ML20063A203

Answer to Second Set of Interrogatories.Certificate of Svc Encl

ML20063A203
Person / Time
Site:	Perry
Issue date:	08/20/1982
From:	Willmore R CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	SUNFLOWER ALLIANCE
References
NUDOCS 8208240235
Download: ML20063A203 (28)

Text

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August 20, 1982,. ._ _ ..., _

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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 1

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' ANSWER TO SUNFLOWER ALLIANCE, INC.

ET AL. SECOND SET OF INTERROGATORIES TO APPLICANTS Applicants for their answers to Sunflower Alliance, Inc.

I i et al. (" Sunflower") Second Set of Interrogatories to Applicants, dated April 30, 1982, state as follows:

i Applicants hereby respond to the interrogatories directed f

to Issue #6. All documents supplied to Sunflower for examina-

tion will be produced at Perry Nuclear Power Plant ("PNPP").

Arrangements to examine the documents can be made by contacting Mr. Ron Wiley of The Cleveland Electric Illuminating Company at (216)-259-3767. Applicants will provide copies of any of the I

produced documents, or portions thereof, which Sunflower requests, at Applicants' cost of duplication. Arrangements for obtaining copies can be made with Mr. Wiley.

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Applicants' counsel conferred by telephone with Mr. Daniel j D. Wilt, Sunflower's counsel, on August 13, 1982, with regard to Applicants' objections. Applicants' counsel explained to Mr. Wilt that Applicants would object to.certain of the interrogatories on the basis of relevancy for.the reasons given in Applicants' answers to Sunflower's First Set of Interrog-atories to Applicants, as further explicated in " Applicants' Substantive Answer To ' Sunflower Alliance, Inc. et al. Motion To Applicant To Compel Discovery'" (July 23, 1982), and as discussed in detail during the August 13, 1982, prehearing telephone conference conducted by the Licensing Board.

Specifically, Applicants' counsel told Mr. Wilt that Applicants would object to those interrogatories that are not directed to whether Applicants should automate their Standby Liquid Control System ("SLCS"). No agreement berween Applicants' counsel and Mr. Wilt was reached as to the scope of Issue #6.

RESPONSES

1. Produce every document in possession of Applicant pertain-ing to SWRs that was used in the preparation of or cited in NUREG-0460, Volumes 1, 2, 3, and 4. (All those listed in Bibliography or References) 1 l

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Response

Issue #6 is concerned with whether Applicants should automate their SLCS. The Issue is not concerned with the possibility or consequen,ces of ATWS e' vents generally, or with any systems other than SLCS which may be used to mitigate ATWS events. Applicants, therefore, object to the Interrogatory as irrelevant and beyond the scope of Issue #6 to,-the extent that the Interrogatory is directed at documents unrelated to SLCS initiation. See 10 C.F.R. S 2.740(b)(1); " Applicants' Substantive Answer To ' Sunflower Alliance, Inc. et al. Motion To Applicant To Compel Discovery,'" filed July 23, 1982, at 17-21. Documents related to SLCS initiation will be supplied for examination at PNPP.

2. Produce any and all documents pertaining to ATWS in BWRs.

Response

Applic' ants will supply for examination only those docu-ments related to SLCS initiation. See Response to Interrogatory #1, surra.

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j 3. Produce all documents, correspondence, transcripts, or i minutes prepared since the publication of NUREG-0460, Volume 4

! (March 1980) pertaining to ATWS in BWRs, including any GE i documents.

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Response

Applicants will supply for examination only those docu-ments related to SLCS initiation. See Response to Interrogatory #1, supra. -

4. One of the modifications included in Alternative 4A-for GE EWRs is modification of the scram discharge volume. Describe .

this modification in detail for the Perry Plant BWR/6 model.

Has this been done at Perry? .

Response

Issue #6 is not concerned with modifications to the scram

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discharge volume, or any ATWS' mitigation systems other than SLCS. Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #6. See 10 C.F.R. 5 2.740(b)(1).

5. Where does the PNPP design presently stand in regard to the alternatives listed in NUREG-0460, Vol. 4? E.g., does the current plant design implement Alternative _2A, 3 A, or 4A?

Responre:

1 Applicants' current design for the SLCS implements

! Alternative 2A of NUREG-0460. However, as noted in the attached letter by Dalwyn R. Davidson to A. Schwencer, dated

, August 13, 1082, Applicants' SLCS design will have the capabil-ity of implementing Alternative 3A.

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e Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #6 to the extent that it is directed at any ATWS mitigation systems other.than SLCS. See Responses to Interrogatories #1 and 94, supra. -

6. What constitutes scram failure in=a BWR/6 such as Perry?

E.g., describe the combination of the following failures which .

will result in the loss of control of reactivi,ty and failure to attain hot shutdown: insufficient rod insertion speed, percent of length withdrawn which results in" failure, number and location of failed rods which results in scram failure.

Response

Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #6. See Responses to Interrogatories

1. 1 and #4, supra.

7. Describe in detail, along with their frequency of occurrence for each year of plant operation, any and all transients capable of initiating reactor scram in a BWR/6.

Response

i Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #6. See Responses to Interrogatories j #1 and #4, supra.

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8. Describe all scram system failures, including common-mode

failures, capable of producing ATWS in a BWR/6.*

l Response: -

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Applicants object to the Interrogatory as irrelevant and t

beyond the scope of Issue #6. See Responses to Interrogatories 4 .

1. 1 and #4, suora. .

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9. Describe in detail the Reactor Protection System for the Ferry Plant, including but not limited to the following

the means of initiating and implementing control rod scram, types of sensors and trip signals generated, which parameters are

monitored, and how the scram system is both redundant and diverse, both in equipment and function: name all components of the scram system (both electrical and mechanical) and give the vendors for all components, for all systems and back-ups.

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i l Response:

Issue #6 is concerned with whether Applicants should automate their SLCS. The Issue is not concerned with the Reactor Protection System. Applicants object to the l Interrogatory as i rrelevant and beyond the scope of Issue #6.

l See 10 C.F.R. $ 2.740(b)(1).

10. For each of the transients listed in #7 above (and for any j transient not listed in the response to #7 but included in l Table A.2, Vol. 4 of NUREG-0460),. perform a time-domain analysis, specific to the Perry Plant, assuming that control rod scram does not occur, but that the recirculation pump trip l

does function and the SLCS, as presently designed, is manually I operated. Assume all plant systems to be as currently

! described in the FSAR. Include in the analysis any and all i plant systems and functions affected by ATWS and any conse-

! quences thereof, including but not limited to core integrity, 6- .

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containment integrity, suppression pool effects, reactor internals, ECCS functions, dilution of SLCS boron by EECS, power oscillations, and offsite radiation doses to the public.

Present the analysis in this manner: the transient begins at 9

t=0; list time of occurrence for each major action or conse-quence during the ATWS (e.g., RPT, bLCS activation, containment isolation, and maximum and minimum values of the following parameters to be presente'd graphically) until such time as either the reactor is brought into cold shutdown or core melting occurs. List all assumptions made for operator actions. Present the following parameters graphically as a function of time (use appropriate units and scales): neutron ,

flux, power levels, RPV pressure, steamline pressure, water level in RPV, heat flux, and fuel cladding temperature and radiation doses to public at site bouddary, 5 mile radius, 10 mile, 20 mile and 50 mile radii.

Also perform the analysis as described above the the [ sic)

, following conditions:

(1) As above, only with automatic SLCS.

(2) Full implementation of Alternate 4A.

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Response

Applicants have not conducted a time-domain analysis i

l similar-to that requested by the Interrogatory. Applicants are 1

under no obligation to conduct analyses or tests in response to discovery requests, but only are under an obligation to provide i

information already known to Applicants or in Applicants'

! possession or control. Applicants are aware of two documents i which contain a form of time-domain analysis: General Electric i Company document NEDO-24222 " Assessment of EWR Mitigation of ATWS, Volume I" (February,1981), and General Electric Ccmpany i

document NEDE-25518, " Design Analysis and SAR Inputs for ATWS Performance and Standby Liquid Control System" (December, l i

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1981). NEDO-24222 will be supplied for examination at Perry Nuclear Power Plant. NEDE-25518 is proprietary, and will be sent to Mr. Daniel D. Wilt under the terms of the Protective Agreement signed by Mr. ifilt.

11. According to Section 15.8.1 of FSAR, "the probability of an ATWS has been assumed to be significantly less than the .

probability of a design basis event. Because it is so extre-mely remote, the NRC will require some specific changes to plant hardware rather than treat ATWS' as a design basis event..."

(a) Give the specific numerical probabilities and of a design basis event. How were these probabilities deter-mined?

(b) What is the basis of the assumption that; (ATWS) "is significantly less thar!" p(DBE)? Provide all calculations and supporting documents substantiating this basis.

(c) Define quanti-totively the terms "significantly less than" and " extremely remote".

(d) Describe in detail the " specific changes to plant hardware" that the NRC will require. When will these changes be required?

Response

Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #6. See Responses to Interrogatories

1. 1 and #4, supra.

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12. Answer #9, above, for the Alternate Rod Insertion (ARI)

System.

4 Response: ,

Applicants object to the Interrogatory as irrelevant and i beyond the scope of Issue #6. See Responses to Interrogatories i #1 and #4, supra. .

17 Describe all operator actions required in the event of an ATWS. Upon what information will the operator rely as a basis for these actions? At what time into the ATWS will these actions be taken?

Response

In the event of the occurrence of an ATWS, the operator will monitor the automatic initiation of the backup scram systems and the average power range monitors. Following the automatic initiation of the backup scram systems, if reactor power remains above specified levels or cannot be determined, the operator will manually activate the SLCS within two minutes of the ATWS event.

i j 14. How many transients occurred in each of the years 1978, j 1979, and 1980?

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Response: .

Applicants object to the Interrogatory as irrelevatt and beyond the scope of Issue #6. See Responses to Interrogatories

1. 1 and #4, supra.

15. Does PNPP have the recirculation pump trip initiated by high pressure? What other conditions can initiate the RPT? .

Explain how this feature mitigates the consequ,ences of ATWS:

about what % negative reactivity does the RPT contribute? When was (or will be) the RPT feature inst'alled?

Response

Issue #6 is concerned with whether Applicants should automate their SLCS. The Issue is not concerned with the recirculation pump trip. Applicants thus object to the Interrogatory as irrelevant and beyond the scope of Issue #6.

See 10 C.F.R. S 2.740(b)(1).

16. Show that the RPT hardware conforms with the appropriate standard, below:

(1) If installed before July 1, 1981, the approved Hatch or Monticello designs (supply the appropriate design)

(2) If installed after July 1, 1981, Appendix C of Vol.

3, N'JREG- 04 60.

Response

Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #6. See Response to Interrogatory

1. 15, supra.

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17. Demonstrate that the ARI system meets the criteria of IEEE Standard 279, and that the RPT and SLCS logic meet the criteria "

of Appendix C of Vol. 3, NUREG-0460, i J  !

Response

. Issue #6 is concerned with whether Applicants should-automate their SLCS. The Issue is not concerned with the .  ;

alternate rod insertion system or the, recircul'ation pump trip.

See Responses to Interrogatories #12 and #15, supra. Nor are 4

i the nine criteria identified in. Appendix C of Volume 3 of NUREG-0460 related to whether the SLCS should or should not be i automated. Applicants, therefore, object to the Interrogatory

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i as irrelevant and beyond the scope of Issue #6. See 10 C.F.R. 5 2.740(b)(1).

18. Have the code verification tests for BWRs described on p.

B-3 of Vol. 4, NUREG-0460 been performed? If not, why not, and when will they be performed? If so, what were the results of these tests?

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Response

i Issue #6 is not concerned with the code verification tests '

I l for EWR's described in NUREG-0460, Volume 4. Applicants object l to the Interrogatory as irrelevant and beyond the scope of l Issue #6. See 10 C.F.R. 5 2.740(b)(1).

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19. What parts of the scram system, back-up scram systems, and ATWS mitigation systems depend on electrical pow'er? What is the back-up source of power for these systems in the event of the loss of all off-site power? How quickly is this back-up source available?

Response

The SLCS components which rely on electrical power for .

operation are two positive displacement pumps,'two explosive valves, two motor operated tank shut-off valves, and associated local valves and controls. Should off-site power be lost, backup power from the diesel generators would be available within ten seconds for the operation of this equipment.

20. Describe in detail the manual scram capabilities at PNPP.

What is the sequence of operation? What is the speed of rod insertion? How much time elapses from the initiation of the manual scram until its completion? When is manual scram used.

Response

Issue #6 is concerned with whether Applicants should automate their SLCS. The Issue is not concerned with the

! manual scram capabilities at PNPP. Applicants, therefore, I object to the Interrogatory as irrelevant and beyond the scope l

l of Issue #6. See 10 C.F.R. 5 2.740(b)(1).

l l 21. Describe the effects of power oscillations, such as are described on p. A-67, Vol. 4, NUREG-0460, on fuel and contain-ment integrity and any other affected system at PNPP.

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Response

Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #6. See 10 C.F.R. S 2.740(b)(1);

" Applicants' Substantive Answer To ' Sunflower Alliance, Inc. et al. Motion To Applicant To Compel Discovery,'" filed July 23, 1982, at 20-21.

22. Give a cost estimate for the installation of an automated standby liquid control system at PNPP, Units 1 and 2; provide documentation to support this estimate. Include in the estimate any necessary modifications to other systems, e.g.,

addition of sufficient diesel generator capacity. Also give a cost estimate for the complete implementation of Alternative 4A as described in Vol. 4 of NUREG-0460.

Response

As noted in the attached letter by Dalwyn R. Davidson to A. Schwencer, dated August 13, 1982, Applicants will have the capability of automating their SLCS. The cost of activating this capability once it has been installed is estimated to be less than ten thousand dollars. Because Applicants now are committed to installing the equipment necessary to automate their SLCS, the cost of installing this equipment is not a relevant issue in this proceeding.

Applicants object to the portion of the Interrogatory that is not directed at whether Applicante should automate their SLCS. See Response to Interrogatory #1, supra. In this regard, it should be noted that the SLCS initiation mechanism of Alternative 4A is no different from the initiation mechanism of Alternative 3A, which Applicants will have the capability of implementing. See Response to Interrogatory #5, supra.

23. Give an estimate of the cost and downtime associated with the cleanup of an inadvertant activation of the SLCS. Give the waste storage tank capacity and evaporator capacity; compare these with other BWRs, and indicate how these systems are .

involved in the boron cleanup. ,

Response

The principal cost resulting from an inadvertent activa-tion of the SLCS would be the downtime of approximately one week needed to clean the water. At approximately one and one-half million dollars per day (in 1984 dollars), a week's downtime would cost Applicants approximately ten and one-half million dollars. An indeterminate additional amount of downtime also might be necessary to determine why the SLCS activated inadvertently. The cost of cleaning the water would be approximately'one-half to one million dollars. The capac-ities of the waste storage tanks and the evaporators, and how they are used in the cleanup process, are described in Applicants' Response to Interrogatory #24, infra.

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24. Describe in detail the borcn cleanup procedure used after the activation of the SLCS.

Response: ,

Activation of the SLCS will necessitate cleaning the reactor water to remove the boron pumped into the vessel. This would be accomplished by flushing the vessel with clean water, followed with recirculation of the coolant through the reactor water cleanup system. The water will be processed and stored for reuse in the liquid radwaste system. This system has the following waste storage tanks that can be used to store the water for processing: two waste collector system tanks, with a capacity of 35,000 gallons each; two floor drain collector system tanks, with a capacity of 35,000 gallons each; and, two chemical waste system tanks, with a capacity of 20,000 gallons each. To remove the boron from the water, the water will be passed through one or both of the plant evaporators, each of which have a capacity of 30 gallons per minute. Finally, the water will be processed through a mixed-bed ion exchange demineralizer. The water then can be reused.

25. Define the term "SLC system" as used in Sec. 9.3.5.3 of FSAR. Exactly which components are part of this system? Does the SLCS include the piping and spargers, or only the pumps, storage tank, valves, and logic?

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Response: ,

The SLC System referred to in Section 9.3.5.3 of the FSAR is described in detail in Section 9.3.5.2 of the PNPP FSAR.

The SLCS includes the piping to the connection to the HPCS line, as shown in Figure 9.3-19 of the PNPP FSAR. Also note the changes in the SLCS design documented in the attached letter by Dalwyn R. Davidson to A. Schwencer, dated August 13, 1982.

26. Provide diagrams and isometric drawings of the SLCS piping into the reactor pressure vessel.

Response

The following Unit 1 diagrams will be supplied for examination at PNPP: flow diagrams D-302-691 and D-302-701, piping drawings D-304-691 and D-304-692, and piping isometric D-314-691 (sheet 3). There are no substantial differences between the Unit 1 and Unit 2 diagrams.

27. According to Sec. 9.3.5.1.1 of FSAR, "A fast scram of the reactor or operational control of fast reactivity transients is not specified to be accomplished by this system (SLCS)" Also, Sec. 9.3.5.3 states that "the system is never expected to be l needed for safety reasons..." According to these statements,

( the SLCS is not expected to function as an ATWS mitigation system. Yet it was listed as such in Sec. 15.8.1. Explain this apparent discrepancy. Exactly why is the SLCS incorpor-ated in the plant design?

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Response

Section 15.8.1 was amended by Amendment 7 to the PNPP FSAR (May 27, 1982). SLCS is not listed in the amended sect'on.

Nevertheless, the SLCS can be used for.ATWS mitigation pur-poses, and neither of the cited statements from 5 9.3.5 of the

< FSAR is inconsistent with that fact. As for the first state-ment, a system can operate to mitigate ATWS events without providing "a fast scram of the reactor. or operational control of fast reactivity transients." SLCS is precisely such a system." As for the second statement, it should be noted that the statement in its entirety reads: "The system is never expected to be needed for safety reasons because of the large number of independent control rods available to shut down the reactor." There is no inconsistency between the fact that the system probably will never need to be implemented, and the fact that it will mitigate an ATWS event should it ever need to be implemented. The SLCS was incorporated in the BWR design to provide backup capability in reactivity control, as stated in the safety design bases. See PNPP FSAR 5 9. 3.5 .1. l( a) .

! 28. What provisions will be made to ensure that, after SLC3 i activation, the boron will not be diluted by the ECCS to such an extent that recriticality may occur (see NUREG-0460, Vol. 4,

p. A-68)?

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! Issue #6 is concerned with whether Applicants should automate their SLCS. T' Issue is unrelated to any postulated dilution of the boron solu'. ion. Applicants, therefore, object to the Interrogator: e.s irrelevant and beyond the scope of Issue #6. See 10 C.F.R. 5 2.740(b)(1).

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29. The FSAR describes the neutron p'ison o used in the SLCS as sodium pentaborate, produced by dissolving stoichiometric quantities of borax and boric acid in demineralized water.

These boron compounds are described as consisting of natural boron. Does this mean that the boron is a mixture of the 2 predominant isotopes in the ratio that they occur naturally,

i.e., 5B/10 at 19.78% and 5B/11 at 80.22%? Boron-10 is the only isotope that is effective at neutron capture; thus, if the sodium penaborate is 80% boron-11, is not the poison then only 20% effective? Has this effect been considered in the asses-sment of the SLCS capabilities?

j Response:

} Issue #6 is concerned with whether Applicants should automate their SLCS. The properties or effectiveness of the

- neutron poison used in the SLCS is unrelated to the automation of the system. Applicants, therefore, object to the Interrogatory as irrelevant and beyond the scope of Issue #6.

! See 10 C.F.R. S 2.740(b)(1).

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30. What boron isotope or mixture of isotopes is used in the control rods?

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Response

Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #6. See Responses to Interrogatories

1. 28 and #29, supra. ,

31. Has the use of different chemicals as neutron poisons, e.g., gadolinium, been investigated? If not, why not? If so, .

with what results? .

Respense:

Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #6. See Responses to Interrogatories

1. 28 and #29, supra.

32. Demonstrate that the initial test procedure for the SLCS described in Sec. 14.2.12.1.5 of FSAR will verify proper mixing of the boron solution, in accordance with Regulatory Guide 1.68, Appendix A.l.b(3).

Response

Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue 46. See Responses to Interrogatories

1. 28 and #29, supra.

33. What is the concentration, in moles / liter, of the sodium pentaborate solution?

Response: ,

Applicants object to the Interrogatory as irrelevant and 4

beyond the scope of Issue #6. See Responses to Interrogatories

1. 28 and #29, supra. -

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34. What is the SLCS injection rate, in gallons / minute?

Include the effects of piping resistance in this answer. .

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Response

As stated in the attached letter from Dalwyn R. Davidson to A. Schwencer, dated August 13, 1982, the SLCS injection rate is 86 gallons per minute. Piping resistance will not affect the flow rate as the pumps are of the positive displacement type.

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35. Perform a value/ impact analysis, like that in NUREG-0460, specific to PNPP for: (1) the automation of the SLCS (2)

complete implementation of Alternative 4A. Both modifications <

j are assumed to be made during construction on both Units 1 and 2.

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Response

Applicants have not performed such a value/ impact ana-lysis, and are under no obligation to perform such an analysis in response to a discovery request. See Response to Interrogatory #10, supra. Moreover, Issue #6 is not concerned with implementation of Alternative 4A, and Applicants object to i

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that portion of the interrogatory as irrelevant and beyond the

) scope of Issue #6. See response to Interrogatory #1, supra.

36. Demonstrate that Fig. 9.3-19 (GAI Dwg. D-302-641) is that

, of the SLCS (in FSAR). If not, provide the correct diagram of the SLCS.

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j Response: ,

j Figure 9.3-19 of the PNPP FSAR was revised by Amendment 7 to the FSAR (May 27, 1982), and.now is a diagram of the SLCS.

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

Jay E. Silberg, P.C.

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

j Washington, D.C. 20036 f (202) 822-1000 1

Dated: August 20, 1982 t

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g.4 THE CLEVELAND ELECTRIC ILLUffilN ATING COMPANY n o sox wao . ettvetano.osio eioi . itttesost inci err esy; e ittusaisarinc etoo . ssevet,csourmt Serving The Best location in the Nation Dal*yn R. Davidson v.et eatsiotui August 13,1982 sYSit u CNGINtf RING AND CoNsTRLPCTION Mr. A. Schwencer, Chief -

Licensing Branch No. 2 -

Division of Licensing '

U. S. Nuclear Regulatory Commission Washington, D. C. 20535 Perry Nuclear Power Plant .

Docket Nos. 50-440;30-441 l ATWS Mitigation Design Features -

Dear Mr. Schwencer:

In e meeting on July 20, 1932, between CE! and members of NRR, we discussed our plans for changing several systems associated with the mitigation of a postulated i ATWS event. The Perry Nuclear Power Plant (PNPP) construction schedule and the current ATWS rulemaking schedule have made it necessary for us to anticipate poten-tial future requirements. We believe it to be in our best interest to modify the current design and install these systems during our construction as opposed to waiting

( until the construction of these systems impacts our construction schedule or operations. The inclusion of these systems is based on the proposed rulemaking and is not based on a belief by CEI that these systems are nee &d to mitigate an ATWS event. As such, we maintain our support of industry comments on the proposed ATWS rule. -

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The basic changes to be made to the Perry plant include the following:

(1) An increased flow capacity for the Standby Liquid Control System from 43 gpm to 86 gpm. This will involve increasing the size of both pumps' suction lines as well as changing the reactor vessel injection point to the HPCS header. Although the design includes both manual and automatic initiation capability, only manual initiation will be functional. The existing pumps wi!! be used.

(2) An upgrade to safety grade of the Recirculation Pump Trip initiation circultry.

(3) A control grade feedwater runback feature.

(4) An Alternate Rod Insertion system which is redundant to the Reactor Protection System scram logic.

A. Schwencer ATWS Mit igation August 13,1952 Page 2 The details of the above described design will be submitted as an amendment ,

to the Perry FSAR by January 1983. -

We believe that this design along with appropriate ertiergency ohrating procedures and training adequately address the ATWS Issue for PNPP.

Very truly yours, Dalwy R. Davidson Vice President System Engineering and Construction DRD:WEC:mb.

cc: Jay Silberg, Esq.

John Stefano Max Gildner l

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CLEVELAND ELECTRIC ILLUMINATING COMPANY .

CLEVELAND, OHIO Frank R. Stead, being duly sworn according to law, deposes that he is Manager, Nuclear Engineering Department of Cleveland Electric

!!!uminating Company and that the facts set forth in the foregoing Applicants' Answers to Sunflower Alliance Interrogatories I, 2,~ 3,5,13, 19, 22, 25, 26, 34, and 36 dated April 30, 1982, are true and correct to the best of his knowledge, information and belief, I

TukQ hkJ I

Sworn to and subscribed a

before me this M day ,

of A OCUST , $0 N .

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U0ESDH C. 5ZWUK0Wp* 1 P*do Mh:. Neecw c.ytcr.

Fy Cm%6an Egiset JW 14, ISSC

e CLEVELAND ELECTRIC ILLUMINATING COMPANY CLEVELAND, OHIO ,

Steve F. Kensicki, being duly sworn at ording to law, deposes that he is

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General Supervising Engineer, Radiation Protection Section of Cleveland Electric !!!uminating Company and that the facts set forth in the ,

foregoing App!! cants' Answers to Sunflower Alliance Interrogatories 23, and 24 dated April 30, 1982, are true and correct to the best of his knowledge, information and belief.

X f

E.J. -

i Sworn to and subscribed  ;

before me this 20 day ,

of 00Gost , l $0?--

OL k-_h ~ "E U D D5DH C. $rM.T0W50 v.ry an:. ne c: om . em. en wy cae.insion Dphet My 18,19ss

AFFIDAVIT _

HENRY C. PFEFFERLEN, being duly sworn according to law, deposes and says that he is .the Manager, BWR Licensing Programs, of General Electric Company, and that the facts set forth in the foregoing Applicant's Answer to Sunflower Alliance's second set of Interrogatories No.'s 10 and

,' 27 (Issue f6) dated April 30, 1982, are true and correct to the best of his knowledge, infomation and belief.

~

c?/zofh%.-- f' Date HENRY C. PFEFFERLEN STATE OF CALIFORNIA )

COUNTY OF SANTA CLARA ) ss:

On August 20, 1982, before the undersigned, a Notary Public for the State of California, personally appeared HENRY C. PFEFFERLEN, known to me to be the person whose name is subscribed to the within instrument, and acknowledged that he has executed the same.

Subscribed and sworn to before me on August 20, 1982.

co:mme:c:crom:oww:c:cw:q {/& 6-C' 4 8 orr1CIAL SEAT; arf PUBLIC, STATE OfJCALIF0F.SlA O 4 KARIN 5, VCK;ELHU!Dt g f NotAtr Ptnuc.cAuto:xto g SANTA CLARA COUNTY , u Mr Co-d b c>xno sam o lapires De<. 21,1984 o:o:ms:;nos l l [

UNITED STATES OF AMERICA 4 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 i ) (Perry Nuclear Power Plant, ) Units 1 and 2) ) CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Answer to Sunflower Alliance, Inc. et al. Second Set of Interroga-tories to Applicants" were served by deposit in the United States Mail, First Class, postage prepaid, this 20th day of August, 1982, to all those on the attached service list. i ROBERT L.'WILLMORE I Dated: August 20, 1982 i

                         -                          NU...SRREGULATORYCOMMISSIOh[

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

                                                                                     )

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

                                                                                      )

(Perrv Nuclear Power Plant, ) Units 1 and 2 )' SERVICE LIST , Atomic Safety and Licensinc Peter 3. Bloch, Chairman Atcmic Safety and Licensing Board Acceal Board Panel Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission U.S. Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry R. Eline Docketing and Service Section 0 :. . . rice or t.ne Secretary Atomic Sar.e ty anc Licensing Board p'. S . Nuclear Reculatorv. Co= mission U.S. Nuclear Regulatorv Cc= mission . Washinc, ton, D.C. 20555-Washincton, a D.C. 20555 d . Ste-he Lewis Esquire ~~ ~~~~ Ib. Prederick J. Shon Atomic Safety and Licensing Board ~Dff5ce~n H.5f'ths Ex'ecutive Legal Director U.S. Nuclear Regulatory Ccmmission U.S. Nuclear Regulato y Ccmmission Wahsington, D.C. 20555 Washington, D.C. 20555 Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt OCRE Interim Representative Appeal Board 8275 Munson Avenue U.S. Nuclear Regulatory Cc= mission Mentor, Ohio 44060 Washington, D.C. 20555 Daniel D. Wilt, Esquire Dr. John H. Buck Atomic. Safety and Licensing P. O. Box 08155 Cleveland, Ohio 44102 Appeal Board U.S. Nuclear Regula: cry Commission Washington, D.C. 20555 Donald.T. E::one, Esquire Assistant Prosecuting Attorney Gary J. Edles, Esquire Lake County Administration Center Atcmic Safety and Licensing 105 Center Street Appeal 30ard Painesville, Ohio 44077 U.S. Nuclear Reculatorv. Commission Washington, D.C. 20555

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John G. Cardinal, Esquire Prosecuting Attorney _e _m=_ _ s. .-..a r.

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Ashtabula County Courthouse

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ve :ersen, O. .nlo s, s 0 4 '/ U.S. Nuclear Regulatory Commission

        .: a s h i n c : c n ,

D.C. 20535 Terry Lodge, Esquire 915 Spitzer Suilding Toledo, Ohic 43604 .}}