ML20052G807

Response to First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20052G807
Person / Time
Site:	Perry
Issue date:	05/10/1982
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	CLEVELAND ELECTRIC ILLUMINATING CO.
References
NUDOCS 8205190014
Download: ML20052G807 (6)

Text

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.W s mrED May 10, 1982 UNITED STATES OF AMERICA - ,^_._.

NUCLEAR REGULATORY COMMISSION

.F' Before the Atcmic Safety and Licensing Board

,Of D ' 17 P156 In the Matter of )

) . ..

CLEVELAND ELECTRIC ILLUMINATING ) Docke t '-Nos . 50-440 COMPANY, Et A1. . ) 50-441

) (Operating License)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

)

OCRE RESPONSE TO NRC STAFF's FIRST SET OF INTERROGATORIES TO INTERVENORS Intervenor Ohio Citizens for Responsible Energy ("0CRE")

hereby files its response to the NRC Staff's First Set of Interrogatories to Intervenors, dated April 15, 1982~

To conserve its scarce resources by reducing duplication and postage costs, OCRE will not reproduce here the inter-rogatories propounded it. OCHE will respond to those in-terrogatories in the same sequence and numeration encountered.

Responses Issue No. 5 (Scram Discharge Volume Pipe Break)

Interrogatory la OCRE cannot now agree with the conclusion in NUREG-0803 at 2.2.1 that BWR 6/ Mark III designs fulfill the requirement of 10 CFR Part 50, Appendix A, GDC 35.

Interrogatory lb In reaching the conclusion cited above, the NRC apparently accepted the analysis given in NEDO-24342.

jl By agreement with counsel for Staff, OCRE has not been limited to 14 days in which to respond to said interrogatories.

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f OCRE cannot do so. Since it has only this forum in which to i protect its interests, and this proceeding deals with a *

] specific facility, PNPP, OCRE chooses not to accept.a generic h finding propounded by an agent of the Applicants.

f The HEDO-24342 analysis is based upon a " typical 218-t l BWR/6" (p. 8.5)'. Perry is a 238-BWR/6. In addition, the Perry design may differ from the standard or typical design.

l OCRE is seeking confirmation of any design differences through discovery. Until such discovery is completed to its satisfaction, t

OCRE cannot agree or disagree with the findings of NEDO-24342 or NUREG-0803. OCRE reserves the right to amend or supplement these responses at such time.

OCRE also notes with interest the disclaimer at page 11 of NED0-24342: "(n)either General Electric Company nor any of the contributors to this document makes any representation or warranty (express or implied) as to the completeness, accuracy,1 or usefulness of the information contained in this document . . ."

OChE would obviously prefer to obtain information through discovery, e.g., interrogatories which must be answered under oath or affirmation (10 CFR 2.740b). rather than relying on a document in which its authors carefully refuse to affirm the truthfulness of the information contained therein.

Interrogatory 2a GDC 35 of Appendix A to 10 CFR Part 50 essentially requires the ECCS design to function following a single failure. Thus, this Interrogatory assumes that the SDV pipe break scenario described in NUhEG-0785 cannot, due to the design of Perry, disable the ECCS. Given this assumption, OCRE does - contend that an SDV pipe break may pose a challenEe

-3 to adequate core cooling and the maintenance.of coolant in-ventory, depending on the specifics of the Perry SDV design.

Interrogatory 2b For the reasons stated in the answer to Interrogatory lb, OCRE at this time must rely upon the findings of NUREG-0785. As stated therein (pp. 3-8), a pipe break in the SDV may be difficult to isolate. (NED0-24342 at

p. 8-5 indicates that for Mark III plants the environmental conditions associated with such a break would be especially severe, thus delaying containment entry and subsequent break isolation.) NUREG-0785 also states that the water lost through the break would not be available for return to the reactor.

OCRE therefore questions whether an SDV pipe break, which is equivalent to a break in the bottom of the reactor vessel, and may not be isolated for some time, could deplete the co61 ant inventory and sources of makeup water.

OCRE contends (again relying on the analysis in NUREG-0785' until further discovery produces reason to do otherwise) that 4

the Perry facility may not meet the following GeneralsDesign Criteria of Appendix A to 10 CFR Part 50:

GDC 14: As the SDV is part of the reactor coolant pressure boundary, this criterion (and those below) applies. OCRE questions whether the SDV has been designed, fabricated, erected, and tested so as to have an extremely low probability of-leakage, failure, and rupture. See, for example, PNO-81-109 (describing an act of vandalism in the SDV piping), the March 12, 1982 letter from D. Davidson, CEI to J. Keppler, NRC Region III describing a deficiency in the stress analysis for the CRD

. hydraulic system, and the March 29, 1982-letter from A. Schwencer,

NRC to D. Davidson, CEI describing a potential safety problem resulting from " fast scram" hydrodynamic loads on CRD syste=s.

GDC.30, 31, and 32 are similar and thus apply as wel'l.

GDC 33 requires the plant to have a reactor coolant makeup system to protect against coolant loss from small breaks in the reactor coolant pressure boundary. As described above and in NUREG-0785 at p. 15, the loss of water from the SDV pipe break could deplete the ECCS inventory.

GDC 54 and 55 deal with piping systems and the reactor coolant pressure boundary penetrating containment. If the Perry design is similar to that studied in NUREG-0785, the PNPP SDV system violates these criteria in that redundant isolation is not provided.

Interrogatory 3a OCHE cannot agree with this conclusion at this time. Further discovery is necessary before OCRE can judge the merits of NED0-24342.

Interrogatory 3b See response to InterroEatories 1b and 2b.

Interrogatory 4a OCRE cannot agree with this statement at this time.

Interrogatory 4b See response to Interrogatories lb, 2a, and 2b.

Respectfully submitted, Susan L. Hiatt OCRE Interim Representative 8275 Munson Rd.

Mentor, OH 44060 (216) 255-3158 g -e w se e W Ae h N * "' " "

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AFFIDAVIT I, Susan L. Hiatt, having been duly sworn depose and say that the facts set forth in the forescing OCRE RESPONSE TO '

NRC STAFF'S FIRST SET OF INTERROGATORIES TO INTERVENORS are true to the best of my knowledge, irformation, anc .

belief.

A E ,

SusEn L. Hiatt Sworn to and subscribed before me this /O h/

day of May, 1982.

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Netary F lic MARLEf FORD DGER, Attorney At IM h:tary Public' State of Ohio

1. 2 C0 .?.ission has no espiration dale.

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CERTIFICATE OF SERVICE 6

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This is to certify that copies of the foregoing OCRE RESPONSE TO NRC STAFF'S FIRST SET.0F INTERROGATORIES TO INTERVENORS have been served by, deposit in the U.S. Mail, first class, o tage prepaid to those on the service list if below this / day of May, 1982.

I Susan L. Hiatt a

! ' SERVICE LIST Peter B. Bloch, Chairman Daniel.D. Wilt, Esq.

! Atomic Safety and Licensing Board 7301 Chippewa Rd.

U . S'. Nuclear Regulatory Comm'n Brecksville, OH 44141 Washington, D.C. 20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D. C. 20555 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 . ' Nu clear Regula tory Comm ' n W&shington, D.C. 20555 James Thessin, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Jay S11 berg, 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 f.-

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