified to 3 accommodate the rapid refueling provisions, and the 4 eves, basically the RESAR-3 design, incorporates a 5 number of modifications to achieve independence from 6 the ECCS and the EBS. 7 An in-depth comparison of the relationship 8 between RESAR-41 and RESAR-3 is presented in Tables 9 1.3-1 and 4.1-1 of RESAR-41. Additional insight to the 10 similarities of the principal parameters and design 11 features of RESAR-41 and RESAR-3 is presented in Attach-12 ment 1. 13 14 15 16 17 18 19 20 21 22 23 24 ATTAC~M E NT 1 Comparison of Principal Parameters and Design Features of RESAR-41 and RESAR-3 Parameter/Feature Reactor Core Power Level (MWt) Number of Loops System Pressure, Nominal, psia Total Thermal Flow Rate, lb/hr Effective Coolant Flow Rate for Heat Transfer, lb/hr Effective Coolant Flow Area for Heat Transfer, ft2 Nominal Inlet Coolant Temperature °F RESAR-41 3800 4 2250 144.7xl06 138.2 xl06 51.1 559.8 Coolant Temperature Av e rage Rise in Core 66.8 Average Thermal Output, kw/ft Heat Flux Hot Channel Faqtor, Fq Maximum Thermal Output for Normal Operation, kw/ft Number of Fuel Assemblies uo 2 Rods per Assembly Number of Grids per Assembly Fuel Weight (as U02), lbs. Fuel Rod Array Clad Thickness, inches Clad Material 5.33 2.50 13.3 193 264 9 253,675 17xl7 0.0225 Zircaloy-4 RES AR-3 3411 4 2250 142.2 x lo 6 135.8xl o 6 51. l 557.3 62.3 5.45 2.50 13.6 193 264 8 222,739 17xl7 0.0225 Zircaloy-4 Parameter/Featur e Rod Cluster Cont r ol Assembly N eutron A b so r b e r , Ful l/Part Le ngth N um be r of C lust e rs, Full/Part Length Number of Absorber Rods per Cluster Core Diameter, in. (Equivalent) Number of Safety Injection Trains High Head Injection Pumps Design Flow Rate (each) gpm Design Head, ft. Low Head Safety Injection Pumps Design Flow Rate (each) gpm Design Head, ft. Emergency Boration System Injection Pumps RES;.R-41 Ag-I n-Cd 61/8 2 4 13 2.7 3 3 800 2 850 3 1400 620 2 Design Flow Rates (each) gpm 4 50 Design Head, ft. 5 00

Centrifugal Charging Pumps ** Safety Injection Pumps RESAR-3 Ag-In-Cd 53/8 24 132.7 2 2* + 2** 150 425 5800 2500 2 3000 375

/~ l '--, 2' " I ..) I I 4 1 I 5 1 I 6 11 I. 7 'I [, 8 Ii ii 9 11 11 ii 10 Ii j! 11 !! 12 11 13 1 14 15 16 17 18 19 20 21 22 23 24 I , derol Reporters, Inc.' 25 D r. Fc.:,a c ocl~, prepa r ed t estir.1o ny? A. My name i s D0ugl2s W. Peacock , Manaq c~ of Reactor .. *-\ Prot ect.io n for tlie Nuc l ear S afety D ep artm ent of \'7e stin 9ho use E l ectric Corporation. The purpose of my test imony is to p rovid e an explanation of what the RESAR-41 r efere nc e design in volves , and an explanation of ho w it evolved from ear lier Westinghouse designs. I s~all also sponsor the RESAR-41 reference safetv analysis report as amended by amendm en ts one through 19, to RESAR-41, which is the Applicant's Exhibit No. 9. I have participated in the overall safety review of the Westinghouse design described in RESAR-41; portions of which were prepared under my direction. RESAR-41 is supplemented through amendment 19 describing the Westinghouse standard 4-loop nuclear steam supply system for a 3817 megawatt thermal pressurized water reactor. Its scope, as incorporated by the South Texas Project PSAR, includes the reactor, the reactor coolant system, the emergency core ing system, the emergency boration system, and various other safety and associated systems. The South Texas Project license application is a first application to reference RESAR-41. The standard plant .. I 2 9 10 l l 12 . : L < l-'.E SA I<.-3 dt2sign a:. 342S r:,cc;,1*i-'OU~s tLcnnal r,'.L:.i11g , ;,-;hj:*;. he,,; been r eviewed and li cens ed by the Conunissi on on sev erctl other ~icense app lications. The RES~R~_41 d~s i gQ is an evoJutionary step from the R ESAR-3 plant des ign and represent s desi gn evo-lution of Westinggouse nuclear technology. The principal design differences and si m i laritie s are summarized in my prepared testimony in Tables 1.3-1 and 4.1-1 of RESAR-41. Q. Dr. Peacock, your testimony indicates that you participated ip the preparation and overall review and approval of RESAR-41 reference safety analysis report, as 13 I amended by amendments one through 19; is that correct? 14 15 16 17 18 19 20 21 22 23 24 ~deral Reporters, Inc. ?5 A That is correct. Q. Is the RESAR-41 reference safety analysis re po rt as so amended true and correct to the best of your knowledge and belief? A. It is. MR. SCHWARZ: Mrs. Bowers, I ask that the RESAR-41 reference safety analysis report as so amended, Applicant's Exhibit No. 9, be received into evidence at this point. MRS. BOWERS: Mr. Pendergraft? MR. PENDERGRAFT: We have no objection. MRS. BOWERS: Mr. Stridiron? MR. STRIDIRON: No objection. t /. . '~ :1 3 :; !, 1, 4 ii II 5 1'* 6 1 7 1 8 1 9 1 I/ 1 o Ii 11 11 12 15 16 17 18 19 20 21 22 23 , deral Reporters, 7n~. I 25 1 . ..--L I ,*. "-~ -l . ; , ~-(The docu: ,:c: nt her ctn Co ro* marked ac; l', n;_::i lic 3.nt' s , ... * . 0 f . d . I EX (J l D l t NO

7 . 0 r l en t l...,. . I fication , is r eceiv ed i n: ! Q. questions A. evidence. ) BY MR. SCH\'7ARZ:

Dr. Peacock, are you familiar with the list of furnished by the Board on November 4, 1975? Yes, I am. ' I ! I I I i I Q. The first of these questions reads: "The increas~d; length of the 14-foot core renders itself slightly l ess stable to axial--" I'm sorry, I'm a lawyer not an engin eer x-e-n-o-n, "xenon oscillation, especially late in the fuel cycle; RESAR-41 suggests that the part-length rods may be relied on to assure stability but the SER notes a departure from nuclear boiling problem associated with the use of PLRs and says that use of such rods in Westinghouse reactors is forbidden. Please discuss the alternate control strategy Westinghouse Mode A and its implications from the standpoints of operational flexibility and safety." Would you please respond to that question? A. The control banks, the part-length rods and the ex-core detectors are provided in our design for control I ). 14 15 1 16 17 18 19 20 21 22 23 24 , derol Reporters, Inc. 25 ! .. ,. : 0 .. !I...~ C as fu e l groun c:_up prof c::.;c;,',-3 , not al lc Med to occu:i:-e:--:r cF L: . . ) *. for """: 1')': \ *. 1. (1 I l. .. ,.., ( _! .... th e full-l e ngth or part-len s U, r od s an.: suffic:.i s:.: n t and c ,:.n b.-=; us ed to dampen and control any a): i a l-:-:en on osc illati o ns. As discussed i n RESAR-41 , t he stabil it y ind e x at the end of cycle lif e i s esse ntiall y the sam e in th e 14-f oot core as it is in the 12-fo ot cores tha t are now in operation. The long 2 x ials osci ll ation periods , ap prox i-mately 24 hou~s, a llows easy control of axial-xenon transient s with part-length rods alon e , and w e see no adve rse i mptions from the st andpo int of operational fl ex ibility and safety under Mode A operation. To date, Westinghouse field reactors have not experienced any difficulty in meeting power distribution limits and in controling xenon transi e nts in the Mode A type of operation. MRS. BOWERS: Mr. Schwarz, the understanding w as we would wait until later for Barad questions. And that is true also in this area. MR. SCHWARZ: That was simply a suggestion, Mrs. Bowers, but Dr. Peacock will be back as part of the panel and that was our suggestion, but whatever the Board prefers, of course. I 2 ,; :1 I' 3 ;I " i! :I 4 :! 5 6 7 13 I 17 18 19 20 21 22 1 231 )de r ol Reporters , ~n~. \ 2s I I h l ,_~ I ' * *1 l . I.' .J.. i . Q. Di-.. Peacoc'-: , the n c~xt q ur2sti on :rc?1.ds: at page 4-1 2 s t ate?.s th a t t he d~!s_ign l_i r.1it .. reak.i ng fact or f or the 14-foo t co r e is 2.5; the S E R suppleme nt , 0t page G-1 , i .i I I I st a t es that t h e an a l yses of E CC S per for mance a ssu med a peaking: f actor of onl y 2.45. Is the EC CS ana l y s e s c o nser vat i ve from t h i s standpoint ?" Wo ul d yo u p l ease r e s nond to t hat q u est i o n? A. T he des ign l i m it peak i ng fa c t or used f or E CCS anal yse s is 2.jS. All a n a l y s e s o f E CCS p e rfo r m anc e w e r e perf ormed using t he p eak in g fa c t o r o f 2.45. Th e 2.50 val u e was a p r e limi na r y nu mbe r d e v elop e d ea rl y in th e r e v i ew of the RESAR-41 ap p lication, and has b e en su pe rs ede d in sub-sequ e nt amendment s. Dr. Peacock, the ne x t qu e stion not e d th at th e SERs asserted that the higher value of peakin g fact o r for the longer core is associated with the effect of th e PL R s. The Board then asked two questions: "(a) If the PLRs ar e not used, will the limit still be 250?" And, "(b) If a lower limit is established, will control of peaking by simple a x ial offset observations still be possible at 100 percent pow e r?" Would you please respond to that? For operation without the part-length rods the nuclear peaking factors in the *14-foot core would be in the 1' , , ;* 1 l-L -') , I ! 1: Ii \.a-'-"*: II I 2 3 v:i L h or \\'i thou t t he par t-len gth roc:s , 1 10,.'eve r, v 1ou lc1 r(:1 K 1in 4 a t 2

4 5 , as cl is cuss c cl under th c response to th e previous 5 :1 8 11 11 9 1 1 10 I I 1 1 I 12 *I 13 . . . .. .. qu est ion. The cont ro l of peaking w ith out the pcirt-.l enq th ro ds has the additional ma rgin noted above. If the li mit if the LOCA li m it wer e lower ed to a valu e typical of Mode A operation, no problems in control are anticipated using the axial offs e t method of control. Dr. Peacock, the Board's fourth question r e ads: ' "The Board not e s that one of the consequences of the new RESAR-41 refueling system is that fuel will be handl e d at a 14 shutdown margin of only five percent. How does this margin 15* compare with that generally allowed for fuel handling in I 16 I reactors and cri tica1 f aci 1 i ties. at present?" 17 A. The National Standards Institute standard in 18.2 18 specifies a value of the K effectiveness should not exceed 19 a value of .95 in fuel storage systems, although no specific 20 criterion is given for the reactor fueling operation.

21 A five percent margin is adequate and is consistent 22 with what is generally allowed today for fuel handling opera-23 tions at reactor facilities. 24 I 'cderal Reporters, Inc. II Q. Dr. Peacock, question SA included a reference to 25 the statement on page 15-8 of the SER, that a revision of r 3 .i ,, i1 4 I! page l\-8 , j!* It further oL,scrv':3s th.-1t , " Su;::ipll~rne nt 1, at su gg0sts thi s 1v ill n ot ?8 reguiP;d , but l oci: i nq out 5 li of valves and re li an c e on nuclc0r ins tr u111ent2t ion *:ill be I I I i 6 1! ii 7 , 1 I I a Ii Is thi s actually I substitut e d." Th e Board asked two questions: "(a) e-#4 ii th e plan?" And, " (b) How many minutes warning will t he 9 11 ii 11 operator have of impending criticality if r e liance is placed 10 1! 11 1 1 I! 12 entirely on nuclear instr umen tation for warning of such criticality wheu it occurs by the most rapid po stulat ed reactivity addition mechanism during refueling?" 13 .1 I ,I A. The present plan for the South T exa s Project is 14

to lock out certain valves in the chemical volume control 15 1 system to preclude a potential for boron dilution during 16 I refueling.

The only makeup water to the reactor coolant I I 17 I system is via the refueling water storage tank. This water 18 adequate boration rpior *is borated and sampled to insure to 19 the release of the reactor coolant system, thus, reliance is 20 not placed entirely on nuclear instrumentation, although it 21 will be available to warn against an approach criticality. 22 MR. SCHWARZ: I would like to recall, at this time, 231Dr. Sumpter of Houston Lighting and Power Company. tb 241 />, c -ccderol Reporters, Inc. , 25 i i I I I 2 () 4 J a m c .s i1 * ::i r m i p t c r

Re : Te ch n i c :=, l G u a l i f i c,:-1 ti o n s
11 A 6 7 T ab 17. (;/l itn ess Su ,::p ter) Yes. liR. sc:-HVA:"?Z

Th i s rfocu:n ent rnay b~ found under 8 L3 Y !M?. SC!f'.'ti.IE: 9 0 D r. S u m pt e r, was t h is d ocument p r epa r ed by you , 1 0 or und e r vour supe rvi sio n? I I 12 A 0 " (W itn e ss S u~pter) Yes, it was. Is the docu r11 ent tru~ and c o r rect to the best of 13 your knowlerl qe 8nd b eli ef? 14 I~ A 0 Yes, it is. Do you c1dopt the docu men t entitled "Tes ti m ony of 16 Ja me s R. Sumpter, Re: Technical Q ualific a tions" as you r 17 testi mo ny in this proceeding?

1 8 19 A I do. MR. SCHWARZ: M rs. B owers, I ask the 9-p a0e docu-20 ment with attachments just identified b y Dr. Sumpter be in-21 corporated into the record as thou qh re ad. Copies h;,ve been 22 furnished to the reporter. 23 24 25 MRS. BOWERS: M r. Penderqraft? MR. PENDERGRAFT: N o ohjection. M r. Stridiron? -, L. 4 6 7 9 10 I I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'I'ESTIMONY OF JAMES R. s c;,i P TE R Re: Technical Qu alif ications 1 My n ame is Jam es R. Sum p ter. I am Manager -2 N ucl e ar Division of the Power Plant Engineering and Con-3 struction Department of Houston Lighting & Power Company. 4 A resume of my educational and professional 5 , qualifications has been previously received in evidence. 6 My responsibilities in connection with the South Texas 7 I Project include the design, engineering, and fuel I 8 j ment of the nuclear system, and the radiation protection, 9 I licensing and safety analysis of the total plant. 10 11 12 13 1.4 15 16 17 18 19 20 21 22 23 24 The purpose of this testimony is to sununarize the information regarding the technical qualifications of Houston Lighting & Power Company as Project Manager for the South Texas Project, as well as the information regarding the technical qualifications of our principal contractors. More detailed information will be found in the Preliminary Safety Analysis Report for the South Texas Project, Section 13.1. You will also find tional specific information in the attachments to this testimony which I hereby incorporate. Houston Lighting & Power Company is keenly aware of its special responsibilities assumed in taking the design, construction and operation of this nuclear power station. 1 The matter of nuclear staffing has been the 2 subject of intensive consideration by our management. 3 We have, in place, a staff fully competent to execute 4 our design and construction responsibilities. Our 5 plans include the addition of further engineering and 6 operating personnel as required to assure the effective 7 design, construction and operation of the South Texas 8 Project. 9 Houston Lighting & Power Company is respon-10 sible for coordinating the overall design and construc-11 tion effort required to achieve a complete facility 12 which will provide safe, reliable and economic power. 13 The principal tasks involved in this effort include the 14 design control of the balance of plant and auxiliary 15 systems; the design control of the nuclear system; cost 16 control and scheduling functions; and finally, con-17 struction supervision. 18 These functions are performed in Houston 19 Lighting & Power Company by our Power Plant Engineering 20 and Construction Department (PPE&C} which is under the 21 direct control of our Executive Vice President, George 22 W. Oprea, Jr. PPE&C is, in turn, divided into four 23 basic groups as follows: 24 (1) The Engineering group is responsible for 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 I I I ' i thereof with the NSSS design. We also review bidders lists, specifications, equipment selection and drawings which are subject to our approval. Other departments with important functions con n e cted with the South Texas Project include the Engineering Department, the Energy Production ment, the Environmental and Inter-Utility Affairs Department, and the Quality Assurance Department. The Power Plant Engineering and Construction Department utilizes forty-three people with engineering degrees in support of the Project. Of these, two have doctoral degrees, thirteen have Masters degrees, and twenty-eight have Bachelors degrees. The Energy Production Department has three people involved in the Project of which two have Bachelors degrees and one is a registered Professional Engineer. The Engineering Department employs twelve people in support of the South Texas Project. Of these, two have Masters degrees, nine have Bachelors degrees, and one is a registered Professional Engineer. The Environmental & Inter-Utility Affairs Department employs nine people in connection with the 2 3 4 5 6 7 8 9 South Texas Project, and of these nine one has a doctoral d egree, five have Masters degrees, and three have Bachelors degrees. The Quality Assurance Department, which is entirely separated from PPE&C includes 16 professiona l personnel working in support of the S outh Texas Project. Of these, three have Masters degrees and eight have Bachelors degrees, and six are registered Professional Engineers. A more detailed presentation regarding this 10 function is presented in the testimony of Mr. Barker. 11 Attachment A to this testimony provides per-12 tinent information regarding the technical qualifications 13 of key South Texas Project personnel including their 14 educational qualifications, experie rice and any special-15 ized courses taken in the nuclear field. 16 Attachment Bis an organizational chart show-17 ing the relationship of the organizational components 18 having responsibilities for the Project. 19 Our architect-engineer-constructor is Brown & 20 Root, one of the largest construction engineering com-21 panies in the world with over 48,000 employees on its 22 permanent payroll. Brown & Root has been intensively 23 involved in the design and construction of central 24 station thermal power plants since 1954. In the past -s-

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 21 years it has bee 1. respo n sitlc far th~ jesign co ns t r uction of 79 fossil fuel ge ne rating sta tio ns , with a combin e d capacity o f over 27 , 000 me gawa t ts, in s i zes rangin g fr om sm a ll ind u st r ial ~~s t allati ons up to units of 870 mega w a t ts each. In the nuclear field, B rown & R oot has been responsibl e for the construction o f tw o 8 20 megawatt boiling water reactor plants for C a rolina Power and Light Company's Brunswick Station. It is presently engaged in similar work on behalf of Texas Utilities in the Comanche Peak Nuclear Power Plant project which consist s of two 1150 megawatt Westinghouse pressurized water reactor systems. Brown & Root's South Te x as Project engineering team is headed by an engineering p r oje ct management group including the engineering p roject manager, the assistant engineering project manager and the design coordinator. The 3 engineers in the group have a combined experience of 42 man-years in power plant engineering and construction and specifically 40 years of experience in nuclear projects. Under the project management group are various support groups including licensing, documents and controls, and various specific engineering discipline

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*----------.... -*---*-*------------. 1 2 3 4 5 6 7 g roups. Fo r the So uth Te xa s Pro ject, Brow n & Roo t has d rawn from its existing pool of fos s il pow er plant experience and from its nuclear po wer talent and has supplemented these with expert s fr o m consu lti ng engineeing organizations.

The 19 key project pers onnel for the South Texas Project have a total of 163 man-years of nuclear 8 experience. The 16 key supporting personnel assisting 9 in the project h ave a total of another 224 man-years of 10 nuclear experience derived from work in 33 nuclear 11 projects. Attachment C to this testimony is an organi-12 zational chart showing Brown & Root's project organiza-13 tion for South Texas Project. Attachment D to this 14 testimony is a table showing the names of 19 key project 15 personnel for the South Texas Project together with a 16 brief indication of their educational background and 17 prior relevant experience. 18 In addition, several nationally known con-19 sulting organizations are making major contributions to 20 the South Texas Project in their areas of special 21 expertise. NUS is responsible for preparing the En-22 vironmental Report and for a number of design activities, 23 including certain auxiliary systems; primary shielding 24 analysis; containment analysis; accident analysis; 1 2 3 4 5 6 7 8 9 10 11 12 radiological effects analysis and licensing sup p ort. NUS engineering personnel now working on the South Texas Project have a total of 800 man-years of previous nuclear experience compiled in more than 80 nuclear projects. Woodward-Clyde Consultants (WCC) are sponsible for the geology, seismology, soils engineering, groundwater hydrology and soil/structure interaction analysis for South Texas Project. wee has gained experience from working on twenty previous nuclear projects. EDS Nuclear has responsibility for pipe stress analysis inside the containment and pipe break analysis. They also provide support to the project in 13 the structural analysis area. EDS Nuclear has gained 1 4 15 16 17 18 19 20 21 22 23 24 experience from eleven previous nuclear projects. The NSSS supplier is Westinghouse Electric Corporation, one of. the leading suppliers of nuclear systems in the entire world. As of October, 1975, 33 reactors of Westinghouse design are in operation in the United States and abroad and 114 are in planning and construction phases. Westinghouse's experience in the nuclear field dates back over 30 years. This history of experience is detailed in Section 1.4.3 of RESAR-41. I should also mention, before closing, that training programs have been planned and instituted by 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Houston Lighting & Power Company for a large number of personnel, including some not presently assigned to the South Texas Project. This approach to the training of engineering personnel in the fundamentals of nuclear engineering will provide us with a pool of trained personnel in the Company who can be assigned to the project on a timely basis. It also provides a balance between utility experience and nuclear training which we feel is desirable. Attachment A provides an tion of the key personnel participating in the training programs. In summary, I believe we have assembled an unusually strong team within Houston Lighting & Power Company and our principal contractors to assure that the South Texas Project is well built and safely operated. Table 1 Table 2 Table 3 Table 4 Table 5 ATTACHMENT A Tables Of HOUSTON LIGHTING & POWER COMPANY PERSONNEL -Power Plant Engineering & Construction -Energy Production Department -Engineering Department -Environmental Protection Department -Quality Assurance Department Department I NAME DEPARTMENT MANAGEMENT E. A. Turner W. M. Meni;i;er J. R. Ridgway, Jr. NUCLEAR DIVISION J. R. Sumpter J. W. Hanson R. P. Murphy R. J. Klapper R. D. Gauny A. J. Grani;i;er PROJECTS R. E. Fulghum M. T. Luke J. R. Yeats S. Veselka TABLE 1 POWER PLANT ENGINEERING & CONSTRUCTION TITLE General Manai:i;er Assistant General Manager Consultini;i; Engineer Manai;i;er Principal Engineer, Nuclear Engineering Supervisin~ En~ineer, Nuclear Fuel ment Supervisin~ En~ineer, Nuclear Safeguards & Licensini;i; Health Physicist Senior En!~ineer, Nuclear En g in e ering Manager Project Manager, STP Supervising Eni;i;ineer, Costs Senior En~ineer EDU C ATION BSCE BSEE BSEE B S En~in ee rin~ S cien ce , M S N E, Ph . D . NE BSME BS Math, M S NE B S NE, MSNE BS Physics Math, M S Biophysics BSEE, MSNE B S EE, M S EE BSME BSME BSEE A D DITIONAL TRAININ G* A,B A B, C ,D, E C, E B,C,E,r',G C ,E,I C C,E ENGINEERING EXPEHI ENCE 24 Years 25 Yea r s 35 Years 11 Yea r s (1 1 yr s. nu~le~r) 1 0 Y ea r s (4 yrs. nu c lear) 6 Yea r s (6 y rs. nu clea r) 4.5 Years (4.5 yr s. nu clc~r) 6 Years (6 yrs. nu clea r) 5 Yea r s (4, 5 yr s. nu c l e~r) 9 Y ears 1 5 Years 27.5 Yea r s 1 9 Ye a rs TABLE l (CONT'D) POWER PLANT ENGINEERING & CONSTRUCTION NAME TITLE EDUCA TIO N CONSTRUCTION E. M. Riddle Manager BSME r. D. Asbeck Construction Supervisor BSCE E. A. Pearson Construction Supervisor B Arch. Design & Const.ruction ENGINEERING B. Sample Manager BSEE W. H. Morgan Prin~ipal En1sineer, Electrical BSEE R. T. Beaubouef Principal Engineer, Mechanical BSME, Ph.D.ME R. D. Ellerman Supervising Engineer, Electrical BSME G. H. Griffin Supervising En~ineer, Electrical BSEE K. L. Moore Supervising Engineer, Mechanical BSEE W. S. Weathers Senior Enisineer, Mechanical BSEE ADDITIONAL TRAINING* D E E,H B,E,H E,H H ENG IN EERI N G E X PE RI E N~£ 27 Years 8 Yea r s 22 Y ea r s 33 Y ea r s 28 Y ea r s 17 Y ea r s 8 Yea r s 10.5 Y ea r s 1 3 Yea r s 3.5 Y ea r s NAME TITLE DEPARTMENT MANAGEMENT R. L. Evans Vice President, Operations E. f. Hud~ins General Mana~er EQUIPMENT MAINENANCE H. G. Latham Maintenance Mana~er PLANT OPERATION W. B. Little Mana12;er TABLE 2 ENERGY PRODUCTION EDU C ATION BA, Math BSME ADDITIONAL T R AININ G* L,M B,C,E ENGINEERING EXPER I~N~~ 23 Yea r s 39 Y e ars 3 9 Yea r s 1 9 Yea r s NAME TITLE DEPARTMENT MANAGEMENT R. M. McCuistion Vice President ENGINEERING DESIGN & DEVELOPMENT K. L. Williams Manager C. S. Kayser Principal En~ineer, Systems Division E. L. Klawitter Supervisin~ En~ineer, System Operations S. C. Schaeffer Senior Eng;ineer, System Operations CIVIL ENGINEERING J. D. Greenwade Manai;i;er T. L. Duoto Principal En~ineer, Civil Division H. P. Horelica Supervising; Engineer, Civil Design TABLE 3 ENGINEERING EDUCATION BSEE BSEE, Math Reg;istered Professional Engineer BSEE, MSEE BSEE BSEE, MSEE BSCE, Civil Tech MSCE ADDITIONAL TRAirHNG* B,E B C E N GINEERING E:Xl'E:RIENCt:

* 30 Y e a r s 15 Y ea r s 30 Yea r s 10 Years 6 Years 10 Year s 5 Years 3 Y ea rs NAME DEPARTMENT MANAGEMENT D. E. Simmons D. R. Betterton NUCLEAR QUALITY B. B. Aufill TITLE Vice President Mana17;er Principal Engineer TABLE 4 ENVIRONMENTAL PROTECTION EDUCATION BSEE BSCE BA Chemistry, MSME, J. D. ADDITIONAL TRAINING*

C,E,K E N GINEER IN G EXPERIEN C~ 28 Yea r s 1 2 Y ea r s 11 Ye a r s NAME TITLE DEPARTMENT MANAGER D. G. Barker Manager SOUTH TEXAS PROJECT R. A. frazer Supervising Engineer PROJECT SERVICES W

N. Ph i1 lips Supervisor TABLE 5 QUALITY ASSURANCE EDUCATION BSME, MENE BSChE U, S. Navy Nuclear Power School ADDITIONAL TRAINING*

A,E B,C,E,J ENGINEERIN G E X~ERi f N CE 10 Years 7 Years 10 Years

NOTE 1 Listed be l~w are the titles of the trainin~ ~ourses. A. Nucle ar Ope r ato r s Sho r t Course fo r Uti l i t y Mana~em e n t conducted by Babcock & ~ilcox B. Intr od ucti o n to N u clear Power produced by NUS C. G eneral Elec t ric BWR Design Orientation D. Nu c lear F undamentals conducted by GE E. Nuclear Power Plant Design Criteria conducted by EDS Nuclear Inc. r. Nuclear Fundamentals Course at Zion, Illinois G. BWR simulator training course at Morris, Illinois H. Westinghouse PWR Information Cours e I. MIT fuel Mana~ement Course J. Training Seminar on Radio~raphic Testing K. Berkeley Short Course on Nuclear Power Plant Sitin~ & Surveillance L. Westinghouse Nuclear Maintenance Seminar M. GE Nuclear Maintenance Seminar ATTACHMENT B HOUSTON LIGHTING & POWER COMPANY ORGANIZATION CHARTS 1. Company 2. Power Plant Engineering

& Construction Department

3. Energy Production Department

4. Engineering Department

5. Environmental and Inter-Utility Affairs Department

6. Quality Assurance Department I , .-------l-----

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COH!Ur,LSHO,M AINT StRV I C(S IR AHSf OR MHI

5 W 1TC H G(AR IIUr,IIU INSTR I, CO NIROL MAINT G:!,~Ur"91N ( CON TROL S HOUSTON LIGHTING POWER CO. Energy Production Department SAM lfRTROH SU1'fR1NT(N0£NT VIC( 'A (S I OE N t 0,(RA110HS A I l\lAI N S G(N (RAL M A NA G(A A.UT GE N. 111,UfA Gt R S.U,(AINl(NO(NT N..AHT Of".IRAttOIIII If .*. ll1rL( Of't RATINO SU,f l'l.ANT OPERATIONI WATHI OUAUTY CONTflot.

£NVIJIOMll£NTAL THTINO. CONTJIOL H(Al TH (NVIAONM(ll!IT

SAHTY FUfL
LU9ftl C ATION ANALYMI OHIC( MANAGEMENT 6 CU RICAl OPUIA T INQ IUl"T. A"* FtSCHlft M A ftllO Morch 1975 Energy Production Deportment J"""'" 111~Pl lf fU <;tHVI U S CU N Sl l l llC I IIIN l\ll l)(O ll 11, l'fUJJ[CI

<;f l ll (JlfLIN(i SU P (R II I S IN G fN G INHJl It' 8 ff/lNWN HOUSTON LIGHTING POWER CO. E ng i n e er i n g Departmen t SU,[R V I S I N G (N Gl N HA B G" 1 ,VR G t$S STA, N OA R OS I, M AT[fll.t.LS STRU T LIG HTIN G SER I/I C ( C E N TE R S I C E N TRA L ZONf I A N O M A.OR U N DERGROU N D 0 1 ST Rl8 SUl'l R V I S IN G f.N G IN U R R l IJ O U CH£R NORT H ZONE SUl'E R II I S IN G fN G I N UR R H Al rH A US s u ,(RIII S ING E NOIN H R J B A LLCS SUl'f.RV I SI N G E N G IN UR N ( S, 1/, U(DI N G __ PROJECTS Ii D EVELO PM E NT SV,(RVISI N G E N GI N EER S U IISU.TI O N COORD IN ATIO N J O G R EE NW ADE SU AVEVI NO I, M~N O O tVIStOH I C I VIL ~1\/I S I O N ,R1NC1, ... L SUR V E't'O fl I j .II PJUNC l P AL E NGIN EE R x G. GOL O I I I t t ouo ro Oll(AAll COO AD1MA1w>N OF E N GI N U R I N G l'OWEfl ,L ANT SU"'°RT SE AVI CES SUl"E R V I SI N G ENO IN U R March 1 9 75 Engineering Department I NUCLEAR QUALITY 1--r.+UCL(AR (NV PROTECllON 1---N U Cl(AR PlRMITS II, 11.WROV.\LS I--lNVIAONMlNlAL LICf~SING L NUCt ( AR MONI I ORING PROGRAJilS HOUSTON LIGHTING POWER CO. Environmental And Inter-Utility Affairs WATUt fiuAUTV l"RIN(:i,Al ENGINUft ft C l'ATYRAI< l-wATER lNV l"ROTECTION I-E NGINEERING STUOIU t WATER QUALITY l"E:RM1HING WATER OIJALITY MONITORING. REPORTING L FEDERAL POWER COMM ISSION REPOIHS L0tt SJ'lll PLAN Lsot t O WASTE PROGRA.M [XIECUllVIE VICIEPRUolDENT G It' Ol'RIA. J R VICll'flUIC>ENT ENVIIIOlraN'NTAl AIIO ... TIHII-UTIUTY .t,r,AIIII DE SllltlONS ........ ENVUK,-:NTAL f'IIOTlCTION 0 It 6f1'f11TON 1coi.oov MINCIPALKIOITIIT Olf. F. G. SCHl/CHT ~*0<00.:-. ......... l'IIELO Ol'fl'IATIONI llOlOOICAl IWACT ITUDIH WILOUFI: MMAOIEMIENT

otOOICAL CONSULTANT Alll~ITT l'flfflilCtf'"'-INCMMIII If'. F. *'iUlltE ...... AIII ENV. l'IIOttcnca

~"°'" **v. **onc:T""' Alft QUALITY PI-ITTIJIQ AUi QUALITY .... TOltllillQ

flEf'ORTINQ Alfi QUALITY .. ACT ITUOtH Ollf'f.RSION MODELING ENOINHRINO ITUOIEI March 1975 Environmental And -Inter-Utility Affairs

() C: Q I "'C 3 .. ::, :J: 0 C V, 0 z r-G) :J: z c, n 0 A:~T ACHMENT C BROh1N & ROOT, INC. ORGANIZATrm

CHARTS 1. South Texas Project Organization

2. Engineering Organization

3. C~nstruction Organization OVERALL STP ORGANIZATION i PROJECT GENERAL I MANAGER I I ... , OVERALL PROJECT* OVERALL PROJECT : PROJECT PURCHASING STAFF ENGINEER I : COST ENGINEER ! SCHEDULER I MANAGER ' I I -------*---* -* --* . CONSTRUCTION PROJECT I PROJECT SUBCONTRACTS i ENGINEERING PROJECT MANAGER MANAGER / MANAGER ASSISTANT CPM : i ASSISTANT EPM -. ---. LINE OF STP AUTHORITY 1 CONSULTANTS\

I --M,i'fERIALS -\ ENGINEERING COORDINATOR H. BAKER UUALITY ASSURANCE , ! MANAGER I T.H. GAMON f ... I UUALITY ASSURANCE/ ENGINEER M. l MEYER I I .PROJECT UUALITY,* ; ENGHJEER : D. F. HANLEN I . *-ARCHITECTURAL -\ PROJECT ARCHITECT)' R. L HARDY I , MECHANICAL \ , PROJECT ENGINEER 1 LE. HAYDEN I I I-STRUCTURAL \ , PROJECT ENGINEER ' M. B. CHAN '.STP ENGINEERING ORGANIZATION ~---* I ENGINEERING PROJECT MANAGER I J. T. MOONEY 1 ASS1STANT EPM P.A. MISKIMIN ., ENGINEERING PROJECT I ----4 MANAGEMENT STAFF FUNCTIONS (POE SHOWN SE PA RATEL Y) MANAGEMENT INFORMATION SYSTEM COORDINATOR A. B. TURNER _I --------'-LICENSING I PROJECT ENGINEER; -PROJECT SCHEDULER i STRESS ANALYSIS M. M LITTLE 1 r I -HVAC \ PROJECT ENGINEER: 0. GIMAIL I J , HEAVY CIVIL & \ I WATER SUPPL y .I PROJECT ENGINEER. l K. AVERA I H. S. WOODBURY , MECHANICAL NUCLEAR PROJECT ENGINEER F. H. POMES INSTRUMENTATION PROJECT ENGINEER J. L. HAWKS : PROJECT ENGINEER I ! S. SETHI I I ELECTRICAL , PROJECT ENGINEER i R. C. HANKS J (-PLffMBI NG -STAFF SPECIALIST I E. L. NANCE LEGEND I 1 PIPING ENGINEERING I PROJECT ENGIN E EH \ R.T.WOLANTE J US , -LINE OF STP AUTHORIT Y 1 LINE OF !_ *** ;;;\INTRADISCIPLIN E AU THOHlfY I_ --LINE OF COOR DINA TIO N 0 -' ' ' : ., ] : i rn 0 rn:* (

ATTACHMENT D BROWN & ROOT, INC. ORGANIZATION CHARTS Personnel Table

.. NAME AVERA, J. K. BAKER, H. H. BIERMAN, G. F. CHAN, M. B. CRANE, c. L. GIMAIL, o. HANKS, R. C. HANLEN, D. F. HAWKS, J. L. HAYDEN, L. E. LITTLE, M. M. ' MILLAS, G. JR. ATTACHMENT D STP KEY PROJECT PERSONNEL BROWN & ROOT, INC. TITLE Project Engineer-Heavy Civil & Water Supply Project Materials Engineering Coordinator EDUCATION B.S. Civil Engineering P.E. Texas B.S. Chemistry B.S. Mechanical Engineering TOTAL EXPERIENC E 10 Yrs. 13 Yrs. 26 Yrs. Project General Manager Project Structural B.S. Civil Engineering 15 Yrs. M.S. Structural Engineering P.E. California,Oregon,Pennsylvania Construction B.S. Mechanical Engineering 24 Yrs. Project Manager P.E. Texas Project Engineer-HVAC B.S. Mechanical Engineering 13 Y rs. P.E. Illinois,Texas Project Engineer-B.S. Electrical Engineering 16 Yrs. Electrical P.E. Texas Project Quality B.S. Psychology 25 Y r s. Engineer M.S. Chemistry Project Engineer-B.S. Marine Engineering 9 Yrs. Instrumentation Project Engineer-B.S. Mechanical Engineering 5 Yrs. Mechanical Project Engineer-A.A. Mechanical Engineering 13 Yrs. Nuclear Licensing B.S. Metallurgical Engineering Project Design B.S. Mechanical Engineering 7 Yrs. Coordinator NUCLE AR EXPERIEN C E 2 Yrs. 1 Yr. 10 Yr s. 4 Yr s. 1 1 Yrs. 8 Yrs. 3 Y r~~. 25 Yr s. 8 Yrs. 2 Yr s. 13 Y r:~. 7 Yr s. NAME MISKIMIN, P.A. MONROE, J. R. MOONEY, J. T. MYERS, M. J. POMES, F. H. SETHI, J. S. WOLANTEJUS, R. T. TITLE Assistant Engineering Project Manager Assistant Construction Project Manager Engineering Project Manager Project Quality Assurance Project Mechanical Nuclear Project Stress Analysis Project Piping & Valves TOTAL NUCLE AR EDUCATION EXPERIENCE EXPERI E NC~ B.S. Marine Engineering 13 Yrs. 13 Yr s. M.S. Nuclear Engineering B.S. Civil Engineering 9 Yrs. 6 Y r s. B.S. Chemical Engineering 22 Yrs. 20 Y r s. P.E. Pennsylvania, N. Carolina, Tennessee B.S. Civil Engineering 7 Yrs. 7 Y rs. P.E. Texas B.S. Mechanical Engineering 18 Yrs. 8 Y rs. M.B.A. Business Administration P.E. Louisiana B.S. Civil Engineering 17 Yrs. 7 Y rs. Bachelor of Laws M.S. Operations Research P.E. New Jersey, Texas B.S. Nuclear Sciience 13 Yrs. 8 Y rs. 2 0 3 p~r ed tcs~i~ony? 4 UI i t n e s s Su rn p t e r ) 1 \ y n a rn e i s J cl :.1 es R * ~-i u 'J p !-, P r , 5 Manager of the Nuc lear Division of the Hou st on Li ghti'l , J 2'1*--:1 6 Power Co mpA ny. A resume of my educ2tional and prof essio 1 1c1l 7 qualifications h':ls been pr e viously received in evide*1ca. 8 The purpose of this testi 1 n0ny is to S U'nm;:iriz e the 9 inform atirm re ga r d in g the t ech nical qua lific ation s of Hou st0n IO Li gh tin g a:1d Power Company as P roj ect l/a n,3 ge r for th e Sou th \ 1 I Texas project, as well as the infor matio n r ega r d in g t echnica l 12 qualific a tions of our principal contr ac tors. 13 Houston Li gh tin g and Po we r Compa ny is aw a r e of 14 its special resp ons ibilities assumed in und e rt nk in g t he 15 desiqn, c0nstruction a nd oper a tion of this nucl ea r stnti0n. 16 We have in place a st a ff fully co mpe tent to execut e ou r 17 design and construction responsibilities. 18 Our plans include the addition of further en g in P.e r-19 ing and operating personnel as required to~ssure the effe ctive 20 design and construction and operation ofthe South Te xR s 21 project. 22 Clur architect-engineer and constructor is B rown clnd 23 Root Incorporated, one of the largest construction engineerinq 24 companies in the world. Brown and Root's experience in the 25 design and construction of power plant extends back to 1 95 4, 2 qe nerati.n r; units. B rnwn 211d Rn'.J t has u t'v e;Jor or i :=i st"-, f r nf 4 en c e d pr o j e c t In a n n q e ri e n t , ;:i n d !z e y p r o ..! e c t p 8 r s n 11 '1 e l 1 ;-, :, i c :-1 i s 5 c ap a b 1 e o f f u l f i 11 i n g the r e s p 8 n s i b i li t i 1) s o f th 9 o r ch i t ':i c t -6 en g ineer f,w the South TexAs projec t. 7 In addition, sev e;n;i l n at i o n a lly kno1m con.s 1.1lti n0 8 or ga nizations are making ma j o r coritributions t o the Sout h 9 Texas proj e ct in t he ir ar eas of speci al expe rtis e , incl uding 10 N U S 1 Corporation, Wocx:l.\.*,urd-Clyde Consulta: '1ts, e1nd NEDS i*iuc l ea r. \.. I I Westinqhouse, the Nuclear Ste am Supply Sys te m Inv en t o ry 12 certainly has been recognized a s a n e xper i e nced, c apab l e 13 en g ineerin g organization in the de si0n of nu cl ea r st ea~ 14 supply systems. 15 In sum~ary, I believe we have a ssembled an unusu a l 16 stronq team within Houston Lighting and Power Co mpany a n d oui-17 principal contractors to insure the South Texas project is 18 well built and safely operated. 19 Thank you. 20 MR. SCHWARZ: Applicant now calls 21 Mr. David G. Barker, Manager, Quality Assurance Dep a rtment 22 for Houston Lighting and Power Company. M r. Barker has been 23 previously sworn. 24 BY MR. SCl-J\'lARZr 25 Q Mr. Barker, do you have before you a 5-paqe C .1 f!, ::i 2 A.s s u r an c e ? 11 J A (\'iitness

_,a r l:0.r)

Yes. 4 5 Tab .1 8. 6 BY ~R. SCH~ARZ: 7 0 Vias t h is mat e rial prep a r*ed hy y o u or u n de r you r 8 sup erv isi o n? 9 10 A 0 (W itness Barker) Yes. Is th e document tru e and correct t 0 th e be st of \ I 1 your knowledge and belief? 12 13 A Q Yes. Mr. Ba r ke r, do you ado pt the docu m ent ent i tled 14 11 Testi m ony of D. G. Barker, Re: Qua lity Assur r mce" ris your 15 testimony in this proceeding?

16 17 A Yes, I do. MR. SCHWARZ: Mrs. Bow e rs, I as k the 5-page docu-18 ment identified by M r. Barker be incorporated in the r r.c o rd as 19 though read. Copies have been furnished to the report e r. 20 21 22 23 24 MRS. BUWERS: Mr. Pendergraft? MR. PENDERGRAFT: No objection. MRS. BUWERS: Mr. Stridiron? MR. STRIDIRON: No object ion. MRS. BOWERS: The document you have just identified 25 will be physically inserted in the transcript as if read. (The complete testimony follows.) ~, T E STIMONY OF D. G. BARKER Re: Q u ality Assurance 1 My name is David G. Barker. My position is 2 Manager, Quality Assurance Department with the Houston 3 Lighting & Power Company (HL&P). 4 A resume of my educational and professional 5 qualifications has previously been received in evidence. 6 My functions in connection with the South 7 Texas Project are the development, implementation and 8 management of the HL&P Corporate Quality Assurance 9 Program. This responsibility extends into all project 10 activities including design, procurement, construction, 11 and operation. 12 The purpose of this testimony is to present 13 information on the matter of quality assurance for the 14 South Texas Project, Units 1 & 2 including the portions 15 of the program implemented by Brown & Root and 16 Westinghouse. 17 Detailed information on this subject can be 18 found in Chapter 17 of the Preliminary Safety Analysis 19 Report for South Texas Project Units 1 & 2 and Chapter 20 17 of the RESAR-41 (Reference Safety Analysis Report). 21 This information may be summarized as follows: 22 HL&P, as Project Manager for the Project 2 3 Participants, has the responsibility for quality assur-24 ance during the design, procurement, fabrication, 1 2 3 4 5 6 7 8 9 construction and operation phases of the South Texas Project. HL&P is fully aware of the attention that should be applied to quality assurance during all of these phases of the South Texas Project. In order to establish and maintain the high quality level required for project activities, HL&P has developed and has fully implemented a comprehensive Quality Assurance Program. This program is documented in the Quality 10 Assurance Program Manual and the South Texas Project 11 Quality Assurance Plan. This Program was implemented 12 prior to the selection of the NSSS vendor and is 13 presently being utilized in all facets of the project. 14 This program requires, at a minimum, that the quality 15 assurance activities performed by HL&P and its prime 16 contractors, subcontractors, and vendors comply with . 17 the NRC criteria established in 10 CFR 50, Appendix B, 18 "Quality Assurance Criteria for Nuclear Power Plants", 19 appropriate Regulatory Guides and industry standards. 20 The HL&P Quality Assurance Department was 21 established to provide for the effective control of all 22 quality activities related to the nuclear power plants, 23 including those performed by all contractors and sup-24 pliers. We have developed and implemented a detailed I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 indoctrination, training and continuing education program to assure that all quality assurance personnel are fully qualified to discharge the responsibilities assigned to them. As the Manager, Quality Assurance, I report on all technical and administrative matters to the Executive Vice President of HL&P. This reporting arrangement provides independence for the quality assurance function. Our HL&P Quality Assurance personnel have the duty and authority to identify quality problems; to initiate, recommend or provide solutions; and to verify the implementation and effectiveness of solutions. To e n force this, they have authority to "Stop Work" in all design, procurement, construction and operation phases of HL&P nuclear power plant projects. A Project Quality Assurance Manager is assigned to the South Texas Project. He has the sibility of implementing the South Texas Project Quality Assurance Plan and deals directly with the HL&P Project Manager, other line organizations, contractors and subcontractors. In addition, HL&P will have on the site qualified resident quality assurance personnel who will perform continuous surveillance on all site activities; 1 t hese i ndi vi du a l s r ep ort t o t h e Pro j e c t Qualit y A ssur an c e 2 Manager. 3 W hile HL&P retains overall responsibility for 4 the Quality Assurance Program, portions of the Program 5 are implemented by Brown & Root and Westinghouse. 6 Brown & Root and Westinghouse have developed 7 and implemented quality assurance programs that satisfy 8 the NRC regulatory requirements and those required by 9 HL&P. 10 Within the Brown & Root organization, a 11 Project QA Manager has been appointed to supervise the 12 site QA activities. He reports to the Brown & Root 13 Manager of Quality Assurance at Brown & Root headquarters 14 in Houston, who in turn, reports to the Senior Group 15 Vice President of the Power Division. At the Houston 16 office, a Project QA Engineer is responsible for quality 17 assurance during design and procurement and reports to 18 the Manager of Quality Assurance. Also, a Vendor 19 Surveillance Coordinator reporting to the Manager of 20 Quality Assurance is responsible for the vendor surveil-21 lance activities. 22 At Westinghouse, the Nuclear Energy System 23 (NES) Divisions are responsible for supplying the 24 Pressurized Water Reactor (PWR) nuclear steam supply

.r--------

*-1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 systems and compo nents for the South Te xas Project. W ithin N ES, the PWR Sy s tems Division , headed b y a General Manage r, is resp on sible for design, procurement, and quality assurance for all of the nuclear s yste ms and components.

The PWR Systems Division Product Assurance Department is responsible for integrating and auditing the quality-related work and the quality assurance programs of the NES Divisions and the external suppliers to Westinghouse. This Department is headed by the Manager, Product Assurance, who reports directly to the General Manager of the PWR Systems Division. HL&P has conducted a comprehensive audit program to verify that this overall QA Program as described is indeed being implement ed in a satisfactory manner. In summary, a comprehensive quality assurance program has been established and implemented for all quality-related activities as described in Chapter 17 of the South Texas.Project PSAR. Implementation will continue for the life of the Project, with reviews and modifications to the program being made, as necessary, to conform to new requirements as they may arise. C i! i: , i 2 0 A .. U Y * \ R

S C: : : ., . 1*t* 1 : /. \ r
8 a r k r. r , c o u 1 d y n u s u rn m a r i 7 o y o u r t. *: s t i f: ' on y ? Plitn e ss Bc:.ir1.e r) :.'.y 1 1.ci: r:e is IJ=i vi cl G. !t;:i r i_,::3 r. '( *. , ., j 4 position i s /,1 an ,:10 er , Q ua li ty i\ssu r ance D opa rt ne nt , 1.*,rith Hn u::;t o n 5 Li r;h tin (J and Powe r Cor.1pa ny. A resume of '11'! educ;::,tion a l 2 nd 6 pr o f ess ion;::, l qua lific at i o ns has previously bee n r e ceived in 7 evidence.

8 My testimo ny presents a brief de s cr iption of t i'le 9 Houston Li g hting and Power Quality Assurance Program and how 10 it is placed into eff e ct through the South Texas project l I quality assurance plan. It provi de s information on the 12 oroanization structure of the Houston Liqhti nq and Po\'/er 13 Quality Assurance Department, including its re p ortin q posi-14 tion and the staff that will be responsible for the i m p l e-15 mentation of the quality assurance plan for the South Te xas 16 project. 17 My testimony further provides information abou t 18 our architect-engineer, and constructor, Brown and Rnot. 19 And the responsibilities they have in implementing an eff e c-20 tive quality assurance proqram for the South Texas project. 21 The organization structure in a brief description of the 22 Westinghouse quality assurance program is also presented in 23 my testimony. 24 This completes my summary. 25 MR. SCHWARZ: Applicant now calls 2 ha s b ee n s w o rri pr e vi0us l*.1. 3 4 0 B Y !'/f-?. SC: J\'/.t1p;;:: * .. Dr. r?o dn e r, d,') y or 1 h u ve l w f 0 r e y ou a 1 6-p.*1 1" 5 docu me nt t 0 gether w ith a list o f r e f e r en c e s an d 6 t a hlss 6 attach ed e ntitle d 11 Jesti mo ny o f l'/a lt o n /1.. t~o c k 1e r, P.e: C o r1p l i*-7 ance W ith Ap p endix I?" 8 9 A 10 Table L-8. I I 12 13 14 Q (W itness Rodger) Yes, I do. MR

SC )-l W , i\ R Z : M rs
Bowers , th i s d o cu m en t i s u n d e r '. I am sorry. Tah I 9. I beg your p a rdon. MRS. BCJWERS: Vi e hF:Jve it. 1hank you. BY MR. S CH W ARZ: Dr. Rodger, was this document prepared by you o r 15 under your supervision?

16 17 A Q <Witness Rodger) rt*was. Do you have any corrections, additions or rn odifica-18 tions to the document? 19 A Yes, sir. There is one typoqraphical error on 20 page 13 at line 6. There are 2 figures. Under gamma, for a 21 single unit. 22 It reads 0.013 millirad per year and it should 23 read 0.13 millirad per year. 24 In addition, I would like to make one addition to 25 Table 6. The first entries on Table 6 are for liquid *, 2 unit, th e *.*1or d *!t hy r o i d" s ho uJ d h::: aclrle d 1 : ": 1 ri t hen h d o.*: t!-i:-1 t 3 *I * *:: o 1 J 1 d

l i k e t n .c-1 ,: i c t* r, ..., 11 ..... 4 a d d O
0 2 7 m i l l i r P 1 ;i s p e r* y 1; 2. r
5 MR'.J. B\J\'/E R S: '.\'o ulrl ','()U rn ind r e p ea ting t hn t? 6 That l a.st c o rr ect i on. 7 WITNE SS P.ODGE F?: Ye s. l Jn t abl e 6 , in th e s eo cond 8 colu mn , reads "li qu id effluent, totc=ll body dose per unit" 9 and then 11 or 9c1n dose per unit. 11 That is th e-; thyroi d d ose. 10 Below thc1t I wou l d like to add 11 1i vcr.11 \ I I In the final c o lu m n, i mmed i a t ely below th e nu m be r 12 00.033 --I would li k e to add 0.0 2 7, millirem pe r year. 13 14 15 0 MRS. B lH'I ER S: Fi n e , th c1 n k you. BY MR. SCHWA RZ: Is the document as so modified true a nd correct to 16 the best of your k nowledge and oelief? 17 18 A 0 (Witness R odger) Yes. Do you adopt the document entitled wresti fllo ny of 19 Walton A. Rodger, Re: Compliance W ith Appendix I" as modified 20 by your testi~ony, as your testimony including the attachme nt 21 thereto? 22 23 A Yes. MR. SCH WAR Z: Mrs. Bowers, I ask that the I 6-paqe 24 document and attachments identified by Dr. Rodger, as modi fied 25 by Dr. Rodoer at this hearing, be incorporated into the record C ,~ :! I () 2 3* 5 6 as th ou qh r ear-/. \ ,--, .. J
MR. PE ND~RG R AFT: ~0 obj e cti o n. M RS. 8l!i'/i-:~?S: /, fr. St ridirnn? MP.. STRIDif?llN: N o objection. MRS. 8l)\'/ERS: 1l,e ciocurient will be physica ll y 7 inserted in the trnnscript as if read. 8 (The complete testi mony follo\, 1 S.) 9 JO l l 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I Re: Complia nce with A~penciix I. 1 My name is Walton A. Rodger. I am a partner in 2 the c onsulting firm of Nuclear Safety Associates.

My 3 technical and professional qualifications have been 4 previously received in evidence. I have been continu-5 ously involved in the nuclear energy field since 1942. 6 Much of my professional career has been devoted to study 7 and consulting in the area of control of effluents from 8 nuclear facilities. 9 This statement addresses itself to the ques-10 tion whether the proposed nuclear facility, South Texas 11 Project Units 1 & 2, will discharge radioactive effluents 12 to air and water which will be "as low as practicable," 13 and whether the proposed facility meets the requirements 14 o:E Appendix I to 10 CFR 50, as adopted by the Nuclear 15 Regulatory Commission ("Commission") effective June 4, (1) (2) 16 1975 and amended.effective September 4, 1975. 17 Under Section I of Appendix I, design objec-18 tives conforming to the guidelines of Appendix I are 19 deemed to be a conclusive showing of compliance with the 20 ii "as low ~s p~acticable" require~ents of 10 CFR 50.34a. 21 1 These guidelines are set forth in paragraphs A, B, C, 22 and D of Section II of Appendix I. This testimony will 23 I show that each unit of STP meets the design objectives 24 j of paragraphs !IA, IIB, and !IC. 1 Paragraph I ID of Ap pendi x I sets f or th a 2 cost-benefit anal y s i s t h at mu s t be pe rf orme d t o ascer-3 tain whether additional items should be added to the 4 radwaste system. As amended by the Commission effec-5 tive September 4, 1975, however, para g raph IID provides 6 that such analysis need not be performed in the case 7 of an application docketed prior to June 4, 1976--such 8 as that for the South Texas Project--if the radwaste 9 systems satisfy the Guides on Design Objectives for 10 Light-Water-Cooled Nuclear Power Reactors proposed in 11 the Concluding Statement of Position of the Regulatory 12 Staff in Docket-RM-50-2 (hereinafter called the "Staff's 13 Concluding Statement") reproduced in the Annex to (3) 14 Appendix I. Applicant has presently chosen to comply 15 with paragraph IID by demonstrating that it satisfies 16 the Staff's Concluding Statement. Thus, this testi-17 mony will also show that the radwaste systems satisfy 18 paragraphs A, B, and C of the Annex to Appendix I. 19 I have made a completely independent analysis 20 of the South Texas Project radwaste systems using the 21 most recent versions of the Draft Regulatory Guides per-22 taining to Appendix I as follows: 23 24 I.AA Calculation of Annual Average Doses to Man from Routine Releases of Reactor Effluents 1 2 3 4 5 6 7 8 9 10 11 for the Purposes of Implementing Appendix I, September 23, 1975. I.BB Calculation of Releases of Radioactive Materials in Liquid and Gaseous Effluents from PWR, September 9, 1975. I.DD Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light Water Reactors, September 22, 1975. The results of my analyses are summarized in this statement. 12 I. Description of Waste Systems 13 The waste systems to be used at the South 14 Texas Project have been described in some detail in 15 Chapter 11 of the Preliminary Safety Analysis 16 Report (PSAR). For an orderly presentation of this 17 testimony, a brief and simplified description of the 18 waste treatment systems proposed for handling the 19 gaseous and liquid wastes from STP follows. 20 A. Gaseous Systems 21 The South Texas Project reactors, in company 22 ith any Pressurized Water Reactor ("PWR"), can be ex-23 ected to have small but discernible releases of gaseous 24 astes from the following sources: 1 2 3 4 5 6 (1) Primar y Gas System (2) Secondary Off-gas (3) Steam Generator Blowdown Vent (4) Containment Purging (5) Ventilation of the Auxiliary Building (6) Ventilation of the Turbine Building. 7 A brief discussion of each of the six 8 sources follows. 9 The primary coolent in a PWR, if the core 10 contains any significant fraction of failed fuel, 11 will contain some radioactive fission products some 12 of which are gases. At one or more points in the 13 system (in the case of South Texas Project at the 14 Volume Control Tank) some of these gaseous fission 15 products are drawn off and sent to the Primary Gas 16 System. This system in the South Texas Project con-. 17 sists of a compressor, cooler, moisture separator, 18 dryer (2 in parallel) and four charcoal-filled delay 19 tanks. The effective holdup time in the delay tanks 20 before discharge is about four days for kryptons and 21 more than 60 days for xenons. The purpose of the 22 holdup is to allow time for the shorter-lived corn-23 ponents of the waste gas to decay prior to release. 24 This significantly reduces the dose impact of the

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 I discharge.

In PWR the primary coolant is used in a steam generator to transfer heat to a secondary water circuit in which steam is produced for use in the turbine generator to produce electricity. So long as there are no leaks in the tubes in the steam tor, there will be no radioactivity associated with the secondary system even if there is radioactivity in the primary system. Thus the loss of radioactivity from the secondary system of a PWR is a "second order" probability, that is, there must be simultaneously present significant failed fuel and significant steam generator tube leakage to produce any significant loss of radioactivity from the secondary system. In this analysis allowance has been made for an assumed release from the secondary system. In most PWR the blowdown taken from the steam generator to maintain proper water chemistry in the tem is discharged into a blowdown tank where it is cooled by allowing a portion of the liquid to flash (boil). The off-gas from this tank has been shown to be a possibly significant source of radioactivity, particularly iodine, if discharged directly. At the South Texas Project, however, the vapor from the blowdown tank is 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 condensed in feed water heaters and all of the liquid is returned to the condenser hotwell. This approach eliminates this source of gaseous waste completely. PWR are provided with containment shells. There is a great deal of equipment inside these tainment shells and it contains the primary coolant at elevated temperature and pressure. It is not sible to maintain all of th is equipment in a pletely leak-free condition. Therefore, it is to be expected that some of the primary coolent will escape into the containment shell, and that some of the caped material will become and remain airborne. When it is necessary to enter the containment shell for any length of time, it is generally desirable to purge the containment atmosphere in order to reduce the activity in the air which will be breathed by the 17 personnel entering. When this is done the remaining 18 air-borne activity in the containment atmosphere will 19 be released to the environment. To reduce the amount 20 so released, the South Texas Project containment in-21 eludes two 10,000-cfm "kidneys", internal devices which 22 circulate the containment atmosphere through charcoal 23 and HEPA filters to reduce the iodine content. In the 24 calculation of emissions from containment, it has been 1 assumed that there wi l l be a continu ou s pur ge of con-2 tainment at a rate o f 100 0-cfm, even though the plans for 3 operation do not include the use of conti n uous purge. 4 The Auxiliary Building of a PW R houses a good 5 deal of anciliary equipment used for the control of 6 radioactivity of the system and for ma n y other sub-7 systems needed for the operation of the reactor. Many of 8 these can be expected to leak small quantities of radio-9 active liquids into the building and some of these will 10 become airborne. Thus there is the possibility that some 11 radioactivity will escape with the ventilation air from 12 this building. At the South Texas Project the Auxiliary 13 Building ventilation air is released without treatment 14 prior to discharge. 15 Similarly, there is a possibility, albeit less 16 than in the case of the Auxiliary Building, that there 17 can be radioactive material in the air in the Turbine 18 Building. At the South Texas Project this ventilation 19 air is released without treatment. 20 B. Liguid sistems 21 Liquid wastes from PWR come from a variety 22 of sources which have a considerable disparity in chem-23 ical and radiochemical composition and concentration. 24 Normally these wastes are collected and treated I 1 separately. The liquid wastes from South Texas 2 Project fall into the following five categories: 3 (1) eves Waste -(Waste Portion of LWPS) 4 5 6 7 (2) Clean Waste -(Recycle Portion of LWPS) (3) Floor Drains -(Waste Portion of LWPS) (4) Chemical Waste -(Waste Portion of LWPS) (5) Detergent Waste -(Waste Portion of LWPS) 8 A brief discussion of each of the five 9 categories follows: The eves System is set up to 10 control the concentration of boric acid in the primary 11 coolant. In a real sense it is not a waste system at 12 all but rather an integral part of the control system for 13 the reactor. However, a portion of the product needs 14 to be discarded to control the concentration of tritium 15 in the primary system; thus the system contributes 16 to the discharges of radioactivity in liquids and needs 17 to be considered as a waste system. 18 The eves System for the South Texas Project 19 consists of two ion exchangers (in parallel), two holdup 20 tanks, an evaporator, and a distillate ion ex-21 changer. A portion of the overhead distillate is sent 22 to the waste portion of the Liquid Waste Processing 23 System ("LWPS"), where it could, if necessary, be given, 24 further processing. Since further processing will. -a- ~: rrnally not be needed, in this analysis I have : I! ~::;sumed that this distill a te is released after 3 4 5 6 an alysis without further processing. The Clean Waste (Recycle) System is set up to handle reactor-grade water from equipment and sample drains. These wastes are collected 7 separately in a Waste Holdup Tank and may be evaporated, 8 deionized, or both, or released without treatment as 9 circumstances dictate. 10 The Floor Drain System is set up to handle 11 the wastes which have been collected from the floor 12 sumps of all of the buildings save the Turbine 13 Building. These wastes tend to be more variable 14 in composition and lower in radioactivity than the 15 clean waste. Their treatment at the South Texas 16 Project consists of collection, evaporation, and/or 17 ion exchange, or they may be released without treat-18 ment if circumstances warrant. 19 The Chemical Waste System collects the 20 regenerant from the condensate cleanup system. This 21 waste, if contaminated due to steam generator tube 22 leakage in conjunction with significant failed fuel, 23 will require evaporation. 24 I 1 2 3 4 5 6 7 8 The overhead from evaporation can be further treated with ion exchange if desired .. The evaporator overhead, with or without further treatment, is released. The evaporator bottoms are solidified and sent to a mercial burial ground. Stearn generator blowdown from a PWR will not contain any radioactivity unless there is sirnltaneous steam generator tube leakage and a significant fraction 9 of failed fuel. At the South Texas Project steam 10 generator blowdown is returned to the condenser hotwell 11 and thence to the condensate dernineralizers. Thus in 12 a sense this waste stream does not exist at the South 13 Texas Project. 14 Detergent wastes come from the laundry, showers, 15 and decontamination operations. The activity level is 16 very low. The detergent content, on the other hand, very . 17 much complicates the treatment of other wastes, were 18 these to be combined with them. Consequently it is 19 desirable to segregate this waste category and this is 20 done at the South Texas Project. The treatment provided 21 for this stream at the South Texas Project is normally 22 filtration, although additional treatment is available if 23 needed. In this analysis only filtration is assumed. 24 Turbine Building drains usually contain only 1 very low levels of radioactivity even if there is some 2 steam generator tube leakage. It is not generally the 3 practice to provide any treatment for this stream. In 4 our analysis, allowance has been made for the contribu-5 tion of this stream to total liquid discharges. 6 II. Emissions of Radioactivity from the South Texas Project 7 The emissions of radioisotopes from the 8 operation of the South Texas Project have been estimated 9 using techniques similar to those used by the Commission 10 Staff in making their analyses. My source terms were 11 developed using the same PWR-GALE code used by the Staff. 12 All such calculations are dependent, however, on a series 13 of assumptions and judgments. I believe that my assump-14 tions are essentially identical to those of the Staff 15 for the gaseous systems--so the resulting source terms 16 (shown in attached Table 1) should be almost identical. 17 The Project's liquid system is so flexible, however, that 18 no two analysts are likely to make precisely the same 19 assumptions. Thus there may be some small differences 20 between the liquid source terms I have calculated (shown 21 in attached Table 2) and those used by the Staff. 22 III. Calculation of Individual and Site Boundary Doses 23 The source terms from Tables 1 and 2 were con-24 verted into site boundary and "maximum individual" doses ,. 1 using the equations giv e n in Draft Regulatory Guid e 2 l.AA (September 23, 1975). Some of the calculations 3 were done by hand calculator, others by the use of 4 computer codes developed by Nuclear Safety Associates. 5 Site boundary calculations were done for the 6 north sector at a distance of 1430 meters. A number of 7 critical residences were checked--the controlling point 8 was taken as a residence located 4300 meters NNW of 9 the reactors. 10 In making these calculations it is necessary 11 to use values of atmospheric dispersion, X/Q, and 12 deposition, D/Q, at the points of interest. The ap-13 plicant's meteorological consultants, NUS Corporation, 14 reviewed the site meteorology as reported in the PSAR 15 and the Environmental Report in light of the new Draft 16 Reg. Guide l.DD (September 22, 1975). They provided the 17 meteorological parameters listed in attached Table 3 18 which I used in this analysis. 19 The calculated maximum doses to an individual 20 from liquid effluents are shown in attached Table 4. It 21 is obvious from Table 4 that the South Texas Project meets 22 with ease either the design objectives of paragraph IIA 23 of Appendix I or those of paragraph A.l of the Staff's 24 Concluding Statement. Further, Table 2 shows that South ---*-1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Texas Project meets parag raph A.2 of the St a ff's c luding Statement. The resulting site boundary air doses were determined to be: Gamma Beta Single Unit Two Units 0.013 mrad/yr 0.26 mrad/yr 0.26 mrad/yr 0.52 mrad/yr Thus it is apparent that the Project also meets with ease the design objectives for noble gas emissions contained in paragraph II.B.l of Appendix I as well as paragraphs B.l and B.2 of the Staff's Concluding Statement. The calculated external doses from gaseous effluents to real individuals, located at the above ~efined residence, were determined to be: Total Body Dose Skin Dose One Unit Two Units 7.7E-03 mrem/yr l.5E-02 mrem/yr 2.0E-02 mrem/yr 4.0E-02 mrem/yr Here again these doses are much below the design tives of paragraph II.B.2 of Appendix I or of paragraph B.3 of the Staff's Concluding Statement. The calculated doses from the emission of iodines and particulates in effluents to the atmosphere are shown in Table 5. The values shown in Table 5 are for dose pathways which could reasonably exist, as required by I 1 A p pe ndix I. These v a lues are for a s i ngle unit. Ev en 2 doubled to allo w for t w o-unit operation at the s i t e , the 3 maximum individual total body dose is less than 1 mrem/yr 4 and the maximum indi v idual organ dose is less than 2 5 mrem/yr. Thus STP satisfies paragraph II.C of Appendix 1 6 and paragraph C.l of the Staff's Concluding Statement. 7 Table 1 shows that STP also satisfies paragraph C.2 of 8 the Staff's Concluding Statement. 9 The above calculated doses are summarized in 10 Table 6 and compared to the requirements of Appendix I 11 and the Staff's Concluding Statement. Again it is clear 12 that STP meets all pertinent requirements with ease. 13 14 15 16 17 18 19 20 IV. Conservativeness of the Nuclear Regulatory Commission _ Staff's "Upper Bound" Calculations In an affidavit filed by Dr. Jacob Kastner for ( 4) the Commission Staff earlier in this proceeding, an "upper bound" calculation of the total annual population dose resulting from the South Texas Project was presented for purposes of demonstrating the unlikelihood that a cost-benefit analysis pursuant to paragraph II. D of Appendix I would require any addition to the radwaste 21 systems. In view of the Commission's subsequent revision 22 of paragraph II.D, as I have previously indicated, no 23 such cost-benefit analysis is presently required in this 24 case. However, it is clear that Dr. Kastner's analysis 1 was indeed a conservative "upper bound" calculation. 2 We are now in a position to make a more nearly 3 precise "upper bound" calculation. Attached Tables 4 4 and 5 show that the real individual subject to maximum 5 exposure may be expected to receive from the operation 6 of a single unit less than 1 mrem/year thyroid dose and 7 less than 0.5 mrem/year total body dose from liquids and 8 gases. 9 In general the average dose over fifty miles 10 is found to be about 1% of the maximum individual dose. 11 Therefore we can expect that the average doses over the 12 SO-mile radius will be about: 13 14 total body thyroid SE-03 mrem/yr lE-02 mrem/yr 15 The projected year 2020 population for the 50-16 mile radius surrounding the Project site is about 17 800,000 persons. Therefore the total annual population 18 dose in 2020 from one South Texas Project unit can con-19 servatively be expected not to exceed: 20 total body 4 person-rem 21 thyroid 8 person-thyroid-rem. 22 Dr. Kastner's "upper bound" estimate, which was 23 based upon a total U.S. population, was about 24 total 24 body person-rem and 35 thyroid-person-rem. This clearly 1 conservati v ely over e stimat e d the annual p opul ation d o se 2 within 50 miles which would be considered if a cost-3 benefit analysis were being performed under paragraph 4 II.D of Appendix I. 5 V. Conclusion 6 My independent analysis of the South Texas 7 Project shows that the radwaste systems proposed by 8 the Applicant meet the design objectives of paragraphs 9 II.A, II.B, and II.C of Appendix I and that, since they 10 satisfy paragraphs A, B, and C of the Staff's Concluding 11 Statement, they also meet the objectives of paragraph 12 II.D of Appendix I. 13 14 15 16 17 18 19 20 21 22 23 24 l References

1. Title 10, CFR Part 50, Appendix I. Federal Register, V. 40, p. 19442, May 5, 1975. 2. Title 10, CFR Part 50, Amendment to Paragraph II.D. of Appendix I. Federal Register, V. 40, p. 40818, September 4, 1975. 3. U.S. Atomic Energy Commission Concluding Statement of Position of the Regulatory Staff (and its Attachment)

-Public Rulemaking Hearing on: Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criteria "As Low As Practicable" for Radioactive Material in Light-Water-Cooled Nuclear Power Reactors, Docket No. RM-50-2, Washington, D.C., February 20, 1974. 4. Affidavit of Dr. Jacob Kastner (Relative to an upper bound estimate of radiological impact on the general public), Docket Nos. 50-498 and 50-499, July 6, 1975. TABLE 1 Gaseous Source Terms Noble Gases Kr-83m Kr-85rn Kr-85 Kr-87 Kr-88 Kr-89 Xe-13lrn Xe-133m Xe-133 Xe-135m Xe-135 Xe-137 Xe-138 Total Noble Gases I-131 I-133 Tritium Others Mn-54 Fe-59 Co-58 Co-60 Sr-89 Sr-90 Cs-134 Cs-137 C-14 A-41 Total Ci/yr 0.0 9.0E 00 2.7E+02 2.0E 00 1. 4E+Ol 0.0 1.7E+Ol 1. 5E+Ol 8.7E+02 0.0 3.3E+Ol o.o 0.0 1.2E+03 1. 8E-Ol 1. SE-01 l.OE+03 3.9E-02 l.3E-02 1. 3E-01 6.0E-02 2.9E-03 5.3E-04 3.9E-02 6.7E-02 8.0E 00 2.SE+Ol

TABLE 2 L i qu id Source Terms Corrosion

& Activation Products Cr-51 Mn-54 Fe-55 Fe-59 Co-58 Co-60 Np-239 Fission Products Br-83 Sr-89 Y-91 Mo-99 Tc-99m Te-127m Te-127 Te-129m Te-129 I-130 Te-13lm I-131 Tc-132 I-132 I-133 Cs-134 I-135 Cs-136 Cs-137 Ba-137m All others Total except Tritium Tritium Total Ci/yr 0.00009 0.00100 0.00009 0.00005 0.00490 0.00880 0.00004 0.00003 0.00002 0.00010 0.00910 0.00870 0.00001 0.00002 0.00007 0.00004 0.00015 0.00005 0.07700 0.00077 0.00200 0.04100 0.01600 0.00720 0.00110 0.02600 0.00210 0.00007 0.22000 480 TABLE 3 Meteorological Parameters Used In Calculations Direction Distance from Site meters X/Q, Sec/m3 1. Noble Gas Values Maximum Site Boundary N 1430 4.7E-06 Residences: ESE 2000 4.3E-07 WSW 3900 3.8E-07 w 3900 4.9E-07 NNW 4300 4.8E-07 2. Radioiodines and Particulates* Gardens ESE 2000 3.4E-07 WSW 3900 2.7E-07 w 3900 2.SE-07 NNW 4300 2.9E-07 Cow E 11,300 l.8E-08 3. Deposition Values* D/Q, m-2 Gardens ESE 2000 2.3E-09 WSW 3900 1. 3E-09 w 3900 l.4E-09 NNW 4300 3.3E-09 Cow E 11,300 4.SE-11

Includes cloud depletion.
TABLE 4 Liquid Doses to "Maximum Individual"*

Pathway Total Body Doses: 1. Ingestion of Fish (Salt Water) 2. Ingestion of Seafood 3. Deposition on Shoreline Total Liquid Total Body Dose Thyroid Doses: 1. Ingestion of Fish (Salt Water) 2. Ingestion of Seafood 3. Deposition on Shoreline Total Liquid Thyroid Dose Child 3.SE-03 l.3E-03 6.lE-04 5.4E-03 1. 4E-03 1. 4E-03 2.SE-03 Teen Adult 9.SE-03 l.3E-02 2.lE-03 2.9E-03 4.3E-03 6.lE-04 l.6E-02 l.7E-02 l.9E-03 2.0E-03 l.2E-03 l.3E-03 3.lE-03 3.3E-03

Assumed to live at "Nearest" Residence shown in Table 5.

TABLE 5 Summary of Part i culate & Iodine Doses a t Nea r e s t Res i d e nce* (fr o m a sin g le unit) Pathway Total Body Doses: 1. Noble Gas Immersion

2. Deposition on Ground 3. Inhalation

4. Leafy Vegetables

5. Stored Vegetables

6. Water Total Thyroid Doses: 1. Noble Gas Immersion

2. Deposition on Ground 3. Inhalation

4. Leafy Vegetables

5. Stored Vegetables

5. Water Total Infant 7.7E-03 2.5E-01 8.4E-03 0 2.7E-Ol 7.7E-03 2.5E-01 5.lE-02 0 3.lE-01 Child 7.7E-03. 2.5E-01 8.SE-03 6.7E-03 9.SE-02 0 3.7E-01 7.7E-03 2.5E-01 3.4E-02 4.4E-Ol 4.4E-02 0 7.SE-01 Teen 7.7E-03 2.5E-01 7.6E-03 7.lE-03 9.5E-02 0 3.7E-Ol 7.7E-03 2.5E-Ol 2.5E-02 2.6E-Ol 2.3E-02 0 5.7E-01 Adult 7.7E-03 2.5E-Ol 1. 6E-02 1. 3E-02 9.7E-02 0 3.SE-01 7.7E-03 2.5E-Ol 3.6E-02 3.3E-01 5.0E-02 0 6.7E-Ol

Located 4300 meters NNW of the site. This is not the "nearest" residence, but it has the poorest value of X/Q.

TABLE Comparison of Calculated Doses with Design Objectives Design Objective Stated In Appendix I: 11IIA 11IIB ,1IIC AP.P_lied to Liquid Effluents Total Body Dose per Unit Organ Dose per Unit Gaseous Effluents ' Gamma Air Dose per Unit Beta Air Dose per Unit Total Body Dose to Real Individual per Unit Skin Dose to Real Individual per Unit Particulates & Iodine per Unit Staff's Concluding Statement: ,1A 11B ,,c Liquid Effluents Total Body or Any Organ per Site Liquid Effluents curies/unit Gaseous Effluents Gamma Air Dose/site Gaseous Effluents Beta Air Dose/site Total Body Dose to Real Individual per Site Skin Dose to Real Individual per Site Gaseous Effluents Particulate & Iodine/site Gaseous Effluents I-131 per unit Design Objective 3 mrem/year 10 mrem/year 10 mrad/year 20 mrad/year 5 mrem/year 15 mrem/year 15 mrem/year any organ 5 mrem/year 5 curies/year 10 mrad/year 20 mrad/year 5 mrem/year 15 mrem/year 15 mrem/year 1 curie/year Calculated Value 0.017 mrem/y e a r 0.0033 mrem/y ear 0.13 mrad/y ear 0.26 mrad/y ear 0.0077 mrem/ye ar 0.02 mrem/year 0.77 mr em/y car (thyr oid) 0.034 mrem/y ear 0.22 curie/y e ar 0.26 mrad/year 0.52 mrad/y ear 0.015 mrern/y ea r 0.04 mrem/y ea r 1.5 mrem/y ear 0.18 curie/y ear c--:i: l l 2 qun.sti oris? 3 4 5 0 BY MP.. SC!-f'-IARZ: Dr. Rodger, would you pl eGse su m marize y0i ir pre-6 pdred testi m ony? 7 8 A (Wit ne ss Rodger) Yes, sir. /1,y name is Ha lton A. Rodger. I am a partner in 9 the nucle a r consultin g firm of Nuc leRr SAfety Asso ciates, 10 Be th esda , \~aryland.

'Jy technical and rrofe ssi o'IA l qualific2-

' 1 I tions have be~n pr e viously received into evidence. 12 M y testi m ony addresses itself to the question of 13 whether the proposed nuclear facility South Tex as p r oje ct 14 Units I and 2, will discharge radioactive effluents to ai r 15 and water which will be as low as practic ab le. 16 I have made a completely independent analysis of 17 the South Texas project radwaste systems, using methods 18 similar to those used by the staff in preparation of their 19 testimony and using the most recent versions of the d raft 20 Regulatory Guides pertaining to Appendix I, specific a lly 21 Regulatory Guide I .AA, which has to do with the calcul at ion 22 of doses, Requlatory Guide I .BB which has to do with the 23 calculation of the source term and Regulatory Guide I .DD, 24 which has to do with the estimating of atmospheric diffusion. 25 The results of my analysis are described in my 2 3 4 5 6 7 8 9 10 1 1 12 S' 13 14 15 16 17 18 19 20 21 22 23 24 25 c1t tachc d thereto. but sp2ci1'ic.=dJy s;r.ir" ffi?,-:: d in Ui:)l,' (, , wh ic h .1.vc just addo.d,' Table 6 , 1 1 i hich 1*1e just ondec:. Tah l e 6 shn*.-:s tr*1c1t the South Texa s p r oje ct 'ncc ts \*!i th e ase in all res pects the r eciu ire rne nts of parr:iq r aphs 2/\, 2i3 a n::i 2 C of Ap pe ndi x I, o rid th a t it a ls o mee ts with e ase in all r espe cts pa r ag r aphs A , Band C of the Staff's concluding st atem ent, and thus un d er the oper-ation afforded, meets para g r aph 2D of .Append i x I. Therefore, it does indeed m ee t all of t he r equ ire-*i , ments of Appe n d ix I a nd its releases are inde ed as lo w as practicable.

(_) ..-! 1 \,' 2 0 4 A Y e s , I , , *, 1

5 Q D r. F/nd (;e rs, t h e l"l st o f t h es e q u esti o n s 6 re EJd s: It i s n o t cl e ar t o t lw f3 0 2 r d 1,1!.e th e r t ho s L 1 t e'r1c n t 7 at page 11-2 or S u p ple r r 1ent to the eff e ct th a t a ir d oc;R::; 8 wi 11 not P. xceeci 1 0 'A r ad per ye a r ga ,i l i: l c! and 2 0 \\ n1d per 9 ye a r beta include con tri butions fro m ga s st r ea m releases 1 0 of Carbon 14, tri tiu m a nd p a ticu l Ates. l., 11 Are we to rely on the i mpl ic ation in the 12 J uly 1 8 , 1 975 aff i d a vit of D r. Boeq li th a t such doses 1 3 due to Ca r bon 14 in pa rtic u l ar a r e n eg li gib le? 14 I beg your pA rdon. I believe it continu e s. 15 If so, is th e dose from tritium also ne 0 li 1 ibl e? 16 And then, 8: are the"rele ases on which the 17 Staff's present air dose assessment is based, those of 1 8 Boegli or those of the FES Table 3.7, as implied in the 19 SER at page 11-7? 20 I reco g nize that this question appears to 21 be addressed principally to the Staff. However, do you 22 have any comments on either of these questions?

23 A Well, yes, in regard to Question AA, based on 24 my knowledge of the development of Appendix I, and a 25 review of Qeg Guide IAA, particularly Appendix B thereof,

, *-~ ~; ' : .:_ L1 r only to the n0ble qA s e st t hat is kry~to n, x e non an d a r g on 4 1 :J a n d .the e ffec ts of car bon 14, triti um and p.1 rt i c u l ate 6 ;:i re t n'~en into r1ccou nt by o t he r me a ns a nd sp e cificc1lly 7 tho se desc ri bed in Appe~rlix C t o Regu l atory Guide I AA. f! I t rw y be not 2 J t ha t T a b l e [3 I o f Pe q u l a to r y 9 Guide !AA inclu des i~~ersi o n rlose f a ctors only for t~e 1 0 no b le 0c1se s. \ I I S in ce there are no immersion dose f a ctors --12 and I didn't hav0 a ny availble to me --for c a r bo n 14, 13 tritiu~ or particulates, I rou gh ly estimated what the 14 dose from these i mme rsions miqht be by the use of a 15 techni que that we formerly used. 16 That is, concentrate the concentration 17 of the release in question at the point of interest, 18 co mpa re that to the maximum permissible concentration as 19 given in JO CFR Part 20, and assu~e that the JO CFR Part 20 20 MPC is equivalent to 500 millirem per year, thus the 21 concentration of the MPC to 500 gives a rough estimate 22 and I repeat, rouqh estimate of the dose. 23 On this basis the estimated releases of 24 carbon 14, tritium and the total of all prticulate 25 releases would increase the calculated noble gas immersion 2 and 3 re rc0nt r esp ectiv e Jy. 3 4 for us to ~nswer that nuestion. 5 6 Appliuint now c a lls M r. P. D. Gauny , h8alt:-1 7 physicist for the llouston Liqhtin(J and Power Cornpa:1y. 9 10 I l 0 J.l r. Gauny hns been previously sworn. DIRECT EXA:.1 1 tiAT I O r~ BY rm. sc1m.l\RZ : Mr. Gnuny , do you have before you an eight-pae I 2 doc urn en t e r1 ti t l e _i Test i mo n y of R
D. Gau n y i~ e O cc up a tin a l 13 Exposures?

14 15 A Yes, I do. MR. SCH~',IAFa

The document w i 11 be found 16 under Tab 20. 17 BY MR. SC!-1'.',Al?Z:

18 0 Mr. Gauny, was this document prepared by you 19 or under your supervision? 20 21 A Q Yes, it was. Do you have any corrections, additions, or 22 modifications? No. :.:, 1 *' 23 24 A 0 Is the document true and correct t6 the best of 25 your knowledge and belief? 2 O no yo~ 1 ado :-i t th e: c: n c 1.1 '"'.'1 e n t c : 1 t i tl e d L~ s t L:-: on'.>' 3 off?. D. (~n:rny Pe (Jr;.:u pati01v: J 1.:XCJris:1r c ,s :1.s y n,1:r* t 0 sti.:1rT1*, 4 i n this p r nceeci i ng? 5 A Y e s, I do. 6 ;, lR. SC!f\'!i\tF: \\rs. ll o1*1ers, r as~: th a t the 7 8-pc:irie documerit just i den tifi P,d by Mr. Ga'...my be 8 in co r porated into t he record as thou gh r ead. 9 MRS. 130\'il:P.S: l.1 r. Pendergraft? 1 0 I 1 12 13 MR. PE NDERGRAFT: No ohjection. .1.rns'*. BOV/~'?:::;

f,l r. Stridiron?

/.P:-:. STRIDIR tl/J: No ohjection. i ,\RS. f3UWEPS: The docw ne nt just identi f i 8d w i 11 14 be physically incorporated in the transcri pt as if re ad. 15 (Testimony follows.) 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Re: Occupational Exo a sures My name is R. D. Ga un y. I am a Health cist in the Nucle ar Division of the Power Plant neering and Construction Dep artment of Houston Lighting & Power Company. A resume of my educational and professional qualifications has previously been received in evidence. It is my function in the South Texas Project to assure that the facility is designed and operated in a manner that assures that exposures are within regulatory requirements. At the earlier hearings in this proceeding, the Board expressed interest in the occupational dose estimate included by the NRC staff in the Final mental Statement for the South Texas Project. The FES assumed that the occupational dose associated with the South Texas Project plant would be 450 man-rem per year per unit. This, of course, is only an estimate based upon experience at other nuclear power plants. fically, it is derived from WASH-1311, "A Compilation of Occupational Radiation Exposure from Light Water Cooled Nuclear Power Plants, 1969-1973.". The matter of occupational exposures is dealt with in detail in the Preliminary Safety Analysis Report for the South Texas Project, specifically in 1 Secti on 12.1.6 and Tables 1 2.1-24 t hrough 1 2.1-30. 2 A t t he out set , I would l ike to state th at the 3 450 m an-rem per unit figure (whi ch i n cl ud e s e x posures 4 to both permanent operating personn e l and support 5 maintenance people) is neither a g o al nor a design 6 objective for the Project. It will be our objective to 7 reduce occupational exposures to a level as low as 8 reasonably achievable and, in fact, we would expect to 9 maintain in-plant exposures significantly lower than 10 those estimated by the Staff. Our management is com-11 mitted to this goal in the manner required by paragraph 12 C.l. of Regulatory Guide 8.8 on "Occupational Radiation 13 Exposures at Nuclear Reactors." 14 In implementation of our management commitment, 15 we are taking steps in the design of the facility and 16 will adopt work practices to help us achieve our goal 17 of minimizing radiation exposures to onsite personnel, 18 whether permanent or transient. 19 Turning first to the matter of design, the 20 South Texas Project facility will incorporate features 21 which should be extremely helpful in reducing occupa-22 tional exposures. Among the specific features designed 23 to reduce exposures are permanently installed scaffolding 24 around the steam generator, and a design that allows 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 for removal of the steam generator in one piece. The use of volatile chemistry in the treatment of the secondary side of the steam generator has also been selected in an effort to reduce exposures. The use of remote welding techniques and explosive plugs are being considered to further reduce exposures during steam generator maintenance. As the Board is aware, the surveillance and maintenance of steam generator tubes has proven to be a major contributor to occupational exposures. It is our expectation that the South Texas Project design features will reduce substantially the dose associated with such operations. The overriding design criterion for the facility shielding, equipment, and layout has been to keep radiation exposure to operating personnel as low as reasonably achievable (ALARA) and well within the limits of 10 CFR 20. The facility is being designed in conformance with the reconunendations of Regulatory Guide 8.8, which suggest ways in which ALARA exposures can be achieved (such as careful selection and placement of equipment, isolation of that equipment from personnel as much as possible, and reducing frequency and duration of equipment maintenance periods). A few examples of how this has been achieved in the design of the South 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Texas Project, Units No. 1 and 2 follow. The Mechanical and Electrical Auxiliary Building where facility radioactive waste is collected, processed, and prepared for disposal, has been arranged with a large part of the middle level exclusively devoted to the routing of pipes containing radioactive fluids. This radioactive pipe chase is connected with all of the shielded enclosures that are provided for equipment containing radioactivity. In this way the facility has been designed so that personnel will always be shielded from radioactive piping and equipment during routine operations. Valve manipulation is accomplished in active systems via remote reach rods or with powered valve operators. Furthermore, the valves are isolated from the system components that they serve. By careful design, personnel.will not normally be exposed to shielded radioactive valves or pipes. When maintenance is required on these valves, the worker will be shielded from the pump, tank or other radioactive system component. Each radioactive system component is similarly isolated from neighboring equipment so that maintenance can be accomplished with minimal radiation exposure to personnel and without shutdown of that system. ~4-1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Each radioactive filter in the facility is individually shielded and these filters are clustered in one part of the Mechanical and Electrical Auxiliary Building. Filter cartridge replacement has been fully planned so that rapid and safe accomplishment is assured. Shielded cartridge transfer casks will provide efficient delivery to the drumming area with minimum personnel exposure. Shielding and isolation are provided for systems containing low levels of radioactivity. Some examples of this are the Laundry and Hot Shower Tank and associated components and the Spent Fuel Pool Cooling and Purification System. The residual heat removal (RHR) system ponents and piping are all either located behind the Reactor Containment Building (RCB) secondary shield or are individually iocated in shielded cubicles. This allows safe access for personnel into the RCB shortly after shutdown of the reactor and while the RHR system is cooling the reactor down. Another important source of occupational posures is that received during refueling operations. It is our expectation that the Westinghouse rapid refueling features incorporated in the South Texas 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Project design will result in decreased radiation exposures. Westinghouse has informed us that this feature may reduce total exposures during such operations by as much as a factor of 4. These are but a few of the many features that will keep occupational exposures as low as reasonably achievable. The design of the facility has been and is being monitored by competent radiation protection specialists to ensure that this goal will be achieved. We are taking other important design measures to minimize occupational exposures. We require our architect-engineer radiation protection specialists to review the plant design to assure that it is consistent with our occupational dose objectives. The engineer must demonstrate to us that criteria intended to reduce radiation exposures are incorporated in the design. In genera"!, we are using the design guidance set forth in Regulatory Guide 8.8. In addition, we have established a systematic method to review abnormal occurrences at other reactors so that this experience can be factored into our design thereby minimizing the possibility of unscheduled maintenance. Turning now to work practices and procedures, the South Texas Project is committed to the development 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 of practices in plant operation to minimize occupational radiation exposures. These practices will be rated in the plant radiation manual and will be revised to reflect operating experience. Among the practices to be followed are such important measures as draining and flushing components before maintenance, pre-job training and planning, proper supervision of maintenance personnel, and the transfer of components under repair to areas with lower radiation fields. In the area of administrative devices to reduce exposures, we expect to make extensive use of personnel training measures, including the use of mock-ups as required to familiarize maintenance employees with the environment in which they will work. We believe that by so doing exposures during maintenance can be significantly reduced. Again our plans and procedures for plant operation will be developed in accordance with the recommendations of Regulatory Guide 8.8. At our earlier hearings, the Board questioned whether the assumption of 450 man-rems per year per unit, as stated in the FES, was compatible with the individual limits on radiation exposures in 10 CFR 20. As noted above, the 450 man-rem figure employed by the staff includes exposures to regular plant personnel as 1 we ll as to support maintenance personnel (i.e. t h ose 2 maintenance personnel not permanently assigned to th e 3 plant). Thus, there is no necessar y inconsistency 4 between the 450 man-rem figure and the requirements of 5 10 CFR Part 20 with respect to individual exposures. 6 In any event, as noted above, 450 man-rem is neither a 7 goal nor design objective for the South Texas Project. 8 Present estimates of occupational exposures, excluding 9 support maintenance personnel, are in the range of 10 104.4 man-rem per unit per year to plant personnel 11 during routine operation and maintenance. We believe 12 that the steps outlined above provide a basis for the 13 expectation that occupational doses for the South Texas 14 Project will be substantially lower than 450 man-rem 15 !per year per unit, even including 16 I In any event, steps will be taken 17 lpational exposures of individuals 18 latory requirements of 10 CFR 20. non-routine maintenance. to assure that are within the regu-19 In summary, the Applicant's commitment to 20 , minimizing occupational exposures is evidenced i 21 1 out the plant design and will also be reflected in our 22 operational practices and procedures. 23 24 ! 2 0 3* pr ope ra~ t 2st i no nv? 4 A 6 Power Company. 7 A r esume of my educational and professi0n A l 8 qu a lific a ti on s h 0 1s been previously receiv ,~d in evidence. 9 At earlier hearings in this proceeding the 10 Board expressed inter est in th e 4SO man-r em pe r year I I per unit occurotional dose esti ma te inclu rled by the 12 NRC Staff in t he F inal Environmental Statement for th e 13 South Texas P r oje ct. 14 450 ~an-rem per unit per year is neith e r a 15 goal nor a desiqn objective for the Project. 16 It will be our objective to re rlu ce 17 occupationAl exposures to a level as low as reason ab ly 18 achievable and, in fact, we would expect to ~aintain in-19 plant exposures much lower than those estimated by the 20 Staff. 21 In the matter of design, we have incorporated 22 numerous features which should reduce occupational 23 exposure. These include improvements in steam qenerator 24 access, considerations of remote welding techniques and 25 explosive plugs, careful selection and placement of t, ,--, ; ...... ,, ,-,-_ I,' ' I !P) i ,,..: 2 O;Je r a ti n'!. 5 utilized. 6 -fhis r ec;uto ry gu i de has been clos e l y follo*.-J0d 7 in the deve lo;::1nen t of work pract ic es arcJ administrativ e 8 procedur es. 9 Amo~0 the p r actices to be follnwerl A r e the 10 flushing of lin es befo re mAi t ena nc e , p rejnb trAining and I I plAnnin q , p r ope r supe rvisi ono f maintenAnce per so nnel, 12 and the tr~nsfer~r co~p onents under r epa ir t o A reas 13 with lower r ad i ation fields. 4dministrative p roce du r e s 14 w ill make extensive use of personnel tr a inin g. 15 In sum ma ry, the Applicant's co mm it me nt to 16 :ninimizin<J occupational exposures is evidenced thro u qh out 17 the plant design andw ill also be reflect ed in the 18 op e rational practices and procedures. 19 We believe that the steps outlined above 20 provide a basis for our expectation that occupational 21 doses for the South Texas Project will be suhstantially 22 lower than 450 man-rem per year per unit. 23 In any event, steps will be taken to assure 24 that occupational exposures of individuals are within 25 the regulatory require m ents of 10 CFR 20. 1 1 I; 2 l~l:=1 pf)e r , ::i: 1 pe r v i:3o t*, tn9 in e:e r in9 1 '.vi th 0*1stn n Li r:htin 1 , 3 Po~e r* Com~~ny~ He h a s be 2 n S',*t0r n. 6 B Y M R. SCH/:.t\.R Z: 7 l)o you h;:ive befor e you a 4-paCJe docu m ent e nt i tl G d H T e sti m ony of R ichar d J. K la ppe r q e Int e rface He t wee n 9 Sout h T ex as Project and R E S S AR-41? 10 I I A Yes, sir. ... \H?. SCH\'IARZ: /.\rs. Bo we rs, this ciocu 11 ent wi 11 12 be found under Tab 21. 13 R Y M R. SC I J:'1/\R Z: 14 0 Mr. Klapper, was this document prepar e d b y y ou 15 or under your supervision? 16 17 A 0 Yes. Is the docu11ent true and correct to the best 18 of your knowledge and belief? 19 20 A Q Yes, it is. Do you adopt the document entitled Testimonv of 21 Richard J. Klapper Re Interface Between South Texas Project 22 and RESSAR-41 as your testimony in this proceeding? 23 24 A Yes, I do. MR. SCHWARZ: Mrs. Bowers, I ask the 4-page 25 document identified by Mr. Klapper be incorporated in the j ,, '._. .-,-, -, ,--i i '. * '*'

2 4 6 i den tifi ed w ill he n hysic~ll y inc orrnr~tAd in the 7 transc r i p t as if read. 8 C Testi~ony foll ow s.) 9 1 0 I I 1 2 13 14 1 5 16 17 1 8 19 20 21 22 23 24 25 '

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 TESTIMONY OF RICHARD J. K LAPPE R Re: Interface Betwe e n South Texas Project and RESAR-41 M y name is Richard J. Klapper. M y position is Supervising Engineer, Nuclear Safeguards and Licensing with Houston Lighting & Power Company. A resume of my educational and professional qualifications has previously been received in evidence. My functions in connection with the South Texas Project are to assure that the design, tion and operation of the Project are in conformity with all applicable NRC regulations and criteria. The purpose of this testimony is to present information on the matter of the safety-related faces between the nuclear steam supply system and the balance of the nuclear power plant. Detailed information on this subject can be found in Section 1.1.2 of the Preliminary Safety ysis Report for the South Texas Project Units 1 and 2 and on the blue pages in RESAR-41. A design interface is a broad term generally used to refer to a requirement established to assure that two related systems will be constructed and ated in an appropriate and compatible fashion. The NSSS supplier provides a great deal of information to the utility, including a large number of specified interfaces, in order to assure that the architect-1 engineer, the constructor and the utility will properly 2 design the balance of the plant (BOP) taking into ac-3 count the characteristics of the NSSS which affect the 4 BOP. In the case of the South Texas Project, this 5 extensive information was provided by Westinghouse as 6 paYt of a scandard design information package. 7 For regulatory purposes, it is necessary that 8 an Applicant for a standard design identify and designate 9 in its submittals to the NRC those safety-related 10 design interfaces that will assure compatibility between 11 the standard design and the BOP. 12 In the case of the South Texas Project, the 13 process of identifying and designuting such safety-14 related interfaces corrunenced in the RESAR-41 submitted 15 by Westinghouse pursuant to the provisions or Appendix 16 0 of 10 CFR Part 50. Section 3 of Appendix O requires 17 that a standard design submitted for NRC approval 18 include a description, analysis and evaluation of the 19 interfaces between the submitted design and Lhe balanc~ 20 of the nuclear power plant. 21 When the South Texas Project application was 22 docketed, the NRC Staff had not completed its detailed 23 review of RESAR-41, including its review of the portion 24 thereof that identifies safety-related interfaces. It

1 thus became important to assur e t hat co mp le t i o n of NR C 2 Staff review of the interfaces appl ica ble to the Sout h 3 Texas Project units would not be dela y ed by the more 4 comprehensive review required for issuance of a Pre-s liminary Design Approval (under Appendix 0) that would 6 be applicable to all future plants that might wish to 7 incorporate RESAR-41 by reference.

8 Accordingly a program was undertaken by 9 Westinghouse and HL&P to identify and designate on a 10 timely basis all of the safety-related RESAR-41 inter-11 faces necessary for purposes of the STP units. This 12 specific effort included a systematic evaluation by 13 Westinghouse of all information provided as part of the 14 standard/information package and to define additional 15 interface information to be included in RESAR-41. Such 16 information was incorporated into Amendment 17 of 17 RESAR-41 submitted in June, 1975. The NRC Staff iden-18 tified those aspects of the South Texas Project units 19 involving RESAR-41 interfaces that had to be resolved 2 o for the specific purposes of the South Texas Project 2 1 docket prior to the issuance of the construction permit. 22 The NRC Staff issued three sets of questions to Houston 23 Lighting & Power Company on RESAR-41 interfaces and 24 these matters were satisfactorily resolved through 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 amendments to the STP PSAR submitted on August 15, October 1, October 9, and October 27, 1975. Thus, the combination of amendments to RESAR-41 and amendments to the South Texas Project PSAR incorporating information specifically applicable to the Project have provided the necessary identification of the safety-related interfaces. The NRC Staff is continuing its review of RESAR-41 for the purpose of issuing a PDA that will enable future utility applicants to reference RESAR-41 without further review. This process, which is aimed at a final, generic approval of RESAR-41 as a reference design will continue. In the interim, those aspects of the design requiring 1: esolution prior to the issuance of the construction permit for the South Texas Project have been resolved to the satisfaction of the NRC Staff. i ,:, j 0 3 .. /*, 5 is :::iue;)~-visi n0 Eno ine 2 rin~, i"iu cl e,:i r Sa fe gu:-~rds anc/ Licer..s iri:1 , 6 !*Iou stcin Li 1ht i;-i g ?. Po.,1c r Cri,npany. 7 A resu.,., e of rny e ducational and rrofession

il 8 qualifications ha ve previously be e n recei.v ed in evi dc:nce. 9 In .su rnrr ,a ry, t he pu rpos e of this testimnny is 1 0 to p r esent inf o rn~tion on the ~atterof th e s a fety-rel a ted 11 interfac es bet~een the nuclear st eam supply ayarwm and 12 the ba l anc e of th e nucle8r plant. I 3 For r e *.Ju l a t or y p u r po s e s i t i s n e c e s s a r y t tv:1 t 14 an Applic3nt for A standard design, RESSAR-41, identif y a nd 15 desi g nat e in its submittals to the NRC those safety rel ated 16 design interfaces that will ensDre compatibility between 17 the stand a rd desiqn and balance of plant. 18 For the South Texas Project, the RESSAR-41 19 document irlentifies the appropriate reglAtQry interfaces.

20 However, when the South Texas Project application was 21 docketed, the NRC Staff had not completed its detailed 22 review of the RESSAR-41 interfaces. 23 The program was undertaken by Westinghouse and 24 Houston Lighting & Power Company to identify and designate 25 on a timely basis all of the safety-related RESSAR-41 2 J* 4 i-'..) 6 7 8 9 10 s/,J b 1 l 12 13 14 15 16 17 18 19 20 21 22 23 24 25 iritor~','lce:-;. T h i:; i nfnn1 ,-::!tirm **.*,c; :Lncn r pnr,,tF1c/ 5.nto Sub se q uently, the r:r:1c Staff i d2 ntifi ed th ose aspect.s of the South lex=is F'roject Ur\i ts involvin g RE S SAR-41 inte rfAces that had to he identified for the sp e cific p *.-p oses of the South Texr1s Proj 0 ct docket prior to issu a~ce of the construction per~it. Co m bination of amend m ents to RESSAR-41 and amendment to the South Texas Project PSAij incorporatinq infornation specifically applicable to the project has provided th e n eces sary identification of the related interfaces. In conclusion, those interfaces requiring identificAtion prior to the issuance of construction permit for the South Texas Project have been resolved. t ,~ -~' ' : ,: ; xxxx L IJ ;I 3 ii 11 ;I 4 ;! 1, I' 5 11 1 1 6 11 1 1 7 !I I! :i 8 ,: 'I I, 9 :! II 10 I' 1* ;I ii 11 i! I I ,I I* *12 I! 13 1! *1 1 4'1 Ji I 16 17 18 Lic;ht.in g and Power Co mp.::i ny. hr. Betterton has been S\'lOrn P,r evio u s_ly. .. i*vh ere upon , D. R. BET'rERTON was called as a witness and, having be e n previously duly sworn, was ex am ined and testified as follows: DIRECT EXAMI N ATION BY MR. SCHWARZ: Do you have before you an eight-page docu men t entitled, "Testimony of D. R. Betterton, re: Site Monitoring Syst ems"? A. I do. MR. SCHWARZ: This document may be found under tab 22. BY MR. SCHh'ARZ : Mr. Betterton, was this document prepared by you 19 or under your supervision? 20 A. It was. 21 Q. Is the document true and correct to the best of 22 your knowledge and belief? 23 A. It is. * *,de rol Reporters, ~n~. I Q. Have you adopted this document as vour testimony 25 in this proceeding? xxxx i'.. 1 do. ' 1! 2 page docum en t just i d e ntif i ed by Mr. B ette rto n b2 inc o r porctt c d i n t he r eco rd a s th ouah read . . -* MRS. BOW ERS: Mr. P enderg r aft? 6 1 MR. PENDER GRAF T: Assuming Mr. Bet terton i s still 7 I aliv e and with us, we h ave no objec tion. 8 I 9 1 10 11 11 11 1 2' 11 13 ' I 14 I 15 16 17 18 19 20 21 22 23 24 I MRS. BOWERS: Dr. Hand though t his ID soun ded as tho ugh h e was getting married. DR. HAND: With regret. MRS. BOWERS: Mr. Stridiron? MR. STRIDIRON: The Staff has no objection. MRS. BOWERS: The document that has been id en tifi ed will be physically incorporated into the transcript as if read. (Testimony follows.) A r ~ederol Reporters, Inc.' 25 1 TESTIMONY OF D. R. BLTTERTON Re: S ite Mon i toring Systems M y name is D. R. Bettert o n. M y position is 2 Manager, Environmental Protection Department with 3 Houston Lighting & Power Company. 4 A resume of my educational and professional 5 qualifications has previously been received in evidence. 6 My functions in connection with the South 7 Texas Project include managerial responsibility for the 8 conduct of a wide variety of studies relating to the 9 suitability of the South Texas Project Site including, 10 but not limited to geological and seismological investi-11 gations. I participated in the development of the 12 13 14 15 16 17 18 19 20 21 22 23 24 monitoring programs at the site which are discussed in this testimony. The purpose of this testimony is to present information on the monitoring progra~ established to measure the settlement of facility structures and to measure regional ground surface subsidence. Detailed information on this subject will be found in the Preliminary Safety Analysis Report for South Texas Project Units 1 and 2, specifically in Section 2.5.4.13 at pages 2.5-157 through 2.5-157f. This information may be summarized as follows: A comprehensive site performance monitoring program will be established to measure the settlement 1 of facility structures and to measure regional ground 2 surface subsidence. The monitoring programs are designed 3 to enhance the safety of the project by giving advance 4 warning of any unforeseen occurrences and to provide s basic data for verification of predicted plant founda-6 tion performance. The settlement portion of the monitor-7 ing program will consist of an array of borehole heave a points, extensometers, open standpipe piezometers, pore 9 pressure cells, and structural benchmarks. The regional 10 ground surface subsidence monitoring program will 11 consist of an array of shallow and deep aquifer open 12 standpipe piezometers, a network of vertical and hori-13 zontal ground control benchmarks, and a deep-reference 14 benchmark with continuous subsidence monitoring 15 instrumentation. 16 The settlement monitoring program will be 17 capable of monitor{ng heave and settlement of individual 18 soil layers during construction as well as the actual 19 settlement of facility structures. This will be accom-20 plished by the installation of twenty conventional 21 downhole monuments that are capable of measuring heave 22 of individual soil layers. Fourteen Sonde extenso-23 meters will also be installed to depths of 230 feet and 24 300 feet below the ground surface. The Sonde extenso-1 meters consist of corrugated plastic tubing with gauging 2 points fixed at selected increments. The flexible 3 nature of the Sonde tubing allows the gauging points to 4 move vertically as the subsoil heaves and settles 5 during construction activities and allows an accurate 6 determination of the deformation of individual soil 7 layers throughout the extent of the installation. In 8 excess of one hundred structural benchmarks will be in-9 stalled on plant structures as plant foundation and 10 substructure construction proceeds. These benchmarks 11 will be measured on a periodic basis to determine the 12 vertical movement of individual structures and Category 13 I piping systems. 14 In addition to the conventional downhole 15 monument, extensometer, and structural benchmark installa-16 tions, a piezometer field will be installed to monitor 17 shallow aquifer ground water in the construction area. 18 The piezometer field will utilize an initial installa-19 tion of open standpipe piezometers that are capable of 20 measuring the piezometric head in individual soil 21 layers. Certain piezometers within the excavation will 22 be located adjacent to extensometer and conventional 23 downhole monument installations in areas beneath plant 24 structures. In order to permit continued monitoring of 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 these piezometers during plant construction, pore pressure cells will be installed in selected piezometers and subsequently monitored remotely at a terminal box at finished site grade. In addition, a number of pore pressure cells will be installed directly in the tural backfill to monitor the ground water in this material. The piezometer and pore pressure cell lations will be used to monitor the effectiveness of the dewatering system and the ground water measurements will be used to evaluate the effects of dewatering on subsoil deformations during construction. The regional subsidence monitoring program will be capable of monitoring both vertical and zontal ground surface movements at the South Texas Project site. This will be accomplished in part by the installation of a deep-reference benchmark that is designed to continuously measure total subsidence at the South Texas Project site throughout the life of the plant. The deep-reference benchmark will be positively anchored to the strata, below the potential subsidence zone (approximately 1155 feet below ground surface) and separated from the possible consolidation effects of the overlying compressible zones by a 4-inch casing. To provide continuous ground surface subsidence measure-1 ments a modified Ste v ens T y pe F Record e r will be i nsta l l e d 2 and operated within an Instrument Shelter. The deep-3 reference benchmark design is similar to the United 4 States Geological Survey deep benchmarks currently in 5 operation in the Houston area. 6 The deep-reference benchmark will be installed 7 prior to the commencement of dewatering and will be 8 used to establish baseline vertical datum control for 9 both the settlement and regional monitoring programs. 10 The deep reference benchmark will be referenced to the 11 National Geodetic Survey (NGS) benchmarks in Bay City, 12 Texas, in order to correlate site specific data with 13 other subsidence readings in the area. This will be 14 done whenever the NGS makes its own level loops. 15 Twelve near-surface monuments capable of 16 measuring vertical ground surface movement will be in-17 stalled in the plant vicinity at a depth (approximately 18 15 feet) sufficient to minimize seasonal shrink-swell 19 ground surface movements due to variations in water 20 content in the surface clays. The near-surface monuments 21 will be referenced on a periodic basis to the deep-22 reference benchmark. 23 Eight near-surface monuments will be installed 24 in the plant vicinity to measure horizontal movement at 1 the ground surface. These monuments will also be 2 designed to minimize seasonal shrink-swell ground sur-3 face movements. The horizontal positions of these 4 monuments will be referenced to the NGS Texas Plane s ordinate System. 6 To supplement the vertical and horizontal 7 near-surface monuments an array of open standpipe 8 piezometers will be utilized to monitor the two distinct 9 groundwater aquifer zones. Ten deep-aquifer piezometers 10 have been installed and are currently being monitored 11 on a weekly basis. One additional deep aquifer piezometer 12 will be installed adjacent to the deep reference bench-13 mark so that variations in ground water level can be 14 directly related to the regional subsidence monitoring 15 data. In addition to the field of piezometers and pore 16 pressure cells installed in the plant area to monitor 17 dewatering in the shallow aquifer zone, twenty open 18 standpipe piezometers will monitor the shallow aquifer 19 zone at various locations throughout the South Texas 20 Project site area. Data from deep and shallow piezo-21 meters will be used to evaluate the Project's regional 22 subsidence model. As regional subsidence results from 23 piezometric decline and is time dependent, the data 24 from the piezometer monitoring system will serve as an 1 advance warning of any unforeseen occurrence and will 2 provide a data base to verify the regional subsidence 3 model. 4 All the subsidence and settlement measurements 5 on deep and near-surface monuments and structural 6 benchmarks will be taken by Houston Lighting & Power 7 Company personnel or their appointed representatives. 8 This program will permit observations within the plant 9 site area to record elevation differences of 0.010 ft. 10 and horizontal movements at an accuracy of 1:10,000. 11 In summary, a site performance monitoring 12 system will be implemented to detect changes in ground 13 water levels across the Project site and to measure 14 changes in vertical elevation in and around the Category 15 I Structures. The vertical monitoring system will be 16 referenced to both a deep-reference benchmark on the 17 site and by periodic level to the NGS's first-order 18 loop in Bay City, Texas. Horizontal measurements 19 between selected monuments will also be accomplished on 20 a periodic basis and referenced to the NGS Texas Plane 21 Co-ordinate System. The level of accuracy of the 22 measurements will be such that changes significantly 23 smaller than the design limits can be observed and 24 evaluated prior to the time that the limits would be 1 exceeded. 2 Results of the monitoring and related studies 3 will give advance warning of any unforeseen occurrences 4 and will provide data in support of predicted plant 5 foundation performance. The Applicant has committed to 6 advise the Nuclear Regulatory Commission should measured 7 performance approach the design criteria limits during 8 the life of the plant. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 t: ' 1----, ,_, J ,.., L. Q. .:..\' 3 Ii testi m o r.y? I! , Ii ' 1 4 1 , A. My na me is Dona, .. R. Dctterton. ~1y position is I' ,, 5 !r ii j: 6 11 11 ., ii 7 I! ii 8 i! ;1 'I 9 !1 I* I! 10 ,: I 1 1 I I, 12 i\ 13 11 18 19 20 21 22 23 24 Manag er of t he Environm en tal Protec tion Departmen t with Houst on Lighting and Po we r Company. My fu nct i ons in con-n e cti on w ith the So uth T e xas P roj ec t inclu de manageria l respon s ibility for the conduct of a wide varietv of studies relating to the suitability of th e South T exas Project site, including the geological and seism olog ical in ve stiqatio ns. In addition, I partici pate d in th e development of the mo n itoring pro g ram at the site, which are discuss e d in this testim ony. The purpose of this testimony is to present information on the monitoring program established to measure the settlement of facility structures and to measure regional ground surface subsidence. These monitoring programs will enhance the safety of the project by giving advance warning of any unforeseen occurrences, and will provide basic data for varification of predicted plant foundation performance. That concludes my summary. MR. SCHWARZ: Thank you. I would now call Mr. John T. Mooney of Brown and Root, who has been previously sworn. />.** " deral Reporters, Inc. 25 Whereupon, xxxx l O I l l 12 I 13 1 14 15 I 16 17 18 19 20 21 22 23 24 /o *ederal Reporters , Inc. 25 \*iaS c,,l:.0 ,c.l as i", *:.Jt*n:_;S~.; I,.-:.\-.:

-._'!i .:-_*_; -;* e x2.1~1i 1~ cc 1 a nr:1 ~. ' . L *' f O .l J c, *, : :-: : S\*1orn , \'la s BY MR. SCHl'-!1\I U: Q. M r. I 1o oney , ar e you f a milia r with th e lis t of questio ns furn is hed b y the Board on Novemb e r 4 , 1 97S? Part i c-ularly, questions SB , 6 and 7. A. Yes, I am. Q. Mr. Mooney , qu est ion SB r ea ds: 11 1'7hat p rec aut ions, such as secondary water tr ea tment and tube ins pe cti on , are now envisaged to assure steam generator tub e int eg rit y under all conditions at South T ex as Proj ect?" Would you please respond to that q u es tion? A. Yes, sir. South Texas Project is well aware of the im po rtance of insuring that adequate steam generator tube integrity is maintained under all conditions of operation.

In light of current nuclear operating experience, the steam generators for the South Texas Project, Unites 1 and 2, will be operated with all volatile treatment. That is AVT, secondary water chemistry, and will follow the Westinghouse AVT chemistry control specifications. All volatile treatment uses volatile means for control of water chemistry rather than a combined phosphate and sodium treatment. i* I I I I ] I *I 11 i i I 12 j 13' 14' 15 16 17 18 19 20 21 22 23 24 I ~derol Reporters, Inc. ' 25 --~-I"\ --I ,' ,; 3 J. minimize the i11t rodu ction of conta mina nts to the syst em and a c ontrol l ed chemi s txy progr_,;J.m to ri:inim i z e the G':'r rosi,on of th e ma t e rial an d c o n s tr uct ion in t he c on densate an d free water sy s tems. The results of pro pe r impl eme ntation of a ll volatile chemistri e s control are to, (a) , minimize m e tal corro s ion, (b) limit accumulation of sludg e in the st ea m generator, (c), to minimize hardness scale for m ation on heat transfer surfaces, (d), minimize the potenti a l for formation of precaustic ~r acid, and (e), to maintain low oxyg e n centration in secondary fluids. Plant design efforts, start-up operations and operating procedures will be prepared and executed in line with these objectives. Fuel licensed PWRs, which have been in operation since August of 1974, including Perry Island Unit 2 and Donald C. Cook Unit 1, have employed llVT water secondary treatment. Other plants have operated successfully for longer time periods using AVT chemistry control .. In service inspec-tion of the steam generator tubes in plants which have verted to AVT without prior long-term phosphate chemistry 1 investigation has showed no corrosion has occurred. Negligibl1 sludge accumulation ~n these plants further confirms that 2 close c on trol and rno ni tor in s; of th e s t (c'c11:1 gen c 1:.-ato r che mistr y; the us e of premiu m c;uali ty ma ter ial s in th e const ruc tion of the c ondenser to minimiz e con dens e r l eak a qe in order to avoid en try of corrosive and scal e form ing ch em icals and continu ous blowdown of st ea m gener ato r, as effect i ve means of maintaining the proper env iro nment to the steam generator; the design of the Westinghouse Model E st e am generator , factors in the mechanic a l modifications previously evaluated in similar steam generators, which minimize lo w flow velocity areas which tend to accumulate 13 sludge. 14 South Texas Project will utilize a condens ate 15 polishing system consisting of mixed bed demineralizer in the 16 cond e nsate stream, between the condensate pump discharge 17 and the planned steel condenser. The function of the 18 condensate polishing system is to remove impurities £~om 19 the streat and to produce a high quality effluent capable of 20 meeting feed water and steam generator specifications. 21 The steam generator blowdown system will provide 22 blowdown of the se~ondary side of the steam generators to 23 maintain the steam generator secondary side water chemistry 24 1 within specification, and to prevent buildup of corrosion Ac P*"ederal Repor1ers , Inc., 25 products and to reduce steam generator activity level. I I. I I t b 7 :! I' II l II 2 1' !I 3 11 4 5 1 I 6 7 a I' I 9 533 A ll v oL:1t i le tr eatr ne nt; ch em ica l sp ec ifi ca ti on s w i l l be insured b y p l an t in-s tr e am i nstru m ent at i o n aft er a backup laboratory analys i s. In-streat monitoring of the steam generator blowdown inc ludes con ductivi t y , s o dium a n d pH* . . ... .. . ' analyses. In-str ea t monitoring of condensate and feed water includes conductivity~ sodium, pH a nd o xyge n an a l yses. stream monitoring of main steam includ e s conductivity and pH analyses. A laboratory program will be established employing approved sampling and analyses procedures schedules 10 and records to insure that all volatile treatment chemistry I 1 l conditions are porperly maintained. This program in the condenser evacuation systems radioactivity monitoring will also insure early detection of 14 the reactor coolant leakage into the secondary system. To 15 reduce the probability and consequences of steam generator 16 tube failures, the South Texas Project will include a program 17 of periodic in-service inspection to monitor the integrity of 18 the tubing. 19 Accordingly, a baseline eddy current examination 20 of the South Texas Project Units 1 and 2 steam generator tubes 21 will be performed. Eddy current inspections have been con-22 ducted on thousands of steam generator tubes in operating 23 plants. The same techniques, with improvements which have 24 been developed over the years of use, will be employed during A* cederal Reporters, Inc. I 25 the South Texas Project baseline examination. tb 8 I* I ,, 11 1 ii Ed dy currenl: accurac y li.:'lvo be;,_-n co nfir.r ,',:.:,-l i n lab-11 2 i ora tory t est programs and th rou q'.1 c-0 ,nr,ari~:; .:,: 1 of ck cc,_'.!:ive LL'!:-c c: 3 I removed from op e rating p l2nts with base li ne c1a ta. The South 4 I T exa s Pro j ec t i s con,,~nc ed th~t these acti ons will assu:i;-e safe 5 operati o n of th e st e am generators throughout the full range 6 of op~rating conditions. This ass ura nce is based on i mp le-7 menting the AVT chemistry control, utilizing a conde nsa t e s[polishing system and steam generator blowdo w n system, monitor-9 ing the secondary side water chemistry and performing periodic 10 in-service inspection of steam generator tubing. 11 Q. The sixth question reads: "The SER at pag e 10-4 12 states that information will be forthcoming regarding the 13 eans by which the Applicant proposes to preclude water hammer 14 in the steam generator feed water system. Is such information 15 vailable? What steps are presently proposed to deal with the 16 ~roblems?" 17 Mr. Mooney, would you provide the Applicant's 18 esponse to question 6 furnished by the Board? 19 A. Yes, sir. 20 The design of the South Texas Project steam generator I 21 s different from that of any employed in Unit 2. The differenc~ I 22 n design will prevent an incident similar to taht experienced j 23 n June of '73 in which a prober wave propagation, water ampere, 24 'nduced cracking of the feed water containment penetration pipe / '!deral Reporters, Inc 25 well. Evaluation of the Indian Point 2 incident showed due to tb 9 !1 ' ,, 'I 11 I , 2 !i 3 I 4 5 1 6 7 I I s !, !\ 1: 11 11 ! ! ,J 13 1 14 I I 151 16 17 18 19 20 21 22 23 24 Ac-cederal Reporters, Inc. 25 the: p c.: culia r a1.-i-c:.ngei;,cnl:. of the sl:.c,3.m gene ra tor an i;clc:t. lin e steam co u ld fi ll portions of the inl et line in lhe event of l o s s of feed water o r lo w feed wate r l evel i n the st e a m g e n e rat o r. Coll apse of th e v olu me upo n c pn c entra ti on of f ee d w ater fl ow result ed in wa t e r ampe r e wh ich eve n tua ll y caus e d the Indian Point 2 incident. The South Texas Project design incorporate s the Westinghouse Model E steam generator. Refer to RESAR figure 5.5-3. For the steam generator the inlet water flows into a preheat section where the feed water is heated to near saturation temperature before entering the boiling section. During normal operation the water level in the steam generator is as indicated in figure 5. 5-3 in RESAR-41. With the steam generator configuration to expose the feed water line to filling with steam, the water level would have to be lowered far below the low steam generator water level set points which initiates the auxiliary feed water system. Redundant capacity implementation is provided to monitor the water level. We understand the Staff has this mater under continuing review on a generic basis. If further requirements applicable to STP are established as a result of the review they will be considered in the final design at STP. Q. Mr. Mooney, the seventh question reads: "What is the status and general plan of the program mentioned in Supplement 1, page 18-2, to review design features intended t blO 4 5 6 7 8 9 I' ! I 1 o I 11 12 :: CODS C'*: .. ,:_.:,.;~ (_;: 1_-_i_r_es'? 11 address e d primarily to the Staff. However , wou ld you please furni sh the Board a re v i ew of th e steps whi ch have been tak e n in connection with the matter? A. Yes, sir. After reports of the Brown's F erry incident on page 22D, 1975, Federal evaluation of the South Texas Projec t design was initiated to establish the likelih ood and possib le consequences of a similar incident at South Texas. evaluation two conclusions are reached. From the First, there is little likelihood of a similar 13 incident at South Texas because of the adherence to updated 14 regulatory guides, and IEEE standards adopted since Brown's 15 Ferry 1 and 2 received their construction permit in 1966. 16 As an example of that, the South Texas Project cable qualified 17 to IEEE 383 of 1974, but passed stringent flame tests and non-18 combustible or self-extinguishing flame retardant sealing 19 material will be used. 20 Secondly, if a cable fire were to occur in a 21 cable spreading room at the South Texas Project, the con-22 sequences would not be as serious as at Brown's Ferry because 23 of the following: (a), the physical separation between Units 24 1 and 2; (b), the independence of safety-related systems; /' -ederal Reporters, Inc. 25 (c), the adherhence to regularory guides on ca~le materials tblJ 1 I' ii 2 I, 11 3 II I 4 1 . , 1 5 6 7 1 a[ I 9 11 Ii 10 1 1 1. I I 12 13 14 15 16 17 18 19 20 21 22 23 24 /. * ~d e ral Repo r t e rs , Inc. 25 anJ separat ion; '. ' ciu::1.u2 autor:*:, li.c ( cJ. ) ' fire pro tee tio n CJ ys terns; a :--1.:1 ( e) , de Lai l cc1 :i c:::i in.is t r2 l:. i *:'-' procedures that \vi 11 prov i d0 for pronpt actio n by tr a i ned on-s i te personnel with port a ble fir efig ht i ng cqu i~ment . Th e design fe atures mentioned above were being im p l emen t ed in th e South T exas Pr o j ec t p rio r to th e Br own's F er r y in c id e nt. De t a iled i nf ormati o n o n th e fi r e p r o t ect i o n d e sign for South T e xas Proj e ct can b e f ound in th e PS AR , particul a rl y in S e ction 9.5.l on page s 9.5-1 th ro ugh 9.5-l A , 9.5-33, 9.5-34 and 9.5-36 through 9.5-3 9. Also Ap p endi x 9.5A and figures 9.5-1 throu g h 9.5-28. No defects have b ee n identi f i e d b y th e evaluation we have conducted, and no n ee d for an y design r eq uirement s ha v e been identified. Any additional information d eve lo pe d by the FRC Staff and applicable to the South Texas Proj e ct will be taken into account in the development of a final South Texas Project design. MR. SCHWARZ: Mrs. Bowers, this completes our I direct case. In accordance with the proposed agenda subrni t ted I to the Board, we suggest that the Staff now be permitted to place the direct case into evidence. Each of our witnesses, along with Mr. Schwantes, who are sworn and identified, will be available to serve on a panel to respond to questions. MRS. BOWERS: Mr. Schwarz, I just wanted to thank you and your associates on behalf of the Board. N ormall y , I e-#7 tb tb12 3 I* I' 4 5 6 7 a l 9 10 l l 12 15 16 17 18 19 20 21 22 23 24 A-"ederal Reporters , Inc. 25 stack o f pa::,e rs a n d th ere: is no 1*.r ay t: nr us t o l:r:m1 v*l*1 --the w i tn e ss e s are go ing t o c ome u p , a n d so a g oo d part uf t i me a t the p r oce e di n g t h e B o a rd is s hu ff li n g t~ro u q h a l l the i I i of t he s e pape r s t o ge t th e dire ct t e s ti m o n y of tha t p art i c ular! I I So w e ar e ve ry gr ate ful f or yo ur or gan i zat i on he re I w itness. and the form in which you ha ve submitt e d your d ir e ct c as e. I It saved eve rybody a lot of ti m e and frustrati on. Th ank yo u. ! I MR. SCHWARZ: We are very pleased t ha t it h a s bee n helpful. MRS BOWERS: Mr. Stridiron? MR. STRIDIRO N: Yes, Mrs. Bowers. As I stated earlier --MRS. BOWERS: Just a minute. We will have a fi ve-minute break. (Recess.) ! I I ' I I I I i

8 FP/nH CRG 1 91 , I ! 2 ' 3 11 II 4 1 5 6 7 I a l 9 11 10 l 1 12 1 13 14 15 16 17 18 19 20 21 22 23 I '.; .3 9 Mr. Stri d iron , arc you r~ody to proc9cd? Pardon me. M r. Pendergraft , is the S tat e of T exa s putting on a dire ct ca se? MR. P ENDERGRAF T: We ha ve no dir ect case. MRS. BO WER S: Mr. Stridi ron , do yo u want to pro-ceed? MR. STRIDIRON:

Yes. As I stated in my op enin g statement, there are a number of gentlemen on the pan e l who have not been previously sworn. At this time I would ask that the following gentemen stand and be sworn: Gordon Chipman, Marvin Denenfeld, Ronald Gamble, and Jai Raj Rajan. Whereupon GORDON CHIPMAN, .1vf..ARVIN DUNENFELD, RONALD GAMBLE AND JAI RAJ RAJAN were called as witnepses and, having been first duly sworn, were examined and testified as follows: MR. STRIDIRON: Mrs. Bowers, I have two documents. One is the safety evaluation report related to the South Texas Project. MRS. BOWERS: Is the page phone on? MR. STRIDIRON: I have two documents which I 24 would ask be marked for identification Staff Exhibit 5, which "ederal Reporters , Inc. 25 will be the safety evaluation report related to construction fm2 xxxx ' i! I 1 *, /1 11 2 1 1 3 !I 4 5 6 7 8 I 9 1 10 11 12 13 14 15 16 17 181 19 20 21 22 23 24 I I I I -ederal Reporters , Inc. ?.5 of the.: SouU1 Texas Projec t , Units l and 2 , Houstu.; .. L ,/1t1.1::j and Power C ompany , et al. The ~~econd docc1:;1ent , Sto.f.C r;xhil;i'~ Number 6, that. is th e safety evaluation rep ort r elated to construction of South Texas Proj ec t Units l and 2, Houston .. Ligh ting and Power Co mpany , et al., Suppl eme nt Numb 0 r 1. MRS. BOWERS: Would you mind r epe ating those num-bers? MR. STRIDIRON: Number 5 will be the safety eval-uation report and Number 6 would be the supplement to the safety evaluation report. MRS. BOWERS: Any objection, Mr. Pendergraft to marking them for identification? MR.PENDERGRAFT: We have no objection. MRS. BOWERS: Mr. Schwartz? MR. SCHWARTZ: Applicant has no objection. MRS. BOWERS. They will be so identified. (The documents referred to were marke Staff Exhibit Numbers 5 and 6 for identification.) MR. STRIDIRON: I would like to qualify the following witnesses. Mr. Chipman, do you have before you a document entitled "Gordon L. Chipman, Jr., Professional Qualifications, Light Water Reactors, Project Branch 1-1, Division of Reactor Licensing"? WITNESS CHIPMAN: Yes, I do. t, L 3 !* I! 'I 2 :; 'i 3 ii 4 1 8 9 ' 1 , 10 1 11 12 ::ii 15 1 161 17 I 18 ----.19 20 21 22 23 .I 24 Ii cederol Reporters, Inc. 25 BY MR. S TRIDIRO~: Q Wa s th e docw-.-1c nt prepared by you or und e r your dir ection? .. A (Wi t n ess Chi pman) Yes. It was. Q Are th e stat eme n ts co ntained in that do cumen t true a nd corr ec t to th e best of yo~r information an d belief? A Yes. They ar e. Q Thank you. Mr. Dun e nfeld, do you ha v e before you a document entitl ed "Marvin S. Dunenfeld, Professional qualifications"? A (Witn es s Dun e nf e ld) Yes, I do. Q Was that document prepared by you or under your direction? A Yes. Q Are the statements contained therein true and correct to the best of your information and belief? A Yes. Q Mr. Gamble, do you have before you a document entitled "Professional qualifications of Ronald M. Gamble, M. S., B.S. "? A (Witness Gamble.) Yes, I do. Q Was that document prepared by you or under your direction? A. Yes, it was. ' I I I I I i I l I I I I I ! I ! 6 7 8 9 ,: Q S 2'_ i_ '-__ -. -; , *_ S l J

true A Y es. Th ey arP.. Q Mr. Rajan ( do you hav e before you a d o cu me nt entitled "Prof e s s ional Qualification s of ,Tai Raj R aja n, U.S. Nu clear R e gulator Co mm i ssion , Me chanic a l Engineer in g Branch, Division of Technical Re v ie w"? A (Witn es s Rajan) Yes. Q Was this docum en t prepar ed by you or und e r your 10 1 direction?

11 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace-F;,derol Reporters , Inc. 25 A Yes._ Q Are the statements contain ed ther ei n true and cor-rect to the best of your information and belief? A Yes. Q Mr. Dromerick, do you have before you a one-p age document entitled "James E. Fairobent, Professional Qualifications, Site Analysis Branch, Nuclear Regulatory Commission"? A (Witness Dromerick) Yes. Q Was the document prepared by you or under your direction? A. Under my direction. Q To the best of your information and belief are the statements contained in the document true and correct? A Yes. They cJ.re. 10 11 I 12 13 14 15 16 17 18 19 20 21 22 23 24 f -ederol Reporters, Inc. 25 move the stat c;,,cnts of r,n,fcssior-,.-il quaJ ific a lion:; gentl eme n be incorporated in the record as r ead. MR. PE N DERG RAF T: No objection. MRS. BOWERS: Mr. Schwnrtz? (_ l. MR. SCHWARTZ: Applicant has no objection. i" , i l ) . -_, lh CSC' MRS. BOWERS: The documents you ju st id entif ied will be physically inserted in the transcript as if read. (The documents stating the profes s ional qualifi-cations of Gordon Chipman, Jr., Marvin S. Dunenfeld, Ronald M. Gamble, Dr. Jai Raj N. Rajan, and James E. Fairobent follow.) I -j GORDON L. Crll P~L\N, JR. PROJ7ESSI0NAL QUALIFICATIONS LIGI-IT WATE R RE A CT ORS PROJE CT BRAN CH 1-1 DIVISION OF REA C T OR LIC ENS I N G I am a Project Manager in Light Water Reactors Branch 1-1 of the Division of Reactor Licensing, U. S. Nuclear Regulatory Commission. I am responsible for the e.valuation of nuclear safety aspects of nuclear reactor facilities and serve as the project manager for technical tion of nuclear power reactor license applications. I attended the University of Nebraska where I majored in Electrical Engineering and participated in the Navy Regular ROTC program. I graduated with a Bachelor of Science degree and was commissioned as a regular officer in the United States Navy in JW1e, 1965. Additional graduate level studies in nuclear reactor theory, health physics and related engineering fields were completed in 1966 at the Officer Naval Nuclear Power School, Mare Island, California. I subsequently studied and qualified as an operator and supervisor at the Naval Reactors nuclear power facility in West Milton, New York. My association with the Naval Nuclear Propulsion program provided me with five years of professional experience in the nuclear field, primarily with pressurized water re~ctors. I have been qualified as a Senior Reactor Operator on three Navy nuclear propulsion plants. For two years I was assigned to an operating nuclear submarine, during which time my dµties included directing, training and supervising technicians in the operation, maintenance and repair of various equipment and systems, including the \. r.-* j nuclear propulsion plant. Starting in 19 6 9, I was assign e d to th e cr ew o f a nuclear submarin e under construction. My duties included s up e r vi sing t he Electrical Division and the Reactor Control Division, testing of the nu c lear propulsion plant, directing and supervising technicians in the inspection, testing and operation of various equipment and systems, and training of technicians for examination and qualification as reactor operators and various other operating positions. In 1970 I was assigned as an instructor in advanced tactics at the Officers Submarine School where I instructed and trained crews of nuclear submarines. I joined the Regulatory staff of the Atomic Energy Corrunission September, 1972 as a reactor engineer. Since then I have participated as an mental Project. Manager in the analysis and evaluation of the environmental features of design of the Dresden Units 2 and 3 facilities. As a Project Manager in operating reactors, I participated in the review and evaluation of safety considerations associated with the design and operation of several licensed power reactors. Subsequently, I have participated in the analysis and evaluation of engineering safety features of design of power reactors under license application review. I have been particularly closely associated with the reviews of the Westinghouse Electric Corporation's Reference Safety Analysis Report, RESAR-41, and Boston Edison Company's Pilgrim Nuclear Generating Station, Unit 2, and the preapplication review of South Car~lina Electric and Gas Company's Virgil C. Summer.Nuclear Station Unit 2. .. .... -------* -..... *---*** .... -*-.... ---*-*-------*----*-*--\. HARVIN S. DUNENFELD PROFESS IO i.li\L QUALIFICATIONS My n ame is Marvin S. Dun e nf e ld. I am a Reactor Physic ist in the Core Perform a nce Branch within the Directorate of Lic e n sing. As a Reactor Physicist, I share with other members of the Branch the responsibility for technical review of reactor physics safety aspects of li g ht water cooled power reactors for Construction Permits and Operating Licenses. I was born in Newark, New Jersey, on December 31, 1926. I attended public schools in Flushing, New York, and entered Queens College in Flushing, N ew York, in 1944. I transferred to the University of Michigan in 1945, graduating with a Bachelor of Science degree (physics major) in 1951 and a Master of Arts in mathematics in 1953. I was employed by the Ford Motor Company in Ypsilanti, Michi g an, , from 1953 to 1957 as an Electrical Product Project Engineer. I joined the nuclear industry in 1957 in a position at the Atomics International sion of North American Rockwell Corp. in Los Angeles, California. I was employed there for about two years in reactor shielding and then four years as a physicist in reactor kinetics. In the latter capacity, I participated in research and analysis of reactor transients on the kinetics experiment on water boilers. In 1963 I accepted employment as a nuclear physicist with the Allison Division of General Motors in Indianapolis, Indiana. I was responsible for safety analysis on the Military Compact Reactor Project, and later formed reactor physics and safety analyses on other reactor concepts. In 1967 I joined the Division of Reactor Licensing, U. S. Atomic Energy Co m mission. My responsibilities with the Conunission have been in the technical evaluation of physics related safety aspects of light water reactors. I have participated in the evalua ti on of all the PWR Operating Licenses Regulatory has reviewed since 1967, about half of the PWR Construction Permits, and a few of the BWR applications. I have also directed the efforts of the four physics consultants to Regulatory at Brookhaven National Laboratory since the inception of this activity in 1967. l'!l'**-1' ' ' ' j ' i ; 1 j 1 -; PROFESSI O NA L QUALIFICATIONS OF RONALD M. GAMBLE, M.S., B.S. I am a materials Engineer in the Materials Applicatipn Section, Materials Engineering Branch, Division of Technical Review, Office of Nuclear Reactor Regulation. My duties and responsibilities involve the review and evaluation of technical reports, metallurgical investigative studies, failure analyses and fracture mechanics analyses as related to the construction of nuclear power plant components including the formulation of regulations , and safety criteria and guides related to materials performance. t I have a M.S. in engineering mechanics from the University of Florida (1972) and a B.S. in engineering mechanics from Pennsylvania State University (1965). Prior to my present appointment, I was associated with Turbodyne Corporation as Group Leader, Materials. My duties and responsibilities included conducting and supervising analytical, experimental and field

investigations in areas related to fatigue and corrosion cracking and fracture mechanics for gas and steam turbines and related components.

I was also responsible for formulating manufacturing and quality assurance criteria related to materials and structural application. \. l I --2 -From 1965 to 1968 I was an analytical engin e er with Hamilton Standard Division of United Aircraft Corporation. My duties and responsibilities included analytical and experimental work in fatigue and fracture and the development of material design li.mits for aerosp~ace components. --, PROFESSI UNA~ QUALIFICATIONS JAI RAJ N. RAJAN U. S. NUCLE AR REGULATORY CONHISS ION MECHANICAL ENGINEERING BRANCH DIVISION OF TECHNIC AL REVIEW I am a mechanical engineer responsible for reviewing and evaluating safety analysis reports with regard to mechanical engineering aspects of components, the dynamic analyses and testing of safety related systems and components and the criteria for protection against the dynamic effects associated with postulated failures of fluid systems for nuclear facilities. I am the Mechanical Engineering Branch's principal reviewer on the issue of the structural integrity and plugging criteria of degraded steam generator tubes. I am also responsible for the review and evaluation of.water hammer problems of a generic nature in the piping systems and components of nuclear facilities. I received a B.S. degree in 1953 from Lucknow University India majoring in Physics, Mathematics and Chemistry. In 1956 I received a B.S. in Civil Engineering from Roorkee University, India majoring in Structural and Hydraulic Engineering. In 1962 I received a M.S .. degree from Duke University majoring in Applied Mech1nics and Ph.D. degree in 1966 from the same university with majors in Fluid Mechanics. From 1960 to 1962 I was an instructor in structural engineering at Duke University. From 1962 to 1966 I was employed by the U.S. Army Research Office in Durham, N.C. as a research engineer conducting theoretical and experimental research in , , -r* r I hi gh pressure pneumatic and hydraulic shock tubes and investigating w.; "'c propagation phenomer:.on in pipes. From 1966 t o 1973 I worked as a pro_;, . .: t mechanical engineer and subsequently as a senior project mechanical engineer at the Naval Research and Development Center at Annap~lis, Md. Major projects involved design an a lysis, test and evaluations of fluid piping systems and power fluid systems of advanced nuclear submarines. Investigations were multidisciplinary in scope utilizing advanced techniques. Mathematical models of power plant machinery and piping systems of nuclear submarines were developed and analyzed to determine system response to flow induced vibrations and hydraulic shock. dynamic and hydrodynamic analyses of naval boilers and steam plants were conducted.including full scale tests. In April of 1974 I joined the U. S. Atomic Energy Commission prior to the formation of the U. S. Nuclear Regulatory Commission and have remained with the Mechanical Engineering Branch of the Division of Technical Review as a mechanical engineer performing the type of work as previously described. I have taught at the University of Maryland on a part-time basis since 1967 both at the graduate and undergraduate levels in courses of mechanics of materials, fluid ruechanics and applied mechanics. Publications include Journals of AI.AA and ASME and I am an associate member of Sigma Xi honor society. \. J J\l!ES E. FAll ZO:H~Wf Pr zot:i:ss I (K\L Q'.JALH' I C!,'l' i.u:~;; SITE A:: 1\l.\'SIS J m.M:C ll t-;U C L LI\.R REGULATOI~Y CO Ml HS SI ON I h ct\*c b een a N 2t corolo[;i c: t Hith th e Site Analy s i c; Br a n c h, Divi 3 ion of Technic c ll Re vic , , , since Febru a ry 1973. I rec e vied a D.S. degre e with a major in meteorolo g y from th e U n iversity of Hichigan in 19 70. While an unclcrgrac1uat c , I p a rticipated in a s t~udy of precipitation scavenging by conv ective stor ms .which ~nclucl e cl field research pro g rams in Okl ahoma and Illinois. My responsibilitie s incl uded maint,:;nance of a precipitation collection network, analyses of rnesoscale weather systc~s conducive of the formation of convectiv e stor I:'.s, and n 2u tron activation and radiochemistry analy se s of water samples. I entered the graduate program at the University of Michigan in 1971, and was awarded an N.S. degree with a major in meteorology in 1972. In continued my association with the precipitation scavenging project as a graduate s tud ent as well as becoming weather observer at the Univ ersity of Michigan climatological station and a teaching fellow. I accepted my present position in February 1973. I am responsible with the St:pervision of the Hctcorology Section Leader, for th e evalu atio n of the meteorological characteristics of reactor sites and th2ir ir.iplic 2.tions with respect to 1 safety requi~ements of nuclear facility design and the impact of these facilitie s on the environ me nt. I am a member of the American Heteorological Society-.

!: !, fm6 1: .I ii 2 i1 II !1 3/ I 4 1! 5 II' 6 7 8 9 1 I 10 11 12 13 14 15 16 17 18 19 20 21 22 I 23 I Ar-~ederol Reporters, 7n~. I 25 mark ed Staff Exhib i t Number 5? A (Witn es s Dro mer ick) Yes. Q This is entitl e d "Sa fety Eva.lu atj_o n Repo rt , Rela te .. to Constructing of South T ex as Projects, Unites l and 2 , Houston Lighting and Pow e r Company, et al."? A. Yes, I do. Q Was this document prepared by you or und er yo ur direction and control? A Yes. It was. Q Are there any corrections or additions you wish to make to the document? A There is one addition I would like to make. That is Supplement Number l to the Safety Evaluation Report. Q With the addition of this supplement, is the document true and correct to the best of your information and belief? A. Yes. It is. Q You --do you have before you a document marked for identification as Staff Exhibit Number 6? A Yes. Q Entitled "Safety Evaluation Report, Related to Construction of South Texas Project Units land 2, Houston Lighting and Power Company, et al., Supplement l"? A Yes. I do Ln7 2 10 13 14 15 16 17 18 19 20 21 22 23 24 /> ~ederol Reporters, Inc. ?.5 Q your contro l? A Y E.:s. Q Are t he st atement s c onta in ed in this docu me nt .. true and correct? A Yes. They a.r-e, Q Mr. Dr o merick, would you briefl y describ e the scope of the staff rs review and the conclu sio ns reac hed with respect to the application to construct the South Texas Project? A Yes. I would. A preliminary safety analysis \ report was submitted with the South Texas Project application. This report desc ri bes the design of the balance of plant structures, systems and components, and incorporates by reference the Westinghouse ElectricCorporation report refer-ence safety analysis report, RESAR-4~, RESAR-41 describes the design of the standard nuclear standard steam supply system. RESAR-41 was submitted by the Westinghouse Electric Corporation in the form of an application for preliminary design approval from the Commission and was in response to option 1 of the Nuclear Regulatory Commission's standard decison policy. Option 1 allows for the review of a ence system that involves an entire facility design or major fraction of a design outside the context of a license application. On March 11, 1974, the Application for RESAR-41 I ti 1 11 1 1 !i 2 ;1 'I I* 3 Ii I I 4! . Ii , I 5 I 6 7 8 9 !1 10 11 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ederol Reporters , Inc. 25 v1Gre dc.,ckc~ted. a copy of which i s attac h ed as A ppendix A , to t he Sou th Texas Project Safety Eva lu a ti on Rena rt . . . In our evaluati o n of th e t he Sout h T e xas P r o-jec~, PS AR , we reviewed the popu l ation densi t y and us e characteristics of the si t e , inclu ding sei smology , me teor-ology, g eo logy and hydrolo gy , to d e t erm ine th at the site met the Commission's sitin g criteria, defined in lO~CF Rr Part 100. We revi ewe d th e de sign fabrication, construe~ tion, and testing criteria, and expected performance acteristics of the structur e , systems and comp o nents tant to safety, to determine that they are in accord with the Commission's general design criteria, quality assuranc e criteria, Regulatory Guides, and other appropriate goals and standards and that any departure from these criteria, goals and standards, be identified and justified. We considered the response of the facility to certain anticipated transients and postulated accidents. We considered the potential consequences of a few highly unlikely postulated accidents and performed conservative analyses of the~accidents and determined that the calculated potential off~site doses , that might result in a very unlikely event of their occurrence, would not exceed the Commission's guidelines. [:. ii J_.' L ; * ).. c _. t. -i. 2 *t of pL::i nl operat j o n , incl*..:.(1.i r ,<J tl 1A 0 1-s j,:!l i za t ir: , ,:,: l I *I I* 3 !! II 4 ,; ;i '/I 6 1 )! I 8' 9 11 10 11 12 15 16 17 18 19 20 21 22 23 24 />---Federal Reporte r s , Inc. 25 I s truc tur o a n d gen e ra l q u al i ficat i ons of op e rnting anc': t c chni-I i I ca l su ppor t pe rs on n e l, a nd mea sur e s t a k e n for in d ustri a l s ec ur-1 b e tak e n in j ity and th e plan n in g for em erg e ncy ac t ions to the unlik e ly event of an accid e nt that might a f fect the general public ,t o determine that the Applicants will be technically qualified to operate the plant and will have es tablish ed effective organization and plants for continuing safe operations of the facility. We evaluated the design o f the systems provided for control of radioactive effluents from the facility to determine that these systems can control the release of radioactive effluents within the limits of the Commission' s regulations. We also evaluated the financial data and inform ation provided by the Applicants, as required by the Commission's regulations, Section 50.33 F, of 10-CFR, Part 50 and 10-CFR, Part 50 And Appendix C to'lOCFR, Part 50, to determine that the Applicants are financially qualified to design and construct the proposed facility. Our evaluation of the South Texas PSAR is now complete and this evaluation, along with our evaluation of RESAR~41, are presented in the South T ex as Project Safety Evaluation Report as updated in our supplement Number l to I I I xxxx e 8 6 7 8 11 12 13 14 15 16 17 18 19 20 21 22 23 24 /' r.ederal Reporters, Inc. 25 ; :.. .. So uth T exa s Proj ec t Un it s l and 2 , c a n be construct ed opera t ed as proposed , wit hout endanger ing the health and safe ty of th e public. Q Thank you, Mr. Dromerick. Mrs. Bow e rs, at this time I would move the documents marked for identification Staff Exhibit Number 5 and Exhibit Number 6 be acce p ted into evidence as Staff Exhibits 5 and 6. MRS. BOWERS: Mr. Pendergraft? MR. PENDERGRAFT: No objection. MRS. BOWERS: Mr. Schwartz? MR. SCHWARTZ: Applicant has no objection, r .1,. MRS. BOWERS: Staff's Exhibit Number 5 and 6 are accepted in evidence. (The documents, .heretofore marked Staff Exhibits Numbers 5 and 6 -for identification, are received in evidence.) fra,-:k C!T:i-!l 6 Q. I-ir.J*c cgl i, Cio :/ou hr.Ve bc:fo r c yoc1 c"1 du:-;11: . .,,,_ entitled Suppl~me ntary Testimony of NttC Stuff on eva~uat j_on of liqui d ~?d gas e ous effluents with r e s pe ct to Appe ndix r cf 1 0 CFR ~ar t 50 , So ut h T ex a s Proj ect , U n i ts 1 and 2 , Docke t Nu mbers 50-49 8 and 50-4 99 , by J. S. B o e gli, ef flu ent systems 7 1 branch, Division of Tech n i ca l R e vi e w, Offi ce of Nuc l ea r R eacto Regulations? 10 l 1 12 14 15 16 171 18 19 20 21 22 23 24 A. Yes, I do. Q. Was the document prepared by you or under your supervision? A. Yes, it was. Q. Are the statem e nts contained in this docu me nt true and correct to the best of your information an d beliefl A. Yes. Q. Would you briefly summarize the document? A. Supplemental testimony presented November 5th, 1975, by the NRC Statf, on evaluation of liquid and gaseous effluents with respect to Appendix I of 10 CFR Part 50, for the South Texas Project provides a detailed assessment, using the meters arid practical model given in draft Regulatory , Guide lHD, entitled Calculation of Releases of Radioactive Materials in Liquid and Gaseous Effluents from Pressurized Water Reactors. PWRs. Dated September 9th, 19 7 5. l)ral Report er s , Inc. This guide was used to calculate few source terms in 25 ,_-. ') .. !I !' I 1 :i 2 Ii 11 , I 3 'I I 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 :. :--: (~ -:-, ' .! _ , : ~--'-l 1 .1 ' * ~' ' : -_' * ~-, I p r es en t e d by Mr~ w~tcr fiel ct. j I I I Based o n the St aff eva l u a tio n and t e stimony p r c se~tc d i. we conclude that t he South Texas ~roJcc t U nit land 2 meet th~ design objectives of Sec ti on r oma n numeral 1I-A , Il-B, and II-C, to Appendix I of lU CFH Part SU. And meet th e requirements of Section II-D by satisfying the Septe~ber 4th, 197S, opti on tc Appendix i, to meet the design objectives set torth in 50-2. Thank you. Thank you, Mr. Boegli MR. STRIDIRON: Mrs. Bowers, at this time I would move the supplemental testimony of Mr. Boegli relating to the evaluation of liquid and gaseous effluents with respect to 10 CFR Appendix I, Part.SO, be incorporated as if read. MR. i:'ENUERGR.~FT: We have no objection. J.Virs. Bowers, for the record I would like to point out we have no objection to tes tirrony i terns ooming in the reoord. We are not stipulating as to their authenti~ity or correctness but only as to their admissibility. I assumed that was understood all along. MRS. BOWERS: That's right. The Board accepts that. Mr. Schwarz? MR. SCHWARZ: .The Applicant has .no objection. MRS. BOWERS: **rhe testimony that you just referred to, Mr. Stridiron, will be physically incorporated into the Ac *c,ol Reporters, Inc. record as if read. ? 25 .I 1 -*~ J ! J I .*, ,. \ .; 1 ** I / SUPPLEMENTAL TESTIMONY OF NRC STAFF ON ... EVALUATION OF LIQLJID AND GASEOUS EFFLUENTS WITH RESPECT TO APPENDIX I OF 10 CFR PART 50 SOUTH TEXAS PROJECT, UNITS 1 AND 2 Docket Nos. 50-498 and 50-499 BY J. S. BOEGLI EFFLUENT TREATMENT svstEMS BRANCH DIVISION OF TECHNICAL REVIEW OFFICE OF NUCLEAR REACTOR REGULATION \. I *i I I J

l l l . -; l i *1 ! j I I J , l ) ; . ' 1 *' I I Int rod u ctio n On July 18, 1975, the NRC Staff (Staff) submitted to the Atomic S a fety and Lic e nsing Board affidavits of Messrs. J. Long and J. Boegli and Dr. J. K astner. Those affid~vits were filed in response to the Bo a rd's conference call of July 9, 1975 concerning the impl eme ntation of Appendi x I .. of 10 CFR Part 50 adopted by the Commission on May 5, 1975, with reg a rd to South Texas Project, Units 1 and 2. The affidavits indicated that the Staff was in the process of reassessing the parameters and mathemati c a l models and that a detailed assessment to determine conformance with Appendix I would be compl~ted in connection with the hearing on logical safety aspects of the facility.

The purpose of this testimony is to present the results of that detailed assessment. The assessment was perform e d to determine if the proposed South Texas Project, Units 1 and 2 met the numerical design objectives specified in Sections IIA, B, C and D of Appendix I of 10 CFR Part 50. On September 4, 1975 (F.R. 172), the Commission amended Appendix I of 10 CFR Part 50 to provide persons who have filed applications for struction pennits for light-water-cooled nuclear power reactors which were docketed on or after January 2, 1971, and prior to June 4, 1976, the option of dispensing with the cost-benefit analysis required by Paragraph II., D of Appendix I. This option permits an applicant to design his radwaste management systems to satisfy the Guides on Design Objectives for Light-Water-Cooled Nuclear Power Reactors proposed in the Concluding Statement of Position of the Regulatory Staff in Docket RM-50-2, dated \. I 1 ' 1 I i 1 ) I 'j 1 '1 . *, i . i "i February 20, 1974. As indicated in the Statement of Consid erat ions includ ed with the amendment, the Com miss ion noted it is unli kely that further reductions to radio ac tive material releases would be warra nted . on a cost-bene fi t basis for light-water-cooled nuclear power reactors having radwaste systems and equipment deten~ined to be acceptable .. under the proposed Staff desiqn objectives set forth in RM-50-2. In a letter to the Commission dated October 1, 1975, Houston Lighting and Power Company chose to comply with the Commission's September 4, 1975 amendment to Appendix I, eliminating the necessity to perform a cost-benefit analysis as required by Paragraph II.D of Appendix I. Evaluation The Staff has evaluated the radioactive waste management systems posed for South Texas Project, Units 1 and 2, to reduce the quantities of radioactive materials re*leased to the environment in liquid and gaseous effluents~ These systems have been previously described in Sections 11 .2 and 11.3 of the Safety Evaluation Report, dated August 1975, and in Section 3.5 of the Final Environm~ntal Statement (FES), dated March 1975. Based on information provided by the applicant in the referenced letter, on more recent operating.data applicable to the South Texas Project, and on changes in our calculational model, we have generated new liquid and gaseous source terms to determine conformance with Appendix I. These values :; \. ' ; j ! i , I ! I i I l i I . i . I f *1 l j l I are different from those given in Tab l e s 3.6 and 3.7 of the FES for Units 1 and 2 and in Table l of M r. Bo e gli's affidavit (Ju ly 18, 1975). The new source terms, sho w n ih Attachments 1 and 2, were calculat ed using the models and methodology described in Draft Regulatory Guide 1 .B B, .. "Calculation of Releases of Radioactive Materials in Liquid and Gaseous Effluents from Pressurized Water Reactors (PWRs)," September 9, 1975. These source terms were used to calculate the doses as described in testimony submitted by Mr. Waterfield. Attachment 3 provides a comparison of the calculated doses, with the design objectives of Sections IIA, Band C of Appendix I and the posed Staff desian objectives set forth in R M-50-2. ' Based on the Staff's evaluation of the liquid radwaste management systems, the expected quantity of radioactive materials released in liquid effluents from Units 1 and 2 will be less than 5 Ci/yr/reactor, excluding tritium and dissolved gases, as shown in Attachment

2. The liquid effluents released from Units 1 and 2 will not result in an annual dose or dose commitment to the total body or to any organ of an individual, in an unrestricted area from all pathways of exposure, in excess of 5 mrem. Based on the Staff's evaluation of the gaseous radwaste management systems, the total quantity of radioactive material~

released in gaseous \, :;--.. ~-*; ",.*l. **--** .... -.... ----*-.. ** ">*-**-, ---**,-.-y**--*--. --*--*-***---*----------,*--... _-..... I l l i l 1 . I j j l *l l J 1 . ' ' effluents from U ni t s 1 and 2 will not result in an annual gan~a air dose in excess of 10 mrads and a beta air dose in excess of 20 mrads at every location near ground level, at or beyond the site boundary, which could be occupied by individuals (Attachment 3). The annual total quantity of iodine-131 released in gaseous effluents will be~less than l Ci/reactor (Attachment l) and the annual total quantity of radioiodine and radioactive particulates released in gaseous effluents from Units 1 a n d 2 will not result in an annual dose or dose commitment to any organ of an individual in an unrestricted area from all pathways of exposure in ~xcess of 15 mrem (Attachment 3). Conclusion Staff testimony demonstrates that the doses *associated with the normal operation of South Texas Project, Units l and 2 meet the design objectives of Sections II.A, II.Band II.C of Appendix I of 10 CFR Part 50, and that the expected quantity of radioactive materials released in liquid and gaseous effluents and the aggregate doses meet the design objectives set forth in RM-50-2. Staff's evaluation shows that the applicant's proposed design of Units 1 and 2 satisfies the criteria specified in the option provided by the sion's September 4, 1975 amendment to Appendix I and, therefore, meets the requirements of Section 11.D of Appendix I of 10 CFR Part 50. i *, ! I I I *j l l 1 j *, ! i ' I , j ' .. } I Based on the Staff's eva lu ation the propos2d liquid and gaseous radwaste management systems for South Te xa s, Units l and 2 meet the criteria given in Appendix i and are therefore acceptable. \. . . . ....... --*--* -----** *-----***---****** *-.. -***--* --**-, AT TACii>li~T l CALCTJLA TED Rl::LL~S rs OF JZ,.\Di n_.\(I J 1.T: '~.\T I:::-'. T_\_l_ ::: G,\S ;::1K:; ::JTTXr-:: ~;-s l .. ' i': '. SOUTH IEX ,\S , i_;:;!TS l x;D 2 (Ci/yr/reactor) 1h: [; t e Gas C ondcnse:r Processit 1f, Bu il cl i i:'.; '.'e:nti l?tion A.i. r ---------------*--------Nu c;JJcd cs _ _§_y_st c::i Reactor ,\1.2:,: i].i;; r~-./ T1J1.*bir:r, _Ej c~:J:-~-Tou.1 ------------------Kr-83 m a a a a a a,. Kr-85m *a 6 2 a 1 9 Kr-85 270 *1 a a a 270 ' -I I I l *1 I i Kr-87 a 1 1 a a 2 Kr-88 a 9 3 .[J.* 2 14 Kr-89 a a a a a a Xe-131m 13 3 a a a 16 Xe-133m a 15 a a a , 15 Xe-133 30 790 28 a 18 870 Xe-135m a a a a a a J *1 Xc-135 a 27 4 a 2 33 Xc-137 a a a a a a 1 Xe-138 a a a a a a 1-131 a 0.111 0.036 0.00028 0.022 0.2 -I-133 a 0.092

o. 054 0;00043 0.034 0.15 ' Co-60 7.0(-5) 3.3(-2) ?,7(-2) C C 6.0(**2) Co-58 1. 5 (-11) 7.2(-2) 6.0(-2) C C J.3(-1) Fc-59 1.5(-5) 7.2(-3) 6. O (-"3) C C 1.3(**2) :Mn-54 4.5(-5) 2.1(-2) l.8(-2) C C 3.9(-2) Cs-J.37 7.5(-5) .3.7(-2) 3.0(-2) C C 6.7(-2) Cs-134 4 .5 (-5) 2.1(-2) 1.8(-2) C C 3.9(-2) Sr-90 6.0(-7) 2.9(-4) 2.4(-4) C C 5.3(-11) *i l .1 s1:-89 3.3(-6) 1.6(-3) 1.3(-3) ' C C 2.9(-3) C-14 8 ll-3 760 . Ar-41 25 -1, a= less than 1.0 Ci/yr noble gases> less than J.O Ci/yr fot iodine. b = exponential notation:

7.0(-5) = 7.0 x 10-5 c -less than 1% of total fo~ nuclide , , ..... ,*~*--r.-,.,. ... ,,.. ...... ........... ---**-* *-. _,_ .. .. --*-*....----,---..... -.--------4------

*--------*---* -

I I .I I I 1 i I j 1 i ** 1 l *l I ' _.::: .. -' Nucli de ATT,\Cll'fU;I 7 CAL CULATE D R E LEAS ES 0~ RADJO ,\CTIVE i'I,\'l'FT,'IALS IN1 , , ~r, LIQUID EFFLUEiiTS FR0:*1 SO UTH TEXA S, U NITS 1 A ND 2 (Ci/yr/re acto r) Ci /yr /r e::ic Lo r Nuc Lide Corr o sion [, ,\c tivc1tion Prod u ct s Cr-51 0.0001 Cs-13!1 0.015 Hn-51+ 0.001 1-135 0.0031 .. Fe-55 0.00009 Cs-136 0.00063 Fe-59 0,00006 Cs-J.37 0.025 Co-58 0.0049 B:1-137m 0.001 Co-60 0.0088 B.:i-140 0.00001 Np-239 0.00003 La-140 b.00001 Fission Products All others o. 000011 Bi:-83 0.00001 Total Except Tritiura'0,22 Sr-89 0.00002 Tritiu.n 750 Y-91 0. OOOll Ho-99 0.01 Tc-99m 0.0098 Te-127r:i. 0.00001 Tc-127 0.00002 Te-129m 0.00007 Te-129 0.00005 1-130 0.00008 Te-13lm 0.00004 1-131 0.1 Te-132 0.00079 1-132 0.0012 1-133 0.028 \. ) 1 i ' j _.i _,.~ _____ . __ _ -.-..-.J!'----

r' ATTACHMENT 3 COMPARISON OF SOUTH TEXAS PROJECT, UNITS 1 AND 2 WITH APPENDIX I TO 10 CFR PART 50, SECTIO~S II.A, II.BAND II.C (M AY 5, 1975)a AND GUIDES ON DESIGN OBJECTIVES PROPOSED BY THE STAFF RM-50-2 (FEBRUARY 20, 1975)5 Criterion Liquid Effluents Dose to total body from all pathways Dose to any organ from all pathways Noble Gas Effluents Gamma dose in air Beta dose in air Dose to total body of an individual Dose to skin of an individual Radioiodines and Other Radionuclides Released to the Atmosphere Dose to any organ from all pathways Appendix Ia Design Objectives 3 mrem/yr/unit 10 mrem/yr/unit 10 mrad/yr/unit 20 mrad/yr/unit 5 mrem/yr/unit 15 mrem/yr/unit 15 mrem/yr/unit a . Federal Register V. 40, p. 19442, May 5, 1975. b RM-50-2 Design Objectivesc 5 mrem/yr/site 5 mrem/yr/site 10 mrad/yr/site 20 mrad/yr/site 5 mrem/yr/site 15 rnrem/yr/site 15 mrem/yr/site Calculated D os es 0.06 mrem/yr/unit 0.08 mrem/yr/unit 0.10 mrad/yr/unit 0.20 mrad/yr/un it 0.0085 mrem/yr/unit 0.024 mrem/yr/unit r 0.75 mrem/yr/unit bConcluding Statement of Position of the Regulatory Staff, Docket No. RM-50-2, Feb. 20, 1974, pp. 25-30, U.S. Atomic Energy Commission, Washington D.C. cDesign Objectives given en a site basis. Therefore, these design objectives apply to 2 units at , the site.

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 I !i I BY MJC S'l'RIUH\)~'.: Q. M r. 1*Jatcrf i eld , do you have a docu irte nt b efore you , a do c ument en t i tl cd Nuclcc.1r Regu l atory c om.i t1.i ss ion S t af f t e sti-.. rno n y of Hobe rt L. Wat erfi eld pe rtai ning t o Appe n dix I? A. (Witn es s W ater f i eld) i do. Q. Was t h is docum e nt prep a red by you or und e r y o u r supervision? A. It was. Q. Are the statements contained in this documen t true and correct to the best of your information and beliet? A. They are. Q. Would you briefly summarize the document? A. And evaluation was made of the effluent releases derived by Mr. Boegli, to see if we would meet the low as practicable guidelines of Docket :RM 50-2 and Appendix I to Part so. The meteorological and atmospheric parameters and -deposition, as presented in Mr. Fairobent's testimony, and the assumptions and models were taken from Regulatory Guide l.AA and the results we obtained indicated that all the expected doses would be far below the guideline values. MR. ST.1:UDIRON: Mrs. Bowers, I would move at this time that the document entitled Nuclear Regulatory Commission's A.c t>ral Reporters, Inc. J Staff testimony of Robert L. W~terfield pertaining to Appendix I 25 --, 4 5 6 7 8 9 10 l l 12 13 14 15 16 17 18 19 20 21 22 23 24 .!,.:: ,. ~ro l Reporters, Inc . 25 be ,1,,.:., l'.11 \.i..J

in the recon_i a.s if r~ad. MR. _.PENDERGRAFT:

No obj e ction. MRS. BOWERS: Mr; ScKw~rz? . .. MR. SCH WAHZ: Applicant h as no objection. MRS. BOWERS: The document you just ide nt ifi ed will physically incorp ora ted in the transcript as if re ad. (The document f o l.lows.) I U N I TE D S TA TES O F AMERICA NUC LE AR REa.J L AT ORY CO MH I SS IO N .. BEFORE Th'E ATOMIC SA F ETY AN D LICENSIN C} BOARD In the Matter of Houston Li c h t in g and ) Power Company ) ) (South Texas Project ) Units 1 an<l 2 ) 't11UCLEAR REGULATORY C:OMMISSION ST AFF 1 S TESTIMONY OF ROB E RT L. WATERFIELD PERTAINING TO APPE N DIX I Docket Nos. 50-4 9 8 50-499 Introduction AFFIDAVIT OF ROBERT L. WAT ER FIELD RELA TIVE TO AN APPENDIX I DOSE EVALUATION OF SOUTH TEXAS PROJECT UNITS 1 AND 2 In an affidavit(l) filed in the site-suitability yhase of this proceeding Dr. Jacob Kastner indicated that a detailed 8Ssessment of maximum individual doses would be completed in connection with the radiological health and safety hearing after completion of our reassessment of assumptions and models. The purpose of this testimony is to present the results of that detailed assessment. The assessment was performed to determine if the proposed South Texas Project facilities met the design objective contained in the Concluding Statement of Position of the Regulatory Staff, Docket No. RM-50-2 (February 20, 19,74), (2) and in 10 CFR 50, Appendix I (May 5, 1975). (3) In a letter dated October 1, 1975, (4) the Houston Lighting and Power Company indicated that it wished to exercise the option provided by the (5) . . Commission's September 4, 1975 amendment to Section II.D of Appendix I. The amendment provides that an applicant nee.cl not comply with the radwaste system cost-benefit analysis required by Section II.D of Appendix I if the proposed radwaste system satisfies the Guides on Design Objectives contained in the Concluding Statement of Position of the Regulatory Staff (Docket No. RM-50-2), dated February 20, 1974. (2) '* j ---Si nce the Guides on Design Objectives apply to all light-water*-cool e d r ea c t o r s at a s it e , it was ne c e s sa r y t o com p a r e the total dose f r om South Te x as Units 1 and 2 with th e Desi g n O b j e ctives cont a in e d in the Concl ud i ng Stat e ment of Position of the Regulatory Staff. (Z) Discussion The dose models used to perform this analysis are contained in Draft Regulatory Guide l.AA. (6) These models were revised (with respect to the models contained in reference

1) to be responsive to the mandate contained in the Opinion of the Commission(?)

relative to Appendix I which called for realism wherever possible in the definition of input parameters for the dose models. Included in this analysis are dose_ evaluations of three effluent categories: ' 1) pathways associated with liquid efflue~t releases to the Colorado River 2) noble gases released to the atmosphere, and 3) pathways associated with radioiodines, particulates, carbon-14 and tritium released to the atmosphere. The dose evaluation of pathways associated with liquid effluents was based on the maximum exposed individual. The dietary and living habits for an adult individual included 1) the consumption of 20 kg/yr of fish and 5 kg/yr of invertebrates harvested in the immediate vicinity of the discharge, and 2) recreational use of the shoreline in the innnediate-vicinity of the discharge for 10 hr/yr. 2

I ! I '--'-*---* . --* .. -----The do s e evaluation of noble gases rel eased to the atmosphere in c lud e d a c alcu l at i o n of b e ta and gamma air doses at the site boundary and total bo dy an d s ki n doses at th e res id e n ce hav ing th e h i g hes t do se. T h e ma ximum a ir d oses a t th e s it e bound a r y wer e foun d a t 1.0 mi l e n o rth (dista n ce and direction) rel a tive to the South T ex as facility.

The location of ma x imu m total body and skin doses we ze d e termined to be at a residence at 2.7 miles N NW. The dose evaluation of pathways associated with radioiodine, particulat e s, carbon-14 and tritium released to the atmosphere was also based on the maxi m um expos e d individual. One such individual is a child whose diet included the consumption of 530 kg/yr of crops, 300 £/yr of milk, and 40 kg/yr of beef and poultry produced at the location of the dairy having the hig h est calculated dose r from these and two other pathways noted below. This location is 7 miles east. Another such individual is a child whose diet includes the consumptien of 530 kg/yr of crops grown at the location of the residence having the highest calculated dose from this and two other pathways noted below. These maximum exposed individuals were also exposed to inhaled radionuclides in this category, as well as those deposited on the ground at each of the locations described above. In addition to the dose estimates for the adult individual, estimates were also made for the teen (12-18 years), the child (1-11 years) and the infant (1 year), with appropriate values of consumption as given Regulatory Guide LAA. (6) For the pathways associated with liquid effluents, the adult individual received the highest dose. The doses 3 \. in r I from n oble gases released to th e atmosphere constituted externa l exposure, and were ther efo re not age-dependent. For the pathways associated with radioi odine and the other radionuclides released to the atmosphere, the child loc a ted at the resid ence received the highest dose at this site. .. All of the doses in this analysis were based on the radionuclide releases presented in Mr. Boegli's testimony. The dispersion of radionuclides in and the deposition of radionuclides from the atmosphere were based on the analysis presented in Mr. Fairobent's testimony. Comparison of Doses with RM-50-2 Design Objectives As indicated earlier, a comparison with RM-50-2 Design Objectives involves all LHR's at a site. Accordingly, using the procedure described above, a calculation was made to determine the doses associated with combined 2-unit operation. The results*are shown in Table 1 and are compared with the RM-50-2 design objectives. This table replaces Table 5.8 of the FES. (8) Comparison of Doses with Appendix I Design Objectives In order to make a comparison with Appendix I design objectives, a calculation similar to the one mentioned in the previous paragraph was performed. This computation, however, was performed on a per-unit basis. The results of the calculation are presented in Table 2. 4 Conc l usion It is con c lud e d, bas e d o n t he va lu es p r e se nt e d in T a bl e 1 , th a t L he agg r egate do ses ass oci a t e d w ith S o ut h Texas Pr o j ec t Un its 1 a nd 2 op e r ation m ee t th e RM-5 0-2 d e si g n object ives. The m ax i m um do se i s sli g htl y l ess th a n on e t e nth of the d e si g n obj e ctive. .. It is also concluded, based on the values pres e nted in T a ble 2, that the per unit doses associated with South Texas Project Units 1 and 2 tion meet the 10 CFR SO, Appendix I design objectives. The dose clos e st to the design objective is the dose to the thyroid from gaseous efflu e nts. 5 I I ! ----** T a bl e 1 C o mp a ri s on o f Ca lcul ated D o ses f r om Oper a tion with Guides on Desi g n O b jectives a Propo se d by the St a ff on Fe bru a ry 20, 1974 (Doses to M a ximum Individual from all Units on Site) Criterion Liquid Effluents Dose to total body or any organ from all pathways Noble Gas Effluents Gamma dose in air Beta dose in air Dose to total body of an individual ' Dose to skin of an individual Radioiodine and Particulatesb Dose to any organ from all pathways RM-50-2 Design Objective 5 mrem/yr 10 mrad/yr 20 mrad/yr 5 mrem/yr 15 mrem/yr 15 mrem/yr Calculated Doses 0.17 mrem/yr 0.20 mrad/yr 0.!10 mrad/yr 0.017 mrem/yr 0.047 mrem/yr 1. 5 mrem/yr aFrom "Concluding Statement of Position of the Regulatory Staff," Docket No. RM-50-2, Feb. 20, 1974, pp. 25-30, U. S. Atomic Energy Connnission, Washington, D. C. bCarbon-14 and tritium have been added to this category. 6 ~I Table 2 Comparison of Calcu l ated Doses from Operation with Sections II.A, II.Band II.C of Appendix I, 10 CFR 50a (Doses to Maximum Individual per Reactor Unit) Criterion Liquid Effluents Dose to total body from all pathways Dose to any organ from all pathways Noble Gas Effluents Gamma dose in air Beta dose in air Dose to total body of an individual Dose to skin of an individual Radioiodines and Particulatesb Dose to any organ from all pathways App e ndix I Design Objective 3 rnrem/yr 10 mrem/yr 10 mrad/yr 20 mrad/yr 5 inrem/yr 15 mrern/yr 15 mrem/yr .. Calcul a ted Doses 0.06 mrem/yr 0.08 mrem/yr 0.10 mrad/yr O. 20 mrad/yr 0.0085mrem/yr 0.024 mrem/yr 0.75 mrem/yr aAs presented in the Federal Register V. 40, p. 19442, May 5, 1975. bCarbon-14 and tritium have been added to this category. 7 References

1. A f f i dav it o f J acob Kas tn er (Re l at i ve t o an Upper Bound Es t imale of logical Imp a ct o n the Ge n e r a l P ublic), Doc ket Nos. 5 0-4 98 a n d 50-~99 , J u l y 18, 1975. 2. U. S. Atomi c Ener g y C ommi ss ion Concludi ng S tatem e nt'o f Positi o n o f the Regul a t o r y St a ff (a nd its A tt a chment) -P ublic Rul emak ing H ea rin g on: Numerical Guid es for Desi g n Obj e ctives a nd Limitin g C onditions for Oper a ti c~ to Meet the Criteria "As Lo w As Practicable" for R a dioactive Mat e r i al in Light-Water-Cooled Nuclear Power Reactors, Docket No. RM-50-2, Wa shin g ton, D. C., February 20, 1974.

3. Title 10, CFR Part 50, Appendix I. Federal Register, V. 40, p. 19442, M a y 5, 1975. 4. 5. Letter, G.W. Oprea, Houston Lighting and Power Company to Benard C. Rusche, U.S. Nuclear Regulatory Commission, "South Texas Project Units 1 and 2, Paragraph II.D. of Appendix I, 11 October 1, 1975. Title 10, CFR Part 50, Amendment to Paragraph II.D of Appendix I. Federal Register V. 40, p. 40918, September 4, 1975. 6. Staff of the U.S. Nuclear Regulatory Commission.

Draft Regulatory Guide 1.AA, "Calculation of Annual Average Doses to Man from Routine Releases of Reactor Effluents for the Purpose Qf Impelementing Appendix I," September 23, 1975. 7. Opinion of the Commission in the Matter of: Rulemaking Hearing -Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Practicable" for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents, Docket No. RM-50-2, April 30, 1975, Nuclear Regulatory Commission Issuances, NRCI-75/4R.

8. Staff of the U. S. Nuclear Regulatory Commission. "Final Environmental Statement Related to the Construction of South Texas Project Units 1 and 2," Docket Nos. 50-498 and 50-499, NUREG-75/019~

Washington, D.C., March 1975. 8 _t.., , c~--r.,~ .) 4 5 , 6 7 8 9 10 l 1 12 13 14 15 16 17 18 19 20 21 22 23 24 e rol Repor t ers, Inc. 25 I on J',:,:c-=i~c: i:: -j b e nt v.'lo clso pci x licipated or is not av ai l abl e a n ct th ercto re b y your le ave L'lr. Dr o rne l*i c k '::i l l I respond to hi s tes ti mony if nobody h a s a n y object i o n. tion, then. Q. MRS. BOViER::i

L e t me c h e ck. M r. Pend er g r af t: MR. PE ND ERG RAF T: N o obj e ction. MRS. B OW ERS: Mr. Schwarz? MR. SCHWARZ: No objection.

MRS. BOWERS: ~he Board will acc e pt this presenta-BY MR. STRIDIRO N: Mr. uromerick, do you have a document before you entitled Testimony of J.E. Fairobent concerning the Appendix I evaluation of atmospheric transport and dispersion at the South Texas Project site? A. (Witness Dromerick) Yes. Was this project prepared by you or under your supervision? A. Under my direction. To the best of your estimation, is the document true and correct? A. Yes. MR. STRIDIRON:

I move the one-page document entitle Testimony of J.E. Fairobent concerning independent evaluation

_ of dispersion and transport at the South Texas site be incor--, 3 MR. l-'ENDERC~RAV r: 1 ho.ve no ob J 2 ction. 4 Mi:<.S. BOWLRS: Mr. Sclr;, 1arz? .. 5 MR. S CHW AR~: Applic a nt has no obJect ion. 6 MHS. BOW~RS: The document you Just iden tified wil l 7 be physically incorporat ed in the transcript as if read. 81 (The document follows.) 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A, 'erol Reporters, Inc. I 25 1:SJ.'Lf,J \i~ (;t* 0. I::. FXL ,'.(J:,;i:;

f CO NCERNWG THE APPEN DIX I E VALUATIO N O f AT MOSPHERIC Tr(ANSPOR T ,\N D D ISPERSION i\T Tl!£ SOUTH TEXAS PR OJ EC T SITE An evaluation of th e at m ospheric trans p ort a nd disp e rsion co~d itions m~~i1c t i o.:.o;;:;-*

<.i 2 ,:;c:.:-i b2<.l in u r a i::. ?.2 6 uL::.;:_ory C:;,,;ide 1. i JJ , ":*: 2th0ci:, F or Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases Fro::i Li g ht Water R~actors", Sept em b~r 22, 1975. The meteorological data used in this evaluation, conslsting of joint frequency distributions of wind speed and direction r.easured at the 33-ft level by atmospheric stability defined by the vertical temperature gradient measured between the 33-ft and 195-ft levels, were collected onsite by the applicant during the period July 20, 1973 through July 20, 1974. The applicant also provided information concerning topography out to a distance of ten miles from the plant which was considered in the ev~~uation. Information on gaseous effluent sources considered in the evaluation, such as source height above plant grade, efflux velocity, and release point configuration, was provided by the Effluent Treatment Systems Branch of the Office of Nuclear Reactor Regulation. A "Straight-Line Trajectory Model", as described in Draft Regulatory Gui.de 1. DD wa.s used in evaluatini atmospheric transpc,'rt and dispersion characteristics. Duet~ the configuration of the release points with respect to adjacent solid structures, a ground level release was assumed. An estimate of maximum increase in calcrilated relative concentration (X/Q) values due to recirculation of. airflow, not considered by the straight-line trajectory model, was also considered using the guidance of Draft Regulatory Guide l.DD. Based on the available onsite meteorological data and on the atmospheric transport and dispersion model and guidance provided in Draft Regulatory Guide I.DD, relative concentration values for noble gases and radioiodines and relative deposition values (D/Q) for radioiodines were calculated for the locations presented in Hr. Waterfield's testimony. C.: : ..

I 2 3 4 5 6 7 8 9 10 l l 12 13 14 15 16 17 18 19 20 21 22 23 24 ~r ol Reporters, Inc. 25 I: I: 1, I 'I of testim'Jny 1:ihicl1 \'18 wil1 h c,VL! tlr. D o:, , 2[ j.c}: spc ,,,.:;or. J t .c:-; tlw Stuff' s re s p ons es to the Doa rd' s quC!s tions. BY MR. STHIDIRON:

Q. Do you have before yo u a docu ment e ntitled NHC Responses to Questions of the Safety and Licensing Board Concerning Health and Safety Matte rs, South Texas Proj~ct Un its 1 and 2, Docket STN 50-498 and STN 50-499? A. Yes, I do. Was the document prepared by you or under your direction? Yes, it was. Q. Are the statements contained in this document true and correct to the best of your information and belief? A Yes, they are. MR. STRIDlRON: Mrs. Bowers, I will move at this time that the document entitled NRC ~taff Responses to Questions of the Atomic Safety and Licensing Board Concerning Health and Safety Matters, s*outh Texas Porject Units l and 2, Docket Numbers SN'I' 50-498 and SNT 50-49~ be incorporated into the record as if read. MRS. BOWERS: Mr. Pendergaft? MR. PENDERGAFT: No objection. MRS. BOWERS: Mr. Schwarz? MR. SCHWARZ: Applicant has no objection. i ii CITd 8 ii ii 1 I 55 6 MKS. BOWERS: The document y ou have Just identi fied 2 will be physically ins e rted in th e transcript as if read. 3 (~he document follows.) 4 5 6 7 8 9 10 11 12 13 1) 15 16 17 18 19 20 21 22 23 24 Ac fe ral Reporters, Inc. 25

NRC STAFF RESPONSES TO QUESTIONS OF ATOMIC SAFETY AND LICENSING BOARD CONCERNING HEALTH AND SAFETY MATTERS SOUTH TEXAS PROJECT UNITS 1 AND 2 DOCKET NOS. STN 50-498 AND STN 50-499 I
QlJC S TION 1 The :increa s ed length of the 14 ft. core rend e r::; s l igh t ly l ess st ab le to axi al-x enon oscil l at i on s , esp ec ially l ate :in the fu e l eycle: RESAR-41 sug ge sts (Sectio n 4.3.1.6) th a t th e pa rt le1 gt h rods rnay be re li ed on to as s u re st ability but the SER , (Sec. 4.3.1) notes a INB pro b l em associat e d w ith the u se of PLR' s and says that use of su ch rods :in Wes tin ghouse reactors is forbidden.

Please discuss the alt e rnate c o ntrol s tr ategy (West:ingh ouse Mo de A) and its implicatims from the stand po:ints o f operational fl exib ility and safety. RE SPONS E Toe restriction o n use of part-l e n g th control rods in v!estii, g house reac tors i s expe cte d to be rem ov ed in earl y 1976 f o ll ow in g completion of and n::view by the staff of analyti~al DNB studies bein g conducted by Wes tin ghouse. In practice, control of the power distribution in_Westinghouse reactors with constant axial offset control (CAOC) procedures (with or without the part-length control rods) effectively prevents xenon oscillations frDm occurring, even ma potentially unstable reactor. This is because constant axial offset control maintains a relatively constant axial power shape during load following maneuvers, so that xenon oscillations are not induced. Being restricted to mode A operation (i.e., without use of length rDds), therefore, will not make the reactor more susceptible to xenon oscillations. It does limit operational flexibility, hcwever, because the requirements to maintain the axial flux shape constant dictates that load changes be made primarily with boron. This is a slower means of maneuvering, especially near the end of core life.

It is D"iv rtan.t to not2 that it is not r,:::c c::::s2.ry to use part-lEc ngth cor,t:-D:_

rods to surpress xen on os cill ations. Full-length control rods can be used for th i s purpose (see letter to J. F. O'Ledry , AEC, frolT! E. E. Utley, CarDlina Power & Li ght Company , "H. B. Robinson Unit 2 axial Xen on Osci llati ons" , October 16, 1972, a copy of wh ich i s attached). To asses s the impact on safety we have evaluat ed th e consequences of xenon oscillation. F o r exam ple , we may postu late that a xenon oscillation does occur regardless of the constant axial offset control procedures designed to prevent it. During the oscillation the axial flux difference (top minus bottom split excore detector readings) will unde....~o large swings. The constant axial offset control Technical Specifications prescribe a power r educ tion to 90% if the flux diff erence cann ot be maintained in a + 5% band around the target value, and reduction to 50% power if the flux difference is out of the + 5% band for more than one hour. The reactor will be safe at half power because the power d ens ities will be reduced by 50 percent. In an extreme case, even if the Technical Specifications ahd alarms were ignored, the overpower temperature difference trip would trip the reactor on excessive flux difference before fuel damage occurs . QUESTI O N 2 The SER at p. 4-12 states that the design. limit peaking factor fo r the 14 ft. core is 2.50; the SER supplement , at p. 6-1, states that the anal yses of ECCS perfonnance. asswned a peaki.rig factor of on ly 2. i+s. Is the ECCS analysis co nser vative from this standpoint? RESP ONSE It is ind eed not conservativ e if the design peaking factor is greater than that assumed for the ECCS analysis. The corr*ct design peaking factor for RESAR-41, however, is 2.45 as stated on page 4.3-242 of Amenc:1rrent 15 to the RESAR-41 Preliminary Safety .Anal ysis Re:i::ort. The figure .2,50 in the Safety Eyaluation Report was in error. All the relevant analysis and the staff's conclusi ons set forth in the Safety Evaluati o n Report and Supplement 1 were based on a peaking factor of 2.45.

QUESTION 3 The SER (loc. cit.) also assert s that th e hi3,her value of the peakirig factor for the longer core is associat e d with the effe ct of the PLR's: (a) If the PLR's are not used, will the limit still be 2.50? (b) If a lower limit is established, will control of peaking by simple axial offset observations still be possible at 100% power? RESPONSE As discussed in our response to Question 2 the design peaking factor for RESAR-41 is 2.45. (a) Yes, the limiting peaking factor will still be 2.45. Toe limiting peaking factor is established by the loss-of-coolant accident analysis not the use of part-length rods. (b) A lower limit has not been established because as stated above the use of part-length rods will not affect the design peaking factor limit .
QUESTIOH lf The Board notes that one of the consequences of the n ew (RESAR-41) refuelinf, system i s that fue l will be han d led at a shutda ... rn ITBrgin of o nl y 5%. How does this rrargin compare with that generally allow ed for fuel handlin g in T'*actors and critical faci lit i e s at present? RESPONSE Historicall y , the desi gns of r*fueling systems (including refueling procedures) and fuel storage fa cil iti es have provided that the keff would be 0.90 or less. This h as not been a regulatory requirement, but industry practice.

~ore recently industry has be en departing fro m this practice and we have i nd i cated that fuel may be stored such that keff does not exceed 0.95 in pure water when all ph ysica l and calcul at ional un-certainties are included. With r*gard to 5% shutdown margin for r*fi..eling we find this is acceptable on the basis that with all the control rods re.moved from the core, there is no longer any credible physical change that can be made rapidly on the core that will* substantially increase its reactivity. Continuous flux and frequent boron concentration rronitoring is required during refueling. In practice, boiling water T'*actors employ a shutdown margin of 5% during refueling

QUESTIC;~

SA. Tne SER , at p. 1 5-8 , stated t hat a revi sion of th e dilution path flow alarm s woul d be required in o rder to assu re adequate warning of potential boron diluti on. Suppl e1T!2 nt l, at p. A-8 , sug ges ts that thi s will not be required , but th at l o ckin g o ut of val ves and re li ance on nucl ear in strwne nt atio n w ill be sub s tituted. (a) Is this actually the plan? (b) How many minutes warr1ing will the operator have of impending criticalit y if relianc e is placed entirely on nuclear tion for wan1ing of such criticality whe n it occurs by the rrost rapid postulated reactivity addition rrechanisrn dur'ing refueling? RESP ONSE SA The plan adopted by Wes~inghouse for RESAR-41, and committed to by South Texas Project, is to lock closed valves FCV-llOB, FCV-lllB, 8338, 8355, and 8361 in the chemical and volume coni:rDl system, as identified on drawing 9. 3-1, Sheet 3, of RESAR-41. This procedure will eliminate all possible direct paths for addition of fresh water to the reactor coolant system. The only remaining path is via the reactor water storage tank. *The Technical Specifications will require sampling of the boron tion following JTBkeup to the tank before addition of this water to the reactor coolant system. As an additional precaution, the high count rate will be alarrred in both the containrrent and the coni:rDl room, and a high source range flux level will be alarrred in the coni:rDl room to indicate an a:i;:prcach to criticality due to any unforeseen dilution occurring . Typically, the source range high flux alarm will be activated one decade above the count rate setting being used. Thus, not only is addition of . fresh water preyented, but an increase in the subcritical rrultiplication factor is alarrred. Since all credible dilution accident flow paths have been eliminated, the need for p::>stulating operator action following a warning alarm has been eliminated.

QUES TI O N 58 vmat precautions (suc.h as secondary water treabnent and tube in specti o n) are now envisaged to assure steam generato r tube int egrity under all conditi o n s at S1P? RESP O N SE SB The NRC staff has evaluated the rreasures that will be taken to assure that th e steam generator tubes in the South Texas Project facility will not be subjected to conditions that will cause degradation of integrity.

We hav e also evaluated the provisions rrade by the applicants to detect such degradation, should it occur, before it has progressed far enough to affect the safety of the plant. The facilities, steam generators, and operating procedures described in this construction permit application for the South Texas Project are of more recent design. than those facilities that have experienced ste~n generator tube degradation. This response is directed to the South Texas Project construction permit application. Regarding the newer plants, including South Texas Project,nuclear steam supply vendors of pressurized water reactors that have experienced significant steam generator tube corrosion have redesigned steam generators and rrade significant changes in the secondary system water chemistry. The affected nuclear steam supply system vendors are obtaining experinental data on tube material compatibility in simulated secondary coolant ronditions so that the new pressurized water reactor plants should not have extensive localized corrision

For the South Texas Project steam generators, current regulatory requirerrents are considered.sufficient to insure plant safety at the ronstruction pennit stage of review. If future NRC staff action on this issue or future inspections of operating Westinghouse steam generators develop significant
safety i ss ues coneernmg de s i gn fo ature s of systen1s or ca-n:;:x:mer:ts for which pre limina ry cesizns iliY\:.'.

p~oposed in this applicat i on , post ccns tr.1ct i on permi t des i gn ch.a1ges ITBY be required o f t he applicants. W e have c o nclu ded that thes e measu res ar\? a d eq ua t e. 'H1ere is no re aso n t o b e li eve th a t p l an t s afety w ill be comprom i se d b y steam gen erator tub e degr ada t ion. O ur conclusi ons are b a s ed o n the foll ad ing c o nsi d erati on s: 1. Th e steam g e n e rators wi11 be of advanced design with improved secondary water flow characteristics, providing more tolerance for occasional lack o f wat e r chemistry control. 2. The applicants w ill use an a11 volatile type of water chemistry that ha s b e en s h a,m by service experience to minimize the probability of tube degradation.

3. Pruvisions f o r monitoring the serondary water chemistry will be included.

Th e se will be used to detect the presence of deleterious impurities before significant tube degradation can occur. 4. Pruvisions for nonitoring reactor coolant leakage to the secondary side are included in the design, and the limits on such leakage that will be l.JTifX)Sed will ensure that tube degradation, should it occur, will be detected before it develops into serious deterioration of integrity.

5. 'Ihe design of the steam generators permits inservice inspection of the tubes by rrethods that will detect incipient tube degradation.

'rubes that could further degrade to rrarginal conditions can be taken out of service by plugging. ' i . Q UESTIO N 6 The SER at p. 10-4 states that inf or.T:3.t i on will be forthc om ing regar<l.inr; the means by which the Applicant prop oses to preclude wate r harrme r in the steam generato r feedwate r system. Is such i.nfo n mtion ava il able? Wha t steps are presently pruposed t o de al w ith the prob l ems? RESPONSE The steam gen erator f eedw at e r piping wa t e r hamrrer problem is bein g .in vesgated by the staff on a gen e ric basis. Work is planned which inclu des inv es tigati on of water hammer pheno me na to date in operating pressurized water reactor plants, analytical means to study rrechan i sms that may cau s e water h am11er , recorrun end ati ons for corrective action, including JTDdifi cat ions to design and operating procedure s to preclude recurrence of such phen omen a. The staff plans to use a consultant t o assist in thi s work. Tests at certain plants on this subject are being clo se ly foll awe d by the staff. We have di scuss ed this problem with the applicants and have prepared a request for additional information which will be forwaru.ed to the applicants in the very near future. We will evaluate the applicants' response and, in conjunction with the generic investigation described above, detennine the necessary steps to preclude this problem for the South Texas Project. We have determined that appropriate rrodifications of the feedwater system can be made if necessary prior to finalizing the design.

QUESTION 7 Wh at i s the s t atus and generaJ. plan of th e pro gr arn me..11tioned in Sup p l emen t 1 (at p. 1 8-2) to review design features in t ended to prevent* fires or l imit t he safety c onse qu e nces of fires? RESPON S E The staff is formulating a program to conduct a comprehen sive revi ew and evaluati on of the fire potential in all nuclear power plants. Th e review will consider experience gained from the Browns Ferry fire, reco mmendat ions from th e N uclear Energy Liabilit y-Pro p erty Insurance Association (NELPIA) and from o ther qualified fire protection consulting ag e ncies. The fire protection systems will be upgraded if the results of our evaluation so dictates.

The staff is preparing a technical position which eventually will be used. as a Regulatory Guide, giving the guidelines for fire protection syste m design f o r nuclear power plants. When compl e ted,. we will send this technical position to all licensees and applicants of nuclear power plants requesting that they review their systems with respect to our guidelines, and propose modifications if required. We plan to review each plant individually, and to issue an evaluation with conclusions and/or recorrmendations for each plant .

('L1[S'Y'JO N 8 Supp l ewe nt 1 to the effect that ai r coses will rot exce ed 10 rnrad/y r 14 2rc'l 20 rrr2c/yr in c lu 0e co1,tritutions from 02s st r eam fflE'c: scs o f C , 3i,, arid particulates. (a) Are we to r e ly on th e irnplic a ticn in the Jul y 1 8 , 1 9 75 affid0 v i t of J. S. Boeali that such 0o se s due to 14 c and pa rticulates a re nealiaible?

If so, is the dose frorr: \1 also nesil ioib]e? (b) Are the releases on which t he staff's prese nt air oo!:'e a s sessmPnt is basec1 those of Pocali or those of t he FES Ta b l e 3. 7 (as i mp li E:d in the SER at paae 11-7)? PFSFONSE (a) The air dose pssessrrent provided in the affidavit of Dr. Kast ne r (July 18, 1975) was based only on the noble gas emissions. In supplemental testirrcny .Presented on Novcrr b er 5, 1975 by the KP.C staff on Evaluation of Liauid and Caseous Effluents with Respect to Appeneix I of 10 CFR Part SO, for the South Texas Project, the dose contributions frorr. carbon 14, tritium and particulates were presented fo the category "Fac1ioiooines and Other nuclides Release<'! to the AtIPosphere" * (b) The air dose assessrrent proviced in the affidavit of Dr. Kastner

was basecl on the noble gas releases provided in Table 1 attached to the JuJy 18, 1975 affidavit of Mr. Eoegli. \.
C:-) i**ol 1 ,**. '.:~ --..._J ... L._ .. Mr. John F. O'L e ary Director a t e of Licen s in g O c t obc 1*J G , 1 972 U. S. Ato m ic En e r g y C omm ission Wa s hington, D. C. 20545 0""\".*.~,.-. ;,,r \.._, u l / ; ;_,' ,. ), ' H. B. ROBI N SON UNIT NO. 2 LICE,\SE DPR-23 AXIAL XE N Q;s; OSCILil\TIO N S

Dear Mr. O'Leary:

In the interest of keeping the Co m mission inforr.1cd of any unusual events connect e d with the normal op e ration of a nucle a r p o1,: e r station, Carolin a P o wer & Light Comp~ny is reporting, by this lett e r, the pres e nce of diverg e nt axial xenon o s cillations in the H. B. Robins o n Plant. Continued oper a tion with this condition existing in the plant is not in violation of a n y T e chnic.nl Specifi c ati o ns or sa fety r e quir e m e nts (FSA.R, page 3.1. 2-3), and the magnitude of tl1c po11cr oscillation produced by the xenon oscillation is easily controlled by existing plant equipment. This letter is merely to inform the Comraission of such a condition, and C a rolina Power,& Ligbt's r..ethod of successfully controlling it. The no .. -mal operation of the Robinson Plant over the last seve r al months has b e en base load at full power, with only ~inor d e viation s due to forced outages, small load changes as requir~d by the system dispatcher, and a weekly test of the turbine stop and governor valves. This valve test is normally the most significant variation from full power oper a tion,' and is instrum e ntal in producing significant xenon-iodine imbalances in the axial direction of the core. The power level of the plant is reduced to 70% of _full load and the valves are exercised in turn to deter.nine any sticking of the valves. This exercise is performed to fulfill the warranty requirements of the turbine manufacturer. The power..._reduction is accomplished by inserting Control Bank D to approximately 100 steps and then compensacing for the increase in negative xenon reactivity by the removal of control rods and boron dilution. The time required to return to full power is determined by the successful functioning of the valves, and has been as short as one hour and as long as twelve hours or more. Upon return to full power, the axial offset of the core, as measured by the excore lone ion chambers, is normally positive, and continued operation leads to a substantial variation in offset (as much as 30% between positive and nc~ative limits) during the first cycle of the oscillation. The axial stability index of the core has been measured as +0.008, indicating an unstable condition. With this value of stability index, the offset differer,ce mentioned above will ir.crease by approximately 23% from cycle to cycle, eventually leadi.1g to a turbine runback as overpower and over.temperature setpoints are exceeded. . ... l

U ctob~r io , J_'_:i.'. l n c*i,:cr l o a\r<_*i Lh i::; occurrc11c c, a ,, t:;_*,,i;;: 1t.:[o l"\:,11d r,_*Lk:d l ,. c onL1ol of*:.."i:L 0:-c i.1J 2.li.c::\ in1.1 o l v i 1,:_; on l.y 1:1ovc;,1e n~: of Cont;:o l. jj.:1;1;, j 1 il:!'.; b een e r:1;)1.oyed , _lth oul;h l'n rt l.::n;:;t:L r(ldo-ha ve h cc n provj_cl c d in the pl::n t f O J.' " UC h J. p ll l' j l l~ ,: C , t Ji Cy 11 : i '-"~ 11 0 t h (' C I l C 1 :\ il l C j C cl f O r J. 11 y p l_ c1 11 l: O )l (_; r i1 l: i O 11 : , sin ce initi,11 startu p, :\J,rl J r e :wt n , q11ired for th e control of the po 1 ,:c r o scillations discussed h e r e. . 1/ Thi s cont rol pro ce dure i s knoh*n as First Overtone Control-, ancl has been t este d successfully on th e Robinson Plant .::rncl is currently hein g used in op e r.:ition.

Tbe procedure. emp lo ys a c;i r e fully tirnecl Dank D ins ertion to J.t t.J.ck s:i.multJneously th e: first har monics of the xenon and iodin e axial clisl:ributions. First Overtone Co ntro l is terrnin ilted and Control Bank D is 1,ithdr3.1,:n 1-1hen the first axial overtones in xenon and iodine have b ee n very significantly reduced and tho xenon-iodine oscill ation is almost enti rely eliminated. The attached figure shows the result of the test performed at Robinson in terms of axial offset and nank D movement, and tho su cc ess of the procedure in reducin g large vari.:ttions in axi;,.l off set in a si mple , relial.ilc manner. Continu e d use of the pro cod t1re is required due to the c ontinued and increasin g instability of llie co:cc as end of cycle lifetime approaches, and there is eve ry reason to expect that th is type of procedure will be required during every subsequent cycle of operation as \..211. However, it is emphasized again that th ere is no violci.tion of s.:1fety requir ement s, and that a simple, strai g!ttfon:ard procedure involving current plant equipment is entin , ly adequate to maintain control of the power oscillations. Yours very truly, ' .. ./ ---.. :----: ' /_ . . C,~;_: ~-/ 6:2<;P--t" E. E: U~ley -) Vice President Bulk Power Supply DBW/za cc: Mr. C. D. Barham Hr. N. B. nessac Mr

B. J. furr lo:. 1/ Bauer, T>.C., "Pract~cal Control Procedure for Xenon Spatial QscillatioP.s", Vols, I and II, PhD 'thesis, Carnegie-Mellon University, 1972. -'
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cr::.-.1 9 4 5 6 7 8 9 557 MR. ~TRl DI H ON: Tha nk y ou. I m i g ht a dd the Staf f h as it s wi tn2ss es av ai lable who can r e spond t o a ny f urther ques t ion s t he pa rt i es or t h e Bo a r d m i ght ha ve on t h ese q u e sti ons o r a ns we r s. . . tation. .. M k S. BO W E RS: Do e s that conclu d e you r dire ct ca se? MK. STRIDIRON: It does conclude our direct p resen-MRS. BUWEHS: As previously agreed, the parties were going to withhold any cross-examination and the Board wa s going 10 I to.withhold questions as well if all the direct presentation e 9 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace e rol Report e rs , Irie. I 25 was in. Unless the parties have objections, 1 think we should have a luncheon recess and we will resume at 1:30 and start out then with cross-examination. (Whereupon at 12:10 p.m., the hearing was recessed, to reconvene at l:JO p.m. this same day.) .!. :, CR6191 2 L .bwl 3 SlO 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 gro l Reporters, Inc . 25 !1 I! i (1:3 0 p.m.) MRS. BOWERS: A ccord in g to the agenda , we are now at Item 8, which is cross-exami nation by the parties and que stions by the Board. At the luncheon break the Board was asked if we could start immediately with matters concerned with Appendix I, because of witnesses that would like to leave as soon as possible, and the parties agreed to that,who were here at the time. Mr. Pendergraft, I don't believe you. were here. Is that all right with you? MR. PENDERGRAFT: We will agree. MRS. BOWERS'. Fine. Well, first I will invite the parties to proceed with any cross-examination of, first, the well, Applicant's and Staff's witnesses are here. They have been sworn and, so, Mr. Pendergraft, do you have questions of either Applicant or Staff witnesses in the Appendix I area? MR. PENDERGRAFT: No. We don!t We don't have any cross-examination on that. MRS BOWERS: . Mr. Stridiron, do you have cross-examination questions of the Applicant's witnesses, in the Appendix I area? MR. STRIDIRON: No, Mrs. Bower, we have no questions w2 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Act .J rol Reporters, Inc. 25 /l ,I ,, i* !i 1: ,, I on that. MRS. BOWERS: Mr. Schwarz , do vou have questions o~ th e Staff w itnesses? MR. SCHWARZ: We ha ve n o ne, Mrs. Bowers. MR. SHON: I have a couple of questions. MRS. BOWERS: The Board has questions. (Whereupon, the Witnesses resumed the stand.) MR. SHON: I would like to direct one question to Mr. Waterfield, on page 1 of his testimony, regarding the revised models that were used, revised presumably by Regulatory Guide 1. 8 (a), in a manner that should result in a poor realistic rather than a pessimistic answer. I note you said the models were revised to be responsive to the mandate of the Commission. It that revision a change with respect to the version of these these models that the Commission

had before it when it issued the September 4 notice? Do you know? WITNESS WATERFIELD:

Yes. I believe that would believe that would be correct. MR. SHON: Then, as I understand the situation, the Corrunission issued the September 4th notice saying that ah Applicant could opt to conform to .Guide*1 AA, that is a concluding statement. And thereafter you changed something, when you made this calculation and changed it in a way that would make the answers less conservative ot 11 *I !1 1* b\*13 , I I 2 3 4 5 6 7 8 9 10 11 12 13 14 151 16 17 18 I 19 20 21 22 23 24 .:.<t ~ral Reporters , In: . 25 o:c l es s pe ss i mist ic. Is th at right? WI TNES S.WATERF IELD: No. I don't think the changes were that su bstantive. MR. SH ON: C oul d you g i ve us a li ttle bi t . . . . . .. a bo ut w hat th e nature o f the ch ange w as? WIT N ESS WAT E RFIELD: Onl y one I ha v e a de f inite recollection of in that area is that there is one he ad in g for effluent release classifications.which had been jsut the term "gaseous effluents." We felt this was not specific enough and it was changed to "noble gas effluents." MR. SHON: I see. Then that would spe~ifically have borne upon the substance of one of the Board's questions also? WITNESS WATE~FIELD: That is right. MR. SHON: And I think you wrote the answer to that, tcq;is that correct? WITNESS WATERFIELD: . Yes' sir. MR. SHON: In p~rticular, then, if there is a substantive change there, it is with respect to counting only noble gases, rather than particulates and carbon 14 and tritium; is that correct? WITNESS WATERFIELD: The particulates were never included in that. class,I don't believe, because there was another class called radioiodine and particulates." MR. SHON: Yes. I recall that is true. I An 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 e r ol Repor te rs , Inc. 25 Ii t; SCl 'The o-Lh-::,r questi.:.-,!-, I had , c .. n you r \...:-i:J_l t:.:3 1 L' , l 1. 2. I know t able 2 was cal cul~te d on the basi s of a reactor unit and table 1 on the basi s of two units; is that r ight? W IT NESS WA TER F IELD: ~hat is rig ht. MR. SHO N: I also kn ow that ev entu a ll y a ll th e numbers in the calculated d o s e s are, as one mi gh t e xpec t, in a simpl e minded fashion, double for two units w hat th e y would be for one, except for one and that is the liquid effluent dose for the body from all pathways. It seems to more than double. Why is that? WITNESS WATERFIELD: I think there must be a typo in this. MR. SHON: Table 1 under i'Liquid Dose to Total Body from All Pathways," . calculated doses lists O. 2 7. Table 2 lists 0.16. That is a factor of very nearly three rather than two. MR. STRIDIRON: May we have a moment? WITNESS WATERFIELD: Yes. Now I see what the difference is. In table 1 the dose is quoted as being to total body or any organ. In table 2 the total body is in one category and all the other organs ~e in-another category. It turned out that the total body dose for two units was .12 millirems per year and a half of that is . 06. bw S m:i 1 lli 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Ac, .erol Reporters, In,. 25 r_*,.. i M R. SWX*i: I ~3C'.' .. It inc l ude d tot a l bo dy f or a: 1 v o r cr~. : 1 , ctnc 1 +-1 ,

oth er is the .08? Is that correc t? WITNESS WATE R}'I E LD: Tlt c:i t is c o rr e ct. The reas on for ch ang ing th e categori e s is, w e w e r e att emp ting to follow the categories that h ad be en ori ginal l y l aid ou t in the two Commission documents.

The ~M 50-2 had t he once classificatio~, whereas Appendi~ I has a differ en t classification of the way to apportion the doses. MR. SHON: I see That clears it up. I just got your response to our ques~ions this morning, but I think if I .understand it correctly, what you are saying is that the ten millirad gamma and twenty millirad beta per year do not include things other than the noble gases; is that right? WITNESS WATERFIELD: Yes. That is right. MR. SHON: Why can we assume that that is what the Commission meant when it said "air dose"?. Don't these thingscontribute to an air dose? Don't they, indeed, cause ionization? WITNESS WATERFIELD: Yes. They do. But I think the original intent was the air dose should bear some. fairly close relationship to-tissue dose and in the case of these nuclides, why that just doesn't happen. And we felt it was more appropriate to include them in the other II 11 :, I, l! b1;;(i !I l 11 2 i i 1, 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ~:t. er ol Reporters, Inc. 25 I I th e ir effe ct ther e. MR. SH ON: I see. I heard the Applicant's res po nse to this question, in which you said that he felt the other so urces , I think the ones that we specifically mentioned were carbon 14 and tritium particulates, would contribute only a tiny fraction, up to three percent, fractions of a percent; that is also in line with your experience? WITNESS WATERFIELD: I am sure that would be, yes: MR. SHON: Thank you. That's the only q~es~ions I have there. MRS. BOWER~:*. Mr. Stridiron, you may want to proceed with redirect following this, if you have witnesses that are anxious to be excused. MR. STRIDIRON: Mrs. Bowers, we have no redirect. MRS. BOWERS: Have these questions generated any questions on the part of the Applicant, Mr. Schwarz? MR. SCHWARZ: No, Mrs. Bowers. MRS. BOWERS: And ~he State of Texas? MR. PENDERGRAFT: None for the State. MRS. BOWERS: As far as the Board is concerned, those witnesses who are here solely on Appendix I matters i i *I !: l !! II b w 7 2 II 3 I 4 I 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A c t e rol Repo rt e r s , Inc. 25 5 6 -~ may MR. STRI D IR ()~:: T h a n k y,)U , :\l r s. £0*.,;e:: rs. MRS. BOWERS: Well, my questions originall y on c ross-exam i nation were limited to Appendix I matters , so let . me c heck. Mr. P e nder g r af t, do y ou ha v e q ue st i on s in othe r areas of either A p p licant's or Staff's witn e ss e s? MR. PE ND ERFRAFT: No. We don't. MRS. BOWERS: Mr. Stridiron, do you have questions in other areas of the Ap p licant's witnesses? MR. STRIDIRON: No, Mrs. Bowers, we have no questions. MRS. BOWERS: Mr. Schwarz? MR. SCH W ARZ: No, Mrs. Bowers, we have no questions. MR. SHON: I had a couple of small questions of Dr. Rodger on his testimony at table 19 in the very nicely prepared little booklet here. The statement starting on page 5 of the testimony and running through page 6; says that the vapor from the blowdown tank is condensed in feed water heaters and all of the l i quid is returned to condenser.hot w~ll. rt may be you are not e x actly the person to answer this, I am not sure, but are there no noncondensables? Nothing results in the form of a gas at all from that? I 11 I! Ii b w8 1 ;! 2 1 I' 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A: .e ral Reporters , Inc. 2.:> 'i'HTL'-iESS F ODCE R: I believe these things will also ven t back to th e condens er hot w e ll and the non-condensables w ill be vented along with the noncond e nsabl e s from the secondary system and , therefore th e contributi o n .. is accounted for. MR. SHON:* I see. It all goes out the air ejector of the system.* On page 9, in several places it is noted that distillants and other materials are released, released with further processing after analysis. Previous paragraphs mention a similar sort of practice. What kin~ of control does one have to assure that a thing is not released without being analyzed first, that it is held onto? Is it purely an administrative control? WITNESS RODGER: I am not sure that that aspect of . this plant has been fully addressed as yet, but normally, and in this case, too, the liquids for release are collected in tanks and these tanks Bre always in at least pairs, so that ~ou can stop putting into tank after you take the samples for analysis. There is always a lot o~ paperwork associated with it, and one has to get the results back from the analytical laboratory, and it is the normal practice, and I presume will turn out to be the operating practice of this plant, too, that the lines or valves through which liquids are ~.: ) :.'9 EslO 1: 1* 1: I! " 1 q 11 2 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 I .1e ral Reporters , Inc. 25 SGG under adMinistrative control. It has not tu rned out to be a problem in ope r ating plat1ts in the past , when one is able to stay on top of this , and things do get rec orded .. before they are tu rned loose. In the case of this plant, there is going to be effort made to review as much of thP. water as po ssible, so I guess a specific answer to your question has to be, there, indeed, has to be some aspect of administrative control to assure that that happens. MR. SHON: Lastly, on page 15 of your testimony MRS. BOWERS: Mr: Schwar~, if you want any other witness to also respond, be sure and so indicate. MR. SCHWARZ: Thank you. I will, ~rs. Bowers. a n 567

I T I C *" -' l 2 c srV linly int r: r os t~~ :::,::. T n ti:*, rn j_cJri l c of t.l10 pr11r.; it s2vs , 3
i; In CJ8 nL:r 2~ 1 ti1e av , 3r*, 1 ,~e doc,;r,~ (>\;r 50* 1*, i l'": s is f0u:-'!d to be 4 p e r c e n t n f t h G ma :< i n r rn i r1 d i v i ci ll a l ci o s c
11 5 I t. *,;ould S2f,fl to , rw that th e re \*,ouldn"t be a ny 6 general fi 9 11r 2 for that , that it \*rnuld v ,, r y very much f r om 7 situ a tion to s 1tuati.on. ;he re did this 1 percent co::1*2 from? 8 \': I T!!C:SS t?CJ DC;t:R: In deed it do e s vary. It can vary 9 fr om l e ss th a n 1 percent or 2 or 3 or s e veral percent. It is 10 in deed a fun ctio n of wha t is the particular meteorolo g y in 11 the site and what is t he populAti~n distribution around a 12 sit e. 13 Th e nur:ib e r co mes fro m some wor!c that we di d i'I 14 the course of ci evelopin g Appendix I in the first p~ra 0 raph, 15 and it ca me o u t of the initial presentation of the Staff in 16 the initial Appendix I hearings.in which we took the initial 17 po p ulation distributions which t hey had averaged for a nunher 18 of sites and the meteorology for the same number of sites and 19 worked out, if you would like a*histogram of dose versus 20 population, and in those particular cases the number was 21 slightly less thAn 1 percent. 22 I think it was a factor of 150 in the case of 23 Pl'IP s and 250 in the case of m*ms. In the case of South 24 Texas, the population in close is quite sparse and you have 25 to get out pr e tty much to the outer part of the 50 mile 2 t hi nl( i t is r e::,snna bl y c nnser v-1 ti.ve in this c A SR. I don" t 4 t o cut bc1 c< a little fu rt hf!r on the u pp8 r ho und c r1 l c 11l ati on S of D r. Ka stner and s haw t he re i s g nod exp e ctation t hAt the 6 nu mho rs wil l be s i qn i ficant l y l e ss than t hnse p res ented by 7 Dr. Kas tn e r. 8 I am in no wny criticizing his uppe r boun d calcul c1-9 ti nn. I am just tryin g to s ay as f a r as th e site is concern ed , 10 it w ill be bounded more so. I I 1 2 peri e nce. 13 1 4 MR. SH O N: It is _just $O m ethin q you got from ex-W IT NESS PODGEJ~: That"s correct. MR. SHON: That is all I h a ve on th a t on e. I 15 ta k e it we are discussin0 all of the material we he a r d this 16 mornin g. 17 Is that right? 18 On the S taff-"'s response to Question 58, which 19 concerned steps taken to insure stea m generator tu be inte q rity, 20 we noted that you mentioned that the South Texas project will 21 be using all volatile treatment.

22 Have there been any other P WR s that have used 23 exclusively all volatile treatement for a very lon g period of 24 ti m e, say, years? 25 WI Tt!ESS GA MI3 LE: Maine Yankee. C -*' ') -' 2 \';IT fJ E::,S G..'1'.'.::5 L L:: I am not ~;ure of the nu mb e r o f 4 r.iq. s: r u (': Has usec:I i t excl u siv 9 ly si.nc,:; st c1 rt-u p? 5 \'iIT fJ ESS G A'H: H.E: Y e s , it hn.s. I don"t havP. t he 6 ex3ct dat2. My best c uess l'tould be so m ewhere a round l 967. 7 1.rn. SHur ,;: I see. That is the only one? 8 l"IITNESS GA.".rnLE: Ho. There are oth e rs that h=1ve 9 used all volatile exclusively. IO HR. S:!O t!: !3ut not for a lon q period of ti me? I I \':IT NESS GA'.\B L E: No t longer than Ma ine Yankee. 12 !, rn. SHON: For years, or a couple of months? I 3 I'll Tf'lESS GA ,\\G LE: I would say" 2 years. 14 l.\R. SHON: 2 years. I understand th e Staff is 15 loo k ing more closely at this matter right now, and h as some 16 sort of special task force lookin q at that. Is that correct? 17 WITNESS GA~B LE: Yes. The Staff is evaluatin g 1 8 this consideration. 19 MR. SHLm: I trust anything they find out wi 11 be 20 applied, will it not? 21 WITNESS GAMBLE: Yes. 22 MR. STRIDIRON: May we have just one moment, 23 M rs. Bowers, so the Staff can discuss a matter? 24 MRS. B0\1ERS: Yes. 25 MR. STRIDirwu: Mrs. Bowers, we are now ready. ~) -(; ,'.~ ~: ~) . ! , I \ ' I J * , , , 1 * * -..) r 2 3* to ;, 1e. *

J *.,1a s in er r or *: 1 h_'.i 1 I s.::i i d ,':1i re Y~n kr:;8 us e d t h i.s in 5 d on"t kno 1: 1 U\e n sJ*: ie s sinc e ": S7. /.\r1 in e Yanke e f)il rti a ll y started 6 up sinc e "7 3 a nd has u s ed a ll v ol a til e. 7 /.1C?. S'.*I d!*I: ThAt sounds li ke a m ore correct a ns we r. 8 W I Ti',!ESS GA ,'W LE: The re a r e a nu mber of dates. I 9 just don~t hove th em. 10 !.rn. Sf-I()N: I s ee. Th ank you. I I I 0uess my next question could be directed to you , 12 or t o one of the App licant"s witnesses who have had so m et h ing 13 to do with t he preriaration of testi mon y on the matte r of s t earn 14 gene rator tub8s. 15 ; I know there will be a con densa te po lis h in g 16 syste m , b ut I am not sure if that is a full demineralization 17 syst efTl , or is it just p art? 18 MR. MOONEY: 1 ,t y name is John Moo ney. 19 The answer to that, M r. Shon, it is a full blown 20 demineralizer.

21 MR. SH CHI: Thank you. 22 I am not quite sure who to address this to, but it 23 has to do with Appendix E-3 on the matter of financial re-24 sponsibility, Ap penidx E-3 to SER Supplement I. 25 On the 3 tables that are presented here, 4 tables, ') ....I

t h:~ nu:'lb ers li 5 t ed f o r e-1c h y c 0 i r* und s:r : , u'.~j c ct n uc]_c,::i r pl~;1 i: 4 an d th e y se e: n n o t t o ad d to U v~ pn rtici pc1n ts tot n l s h21 re. I s this ri g ht? Is this be c aus e they \'t ill he 6 puttin c; mone y in for y":ars that are n o t crintested the r e , o r 7 why is that? 8 9 M r. Shon? 1 0 I I 12 MR. o;~o?IEP.I CK: C an I po int out a n example, /.!P.. S i-JON: Take cit y pub lic service. MF~. ST!H DifWtJ: ,'/hat p 9 ge? MR. S~CHJ: Page 3-9. 13 If one adds th e bottom line her e , subj ec t nu cl ea r 14 pl a nt for each year, one comes up with something li ke S375 15 million, and their share is listed as $450 m illion on page 16 20-2. 17 18 MR. D R JME R ICK: l'l hat was that first number? MR. SHON: $375 million, or S3, 73 9 ,000, I t h ink 19 was the number I actually g ot. 20 MR. DRO\IERI C K: I th ink the reason why that doesn't 21 come out is because, if you know, we have an asteris k on con-22 struction expenditures and that is exclusive of AFDC cost, 23 which is an allowance for funds used during constructi o n. 24 MR. s:-ION: In other words, the difference l'IOU ld be 25 the AF DC. ,* l 2 r:1 i nut e , ;:* J. , , cJ s 0 * ')' ...) 4 5 ( l~ e c e s s * ) M r. St r idiron , do you wa nt to p r o c eed? ::., 7 2 6 7 \.\!<. Df-?U\'.f:

l/ICK: ,'.\r. Sho n, on p2qe E-9 , those co.sts 8 t hat y ou \'!<?r e r e fe rr in q to, t he r ea s o n, the d i ff ,?rr:ince th ,? 9 c ost.s ,11e n t i onod o n [-9 do n o t i nclude the t r a n sr'liss i on c ost , 1 0 f ue l co s t o r the A F DC cos t. l l 1 2 1 3 1 4 !H?. SHLlN: I s e e. A ll 3 of t hem. I-IP. DD.CJ:\cR I C1(: That-'s ri g h t. M2.

SHCJf ,!: Than k you. l\RS. !:3()\'!ERS: .'..~r. S ch 1*1a rz, d id you ha ve a n y l:i furt he r if o r: riat i o n on t h is? 16 l,rn. SC ll\'!ARZ: S i mp l y confir m in g *:that M r. D r ome ric k 17 said, if t he B o a r d woul d lik e for us to pr e sent a st a t eme nt 1 8 on i t , we c a n. B ut o u r inform a tion is i de ntical t o wha t 19 M r. Dro m eric k just sai d. 20 M RS. GOW E R S: -ine B oar d has no furth e r qu e sti o ns. 21 Let me chec k with the parti e s a nd see if t he q u e s-22 tions have gener a ted a ny r e dir e ct? 23 2 4 25 /,\r. Sch w arz? M R. SCH~ARZ: W e h a ve no furth e r q uestions?

M RS. [3 0\'I E RS: i,\r. S tridiron? 2 3 4 ' . !.Jb. r3l J'.:U?3: Tr ,e n ex t it em on t he cic;e n cia i c; ~n 5 tal l~ c:10oul 1:;os t-h c~u rin g pr n cs::-lu r es and sche du l e:;. And* . .,,; *.1 ill 6 IV<'F,t t o t , 1 1 r: ab out t he ti me for th e r r oposed finr.:J i rv.j s ()1 1',-, ct 7 a n d concl us i ons of l aw. 8 9 D J:1 t \

SCH\'/ ARZ: M rs. L-3ov1 ers, \: le have hee n in c orn~n m i-10 c a tion wit~ c ou nsel for th e Staff, a n d anticipate the filinq 1 I of a joint propose~ findin0s just.as p romptly as the Bo ar d 12 may --v1ell, p ro rnp tl~,. W e would arpreciate any co nrne nt the ---.._ 13 Boa rd m ight h ave on what their wishes are. 14 !.ms. [30\'/E:~S:

\'!ell, w e *.-rould like to have t hc.l as 15 pro mp tly as possible. 16 17 MR. SCHWARZ: Thank you, ,'i~rs. Bowers. /,\RS. BU'.'/ERS: The Goard does have other conmi t in ents 18 until the first part of December. Like the 2nd of December. 19 So anything that would come in prior to that date would not 20 be acted on. 21 Do you think you can meet that date or s oo n there-22 after? 23 M R

SCH\'! AR Z : Th e Appl i can ts , I f e e l , ca n m e e t 24 that date. Mr. Stridiron l'tould like to speak for the Staff. 25 MR. STRIDIRO N: Yes, I believe the Staff can be C --') 2 3 .. '.:, 7 4 4 /.l~. P E: i 1 1)['.~G:->AFT: :*: e w ill r e vi e 1*1 th e fin d i n----~s *.-: he n 5 th 2 y a r e file d , b ut '.v e don., t 1.-1ri nt to cic l c1 y un n ec e s s c.ril i* 6 :-: r. a re a0ree-J ble tn 1-:hat couns e l has a lr c i'ldy prop0.s e i: L ;*:e 7 have talk:~d to th n, r:1 abnut it. 8 I.IRS. BU'.'.'C: F?S: You \*:oul d perhaps be in o n a n e F irly 9 dr a ft so that 1*1 hen th-~ I3oard receives t he joint proposed 1 0 f in d in gs , ~c w ill feel f re e to act on th e~, both App lic ant 1 I and Staff and the State o f Texas hav e done their final posi-12 tion. 13 Ar e you shaking your head yes, 0 r. Pend e r 1raf t? 14 15 16 able to us. 1.rn. PENDERGRAfT:

I am sayin g yes, that is agr e e-,../ I am sure we can wo rk that out among counsel. Mi1S. BO\'IE!?S: Are you saying in our han ds by 17 D e ce mbe r 2nd, or it wi 11 be in the mail hy December 2 n d? 18 MR. SCYW ARZ: W e would anticipate it bein g in your 19 hands, M rs. Bo we rs. 20 MRS. BO~!ERS: The Board has nothing further. 21 Let me check with each party and see if there is 22 any other unfinished busines that needs to be taken care of. 23 M r. Schwarz? 24 25 MR. SCH\'/Af?Z: We have nothin9, Mrs. Bowers. ? ? --' 4 ~-:) 6 7 8 9 1 0 l l 12 1 3 1 4 15 16 17 18 19 20 21 22 23 24 25 ~rn. SJRifJU'.lJ:'!: Th e ~:;ti:l ff h a s no f u rth e r **~.:'!tter to put.befo r e tho ~0 2 r d. 1\f?S. 8()'.'/EF: S .\n d the r e a re no ('lat t e rs t in t t:-1 e r eco r d needs to be kept ope n f o r. A ll t e sti mo ny and A ll evi d e n ce i s i r~. Is t h a t c o rrect, M r. S ch wa r z? rm. SCH\)A/-{2

I b eli eve tha t is co rrect, M r s

Bo ,,., e r s
c o rr e ct. ;.ms. 8()\'iERS: :.1 r. Pen de r g raft? f..lR. PEND ER GF?AF T: That's corre c t.. , 1/iR S. L~UHERS: /\r. Stri d iron. MR. STR IDI R ON: l)n the Sta ff's si d e, th a t i s *--. MR S. DO\*IE RS: Then th e record wi 11 be cl osed a n d this proceeding will adjourn. We would li ke to thank you and the audie n c e for your very cooperRtive participation in this proce e di ng and we will look for wa r d to receivin g the proposed findin g s a n d clusions of law December 2nd. (Wher e upon, at 2: 15 p.m., the hearing was a d journed.)}}

@@ Line 3: / Line 3: @@
 | issue date = 07/18/1989
 | title = Certification by Emile Julian Providing a Certified Copy of the Transcript of 11/12/1975 Aslbp Hearing in South Texas Project Adjudicatory Proceeding (Docket Nos. 50-498 & 50-499-OL)
-| author name = Julian E L
+| author name = Julian E
 | author affiliation = NRC/SECY
 | addressee name =

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