ML20081B199

Rebuttal to Applicant 831012 Statement of Matl Facts as to Which There Is No Genuine Issue as to Contention I-62

ML20081B199
Person / Time
Site:	Limerick
Issue date:	10/24/1983
From:	Lewis M LEWIS, M.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20081B075	List: ML20081B073 ML20081B187 ML20081B199 ML20081B207
References
NUDOCS 8310270362
Download: ML20081B199 (3)

Text

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'WITED STAE OF AMERICA NUC:2AR REGU'_ATORY C3:CI"FI%

3: fore the Atytic Sifety and ticansine Board 00CKETED USN80

. In the matter of 32iladelphia Electric Company \

Daclets Nos. 353 a g 3 g g g g (Limerick Generating Station Unit's 1 ari 2.) 0FFICE OF SECRITW 373tKTAL T0" A72'.ICANT'? STATE:GT OF MATERIAL FACTS AS TO '4HICH T:#EN[d[M GTNUINE ISSUE TO 3E HEARD AS T3 CONTENTION I-62 dated oct 12,1933."

1. Pressurised thermal shock is a condition that results from the introduction of cold water into or onto or troximate to , a hot pressure vessel while pressure is or becomes high. (Intervenor's Statement at A.4)

• Please note that the numbering system proposed and used in the Applicant's Statement of Material Facts is used in this Intervenor's Rebuttal.

Intervenor differs with Applicant in this 1st fact , andarea of disagreement is underlined. Justification for disa6reement and Intervenor's position can be found in referenced (Intervenor's Statement at A.4 ). Similar convention will be carried throughout this Rebuttal to show areas of disagreement.

2. Thermal Stresses are produced in the vessel w:.lls when cold water is introduced into, on or woxirt. ate to the vessel (n.)

3 Stresses are produced when vessel is subjected to high pressure.(n.)

1. 3 is accepted by intervenor as it stands.

4. No comment.

5. No comment.

6. No comment.

7. No comment.

3. High reactor vessel pressure , during or after cold water injection , can occur in a 3'4R. (f ee Statementof j ntervenor at A.5.1.)

9.It has not been adeouately de.r.onstrated thst significant neutron embritf.e: ant does not occur in a E4R. 'Intervenor's Statement at A.4 an! A.j(2)) .

It.Has not been adecuately demonstrated that the decrease in vessel material toughness as a result f' irradiation is substantially; less in a F4R than that in a IVE. (Intervenor's Statement at A.11 and A.13.)

8310270362 831024 PDR ADOCK 05000332 -

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13.

11. No comsnt, 12, No comment.

13. The neutron fluence at the vessel wall in a L'R should be very low compared with a FWR due to the presence of a large water filled annulus... A Comment: Intervenor disagrees with this #13 .(Intervenor's Etatement at A.5.2.) -

14. Intervenor disagrees in totowith this #14 for the reasons stated in Intervenor' s Etatemeht at A.5 15.No coment.

16. No coment

17. Required weld test samples were perfor:ed. . . Intervenor must disagree with thic All7 because it is a conclusory statement that another Contention on CA/QC in this proceeding will be without merit.

Until and unless {r Romano's C:atention on CA/qC is disnissed without merit, #17 is conclusory and without basis.

18. Same comment as 17

19. Same coment as 17

20. No comment.

21. Same comment as 17

22. No comment.

23. Same comment as 17,

24. Same comment as 17

25. same coment as 17

26. Same coment as 17.

27. Same coment as 17.

23. Esse coment as 17

29. This is a promise not a statement of material fact.

30.No comment.

31. No comment.

32. This " material fact" is rife with assumptions,"well above those expected"; undefined nuances," conservative calculational techniques": and allusions to data that is not on the record," verified by operational experience."

33. No comment.

34. No comment.

35.No comment.

36. This " material fact " hangs upon data that is not in the record," field, measuremente and nuances that intervenor has not had access to even the definition of words," conservatively uverpredict."

37 This ":.aterial fact"is only true frr the calculation of average valves and is not exact or reliable for point data.

38. No comment.

39. No coment.

14

40. No comment

41. No cument.

42. No comment.

43.A maximum fluence reported by the Applicant in this "Faterial Fact" is really a calculational average that does not take into account anomalies.(See Intervenor Statement at A.5.(2))

44 This " material fact" hangs or a framework of assumption , calculations, and complete ignoring of the possibility f Pr3 in a %*a.

45.No comment.

46. fame comment as 44

47. Eame comment as 44. Also this " material fact" appears conclusory without factual basis on the record.

-49. This " material fact" is really a prediction and is the crux of the Contention.

49. No comment.

50. " Fracture Mechnaics evaluation" has severs.1 drawbacks . This should not be depended upon unless and until defended upon the record. (SeeIntervenor Statement at A.12.)

51. Aside from the concerns stated in the answer to " material fact" 30, above, the term "available materials" is not defined herein. I may not really understand what the Applicant is trying to say here ,but if actual data is not obtained from materials actually used in the reactor (archival is scmetimes the word used), this material fact is without basis.

32. This is conclusory, and merely describes the results of an analys.is thtt has not passed any scrutitly ani is not on any AS3 record. .

33. This is merely a statement of an assumption. It is not a " material fact."

54. Same comments as 43,50, and 51.

l

55. No comment.

36 thru 60. No comment.

61. This is really a promise and not a sW.ement of material fact.

Respectfully submitted, l

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F.arvin I Iawis, R.P.I.

6504 3radfurd Terrace Philadelphia , Pennsylvania 19149 (215) CU 9 5964 (215) 725 7325 (Answerphone.)