ML20053D103

Answer to 820224 Request for Production of Documents. Certificate of Svc Encl

ML20053D103
Person / Time
Site:	Perry
Issue date:	05/28/1982
From:	Willmore R CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	SUNFLOWER ALLIANCE
References
NUDOCS 8206040085
Download: ML20053D103 (16)

Text

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r d [ f l' TMay 28, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC )

ILLUMINATING COMPANY, et al. ) Docket Nos. 50-440

) 50-441 (Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' ANSWER TO SUNFLOWER'S REQUEST FOR PRODUCTION OF DOCUMENTS Applicants for their answers to Request For Production Of Documents of Sunflower Alliance, Inc., et al. (" Sunflower"),

dated February 24, 1982, state as follows:

All documents to be supplied to Sunflower for inspection will be produced at Perry Nuclear Power Plant ("PNPP").

Arrangements to examine the documents can be made by contacting Mr. Ronald Wiley of The Cleveland Electric Illuminating Company at (216) 259-3737. Applicants will provide copies of any of the produced documents, or port. ions thereof, which Sunflower requests, at Applicants' cost of duplication. Arrangements for obtaining copies can be made with Mr. Wiley.

3 8206040085 820528 PDR 0 ADOCK 05000440 f/8 l

PDR

In compliance with the Licensing Board's Special Prehearing Conference Memorandum and Order, LBP-81-24, 14 N.R.C. 175, 230-31 (July 28, 1981), Applicants' counsel conferred by telephone with Mr. Daniel Wilt, Sunflower's counsel, on March 29, 1982. Also participating in the tele-phone conference were Ms. Sue Hiatt, in her capacity as advisor to Mr. Wilt, and Mr. Wiley. The participants in the conference discussed as to each document request Applicants' objections and requests for clarification. As to several of the document requests, Mr. Wilt told Applicants' counsel that he would provide clarification later. Clarification was provided by telephone conference of May 27, 1982. As indicated below, Mr. Wilt has informed Applicants' counsel as to several of the document requests that Sunflower no longer seeks production.

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1. Perry Nuclear Power Plant Operations Manual

Response

The PNPP Operations Manual still is being drafted. None of the portions of the Operations Manual relevant to the admitted contentions has received final review and approval.

As relevant portions of the Operations Manual are completed and approved, Applicants will supply those portions for inspection.

2. Perry Nuclear Power Plant Quality Assurance Manual

Response

The PNPP Quality Assurance Manual will be supplied for

inspection at PNPP.

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3. GE, ATWS, Mitigation Report, NEDD[ sic]-24222

Response

The document (NEDO-24222) will be supplied for inspection at PNPP.

4. Radiation Protection Manual, PNPP (referenced at p. 1-8 of Vol. 13A (Appendix) of FSA:4)

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Response

Applicants object to the document request as irrevelant and beyond the scope of any of the admitted contentions. See 10 C.F.R. S 2.740(b)(1) (discovery shall relate only to those matters in controversy identified in prehearing order).

Sunflower, through Ms. Hiatt, informed Applicants that it wishes to inspect the PNPP Radiation Protection Manual for the purpose of assessing on-site worker protection. As Applicants informed Sunflower, on-site worker protection from radiation exposure is not witnin the scope of Issue #1 (emergency evacuation planning) or any of the other admitted contentions.

5. The General Electric documant [ sic] known as the Reed Report (GE Nuclear Reactor Study)

Response

As agreed between Applicants' counsel and Mr. Wilt, the relevant portion of the document will be sent to Mr. Wilt under the terms of the Protective Agreement between Sunflower and General Electric Company as soon as Sunflower returns an executed copy of the Protective Agreement to General Electric Company. The Protective Agreement is being sent to Mr. Wilt under separate cover.

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6. '

. roduce all documents Applicant has relative to the 30' sector steam test.

Response

The documents will be supplied for inspection at PNPP.

NEDO-24712 (" Core Spray Design Methodology Confirmation Tests," t August, 1979), and the two NRC letters approving NEDO-24712 already have been supplied to Sunflower with " Applicants  !

Answers to Sunflower Alliance, Inc. First Round Discovery Requests," filed February 5, 1982.

7. Produce the ECCS evaluation model f ro[ sic] General Electric BWR/6 designs with 8x8 fuel array and Mark III containment.

Response

Applicants object to the document request as irrelevant and beyond the scope of any of the admitted contentions. See 10 C.F.R. S 2.740(b)(1).

8. Produce Applicant's QA Manual in effect immediately prior to the February 1978 stop work order and produce all changes in Applicant's QA Manual adopted since the February 1978 stop work order.

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Response

The requested documents will be supplied for inspection at l

PNPP.

9. Produce a copy of GE documents listed hereinafter:

JL) NEDD[ sic]-10846 "BWR Core Spray Distribution" B) NEDD[ sic]-10801 "Modeling the BWR/6 LOCA" C) NEDD[ sic]-20231 ECC Tests of an Internally Pressurized ZIRCALLORY [ sic]

Clad, 8x8 Simulated Fuel Bundle" D) NEDD[ sic]-20533 "GE Mark III Pressure Suppression Containment System Analytical Model" E) APED-5286 " Design Bases for Critical Heat Flux Conditions in BWR's" F) NEDD[ sic]-10958-A "GE BWR Thermal Analysis Bases (GE TAB): Data Correlation and Design Application G) NEDD(sic]-20566 "GE LOCA Analysis in Accordance with 10 CFR, Part 50, Appendix K" l

Response

Applicants object to document requests 9(B), (C), (D), (E) and (F) as irrelevant and beyond the scope of any of the l admitted contentions. See 10 C.F.R. S 2.740(b)(1). NEDO-10846 and NEDO-20566 will be supplied for inspection at PNPP.

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It appears to Applicants that Sunflower has simply requested all General Electric documents cited in sections 1.5.1.3 (" Core Spray and Core Flooding Heat Transfer Effec-tiveness"), 1.5.1.4 (" Verification of Pressure Suppression Design"), and 1.5.1.5 (" Critical Heat Flux Testing") of Applicants' FSAR. While these documents may be of interest to Sunflower, the mere fact that they are cited in those FSAR sections does not make them relevant to the 30' sector steam tests conducted by General Electric or to any of the other admitted contentions.

As indicated in the FSAR, NEDO-10801 and NEDO-20231 deal with core flood heat transfer effectiveness, and not with tests of the core spray distribution. NEDO-20533 documents the analytical methods used to simulate the short-term transient response of the Mark III containment to a loss-of-coolant-c accident, a matter irrelevant to the 30* sector steam tests.

APED-5286 and NEDO-10958-A (superseding APED-5286) deal with critical heat flux testing, also irrelevant to the 30' sector l steam tests. The documents are not within the scope of any of I

the other admitted contentions.

10. Produce any and all documents pertaining to ECCS eval-uation models, testing, and operation history of BWR's.

Response

Applicants will supply for inspection at PNPP all docu-ments within the scope of Issue #4 (that is, all documents pertaining to the 30' sector steam tests conducted by General Electric). As such, Applicants construe the document request as a restatement of document request #6, supra. To the extent that Sunflower requests documents not related to the 30' sector steam tests, Applicants object to the discovery request as irrelevant and beyond the scope of any of the admitted conten-tions. See 10 C.F.R. S 2.740(b)(1).

11. Produce BEIR III report for the linear quadratic dose (effect relationship [LG-L designation]).

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Response

l l The requested document will be supplied for inspection at t PNPP. .

12. Produce RERF Report, TR-10-76, 1976.

Response

Sunflower has withdrawn the document request.

13. Produce Guide for determining the effects of ionizing radiation on insulating materials, Part I: Introductory Document, Publication 544-1, First Edition, IEC, 1977.

Response

Sunficwer has withdrawn the document request.

14. Produce Control of Combustible Gas Concentration Containment Following LOCA, Safety Guide 7, 3/10/71.

Response

The requested document will be supplied for inspection at PNPP.

I 15. Produce NUREG-0123.

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Response

l Sunflower already has obtained the requested document from the NRC. See Letter from James H. Thessin to Daniel D. Wilt, dated May 20, 1982.

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16. Produce documents used as a basis for NUREG-0696 and l NUREG-0814.

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f Response:

Sunflower has withdrawn the document request.

17. Produce Regulatory Guides 1.97 Revision 2 and 1.23.

Response

Sunflower has withdrawn the document request.

18. Produce ICRP Report 2 (cited in Section 5.5.2.6 [ sic] of App.-13A of FSAR).

Response

The requested document will be supplied for inspection at PNPP. For purposes of clarification, the document is cited in S 5.5.2.4 of Appendix 13A.

19. Produce Regulatory Guide 1.109 (cited in Fig. 6-2 of App'.

13A of FSAR).

Response

The requested document will be supplied for inspection at PNPP.

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20. Produce NUREG-0772 " technical Basis for Estimating Fission Product Behavior During Light-Water Reactor Accidents" March 6, 1981.

1 Response: 1 l

Sunflower has withdrawn the document request.

21. Produce Commission Action Paper SECY-80-257/257A, May 20, .

1980 "NRC Interim Policy on Stockpiling Potassium Iodide for use during a Reactor Accident" and any final or updated policy related to this .

Response

Applicants do not have the requested document.

22. Produce NUREG-0649 " Task Action Plan for Unresolved Safety Issues Relative to Nuclear Power Plants" Feb. 1980.

Response

Applicants do not have the requested document.

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23. Produce NUREG/CR-1558 "BER Refill-Reflood Program Task

, 4.2--Core Spray Distribution Task Plan" Nov. 1980.

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i Response:

Applicants do not have the requested document.

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24. Produce NUREG/CR-1745 " Analysis of Techniques for Estimating Evacuation Times for Emergency Planning Zones" Nov.,

1980.

l Response: l Sunflower has withdrawn the document request. >

25. Produce NUREG-0626 " Generic Evaluation of Feedwater 1 Transients and Small Break form of Coolant Accidents in GE Designed Operating Plants and Near Term Operating License l Applications" Jan. 1980.

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Response

Sunflower has withdrawn the document request.

26. Produce EPA-520/1-75-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, Sept.

1978.

Response

The requested document will be supplied for inspection at PNPP.

27. Produce Respiratory Protective Devices Manual, Amenion Industrial Hygiene Association, 1963, pages 123-126.

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Response

The requested document (pp. 323-26) will be supplied for inspection at PNPP.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By:

Jay E. Silberg, P.C.

Robert L. Willmore Counsel for Applicants 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: May 28, 1982 i

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.i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, et al. ) , 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

~

CERTIFICATE OF SERVICE *,

This is to cert'ify that copies of the foregoing " Applicants' Answer To Sunflower's Request For Production Of Documents", were served by deposit in the U.S. Mail, First Class f postage prepaid, this 28th day of May, 1982, to all those on the attached Service '

List. 9 l

Robert' L. Willmore Dated: May 28, 1982 ,

t J.

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b, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .

Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC

) Docket Nos. 50-440

' ILLUMINATING COMPANY, e_t _a_l.

) 50-4 l

)

(Perry Nuclear Power Plant, )

Units 1 and 2 ) .

SERVICE LIST Peter B. Bloch, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 .

Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Frederick J. Shon James H. Thessin, Esquire Atomic Safety and Licensing Board Office of the Executive

_U.S. Nuclear Regulatory Commission Legal Director U.S. Nuclear Regulatory Commission

_ Washingp,n,o D.C. 20555 Washington, D.C. 20555 Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt Appeal Board OCRE Interim Representative U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D.C. 20555 Mentor, Ohio 44060 Dr. John H. Buck Daniel D. Wilt, Esquire Atomic Safety and Licensing Wegman, Hessler & Vanderburg Appeal Board Suite 102 U.S. Nuclear Regulatory Commission 7301 Chippewa Road Washington, D.C. 20555 Brecksville, Ohio 44141 Gary J. Edles, Esquire Terry Lodge, Esquire Atomic Safety and Licensing 915 Spitzer Building Appeal Board Toledo, Ohio 43604 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Tod J. Kenney 228 South College, Apt. A Atomic Safety and Licensing Bowling Green, Ohio 43402 Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

The Cleveland Electric -

Illuminating Company, et al.

Service List Page Two Donald.T. Ezzone, Esquire Assistant Prosecuting Attorney Lake County Administration Center 105 Center Street Painesville, Ohio 44077 -

John G. Cardinal, Esquire Prosecuting Attorney Ashtabula County Courthouse ~,

Jefferson, Ohio 44047 e

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