ML20054B779
| ML20054B779 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/15/1982 |
| From: | Lewis S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | OHIO CITIZENS FOR RESPONSIBLE ENERGY, SUNFLOWER ALLIANCE |
| Shared Package | |
| ML20054B776 | List: |
| References | |
| NUDOCS 8204190190 | |
| Download: ML20054B779 (6) | |
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04/15/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CLEVELAND ELECTRIC ILLUMINATING Docket Nos. 50-440 COMPANY, et al.
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50-441
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(Operating License)
(Perry Nuclear Power Plant
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Units 1 and 2)
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NRC STAFF'S FIRST SET OF INTERR0GATORIES TO INTERVENORS OHI0 CITIZENS FOR RESPONSIBLE ENERGY AND SUNFLOWER ALLIANCE In accordance with the Licensing Board's Memorandum and Order of September 9,1981,(LBP-81-35,14NRC682)theseinterrogatoriesare being served upon Ohio Citizens for Responsible Energy (0CRE) as lead intervenor on Issue No. 5 (Scram Discharge Volume Pipe Break) and upon Sunflower Alliance (" Sunflower") as the other participating intervenor on that issue.
See LBP-81-24, 14 NRC 175, at 217 (1981). As indicated by the Licensing Board, OCRE should coordinate the responses to this discovery.
If Sunflower simply adopts 0CRE's response, it may so indicate in writing. Otherwise, we would expect Sunflower to file separate substantive responses.
Copies of the documents referenced in these interrogatories (NE00-24342 and NUREG-0803) are enclosed.
The interrogatories submitted herein are filed pursuant to 10 C.F.R.
l 2.740b, which requires that the interrogatories be answered separately and fully in writing under oath or affirmation, within 14 days after service.
/ M SIGRATED oprap7ggg; DOCK O hhokko D
PDR g
. s INTERR0GATORIES Issue No. 5 (Scram Discharge Volume Pipe Break)
Interrogatory la Does OCRE (Sunflower) agree with the conclusion in NUREG-0803 (at 2.2.1) that BWR 6/ Mark III containment designs (e.g., Perry) fulfill the requirement of 10 C.F.R. Part 50, Appendix A, GDC 35?
Interrogatory lb If the answer to the preceding question is anything other than an unqualified yes, specify the bases for your answer.
Interrogatory 2a Assuming that the Perry design fulfills the requirements of 10 C.F.R. Part 50, Appendix A, GDC 35, does 0CRE (Sunflower) contend that the Perry design nevertheless provides insufficient assurance of adequate core cooling in the event of Scram Discharge Volune pipe breaks?
Interrogatory 2b If your answer to Interrogatory 2a is other than an unqualified no, specify the bases for your answer and any NRC criteria not met by the Perry facility insofar as SDV pipe breaks are concerned.
Interrogatory 3a Does 0CRE (Sunflower) agree with the conclusion of NED0-24342, at A-13, that "the ECCS pumps in the Mark III plant cannot be affected by the SDV rupture...."?
Interrogatory 3b If your answer is anything other than an unqualified yes, specify the bases for your answer.
Interrogatory 4a Do you agree that any break in the Scran Discharge Volume piping is bounded by other small break LOCA's analyzed for determining compliance with 10 C.F.R. 9 50.46. NED0-24342, Section 8.5; NUREG-0803, Section 2.2.1.
Interrogatory 4b If your answer is other than an unqualified yes, specify the bases for your answer.
Respectfully submitted, Stephen H. Lewis Counsel for NRC Staff Dated at Bethesda, Maryland this 15th dry of April,1982 l
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o 04/15/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CLEVELAND ELECTRIC ILLUMINATING
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Docket Nos. 50-440 COMPANY, ET AL.
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50-441
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(Perry Nuclear Power Plant,
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Unit 1 and 2)
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NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter.
In accordance with 10 C.F.R. % 2.713(a), the following information is provided:
Name:
Stephen H. Lewis Address:
U.S. Nuclear Regulatory Comission Office of the Executive Legal Director Washington, DC 20555 Telephone Number:
(301)492-8655 Admissions:
Supreme Judicial Court of Massachusetts District of Columbia Court of Appeals United States Supreme Court Name of Party:
NRC Staff Respectfully submitted, bN Stephen H. Lewis Counsel for NRC Staff Dated in Bethesda, Maryland this 15th day of April,1982 I
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CLEVELAND ELECTRIC ILLUMINATING
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Docket Nos. 50-440 OL COMPANY, ET AL.
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50-441 OL (Perry Nuclear Power Plant, Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S FIRST SET OF INTERR0GATORIES TO INTERVEN0RS OHI0 CITIZENS FOR RESPONSIBLE ENERGY AND SUNFLOWER ALLIANCE" and " NOTICE OF APPEARANCE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 15th day of
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April, 1982:
- Peter B. Bloch, Esq., Chainnan Donald T. Ezzone, Esq.
Administrative Judge Assistant Prosecuting Attorney Atomic Safety and Licensing Board 105 Main Street U.S. Nuclear Regulatory Coninission Lake County Administration Center Washington, D.C.
20555 Painesville, Ohio 44077
- Dr. Jerry R. Kline Tod J. Kenney Administrative Judge 228 South College Apt. A Atomic Safety and Licensing Board Bowling Green, Ohio 43402 U.S. Nuclear Regulatory Connission Washington, D.C.
20555 Daniel D. Wilt, Esq.
Wegman, Hesiler & Vanderberg
- Mr. Frederick J. Shon 7301 Chippewa Road, Suite 102 Administrative Judge Brecksville, Ohio 44141 Atomic Safety and Licensing Board l
U.S. Nuclear Regulatory Coninission Jeff Alexander Washington, D.C.
20555 920 Wilmir.gton Avenue Dayton, Ohio 45420 Jay Silberg, Esq.
l Shaw, Pittman, Potts and Trowbridge Terry Lodge, Esq.
1800 M Street, N.W.
Attorney for Intervenors l
Washington, D.C.
20036 915 Spitzer Building Toledo, Ohio 43604 1
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- Atomic Safety and Licensing Board Robert Alexander U.S. Nuclear Regulatory Commission 2030 Poartsmouth St., #2 Washington, D.C.
20555 Houston, Texas 77098
- Atomic Safety and Licensing Appeal Board Panel John G. Cardinal, Esq.
U.S. Nuclear Regulatory Commission Prosecuting Attorney Washington, D.C.
20555 Ashtabula County Courthouse Jefferson, Ohio 44047
- Docketing and Service Section Office of the Secretary Susan Hiatt U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D.C.
20555 Mentor, Ohio 44060 h ~h4Ah-2 1
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Stephen H. Lewis Counsel for NRC Staff 6
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