ML20039A018
| ML20039A018 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/02/1981 |
| From: | Wilt D SUNFLOWER ALLIANCE, WILT, D.D. |
| To: | CLEVELAND ELECTRIC ILLUMINATING CO. |
| References | |
| NUDOCS 8112160143 | |
| Download: ML20039A018 (15) | |
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UNITED STATE.S OF AMI.RICA j _ _ _ _ _
NUCLEAR R6GULATOR{Cgy31.S.SION r
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For the matter of: 'M C Docket No's;vW (, o The Cleveland 7,lectric 50-440" 3 111uminating Co., et al '81 DEC -4 P4 :10 (Perry Nuclear Power l'1 ant. Unita 1 arxi 2) - A - December 2, 1981 304{ (u,
.g,d a oggll1 / gIi in- :UTT3 i Sunflower Alliance, Inc. , et al. First' Set;o'f Interrogatories to Apolicants. terr J/
- N These hvH r 1, g pursuant to the. previous Interrogatories (FirstSafety orders of the Atomic Sot)and areLicensing
?$$esBoard by Sunflower and Allian pursuant to 10 CFR 2.740 b. These interrogatories are directed to each utility making up the Applicants and pertain to one or more of the seven issues that have been admitted to date in this proceeding.
It is required that each interrogatory be answered separately and fully in writing under oath or r T.rmat', ion, within 14 days after service. These interrogatories chal.1 be continuing in naturo and the answers must be immediathly supplemented-cr amended, as appropriate, should the applicants, or anyone of them, obtain-any n;w or differing information responsive to the Interrogatories.
For purposes of these Interrogatories the term " documents" means all writingt and records of every type in the possession, control or custody of the Applicants or-any one of them., or of the Applicants' attorney (s), including, but not limited to, memervida, correspondence, reports, surveys, tabulations, charts, books, pamph-lets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings, and all other writings, recordings or video tapes of anf kind.
" Documents" shall also mean copies of documents even though the originals thereof -
are not in the possession, custody,:or control of the Applicants.
For purpcses of those Interrogatories, a document shall be deemed to be within the ' control' of the Applicants or Applicants' attorney (s) if they have ownership, pocsession or custody of the document or copy thereof, or have the right to secure the document or copy thereof from any person or public or private entity having physical possession thereof.
When identification of a document is requestd, briefly describe the document, i.e. , letter, memorandum, book, pamphlet, dc. , and s*.nte the following information as applicable to the particular document name, title, number, author, date of publication and publisher, addresses, date written or approved, and the name and address of the person (s) having pcssession of the document.
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ll 8112160143 811202 PDR ADOCK 05000440 G PDR
UNITED STATES OF AMERICA l
NUCLEAR RiGULATORY COMISSION l 4
For the antter of: Docket No's: 5040 The Cleveland Electric 50-W ,
Illuminating Co. , et al J
(Ferry Nuclear Fower Plant, Units 1and2)
Sunflower Alliance. Inc. . et al. Mrs,t Set of Interrogatories _ to A,pplicants t W ese Interrogatories pursuant to the previous orders (First Set) of theare filed Safety Atomic by Sunflower Alliance and Licensing Inc.et Board andal, pursuant to 10 CFR 2 740 b. %ese interrogatories are directed to each utility making up the Applicants and pertain to one or more of the seven issuec that have been admitted to date in this proceeding.
It is required that each interrogatory be answered separately and fully in. writing under oath or affirmation, within 14 days after service. These interrogatories shall be continuing in naturo and the answers must be immediately supplemented or amended, as appropriate, should the applicants, or anyone of them, ofter any new or differing information responsive to the Interrogatories.
For purposes of these Interrogatories the term " documents" means all and records of every type in the pcssession, control or custody of the Applicants or any one of them, or of the Applicants attorney (s), including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamph-
.lets, photographs, n ps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings, and all other writings, recordings or video tapes of any kind.
" Documents" shall also mean copies of documents even though the originals thereof are not in the possession, custody, or control of the ' Applicants.
For purposes of those Interrogatories, c. document shall be deemed to be within the ' control' of the Applicants or Appliccats' attorney (s) if they have ownership, possession or custody of the document or copy thereof, or have the right to secure the document or copy thereof from any person or public or private entity having physical possession thereof.
When identification of a document is requested, briefly describe the document, i.e. letter, memorandum... book, pamphlet, etc. , and state the following information as applicable to the particular documents name, title, number, author, date of publication and publisher, addresses, date written or approved, and the name and address of the person (s) having possession of the document.
ISSIE d 1 Applicants cc:rg:ncy evacuation plans do not demonstrate that they provide reason-able t.ssurance that adequate protective measures can and will be taken in the event of an emergency.
STATDENT OF PURPOSE The 3urpose of the interrogatories directed to Issue #1 is to discover whether Applicant has plans that will provide adequate protective measures in the event of an emergency. '!he information obtained will be used upon the hearing in support of Issue #1.
. 1. Demonstrate (pursuant to 10 CFR S50 33 (g) and 10 CFR S50.47 (c) (2) that the plume exposure pathway EPZ and the ingestion exposure EPZ for the Perry Nuclear Power Plant have been established with appropriate considerat. ion of local emergency response capabilities as they are affected by demography, topography, land characteristics, and jurisdictional boundaries. In addition, identify who established these EPZ's for Perry, and provide a legible map of each of the EPZ's.
- 2. NUREG -06$. Rev.1, concludes at page 13 that the duration of a release from a reactor accident could range from 30 minutes to several days. Explain in detail how plant operators are expected to determine the time duration of a radio-logichl . release and how this time duration affects the choice of offsite public protective actions. In addition, fully eOlain how offsite radiological energency response. plans for Perry take into account the parameters of the duration of:
release.. .
3 NUREG- 06$, Rev. li, concludes at page 19:
"The concept of Emergency Planning Zones (EPZ's) necessarily implies mutually supportive emergency planning and prepared-ness arran6ements by several levels of government: Federal, State and Local governments, including counties, townships and even villages."
Pursuant to this conclusion, demonstrate that, for the Perry Nuclear Power Plant EPZ's, " mutually supportive planning and preparedness arrangements" have been made. Provide full documentation to support the response to this interrogatory.
4 Fully describe and document the Applicants' rrangements with RAP and IRAP.
For each capability of these programs relied upon by the Applicant in responding ^
to a radiological emergency, describe each capability in detail and provide the best estimate of the time required for the capability to be implemented at the O
Ferry'auclear rowsr riant sita cr environs, including normal veahr ar4 aWomi em ti m ce uitions ( adv;rso wrathrr, such as heavy enoufall, fog, frsszing rain, etc. , as appropriate for the Perry Nuclear Power Plant region).
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5 For each of the planning and evaluation criteria in NUREG- 065+, Rev.1 (not i
tha standards but the criteria), demonstrate that each emergency plan for the j
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Perry Nuclear Power Plant site and EPZ's meets the appropriate criteria or provides '
an equivalent level of protection to the public health and safety.
- 6. Provide copies of all letters of agreement with agencies and/or organizations and individuals with an emergency response role in the EPZ's or onsite for the Perry Nuclear Power Plant. For each such letter of agreement, demonstrate that the letter specifies the emergency measures to be provided and that +he. letter includes mutually acceptable criteria for the implementation of such measures (no required by Criterion II.A.3, page 32, NUREG-065ff , Rev. 1). For any such agency, cr6anization, or individual, with an emergency response role that does not now have a letter of agreement, discuss whether letters are needed (and why or why not) and discuss when such letters will be obtained. As to those letters of Agr:ement which require Applicant to bear the costs of emergency planning of L bear the costs of enabling the agency, organization or individual to participate in caergency planning then state: A) the cost involved; B) the legal reasons which cupport Applicants' assumption of these costs; c) the current status of any
- improvements to be assumed by Applicant for any such agency, organization or individual ~so that such agency, organization or individual may participate in such emsrgency pinn;-specifically state each item which such agency, organization or
- individual required Applicant 6o assume prior to such agency, organization or individual's agreement- to participate in the emergency plan.
7.
A FEMA-sponsored report, Evacuation Planning in the TMI Accident. (January 1980, RS 2-8-34, prepared for EMA by Human Sciences Research, Inc. ), concluded on page 173:
" Volunteers can be highly effective as supporting members of professional emergency management staffs, but they cannot be relied upon ever extended periods of threat . . . Tney cannot
. . . be regarded as a substitute for re6ular staff or as a main-stay of a crucial operating area iike communications. Further-more, they should not be expected to perform on the same basis as professionals over a prolonged, standby period."
Regarding this conclusion, respond to the following:
A.
Do you agree with this conclusion? If not, fully explain why and discuss the basis for your alternative conclusion.
Provide copies of all documents relied upon in reaching
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B. If you agras, discum fully how this conclusion affcets tha' ability cf offalta cmerg:ncy response organizations and agencies to respond to radiolo-gical emergencies at Ferry and to drills.
C. Regardless of ycur position on the above conclusion, for each offsite/onsite evergency response agency or organization, identify by position and by numbers of personnel how may such personnel are volunteers (non-paid personnel who say or may not hold regular f,obs).
D. Fully discuss the impact of relianae of each organization or agency with emergency response responsibilities on volunteers in terms of how such reliance may impact on the ability to maintain a 24-hour a day operation over a protracted period of time (as required by Criterion II.A.4, page 33, NUREG-06$, Rev.1).
8 For any example initiating condition in Appendix 1 to NUREG-06$, Rev.1, which is not included within the Applicants' emergency plan, discuss why each such example initiating condition should not be included within the Applicants' emergency plan. Furtner, for accidents and emergencies involving initiation conditions other than thenc specified. in Appendix 1 to NUREG-06$, demonstrate that there .is _ .
adequate assurance that the Applicants' operating staff will promptly recognize-auch initiating conditions and promptly and correctly declare the appropriate-caergency class (i.e., Unusual Event, Alert, Site Emergency, or General Emer6ency).
9.
Provide copies of the Applicants' Operating Procedures and/or Emergency Pro-cedurec (as appropriate) which contain instructions to plant operators regardir4 the declaration of an emergency (i.e., Unusual Event, Alert, Site Emergency, or G:neral Emergency) pursuant to Appendix 1 of NURED-06$, Rev.1. '
~ 10. pursuant to Criterion II.E,5 of NUREG-06$, Rev.1, page 54 , provide a full l
and complete description of the system (s) intended to be utilized by State and local governments for dissemenating information on plant emergencies to the general ,
public within the EPZ's. Include in your response all applicable procedures, manuals, Ir,tters, orders, memoranda, and other applicable do:umentation, also include the con-ttnt of mess' ages if such messages are established. ~
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- NW , page 85, and ' o CFR Fart 50, App;ndix E,Section IV.D.3, de3anttrate that the administrative and physical means to be utilized to notify the public within the plume exposure patnway EZ within 15 minutes. In your response, provide any and all documents discussing the Ferry prompt alert and notification system, including bid specifications, sound curveys, engineering studies, evaluations of alternative hardware and systems, hardware location studies, and theoretical or actual field tests of system coverage.
Describe who has the authority to activate the system and under what conditions.
In addition, demonstrate that the system can successfully operate under the following conditions: loss of power, rain, icing, lightning, severe snowstorm.
Further, demons ~trate that the financial and administrative means exist to assure the operability of the system thoughout the operating lifetime of the Perry Nucl. ear Power Plant, and discuss who has responsibility for testing and maintenance of the system once it is installed.
12.
Pursuant to Planning Standard G of NUREG-0634, Rev.1, page 49 and the associated Criteria on pages 49-51, provide a full and complete description of the public education and information programs for the Plume Exposure Pathvay DZ and the Ingestion Exposure Pathway HZ. Include in your-response all written materials prepared for public distribution and for distribution to local and State emergency management personnel which describe the public education and information program.
Identify any and all consultants utilized in the preparation of such materia's, including the name of the company, name of the prineipal contact person, business address and-business telephone number of the principal contact person.
13..
Fully describe the Applicants' Technical Support Center (or its equivalent),
and demonstrate that the center meets the criteria and standards set forth.in NUREG-0696, Rev. 1.
1 14.
Pursuant to Criterion II.H.8 and Appendix 2 of NUREG-0654, Rev.1, fully describe the meteorological instrumentation and procedures for the Perry Nuclear Power Plant. Include in your response the sensitivity of the system and the suscep-tibility of the system to adverse environmental conditions, such as lightning, loss of normal power, damaging winds, hail, and icing.
15 Fully describe any dose projection system intended to be used by the Applicant and/or offsite authorities. Include in your response full design details of the '
syst,em, including specifications, physical and conceptual limitations of the system, and the accuracy of the system. Fully describe the ability of the system to accur-ately predict offsite doses under the following conditions: a heated release, releases involving large quantities of radioiodines and/or ; articulates, and shifting wind patterns, and any combination of these factors.
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16.
~ Drcribe tha capacity cf Laka Ccunty Mgmorial Hospital i,ast to r:esiva patients cuffering from radiation exposura. D :cribe the cystem of prioritics instituted by Applicant and Lake County Memorial Hospital East in receiving on-site and off-site patients. '
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State the expected number of employees to be on-site during normal operations ;
at each shift if and when Ferry Nuclear Power Plant Unit I and II go into operation.
18.
Describe the notification system to be used relative to the 50 mile plume ingestion EPZ. Describe in detail the system including but not lir.ited to persons responsible for such notification; the notification system to be employed; the criteria to be used in determining when to issue such notification; the persons to whom such notification will be given in each community or township within the 50 mile EP2; the physical and conceptual limitations of the notification systems the names and addresses of those individuals responsible for maintaining the integrity of this notification system; the plans Applicant has, if any, to test this system and the names and addresses of all agencies, governments, organizations and individua'Is who will-be involved with such-testing.
19.
Attached to the May,1981, revision of Applicants'-- Emergency Plan-are copies of letter agreements with several institutions and local government units. Does this represent all of the letter agreements which Applicant has to date? Set forth App-licants' plans to obtain future letter agreements including the name 'and address of the organization, be it governmental or not, involved. Set forth the names of all organizations with wham Applicant will have letter agreementscan the date, if it occurs,'that~ Ferry Power Plant Unit s I and II~will go into operation.
20.
~ Define what is meant by the primary working document of the emergency plan.
Sec. 25 of May,1981, revision Ferry Nuclear Power Plant Emergency Plan.
21.
Does Applicant have a security plan and procedures and a Health Physics instructions?
22.
The emergency plan revision of May,1981, discusses Emergency Action Levels (EAL). Discuss the following as it specifically relates to ea:h EAL. State the specific parameters, boundaries and criteria of each EAL; state the guidelines issued by Applicant to assist the Emergency Duty Officer or other proper official to assist that official n determining which EAL to impliment.
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23 State the procedures and criteria adopted by Applicant to assure the ability and effectiveness of Applicants' Emergency Plan. What procedures are to be adopted \
to update the Emergency Plan?
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2M Who are th2 cff-2its teaturing gr ups catablished in scetion 4.1.4 of h E::rg:ncy Plan? What critsria and staMawin hava be:n adopted tp ncasure the offec-tiveness and expertise of the off-site measuring groups ? What agreements exist between Applicant and the off-site measuring groups and attach copies of each agreement with each off-site measuring group.
25.
Describe in specific detail the specialized training and experience require-cents of all persons who will hold the positions set forth on pages 5-2 and 5-3 of the Emergency Plans further, set forth in specific detail The specialized train-ing, experience and qualifications of shift supervisors; set forth in detail the procedures to be employed by Applicant to verify and to continue to verify that s2bject employees do have and will continue to have the specialized training, experience and qualifications required.
26.
Set forth in detail the reasoning behind Applicants' decision not to have an caergency duty officer on-site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, seven days per week. What assurance does Applicant have that substitutes for the emergency duty officer will have the timo, experience-and-ability to perform in an emergency situation in the absence cf the emergency duty officer?
27 Set forth in specific detail the training, if angr, any off-site organization will recieve to respond to any emergency at Perry Nuclear Power Plant. Set forth whether training manuals exist for such trainings whether instructors exist for cuch training; the background, training and expertise of such instructors; the frequency of such instruction and all other details concerning such instruction.
28 What facilities are available, not proposed, to transport members of the public or Perry Nuc1' ear Power Plant staff to~ Radiation Medical Center Hospital, in Philadelphia, Pennsylvania?
29.
Set forth in detail the emergency medical plan adopted by Applicant.
30 Set forth in detail the agreements between Applicant and other off-site organizations, institutions or individuals which will provide security services tcwing service; ambulance service; police services fire service; radio and tetephone communications service; meteorological service s medical service net specified in tha May ,1981, version of Applicants' Energency Plan.
31 Set forth in specific detail the ' provisions and procedures to be employed by Radiation Management Corp to assure that any individual exposed to excessive radiation will recieve prompt evaluation and treatment.
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32, Scotions 5 6.2.1 to 5.6.2.8 cf Ferry nuclear Pouer Plant hmergency Flan not forth Applicanta' cxp;ctations of csrtain civil agsncies. Set forth in specific detail the agreements between each of these civil agencies and Applicant whien pro- !
vides Applicant with assurance that the Civil Agencies will perform in the event of an emergency at Perry Nuclear Power Plant. Set forth in detail any training which these Civil Agencies will receive so that the Civil Agencies can respond to an smergency at Perry Nuclear Power Plant. Finally, what assurance does Applisant have that the' comnunication links, and responsibilities by these off-site Civil Agencies will in fact, not theory, be performed?
33 Radiation Management Corporation is not located in the State of Ohio. Why wss it chosen to provide emergency medical services in the event of an emergency at Perry Nuclear Power Plant? What assurance does Applicant have that Radiation Man-egement Corporation will have the expertise and capability to respond to emergency conditi-ons at Perry Nuclear Power ?lant within 15 minutes of a declaration of crergency at Perry Nuclear Power Plant?
34.
What provisions are being made to protect citizens of Canada who are within the 50 mile EPZ? Set forth in specific detail these provisions. If any formal ag -
esnts exist, provide such agreements.
35 What is the maximum exposure level an off-site emergency worker is expected to expose himself to during any emergency work? Specify in detail the training and warnings off-site emergency workern will receive before they are expected e to e themselves to radiation doses of any amount.
36.
When will- the Emergency Operations Facility be planned and -implemental? ere Wh will-it.be-located?~How will"it~have access to data displays-and information' read -
outs from the control room?
37.
To what extent will Applicant assist the affected counties with the develop-4 unt of County Emergency Operation Centers?
38 When will the comprehensive communications network with backup capabilities be procedural?
39.
When will the emergency organization notification system be instaned? '
- 40. How is the emergency communications system powered? d 41.
Describe the layout of emergency warning devices in the control room l
. What accrss is there to the multipoint recorders in the control room? If theroom control {
! becomes inoperable, describe in specific detail the backup emergency warning systems. o and contr l~ '[
i 42 What type of protection system from radiation 'expesure is available
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cntering and leaving the Unit Control Room?
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ISSUI 3g QUALITY ASSURANCE STATaGNT OF FURPOSE 1he purpose of the following interrogatories as they relate to issue 3 is to discover information concerning the stop work order of February,1978,; to discover what steps, if any, were taken to remedy the deficiencies that led to the stop _
work order, and residual deficiencies related thereto.
- 43. Specify in specific detail the violations of NRC requirements which resul.ted in the February,1978, stop work order. Include in your anseer reference to the specific NRC requirement as well as the specific violations. Identify all areas of construction that were affected. Specify the weaknesses in Applicants' Quality Assurance and Quality Control Programs that were exposed by the stop work order.
- 44. Relative to each viciation referred to in Interrogatory 43 stated above, set forth the following:
A) each. time each specific violation was inspected after February, 1978, B) trte date that each specific violation was cleared; C) the date that any further violation of the same NRC requirements was found by an NRC inspector D) the exact response provided by Applicant to the NRC violation both as to the original violation and as to any future violations; E) What changes were made in Applicants' quality Control and Assurance Program; and document:the changes as. a result of the work stoppage -of- - .
robruary, 1978 45 As a result of the work stoppage of February,1978, an augmented inspect 6on~--
program was initiated. Specify in detail what the results of this augmented inspec-tion program are. Further, state what violations of NRC requirements were discovered as a result of the augmented inspection caused by the Bebruary,1978, stop work order.
- 46. Define the term " critical blueprints".
- 47. What are the specifications for torque-ing of cable tray bolts?
48 Was there any damage to' the Unit I containment building dome during placement?
49, What engineering specifications or judgement were used in establishing the Quality Control and Assurance Programs at Perry Nuclear Power Plant. Based on oper-oting experience, has the Stop xprk order of February,1978, verified or not verified the engineering judgements set forth in the Quality Control and Assurance Program?
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- 50.' As a rs:: ult cf tha stop work order of February, 1978, hava there besn changes made in Applicants' quality Control and Assurance Program? Spscify in detail all cuch changes. Further specify the reasons thr.t the changed requirements of.the Quality Control and Assurance Program were not adopted in the original Quality Control and Assurance Program.
ISSUE #4 STATEMENT OF PURPOSE h e purpose of the interrogatories as they relate to Issue #4 is to determine the nr.ed for a full scale 30 degree sector steam test; to find out the relationship between Applicants' ECC5 and the 30 degree sector steam test; to determine when cuch a test will be performed.
- 51. Section 151.2. of FSAR states that the Applicants' model of care spray distributions will be confirmed by a full scale 30 degree sector steam test.
A) When will this test be performed?
B) WillthistestbeperformedonagenericBWR/6model, or on a specific plant? If this test is not performed on the actual Perry plant, explain how the results of the test can apply to a standard 238 size plant, of which Perry is a prototype (FSAR, p. 1 5-1).
c) Describe-the " full scale 30 degree sector steam test"in detail, including.but not limited'.to.-the conditions -and -
parameters used for the test, which ICC systems are test n-ed (HPCS, LPCS, LPCI, ADS), whether-the diesel generators -
pottering the systems will be tested concurrently, type of LOCA assumed, any ECCS failure modes assumed, and how the operating c' ore accident conditions will be simulated.
Supply the test procedures, j D) Will this test be performed on a fueled and operating reactor? If not, explain why and indicate how this data can apply to an operating reactor.
- 52. cive the source of the following quotation, attributed to the NRC, found in Section 151.2 of TSAR: "The NRC has agreed 'that the method for verification 'of I the currently assumed core spray distributions which are used to justify conser-vatisms of the spray cooling heat transfer coefficients in ECCS-LOCA licensing l calculations. '" here is another quotation in the material immediatQy following ~
in the FSAR. Give the source of this quotation as well.
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53, '4hy is expcrim:ntal data missing on the safety of Applicants' ECCS?
- 54. Specify the namn and addrus of the parson or organizations vho will perform the full scale 30 degree sector steam test.
55 Is the 30 degree sector steam test sufficient 1,o provide a worthwhile data base on a prototype ECCS onaprototypeB4R/6reactorsonaprototypeMark III containment? Why?
ISSUE #6 STATSMENT OF FURPOSE
'Ihe purpose of the following interrogatories is to explore the nature of an AT4S: to determine Applicants' responses to the various consequences of an ATWS to demonstrate the need for an automated standby liquid control system at Perry Nuclear Power Plant.
- 56. Based on postulated AT4S accidents, how long would it take after the event occurred before the operators at the control room would discover the event?
- 57. How long would it take once the operators have determined an AT2S has occur-red to impliaent .the SMS?
38 Once the SMS has been initiated, specify the time it would take for the SMS to bring the accident under control.
- 59. . Assuming.an automated SMS was installed at Perry Nuclear Power Plant, how long would-it~ take-the automatic- SLCS to determine that an AT4S event has ~ occurred,- _
impliment-the SMS and bring the accident under control?
- 60. Specify current Applicant thinking as to when to commence the SMS after an AT4S has occu- sd?
- 61. For B4R's of the type being installed at Perry Nuclear Power Plant, what is the pro 1 ability of an AT4S occurring?
- 62. For H4R's of the type being installed at Perry Nuclear Power Plant, what is the probability of a common mode failure occurring?
63, Assuming an unmitige.t.ed AT4S occurs, with the BWR being instaned at Perry Nuclaar Pcwer Plant, what is the risk' of off-site exposure of radiation in excess cf the allorable 10 CFR limits.
64 For H4R* s cf the type being installed at Perry Nuclear Power Plant, what are the probabilities of a pellet-clod interaction failure occurring?
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' 63 In tha event of en ATJS sv:nt ocming at, a B4R of the typa being installed i at Ferry Nuclear Powcr Plcnt, what cra the probabilities of a core nit-down with the currently installed SMS and what are the probabilities of a core melt-down !
with the proposed automatic SIES?
66.
Specify the amount of time caved in the event an AT4S occurs using the automa' tic SLCS as opposed to the manual SLCS at Perry Nuclear Power P1Lant?
67.
Volume 4 of NUREG-0460 contains what is known as alternate 4A to handle AT4S events. Specifically state all of the factors being relied on by Applicant for not installing the equipment set forth in Alternate 4(A). Demonstrate how the current Applicant response to AT4S (as shown by the equipment installed at Perry Nuclear Power Plant) is superior to A16ernate 4(A) of NUREG-0460 68.
Is it not true that Alternate 4(A) (of NUREG-0460) reduce the risk of severe consequences from AT4S by a factor of 100 for BiR's. Demonstrate how Perry Nuc1. ear Power Plant's current response to AT4S is superior to Alternate 4(A) in terms of reducing the risk of AT45.
69.
Demonstrate the ability of the suppression pool to absorb the core heat generated before the SIES shuts the reactor down. Demonstrate how the ability of the suppression pool to accomplish this result would be improved by the install.ation cf an automatic SLCS.
- 70. D-enstrate the ability of the High Pressure coolent injection system to ksep the core covered following an AT4S.
- 71. What mechanisms are available-at Perry Nuclear Power Plant to rec'.uce tha -u-power ceciriations .in the B4R that ~would -occur ~after2n AT4S? '
- 72. 'What mechanisms are available at Perry Nuclear Power Plant to reduce dilution of the form injected by the SLCS.
73 Submit off-site radiation dose estimates for the worst case transients based on G.E. codo CDYN.
- 74. What training or procedures are available to plant operators in the event of an AT4S?
75 Describe the mechanisms available at Perry Nuclear Power Plant to avoid a pressure regulator failure AT4S.
- 76. Describe the mechanisms available at Perry Nuclear Pever Plant to avoid tran-sition backing.
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Respectfully submitted,
/ A 1 i{r f r> /: ],I; $'l{.
Daniel D. Wilt, Esq.
Ittorney for Sunflower Alliance et. a L 7301 Chippewa Rd.
- Breeksville, Ohio 44141 (216) 526-2350 PROOF OF SERVICE A. copy of this First Set of Interroga tories to Applicant has been sent to all persons on the attached Service List by regular First Class Mail on this 2nd Day of December, 1981
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Dnnie1 D. Wi.1t, Esq.
j'ttorney for Sunflower Alliance et al
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SERVICE LIST .
Peter B. Bloch, Chairman Dr. Jerry R. Klein Atomic Safety & Licensing Board Atomic Safety & Licensing Board Nuclear Regulatory Commission Nuclear Regulatory Commission Washington, D.C. 20555 . Washington, D.C. 20555 Frederick J. Shon Jay Silberg, Esq.
Atomic Safety & Licensing Board 1800 M Street N.W.
Nuclear Regulatory Commission Washington, D.C. 20036 Washington, D.C. 20555 Donald T. Ezzone, Esq. Daniel J. Herron, Esq.
Assistant Prosecuting Attorney Assistant Prosecuting Attorney Ashtabula County Courthouse 105 Main Street Jefferson, Ohio 44047 .
Painesville, Ohio 44077 Tod J. Kenney- Jeff Alexander 228 Soouth College St. Apt. A 920 Wilmington Ave.
Bowling Green, Ohio 43402 Dayton, Ohio 45420 Terry Lodge, Esq. Robert Alexander 915 Spitzer Bldg.
2030 Portsmouth St. Apt. 2 Toledo, Ohio 43604 Houston, Texas 77098 Atomic Safety & Licensing Appeal Board Docketing & Service Section Nuclear Regulatory Cammission Office of the Secretary Washington, D.C. 20555 Nuclear Regulatory Commission Washington, D.C. 20555 Charles Barth, Esq.
Nuclear Regulatory Commission Washington, D.C. 20555 o Da- ors s
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DEC 4 1981 , -44 0;$ C - : -- ,. .
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