ML20028A318

Eighth Set of Interrogatories.Certificate of Svc Encl. Related Correspondence

ML20028A318
Person / Time
Site:	Perry
Issue date:	11/12/1982
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	CLEVELAND ELECTRIC ILLUMINATING CO.
References
NUDOCS 8211180274
Download: ML20028A318 (4)

Text

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, P.EU.TED curmPoNernc:; November 12, 1982 t

UNITED STATES OF AMERICA "

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NUCLEAR REGULATCRY COMMISSION ,

Before the Atomic Safety and Licensine Board% 2 !ay 15 pt 13 In the Matter of ) cj

) .:;- . V, _.- M U, ta.w CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50 W, O3fchWE COMPANY, Et A1. -- ) 50 441

) (Operating License)

(Perry Nuclear Power Plant, -)

Units 1 and 2) )

)

OHIO CITIZENS FOR RESPONSIBLE ENERGY EIGHTH SET OF INTERROGA'IORIES 'IO APPLICANTS Intervenor Ohio Citizens for Responsible Energy ("OCRE") hereby files its Eighth Set of Interrogatories to Applicants, pertainmg to I'ssue #9. The i

Licensing Board, in its September 16, 1982 Memorandum and Order (Concerning Scheduling) set October 15 as the date for the close of discovery on Issue #9.

On October 15, OCRE noved to extend this deadline to November 1, for reasons ex-plained in the notion. On November 1, CCRE moved to extend this deadline further, to a week follwing OCRE's receipt of docients requested of Applicants. Daring the November 10 conference call, the' Licensing Board granted OCRE's motion, with the requirement that CCRE offer a clear explanation for each interrogatory of why the delay was necessary. These explanations are grouped bel m , to avoid unnecessary repetition.. .

For Interrocatories 8-1 to 8-4: These interrogatories request clarification of or further information regarding documents requested by CCRE, which were received on November 4. Applicants, in answering OCRE's Third Set of Interrogatories, refered OCRE to various documents available for inspection at PNPP. Applicants filed their answer on September 14; CCRE, being busy with~other matters until October 1, tried thereafter to contact Mr. Ronald Wiley, Applicants' contacr person at PNPP. For several days the phone was continually busy; one day the phone system wastoN11youtoforder. On October 7 CCRE was finally able to get through to the plant, only to be told that Mr. Wiley was on vacation. CCRE then asked if another person might be able to help; the answer received was that CCRE would have to wait until Mr. Wiley returned,.on October 12. Only after conferring with Mr. Wiley did CCRE learn that these doctrrents could only be inspected on a Sunday, as they were work.ing documents that could not be removed frcm the site during t?e week: the first Sunday available was October 24. Upon inspecting these documents on October 24, CCPM found that they were of such'a voluminous nature that only a cursory inspection l 0211180274 PDR ADOCK 05000440 821112PDR

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would be possible at that time and requested copies of sme of the. documents -to be examined in more detail at a later time. When m filed its original motion to extend discovery on Issue #9, it assumed that the copies of the documents

'would be provided well before Novmber 1. hhen .it became apparent that they would not be, OCRE filed its motion to extend further the deadline for discovery on Issue

1. 9. M received the documents on Novenber 4; for these reasons the delay until this tire was necessary.

For Interregatories 8-5 to 8-8: These interrogatories request clarification of or further information regarding FSAR Section.3.11, Amendment 9. This was one of the documents t1 be provided at PNPP. CCRE did not request a copy of same, because OCRE has use of the FSAR copy that Applicants have provided to Mr.' Daniel D. Wilt, counsel $orSunflowerAlliance,Inc.etal. CCRE has limited financial resources and therefore did not request a copy of this amendment .frarApplicants, at a cost of S 0.10 per page, when a copy would be readily available at no charge. OCRE did not receive the FSAR amendment until November 7,1982 fran Mr. Wilt.

INTERIOGA'IORIES 8-1. Dcactly what type ,of' polymer is Rockbestos Polymer LD? This substance is used as electrical insulation in chbles manufactured by Rockbestos Co.,

which are used in PNPP (e.g. , types EKC-- 81, 82, 83, 84, 85, 92, 93, 94, 95 ).

8-2. Section 2:07.10 of GAI Conforned Specification SP-567-4549-00 states that cable jackets shall be heavy duty chlorcsulfonated polyethylene. Yet the cables (EFK-1 to EKF-35) which reference this specification-have hypalon listed as the cable jacket material. Is hypalon the same as chlorosulfonated polyethylene? If not explain.

8-3. Sane of the circuits listed in " Circuits by Equiprnent for PNPP, Unit 1" used cables identified as VIC-57, Vic-13, VFC-16, and VFC-17. These itdms appear not tbhavebeenreferencedintheGAIConformedSpecificationsprovided. Please produce specifications for these cables as well.

8-4. The GAI Conformed Specifications (e.g. , SP-561-4549-00) state that the cables shall be suitable for operation with an integrated gamna radiation dose of 35 Iregarads in carbon, integrated over 40 years.

(a) Wnat is neant by'35 megarads in carbon?

(b) Wnat dose rate, in rads / hour,. is used for the gama radiation? For the neutron radiation?

(c) Is the maximum dose rate of "0.18 Megarads per hour, in carbon" listed a e

,s .

for design basis event conditions the actual dcse rate used to qualify the material? If not. explain.

8-5. FSAR Section 3.11.2.1.3.5 (Amendment 9) states that a "well-stpported main-tenance/ surveillance program in conjunction with a good preventive main +2 nance program will assure that equipnent.that meets the ' specification is qmMied for the designed life." Please describe in detail the maintenance / surveillance and preventive maintenance programs Applicants will use for electrical cable ,

insulation. Specifically, hcw will degradation be~ detected and corrected?

At what intervals will cables be inspected? Hcw will cables in conduit or in other unaccessible locations be inspected?

8-6. FSAR Section 3.11 is unclear as to who is to perfgrm the gaalification .af electrical equipet, vendor, Applicants, or scrne third party? Please clarify.

8-7. Which of the four options listed in FSAR Section 3.11.2.2.1.7 is utilized for aging of electrical cable?

8-8. FSAR Section 3.11.2.2 states that safety-related electrical equipnent in a g harsh environment supplied by General Electric is qualified under NEDE-24326-P.

(a) Does.GE supply any safety-related electrical cables used in a harsh environment? If so, list all such cables and provide their specifications.

(b) If so, please produce NEDE-24326-P, under an appropria+2 protective agreernent. ,

Respectfully subritted, Susan L. Hiatt CCRE Representative 8275 Munson Rd.

Mentor, OH 44060

-- - (216) 255-3158

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C')L KETEP

• q. n CERTIFICATE OF SDNICE .

This is to certify that copies of the foregoing OHIO CIT 1 b [ b k EERGY EIGfIE SET CF INTERROGATORIES 'IO APPLICANIS were served by deposit in .the u-2.: mr.:. w '

U.S. Mail, first class, postage prepaid, this 12th day of Novdettierig2pV6fose on the service list below, ff Susan L. Hiatt

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.3 ----. ._. .. . - . . . . . . . .

., SERVICE LIST

.[eterB.Bloch, Chairman Daniel..D. Wilt, Esq.

/ Atomic Safety 'and Licensing Board '

U.S. Nuclear Regulatory Commtn '.b.Boic'08159 P

Washington, D.C. 20555 Cleveland, OH .44108 Dr. Jerry R. Kline Ronald G. Wiley Atomic Safety and Licensing Board CEI-PNPP U.S. Nuclear Regulatory Commin P.O. Box 97 Washington, D.C. 20555 Perry , OH 44081 Frederick J. Shon Atomic Safety and Licensing Board .

U.S. Nuclear. Regulatory Comm'n Washington, D.C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 -

IV Esq.

James OTriceM,ofCatchin,Exe,cutive the Legal Director U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 ,

Jay Silberg, Esq.

1800 M Street, N.W.

Washington, D.C. 20036 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D. C . 20555

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