ML19330B145

Response to Doherty Requests for Admissions.Admits Presence of Small Blowdown Load Due to BWR Pipe Rupture.Admits Lack of Automatic Means to Place RHR Sys in Cooling Mode.W/ Certificate of Svc & Affidavit.Related Correspondence

ML19330B145
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	07/24/1980
From:	Copeland J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL, METROPOLITAN EDISON CO.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-CP, NUDOCS 8007300449
Download: ML19330B145 (14)

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N 00CKETED g UNITED STATES OF AMERICA  % USNRC NUCLEAR REGULATORY COMMISSION 6~

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BEFORE THE ATOMIC SAFETY AND LICENSING BO Ogoynygggy Branch In the Matter of 5 y S .n G HOUSTON LIGHTING & POWER S COMPANY S Docket No. 50-466 S .

(Allens Creek Nuclear S

' Generating Station, Unit S No. 1) S APPLICANT'3 RESPONSE TO JOHN F. DOHERTY'S THIRD REQUEST FOR ADMISSIONS TO HOUSTON LIGHTING & POWER COMPANY In response to the requests for admissions propounded by John F. Doherty, Houston Lighting & Power Company (Applicant) answers as follows:

REQUEST NO. 1:

Admit or deny therc is an event which would require complete evacuation of the power block (that is all the buildings attached to reactor building).

RESPONSE: )

1 Applicant knows of no Design Basis Accident that would require complete evacuation of the power block.

l REQUEST NO. 2:

Admit or deny that the role of delayed neutrons is l not treated in the WIGLE code. I

RESPONSE

GE does not use WIGLE for reactor excursion calcu-lations such as the rod drop accident, but to the best of Applicant's knowledge, delayed neutrons are accounted for in

• the WIGLE code.

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REQUEST NO. 3:

Admit or deny that Applicant has never stated its RHR system will achieve cold shutdown in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from 100%

Power. i

RESPONSE

The ACNGS PSAR indicates that the RHR system is capable of cooling the reactor to 125' F. within 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> after shutdown. This is applicable to all licensed power levels including 100% power.

REQUEST NO. 4:

Admit or deny that in-core neutron monitor cannot detect control rod vibration amplitudes?

RESPONSE

In-core neutron monitor is not designed to detect control rod vibration amplitudes.

REQUEST NO. 5:

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Admit or deny there will be " flashing" of water to steam at the end of the ECCS cycle following water injection in response to a LOCA as alleged in Doherty Cont. #45.

RESPONSE

Applicant admits, as noted in NUREG/CR-1018, that there is a small blowdown load due to pipe rupture in a BWR, but is does not prcduce lateral impacting between the fuel assemblies due to differential flashing.

REQUEST NO. 6: l l

Admit or deny the control rod insertion speed will )

be slowed if the Control Rod Drive Return line is not used.

(Rel. to Doherty 48).

RESPONSE

Removal of CRD return line will not slow the scram time; normal control speeds may be slowed slightly.

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REQUEST NO. 7:

Admit or deny there will be " Flashing" of water to steam at the beginning of the ECCS cycle (at times called

" Initiation" of said cycle) from water injected as a re-sponse to the receipt of signals that a LOCA has occurred (sic] as alleged in Doherty Cont. #45. _ _ _ _

RESPONSE

See response to Reque..c No. 5, REQUEST NO. 8:

Admit or deny the " uncoupling tool"~is called an uncoupling rod. (See reply on P23 to Question 2, relating to Doherty Cont. #46.)

RESPONSE: . - - . .

Applicant is not f amiliar with the term "uncoupl-ing rod". The control rod is removed by a tool called the

" control rod latch tool".

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REQUEST NO. 9:

Admit or deny the absence of the control rod drive return line will slow control rod drive insertion for the .

ACNGS.

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RESPONSE

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See response ta Request No. 6.

REQUEST NO. 10:

Admit or deny that ACNGS is planned to~ operate for more than one day with the HPCS out of servic'e'. ~(Rel'.' to Doherby #48).

RESPONSE

Standard BWR-6 Technical Specifications allow the HPCS to be inoperable during power operation ~if~the~ RCIC l system, the ADS, and the LPCS and LPCI systems are operable. j The inoperable HPCS system must be restored to operable 1 status within 14 days.

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REQUEST NO. 11:

Admit or deny that high initial withdrawal speed of the control rod is an issue raised against giving permis- i sion for the removal of the control rod drive return line I for BWR 6/238" core plants by G.E.?

RESPONSE

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The higher initial withdrawal speed of the control l rod after the removal of the CRD return line was considered, l buh uE ha- satisfied the NRC that there is no safety concern. 1 l

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REQUEST NO. 11:

Admit or deny .pplicant will have no responsi-bility for Quality Assu ance at ACNGS. i

RESPONSE

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Applicant denies that it will have no responsi-bility for quality assurance at ACNGS. ,

l REQUEST NO. 12:

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Admit or deny there is no training program for welders described in the PSAR. _

RESPONSE

All welders will be qualified by tests conducted at the site in accordance with ASME IX or AWS code Dl.l.

PSAR Section 3.8.2.7.2 states the Applicant's commitment to the latest edition of ASME IX. .,

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REQUEST NO. 13:

Admit or deny there is no difference between

" scram reactivity function" and " scram reactivity coef-ficient" in nuclear research literature.

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RESPONSE

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The " scram reactivity function" is not the same as the " scram reactivity coefficient".

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REQUEST NO. 14:

Admit or deny that at the June 16th deposition and in the ensuing three days this Intervenor made available for Applicant copying at Baker & Botts offices in Houston, more than 200 items this Intervenor has deemed relevant to con-tentions admitted in the Order of March 15th.

RESPONSE

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Counsel has not counted the number of items pro-duced by Mr. Doherty. Moreover, the identity of a single item is not defined.

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REQUEST NO. 15:

Admit or deny, that as currently designed "short reactor periods" (quoting T. Biddle) can occur if a control rod uncouples and damage [ sic] fuel in the ACNGS.

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RESPONSE

If a control rod decouples and drops, the fuel enthalpy Will be considerably less than the prompt fuel failure limit of 280 cal /gm. -- - - - -

REQUEST NO. 16:

Admit or deny that Applicant k' s.s of no BWR 6/238" reactor for which NRC has agreed 7.o remove the CRD return line.

RESPONSE

Applicant knows of no "BWR 6/22C" reactor which the NRC has denied the removal of the CRD return line.  :..--...-

REQUEST NO. 17:

Admit or deny that currently there are no calcu-lations of the loading (lateral) on the ACNGS core which combine SSE, LOCA " flashing" at any point in the ECCS cycle, and LOCA loadings. (45) --

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RESPONSE

ACNGS is designed to accommodate SSE plus LOCA load combinations. The flashing associated with LOCA pro-duces a differential pressure as set out in PSAR Table 4.2.14.

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REQUEST NO. 18:

Admit or deny the ECCS code make [ sic] no provi-sion for end of cycle blowdown flashing as described in Contention #45, for the ACNGS.

RESPONSE

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See response to Request No. 17 .' ~- ~

REQUEST NO. 19:

Admit or deny the Residual Heat Removal system is only available for spent fuel pool cooling _when the reactor is in " cold shutdown" condition. (38)

RESPONSE

RHR system is used for spent fuel cooling when the reactor is shutdown and pressure reducecl_to; atmospheric.

REQUEST NO. 20:

Admit or deny there is no automatic system for placing the RER to SFP-Cooling mode when the reactor is not at cold shutdown. (11) _

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There is no automatic means to place the RHR system in the spent fuel cooling mode. -

REQUEST NO. 21:

Admit or deny Applicant has no plan for what to do about maintaining spent fuel pool cooling if the spent fuel l pools cooling system fails and the crev had had [ sic] to  ;

leave the facility.

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??SPONSE:

The design of the spent fuel pool cooling system provides for any single failure; the habitability decign of the control room precludes the need for such plans. As an additional safeguard, the Fuel Pool Cooling pumps will be operable from the Remote Shutdown Room.

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REQUEST NO. 22:

Admit or deny Applicant has made no study of the environmental consequences of the release of materials from the spent fuel pools' contents to the environment during unattended operation of the pools. .

RESPONSE: )

l As discussed in PSAR Section 11.3.2.1.6.4, radio-active gases emanating from the Spent Fuel Storage pool'is an input to Applicant's assessment of normal radioactive

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releases. The Spent Fuel Storage Pool is normally unat- j tended but can be monitored from the control room. l 1

REQUEST NO. 23: _ - -

l Admit or deny there is no experimental data on fuel rod burn-up in BWRs and its effect on peak cladding I temperatare during LOCA. (39) l l

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FGSPONSE:

Applicant is not knowledgeable as to the whole universe of experimental data, but to the best of its knowl-edge,- there is no experimental data which directly links fuel burn-up with peak cladding temperatures during LOCA.

REQUEST NO. 24:

Admit or deny there is [ sic] nc experimental data on fuel rod burn-up in BWRs and its effect on_ maximum cladding

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oxidation during LOCA. (39)

RESPONSE: _. _

Applicant is not knowledgeable as to the whole i universe of experimental data, but to the best of its knowl-edge, there is no experimental data which directly links fuel burn-up with maximum cladding oxidation during LOCA.

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REQUEST NO. 25:

Admit or deny there is no experimental data on fuel rod burn-up in BWRs and its effect on maximum hydrogen generation during LOCA. (39)

RESPONSE

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Applicant is not knowledgeable as to the whole

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universe of experimental data, but to the best of-its knowl-edge, there is no experimental data that directly links fuel burn-up with hydrogen generation during LOCA.

REQUEST NO. 26:

Admit or deny there is (sic] no experimental data on fuel rod burn-up in BWRs and its effect on coolable geometry in core during LOCA. (39)

RESPONSE

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Applicant is not knowledgeable as to the whole universe of experimental data, but to the best of its knowl-edge, there is no experimental data that directly links fuel ,

burn-up with coolable geometry in core during LOCA'. j REQUEST NO. 27:

Admit or deny there is (sic] no experimental data on fuel rod burn-up in BWRs and its effect on long term

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cooling. (38)

RESPONSE

Applicant is not knowledgeable as to the whole universe of experimental data, but to the best of its knowl-edge, there is no experimental data that directly links fuel

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burn-up with long term cooling. --

l REQUEST NO. 28:

I Admit or deny the coolant void fraction is not changed by increasing its temperature if the pressure is

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constant.

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RESPONSE

Applicant denies that the coolant void fraction is not changed by increasing its temperature if the pressure is constant.

REQUEST NO. 29: .

Admit or deny that Applicant's project manager for Allens Creek stated in a June 9, 1980 publication of Appli-cant's "Public Affairs Department" that, "Each year comple-tion of Allens Creek is delayed, the company and our customers will have to shoulder $100 million for alternate fuels.

That doesn't include another approximately $100 million a year in inflationary cost increases." Relevant to the Doggett-Perrenod Contention on financial capability. (Name of the publication: " Transmissions").

RpSPONSE:

The cited article speaks for itself.

REQUEST NO. 30:

Admit or deny that the project manager for Allens Creek in request 29 (above) has not been able to determine the exact source of this amount and the exact. method..of.__

calculation.

RESPONSE: -

The source of the statement was the Project Manager and the number was based on his general knowledge of the i subject matter. ,

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REQUEST NO. 31: -

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1 Admit or deny that Applicants fuel assembly cannot withstand a 5.1% increase in fuel rod outside diamteral swelling without impeding core flow to the extent _the ____

critical power ratio will be less than 1.0.

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RESPONSE

General Electric designs to limit plastic strain to 1% and maximum critical power ration to greater than 1.0 for all transients including abnormal transients. Applicant is unfamiliar with the term "diamteral swelling" and does not know how these design parmeter translate into that term.

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REQUEST NO. 32:

Admit or deny that pressure within the BWR fuel rod cannot become sufficiently high tc produce a 5.1% in-crease in fuel rod outside diameter.

RESPONSE: -- _.

The pressure within an ACNGS fuel rod canno';

become sufficiently high to increase the fuel rod outside

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diameter by even 1%.

REQUEST NO. 33:

Admit or deny that Applicant does not believe there is any condition of reactivity insertion mentioned in any G. E. publication where the reactor bulges.

RESPONSE

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Applicant does not have complete knowledge of every statement made in every publication by G.E.

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REQUEST NO. 34:

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Admit or deny that the issue in Dohwrty Contention

1. 48 is the number of paths of high r.ressure water to the , _

reactor core.

RESPONSE

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Applicant did not write Doherty Contention No. 48 and cannot discern what Mr. Doherty had in mind, if any-thing, when he wrote the contention.

REQUEST NO. 35: -

Admit or deny that Applicant was aware of the apparent error on page 20-1 of the SER Supp #2.which stated the figure of $1,055,000 instead of the figure from Amend-ment #2 of approximately $1,372,000,000 mentioned in your reply to Doggett-Perrenod Interrogatory Se't #1.

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RESPONSE: l Applicant became aware of the difference when it answered Doggett's interrogatories.

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Respectfully submitted,

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OF COUNSEL: J. egorygCo C. omas 'Bi@21e, planar Jr.

BAKER & BOTTS Da ell Hancock 3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 Lowenstein, Newman, Reis, Jack R. Newman Aralrad & Toll Robert H. Culp.

1025 Connecticut Ave., N.W. David Raskin Washington, D.C. 20036 1025 Connecticut Ave., N.W.

Washington, D.C.

ATTORNEYS FOR HOUSTON LIGHTING.& POWER COMPANY l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket No.'50-466 5

(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing App ~licant's Response.to John F. Doherty's Third. Request for~A'dmis'iiii: ins ~in the above-captioned proceeding were served on the following by deposit in the United S ates 11, postage prepaid, or by har.4-delivery this dQ day of

, 1980.

V Sheldon J. Wolfe, Esq., Chairman Hon. Charles J. Dusek Atomic Safety and Licensing Mayor, City of Wallis Board Panel P. O. Box 312 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D. C. 20555 Hon. Leroy H. Grebe Dr. E. Leonard Cheatum County Judge,-Austin County Route 3, Box 350A P. O. Box 99 Watkinsville, Georgia 30677 Bellville, Texas 77418

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Mr. Gustava A. Linenberger Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory Commissior.

U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Atomic Safety and Licensing Mr. Chase R. Stephens Appeal Board Docketing and Service Section U.S. Nuclear Regulatory Commissior Office of the Secretary Washington, D. C. 20555 of the Commission U.S. Nuclear Regulatory Commission Steve Schinki, Esq.

Washington, D. C. 20555 Staff Counsel U.S. Nuclear Regulatory Commissior Richard Lowerre, Esq. Washington, D. C. 20555 Assistant Attorney General for the State of Texas P. O. Box 12548 Capitol Station

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Austin, Texas 78711

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Mr. Bryan L. Baker D. Marrack 1118 Montrose 420 Mulberry Lane Houston, Texas 77019 Bellaire, Texas 77401 J. Morgan Bishop Brenda McCorkle 11418 Oak Spring 6140 Darnell Houston, Texas 77043 Houston, Texas 77074 Stephen A. Doggett W. Matthew Perrenod P. O. Box 592 4070 Merrick Rosenberg, Texas 77471 Houston, Texas 77025 John F. Doherty F. H. Potthoff 4327 Alconbury 7200 Shady Villa, No. 110 Houston, Texas 77021 Houston, Texas 77055 _.. .

Robert S. Frimson Wayne E. Rentfro Madeline Bass Framson P. O. Box 1335 4822 Waynesboro Rosenberg, Texas 77471 Houston, Texas 77035 James M. Scott Carro Hinderstein 13935 Ivy Mount 609 Fannin, Suite 521 Sugar Land, Texas 77478 Houston, Texas 77002

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J. egorypopland' ,

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STATE OF TEXAS S S

COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared L. D. Richards, who upon his oath stated that he has answered the foregoing Houston Lighting &

Power Company's Response to John F. Doherty's Third Request for Admissions to Houston Lighting & Power Company in his capacity as Lead Engineer for Houston Lighting & Power Company, and all statements contained therein are true and correct to the best of his knowledge and belief.

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L. D. Richards _

SUBSCRIBED ANp SWORN TO BE ORE ME by the said L.

D. Richards, on thisc ?$fle day of , 1980.

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b e b cdodd M N6tary Public in and for

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Harris Cotmty, Texas

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