ML20040E513

Second Set of Interrogatories Directed to Nrc.Certificate of Svc Encl.Related Correspondence

ML20040E513
Person / Time
Site:	Perry
Issue date:	01/30/1982
From:	Ryan Alexander OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
Shared Package
ML20040E510	List: ML20040E509 ML20040E513
References
NUDOCS 8202050020
Download: ML20040E513 (3)

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t.' I. ~ *- 9 January 30, 1982 UIIITED STATES OF AMERICA NUCLEAR REGULATORY C0!CISSIO!! '82 fC '~3 P2 S ' .

Before the Atomic Safety and Licensing Board ..,.,

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In the Matter of )  !

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CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50-440 C0!?ANY, Et A1. ) 50-441

) (Operating License)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

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' 0:iIO CITIZE!!S FOR RESPONSIDLE E!!ERGY I SECO !D SET OF I!!TERROCATORIES TO STAFF Ohio Citizens for Responsible Energy ("0CRE") hereby propounds its second set of interrogatories to Staff purcuant to the Licencins Board's Order of July 28,1031. A statement of purpose will follow.

2-1. bhat method, for detectin; the preconce of corbicula in Lake Eric near P !PP docc the Staff rococnend? ID: plain.

2-2 In its response to OCRE interrogatory 1-21, Staff stated that the " discharge ctructure of the Perry plant, houever, is an offchore, submcrced, high-velocity diffucer that should provido no thermal habitat or refuso for the clanc." Please state the basis (cc) for that statencnt. It vould be help-ful if a contract botucen thoce conditionc uhich create a good thercal habitat or refu ,e and those that do not vould be provided.

2-3. In its responce to OCP.C interro;atory 1-22, Staff .lictad equipnent uhich ucro cerviced by the Emercency Service Unter System. Characterice that equipacnt in tornc of vulncrabilit" to postuleted biofoulin;- due to clar.c, c:'. tihich heat e::chan-orn or ccNencerc arc :oct cucceptible?

--4 List all thoce nuclear power plante in the United States and Puerto 2ico uhcro corbicula trac hnoun to be procent in the vicinity of the nlant or l' still is r.recent. (Omit Arkansac ::uclear One as thic Intc. cnor ic ,

anarc of that cituation.)  !'

i-2-5. For thoce planto licted in 2-4 above, characterice the corbicula/ plant interaction ac bein, cither nc;ative (a problem) or othertlisc. For each cuch plant with a nc:;ative interaction, enumerate the c:: tent of the problen, cr;. uhat equi?nent vac a'fected?

C-0. For those negative interactions listed in 2-5 above, outline the licencoc's attenpts to control the probica. : oto alco the relative cuccccc of the ,

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~different methods used.

2-7. Acsuming corbicula is detected in the vicinity of Perry plant, what control methods does Staff recommend? If Staff still has not yet analysed methods for detecting and preventing potential flou blockage at Perry caused by corbicula, when does it c::pect to have such analysis completed? I 2-3. In its response to OCRE interrogatory 1-19, Staff states that "(n)either  ;

the cost effectiveness nor the environmental implications of hypothetical forms of clam control are at issue in this proceeding." Please explain and provide factual bases for that statement. Also, interpret the sig-nificance of the following portion of Issue 7: "...and (Applicant) has not demonstrated how it could adequately cope with these clams should they be present." Order of July 28, 1981 at 84 3 Statement of Purpose f The purpose of the foregoing interrogatories is to clarify the scope of Issue '7, ascertain the factual bases upon which the IEC Staff expects to found its support of an operating license with regard to Issue 7, and to further pre- ,

pare OCRE for the offering of evidence on this issue.

Respectfully submitted , f M

Robert Alexander OCRE Interim Representative 2030 Portsmouth St. #2 Ilouston, TX 77098

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CERTIFICATE OF SERVICE This is to certify that cc pies of OCRE First Set of Interrogatories to Applicant and OCRE 'Second. Set of Interrogatories to Staff have been served upon the following persons by deposit, postage prepaid, in the United States mail this 3 0 th day of January, 1902 C

Robert Ale::ander Y--40 SERVICE LIST Peter B. Bloch, Chairman Atomic Safety & Licensing Board U.S. Iluclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Klein j','~~

Atomic Safety & Licensing Board U.S. Iluclear Regulatory Commission Washington, D.C. 20555 82 fe -3 P3:0';

Frederick J. Shon Atomic Safety & Licensing Board ,. g . - _

U.S. !!uclear Regulatory Commission hh;.'f i;..} , -e Washington, D.C. 20555 * "

Docketing and Service Section Office of the Secretary U.S. I!uclear Regulatory Commission Washington, D.C. 20555 Charles A. Barth, Esq. -

Office of the Executive Legal Director U.S. Iluclear Regulatory Commission Washington, D.C. 20555 Jay Silberg, Esq.

1800 M Street, II.W.

Uashington, D.C. 20036 l

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