ML20055B911

Request for Admissions Re Issue 4.Proof of Svc Encl

ML20055B911
Person / Time
Site:	Perry
Issue date:	07/21/1982
From:	Wilt D SUNFLOWER ALLIANCE, WILT, D.D.
To:	CLEVELAND ELECTRIC ILLUMINATING CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8207230543
Download: ML20055B911 (5)

Text

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D MIFh0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION %fy ..,.y E

4 I Before the Atomic Safety and Licensing Board U r

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In the Matter of )

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

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

SUNFLOWER ALLIANCE INC. et al.

REQUEST TO APPLICANT AND STAFF FOR ADMISSIONS CONCERNING ISSUE 4 Pursuant to 10 CFR 2.742, Intervenor Sunflower Alliance Inc., et al. requests admission by Applicant and NRC Staff, separately, of the truth of each of the following matters of fact concerning Issue #4 in th'.s proceeding. As provided by 10 CFR 2.742(b), each admission shall be deemed made unless Applicant or Staff within 10 days serves on Sunflower Alliance either (1) a sworn statement denying specifically each_ matter of fact, or why it can be truthfully neither admitted nor: denied; or (2) written objections on the ground that these matters are irrelevant, privileged, or otherwise improper.

1. The ECCS evaluation model for the Perry Nuclear Power Plant has as a fundamental assumption the adequacy of core spray flow and core spray distribution for the LOCA spectrum considered.

2. Experimental data from both the European tests which led to 8207230543 820721 PDR ADOCK 05000440 PDR OPjI O,jf G

the development of unresolved safety issue A-16 and recent tests in Japan indicate that core spray flow and core spray distribution may be inadequate in BWHs.

3. Appendix K to 10 CFR Part 50 mandates confirmation of ECCS evaluation models with appropriate experimental data.

4. BWR ECCS core spray distribution is influenced by a variety of factors, including system pressure, temperature, and steam flow rate, and may involve core-wide phenomena such as vortex, swirling, redistribution, and 2-phase froth buildup.

5. Core-wide phenomena such as vortex, swirling, redistribution, and 2-phase froth buildup would not be discovered without actual full-scale, multi-nozzle experiments in steam at pressures typical of tnose present in the BWR upper plenum following a LOCA.

6. The 30 0 sector steam test methodology as described in NEDO-24712 cannot duplicate actual conditions present in the core following a LOCA and thus cannot provide experimental cata on core-wide phenomena such as vortex, swirling, re-distribution, and 2-phase froth buildup.

7. The 30 sector steam test methodology as described in NEDO-24712 cannot represent realistic core conditions because spray distribution in the center 2 feet of the core is affected by both sectcr size and the influence of the sector walls.

. 8. Since the center core region is farthest from the spray nozzles, this region would be the most adversely affected by steam pressure effects on core spray distribution.

9. Because the test facility cannot simulate steam flow in the oypass region, the 300 sector steam test methodology as described in NEDO-24712 cannot produce meaningful data for steam flow rates exceeding 20,000 lb/hr.

10. Steam flow rates exceeding 20,000 lb/hr are encountered during accident conditions.

11. The 30 sector steam test methodology as described in NEDO-24712 has not adequately investigated the variation of core spray distribution with pressure due to the limited range of pressures tested (29.5 psia, 44.1 psia, and 73.5 psia).

12. Pressures far in excess of the highest pressure tested (73.5 psia) are encountered during accident conditions.

13. The 300 sector steam test methodology as described in NEDO-24712 cannot investigate any possible effects on core spray distribution due to non-condensible gases or to varying gas temperatures.

14. Non-condensible gases and widely varying gas temperatures may oc present during accident conditions.

15. The results obtained from the 300 sector steam test as described in NEDO-24712 have not been applied to each different reactor size and design for which the full-reactor-

core, pos t -LO CA spray distribution is to be detcrmined (as required by the February 3, 1978 letter from Eisenhut and Moss, NRC, to G. Sherwood, GE).

16. Due to a severe funding shortaEe for the SSTF program, the application / evaluation described abe,, mu7 r ever be accomplished.

17. Points of concern identitled at p. 5 of the NRC's Topical heport Evaluation for UEDO-24712, portaining to the large uncertainty bands on the SSTP data and variation with steam flow and pressure, have not been resolved.

16. Tne assumption that thermodynamic and hydrodynamic effects on BPIR core spray distribution in steam are separable is based on engineering judgement.

19. Acceptance of the 30 sector steam test methodoloC7 13 based on engineering judgement.

NOTE: The following matters of fact pertain to the NRC Staff only.

20. The NhC's vluw that the continued operation of licensed GE plants (and the issuance of OLs and cps) will not present undue risk to the public health and safety while the core spray distribution issue is being investigated is based on engineering judgement.

21. The NRC never intended to make an objective determination on the safety of the continued operation or licensing of

GE plants due to the ECCS core spray distribution problem, as evidenced by tne following statement (from TAP A-16, liUhEG-0371) :

If such concerns reEurding safety of continued plant operation are found, it might occome necessary to grant exemption to certain of the requirements of 10 CFR 50.46 if plant operation is to continue while the Plan is completed.

Respectfully submitted, f

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Danj'el'D. Wilt, Edg.

Attprney for Sunflower Alliance Inc, et al P.O. Box 08159 Cleveland, Ohio 44108 (216) 249-8777 PROOF OF SERVICE This is to certify that a copy of this Request for Admissions on Issue 4 has been sent to all persons on the Service List on this day of July, 1982.

Respectfully submitted, A4 / b pnielD. Wilt,lEsq.

Attorney for Sunflower Alliance Inc, et al

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