Similar Documents at Perry |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20083B7881991-09-20020 September 1991 Ohio Edison Co Interrogatories to NRC Staff.* Requests That NRC Answer Separately & Fully in Writing,Each Listed Interrogatory within 30 Days.W/Certificate of Svc.Related Correspondence ML20059H4141990-08-31031 August 1990 Licensee Response to Ohio Citizens for Responsible Energy, Inc Interrogatories & Request for Production of Documents.* W/Certificate of Svc & Svc List.Related Correspondence ML20056B1811990-08-0808 August 1990 Interrogatories & Request for Production of Documents.* Requests That Util Answer Interrogatories & Request for Production of Documents No Later than 900831.Certificate of Svc Encl.Related Correspondence ML20137J0871986-01-17017 January 1986 Response Opposing Ocre Offer to Withdraw Proposed Contentions B-1,B-2,B-3 & B-5.Condition to Limit Single Loop Operation to 50% of Rated Thermal Power Unacceptable. Certificate of Svc Encl ML20100H1921985-04-0101 April 1985 Updated Response to Interrogatories Re Issue 16 Concerning Diesel Generator Reliability.Documents Relevant to Issue, Which May Be Used in cross-examination or Offered as Exhibits,Listed.Related Correspondence ML20114B7081985-01-25025 January 1985 Supplementary Response to Ohio Citzens for Responsible Energy 10th,11th & 12th Sets of Interrogatories to Applicants Re Issue 16.Certificate of Svc Encl.Related Correspondence ML20114A5421985-01-22022 January 1985 Updated Response to Applicant Second Set of Interrogatories Re Issue 8.Certificate of Svc Encl.Related Correspondence ML20113F2521985-01-22022 January 1985 Answers to 850107 Fourteenth Set of Interrogatories Re Issue 16.Supporting Documentation & Certificate of Svc Encl. Related Correspondence ML20112C9171985-01-0707 January 1985 Fourteenth Set of Interrogatories,Pertaining to Issue 16 Re Tdi Diesel Generators & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20101M4441984-12-28028 December 1984 Second Voluntary Answers to Portion of Ohio Citizens for Responsible Energy 840730 Thirteenth Set of Interrogatories. Prof Qualifications of Gm Fuls & Jd Richardson & Certificate of Svc Encl.Related Correspondence ML20099C6591984-11-16016 November 1984 Voluntary Answers to Portion of Ohio Citizens for Responsible Energy late-filed Thirteenth Set of Interrogatories Re Issue 8.Prof Qualifications of Rj Schmehl & Certificate of Svc Encl.Related Correspondence ML20094E5171984-07-30030 July 1984 Thirteenth Set of Interrogatories Pertaining to Issue 8 Re Hydrogen Control.Interrogatories Concern Generation,Release & Combustion of Hydrogen Gas in Degraded Core Accident. Certificate of Svc Encl.Related Correspondence ML20140C3561984-06-15015 June 1984 Amended & Supplemental Answers to Sunflower Alliance First Round Discovery Requests & Second Set of Interrogatories Re Issue 1.Certificate of Svc Encl.Related Correspondence ML20091P9241984-06-11011 June 1984 Answer to Ohio Citizens for Responsible Energy Twelfth Set of Interrogatories to Applicant Re Issue 16.Certificate of Svc Encl.Related Correspondence ML20084P0751984-05-14014 May 1984 Twelfth Set of Interrogatories on Issue 16 Re Diesel Generator Reliability.Certificate of Svc Encl.Related Correspondence ML20084P0791984-05-14014 May 1984 Response to Applicant 840309 Interrogatories & Request for Production of Documents (Fifth Set).Certificate of Svc Encl. Related Correspondence ML20087C6901984-03-0909 March 1984 Interrogatories & Request for Production of Documents to Ohio Citizens for Responsible Energy Re Reliability of Transamerica Delaval Standby Diesel Generators.W/Certificate of Svc.Related Correspondence ML20087C2701984-03-0808 March 1984 Answer to Ohio Citizens for Responsible Energy Eleventh Set of Interrogatories to Applicant Re Issue 16.Certificate of Svc Encl.Related Correspondence ML20086T3691984-02-29029 February 1984 Supplemental Answers to Interrogatories on Issues 6,8 & 15. Certificate of Svc Encl.Related Correspondence ML20080N2461984-02-21021 February 1984 Order Extending Time Until 840228 for Commission to Act to Review 831115 Director'S Decision ML20080N8191984-02-17017 February 1984 Eleventh Set of Interrogatories on Issue 16 Re Diesel Generators.Certificate of Svc Encl.Related Correspondence ML20080J7761984-02-0808 February 1984 Answers to Ohio Citizens for Responsible Energy Tenth Set of Interrogatories Re Issue 16.Certificate of Svc Encl ML20086L2651984-02-0303 February 1984 Motion to Reopen Discovery on Issue 1 Re Emergency Planning. Certificate of Svc Encl.Related Correspondence ML20082P2621983-12-0505 December 1983 Supplemental Discovery Response Consisting of Status Rept: Planning for Accident at Perry Nuclear Plant, by Perry Legal Defense Fund.Certificate of Svc Encl.Related Correspondence ML20072E5521983-06-21021 June 1983 Supplemental Response to Third Set of Interrogatories. Certificate of Svc Encl ML20072E5421983-06-21021 June 1983 Responses to Fourth Set of Interrogatories & Request for Production of Documents.Related Correspondence ML20071H1241983-05-19019 May 1983 Update to Util 830205 Answer to Interrogatory 3 of Sunflower Alliance 811202 First Set of Interrogatories.All Three Counties Have Submitted Draft Plans to Ohio Disaster Svcs Agency.Svc List Encl.Related Correspondence ML20073B8001983-04-0808 April 1983 Fourth Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20072K0151983-03-18018 March 1983 Response to Third Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20069C1451983-03-14014 March 1983 Updated Response to Applicant 830308 Response to Interrogatory 9-1 in 830131 Ninth Set.Svc List Encl ML20069C3341983-03-14014 March 1983 Answer Opposing Oh Citizens for Responsible Energy 830223 Motion for Rewording of Issue 8 & Spec of Guidelines for Litigation.Motion Seeks to Frustrate & Further Delay Issue 8 Litigation.Certificate of Svc Encl ML20071E8531983-03-0808 March 1983 Answers to Interrogatories 9-1 Through 9-25 & 9-38 Through 9-52 Re Issues 13 & 15,from 830131 Ninth Set of Interrogatories.Prof Qualifications & Certificate of Svc Encl ML20071C7051983-03-0303 March 1983 Response to Relevant Portion of General Interrogatory 9-52. Svc List Encl ML20071C1491983-02-25025 February 1983 Answers to Interrogatories 9-26 Through 9-37 Re in-core Thermocouples (Issue 14).Interrogatory Portions Re core-exit Thermocouples Irrelevant & Will Not Be Answered.Certificate of Svc Encl ML20071B8841983-02-25025 February 1983 Answer to 830131 Interrogatories 9-26 Through 9-37 Re Issue 14 on in-core Thermocouples.Certificate of Svc Encl.Related Correspondence ML20070U7791983-02-0707 February 1983 Supplemental Response to Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20028G2451983-01-31031 January 1983 Third Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20070T2591983-01-31031 January 1983 Ninth Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML20070T1711983-01-31031 January 1983 Ninth Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20083J4081983-01-0606 January 1983 Tenth Set of Interrogatories on Diesel Generators. Certificate of Svc Encl ML20028C2931983-01-0303 January 1983 Supplemental Answers to Third Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl. Related Correspondence ML20070L4631982-12-28028 December 1982 Supplemental Response to Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl. Related Correspondence ML20079H3561982-12-13013 December 1982 Answers to Second Set of Interrogatories,Numbers 20,28 & 31. Certificate of Svc Encl ML20079H3511982-12-13013 December 1982 Answers to Eighth Set of Interrogatories.Certificate of Svc Encl ML20067B2631982-11-30030 November 1982 Resubmission of Sixth Set of Interrogatories & Motion Requesting Presiding Officer to Require NRC Answers. Certificate of Svc Encl.Related Correspondence ML20067A1131982-11-29029 November 1982 Updated Response to Oh Citizens for Responsible Energy 820928 Interrogatory 4-2.Svc List Encl.Related Correspondence ML20069L8321982-11-15015 November 1982 Response to Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20069L8391982-11-12012 November 1982 Update to 820625 Answers to Second Set of Interrogatories. Svc List Encl.Related Correspondence ML20028A3181982-11-12012 November 1982 Eighth Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML20027D4661982-11-0101 November 1982 Supplemental Response to First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl. Related Correspondence 1991-09-20
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212J1581999-09-30030 September 1999 Order Approving Transfer of License & Conforming Agreement. Orders That License Transfer Approved,Subj to Listed Conditions ML20205D4901999-02-22022 February 1999 Transcript of 990222 Informal Public Hearing on 10CFR2.206 Petition in Rockville,Md.Pp 1-105.Supporting Documentation Encl ML20198D9711998-11-0909 November 1998 Petition Per 10CFR2.206 Requesting That Facility Be Immediately Shut Down & OL Be Suspended or Modified Until Such Time That Facility Design & Licensing Bases Properly Updated to Permit Operation with Failed Fuel Assemblies ML20155F4561998-08-26026 August 1998 Demand for Info Re False Info Allegedly Provided by Wh Clark to Two NRC Licensees.Nrc Considering Whether Individual Should Be Prohibited from Working in NRC-licensed Activities for Period of 5 Yrs ML20236V5261998-07-20020 July 1998 Computer Access & Operating Agreement Between Cleveland Electric Illuminating Co & NRC PY-CEI-NRR-2284, Comment Opposing Proposed Generic Communication, Lab Testing of Nuclear-Grade Activated Charcoal1998-05-21021 May 1998 Comment Opposing Proposed Generic Communication, Lab Testing of Nuclear-Grade Activated Charcoal ML20216B5111998-04-0909 April 1998 Order Imposing Civil Monetary Penalty.Denies Request for Remission of Violation C,Ea 97-430 & Orders Licensee to Pay Civil Penalty in Amount of $50,000 within Next 30 Days PY-CEI-NRR-2269, Comment on Proposed Rule 10CFR50.NRC Should Demonstrate That Not Only Is Code Process Flawed,But That Proposed Change Justified from Cost Versus Safety Protective1998-04-0303 April 1998 Comment on Proposed Rule 10CFR50.NRC Should Demonstrate That Not Only Is Code Process Flawed,But That Proposed Change Justified from Cost Versus Safety Protective ML20216G3821998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Duquesne Light Co & Allegheny Power Systems,Inc ML20217J0661998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Dqe, Inc & Allegheny Power System,Inc ML20198P9311997-11-0707 November 1997 Comments of American Municipal Power-Ohio,Inc.NRC Should Require Allegheny Power Sys,Inc to Affirm That Capco Antitrust License Conditions Will Be Followed ML20134L3401997-01-22022 January 1997 Resolution 96-R-85, Resolution Supporting Merger of Centerior Energy Corp & Ohio Edison Under New Holding Co Called Firstenergy ML20133B6941996-12-18018 December 1996 Submits Ordinance 850-96 Re Approval of Merger of Centerior & Oh Edison Into Firstenergy ML20135F4731996-12-0606 December 1996 Memorandum & Order CLI-96-13.* Commission Reverses & Vacates ASLB LBP-95-17 Which Granted Motion for Summary Disposition Submitted by Ocre & Hiatt.W/Certificate of Svc.Served on 961206 ML20132A8461996-12-0202 December 1996 Resolution 20-1996 Supporting Merger of Ohio Edison & Centerior Corp Under New Holding Company Called Firstenergy ML20134M6191996-10-28028 October 1996 Proclamation of Support by City of Sandusky,Oh Re Merger of Ohio Edison and Centerior Energy Corp ML20112J8281996-06-18018 June 1996 Licensee Reply Brief on Review of Licensing Board Decision LBP-95-17.* W/Certificate of Svc ML20112D8721996-05-29029 May 1996 Intervenor Brief in Support of Commission Affirmation of LBP-95-17.* Commission Should Affirm Licensing Board Decision.W/Certificate of Svc ML20108D9571996-05-0303 May 1996 CEI Response to City of Cleveland 2.206 Petition.Nrc Should Deny Petition ML20108B7571996-04-26026 April 1996 Licensee Brief on Review of Licensing Board Decision LBP-95-17.* Recommends That Commission Reverse Board Memorandum & Order Issued 951004.W/Certificate of Svc & Svc List PY-CEI-NRR-2034, Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matl1996-03-11011 March 1996 Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matl ML20101B5841996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement Or,In Alternative,For Severance of Issue & Expedited Hearing Procedures.W/Certificate of Svc ML20097B8721996-01-23023 January 1996 Petition of City of Cleveland,Oh for Expedited Issuance of Nov,Enforcement of License Conditions & Imposition of Appropriate Fines,Per 10CFR2.201,2.202,2.205 & 2.206 ML20097B8911996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement or in Alternative,For Severance of Issue & Expedited Hearing Procedures ML20096E2471996-01-0303 January 1996 Comment on PRM 50-64 Re Stockpiling Ki for Use as Thyroid Protectant in Event of Nuclear Accident.Supports Distribution of Ki to Public ML20094N1951995-11-17017 November 1995 Oh Edison Application for License Transfer in Connection W/ Sale & Related Transactions ML20094M5941995-11-15015 November 1995 Intervenors Answer to Licensees Petition for Review.* Intervenor Conclude That Commission Should Not Review Board Decision.W/Certificate of Svc ML20094J9141995-11-0707 November 1995 Petition for Review.* Submits That Commission Review of Board Decision Appropriate Under 10CFR2.786. W/Certificate of Svc & Svc List ML20093N9491995-10-23023 October 1995 Licensee Request for Extension of Time to File Petition for Review.* Requests That Commission Grant Extension Until 951107 of Deadline for Filing Petition for Review. W/Certificate of Svc ML20065L3571994-04-0505 April 1994 Intervenors Answer to NRC Staff Response to Intervenors Motion for Summary Disposition & Licensees Cross Motion for Summary Disposition.* Urges Board to Deny Licensee Cross Motion.W/Certificate of Svc ML20064N6341994-03-21021 March 1994 Affidavit of RW Schrauder in Support of Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition.W/Certificate of Svc ML20064N6081994-03-21021 March 1994 Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition.* Moves for Decision in Licensee Favor on Ocre Contention ML20064N9201994-03-21021 March 1994 Affidavit of RW Schrauder in Support of Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition. W/Svc List ML20063L4621994-02-0707 February 1994 Motion for Summary Disposition.* Intervenors Request That Board Grant Summary Disposition Favorably & Issue Declaratory Relief by Finding Challenged Portion of Amend 45 to Be in Violation of Aea.W/Certificate of Svc ML20058P4451993-12-13013 December 1993 Licensee Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Supplemental Petition for Leave to Intervene.* W/Certificate of Svc ML20059L9391993-11-12012 November 1993 Petitioners Supplemental Petition for Leave to Intervene.* Court Held That NRC May Not Eliminate Public Participation on Matl Issue in Interest of Making Process More Efficient. W/Certificate of Svc ML20059B1421993-10-19019 October 1993 Order.* Petitioners Shall File Supplemental Petition in Accordance W/Schedule in 931018 Order.W/Certificate of Svc. Served on 931020 ML20059B1761993-10-18018 October 1993 Order.* Informs That for Each Contention,Petitioners Shall Comply Fully W/Requirements of 10CFR2.714(b)(2)(i),(ii) & (III) & Their Filing Should Address Requirements Set Forth in Regulations.W/Certificate of Svc.Served on 931019 ML20059B0701993-10-12012 October 1993 Motion to Defer Consideration of Remanded Issue.* Requests That Licensing Board Defer Consideration of Remanded Issue Pending Outcome of Commission Review of 2.206 Process.W/ Certificate of Svc ML20058M8761993-09-30030 September 1993 Memorandum & Order CLI-93-21.* Appeal for Hearing Re Amend to Plant OL Denied.W/Certificate of Svc.Served on 930930 ML20057C0461993-09-21021 September 1993 Supplemental Director'S Decision DD-93-15 Involving 920929 Request for Certain Actions to Be Taken Re Proposed Construction of Interim onsite,low-level Radioactive Waste Facility at Plant.Request Denied ML20056C8951993-07-19019 July 1993 Order Extending Time within Which Commission May Rule on Petitions for Review of LBP-92-32.W/Certificate of Svc. Served on 930720 ML20045B5661993-06-0707 June 1993 Comment Re Proposed Generic Communication on Mod of TS Administrative Control Requirements for Emergency & Security Plans,As Published in Fr on 930401 (58FR17293).Believes Concept of Technical Review Not Addressed by STS ML20044E2781993-05-13013 May 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re VEPCO Petition to Change Frequency of Emergency Planning Exercise from Annual to Biennial ML20127A6171993-01-0606 January 1993 Order.* Time within Which Commission May Rule on Petitions for Review of Board Order LBP-92-32,dtd 921118,extended Until 930208.W/Certificate of Svc.Served on 930106 ML20126D5171992-12-23023 December 1992 City of Brook Park Answer to Petitions for Review.* Opposes Applicants 921208 Petitions for Review Based on Fact That ASLB Decision in proceeding,LBP-92-32,adequately Addressed Issues Raised in Petitions.W/Certificate of Svc ML20126F6501992-12-23023 December 1992 Answer of City of Cleveland,Oh,Intervenor,In Opposition to Petitions for Review of 921118 Decision of Aslb.* Petitioners Petitions for Review Should Be Denied. Certificate of Svc Encl ML20126D5461992-12-23023 December 1992 Answer of Cleveland Electric Illuminating Co & Toledo Edison Co to Limited Petition for Review of City of Cleveland,Oh of 921118 Decision of Aslb.* Commission Should Deny City of Cleveland Petition.W/Certificate of Svc ML20126D5781992-12-23023 December 1992 Answer of American Municipal Power-OH,Inc in Opposition to Petitions for Review of Oh Edison Co & Cleveland Electric Illuminating Co/Toledo Edison Co.* W/Certificate of Svc ML20126D5801992-12-23023 December 1992 NRC Staff Answer in Response to Petitions for Review Filed by Oh Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & City of Cleveland.* W/Certificate of Svc 1999-09-30
[Table view] |
Text
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DOCKETED usnRC
.jpPggpbgrgdR33 2 1982 r.c r y - - - . >
UNITED STATES OF AMERICA i" NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinq 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) ) 7 APPLICANTS' ANSWER Tb OHIO CITIZENS -
FOR RESPONSIBLE ENERGY FOURTH SET OF INTERROGATORIES TO APPLICANTS Applicants for their answers to Ohio Citizens for Responsible Energy ("OCRE") Fourth Set of Interrogatories, dated September 7, 1982, state as follows:
All documents supplied to OCRE for inspe,ction will be produced at Perry Nuclear Power I'lant ("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 portions thereof, which OCRE requests, at Applicants' cost of duplication. Arrangements for obtaining i
copies can be made with Mr. Wiley.
.1 8210010345 820928 PDR ADOCK 05000440 0
RESPONSES _.
4-1. Please produce a copy of the following document identi-fied in the response to OCRE interrogatory 1-12: " Evaluation of the Asiatic Clam Corbicula Fluminea in the Western Basin of Lake Erie," prepared by Ms. Jennifer Scott-Wasilk, Mr. Gary G.
Downing, and Mr. Jeffrey S. Lietzow of Toledo Edison.
Response
The document wi11 be supplied for examination at PNPP.
4-2. Please list all documents in the possession of Applicants concerning the presence of Corbicula in Lake Erie. Produce all such documents (except those previously provided).
Response
The following is a list of all documents Applicants have concerning the presence of Corbicula in Lake Erie that have not yet been provided:
(1) Scott-Wasilk, Downing, Clayton and Lietzow,
" Environmental Survey for Corbicula at the Eastlake Power Plant," dated September 9, 1982, plus cover letter from Scott-Wasilk to Zucker, dated September 13, 1982.
(2) NUS Corporation report, " Preliminary Planning Considerations Regarding Corbicula at the Perry Nuclear Power Plant," dated December, 1981.
(3) Letter from Kovalak to Madsen, dated May 7, 1981. ,
= (4) , Memorandum from Zucker to Banks, dated May 19, 1981.
(5) Letter from Wells to Keppler, dated July 7, 1981.
(6) Letter from Scott-Wasilk to Kovalak, dated July 2, 1981.
(7) Letter from Stansberry to White, dated May 7, 1981, with cover letter from White to Szwejkowski, dated May 19, 1981.
(8) Letter from Davidson to Schwencer, dated June 18, 1981.
These d6cuments will be~ supplied for examination at PNPP.
4-3. The "Corbicula Reconnaissance Survey" (May 1981) prepared '
for Applicants by NUS Corporation at p. I lists various methods for controlling Corbicula: chemical treatments, clam traps, mechanical cleaning devices, centrifugal separators, and magnetic water conditioners. Please provide a description of each of these methods with an assessment of their efficacy and their feasibility for use at Perry.
Response
l
! The "Corbicula Reconnaissance Survey" prepared by NUS Corporation noted the referenced control methods because they are either in use or being tested in the industry. No eval-uation of their efficacy or feasibility for PNPP has been done.
Some of the referenced control methods are described in a July, 1982, Power Magazine article. This article will be supplied for examination at PNPP.
O l
4-4. The " Report on General Plans (Permit to Install and 401 Certification) for the Proposed Perry Nuclear Power Plant" (part of the Ohio EPA permit dated July 12, 1974) at p. 2 i stat 6s that there will be no backwash of the intake.
Considering the potential for clam biofouling at PNPP, do Applicants still believe this statement is true? Specifically, if flow blockage due to Corbicula in the intake were to occur, would Applicants consider backwashing the intate, possibly with heated water, to kill / remove the clams?
i -
Response
1 The statement still i;s true.- No backwash of the intake is planned, large}y because such an operation could not be accomplished without extensive modifications.
- 4-5. If backwashing is not contemplated, how.would such a problem be corrected?
Response
Because flow blockage due to Corbicula in the intake is not possible, Applicants have no plans at this time to correct
- "such a problem." The openings in the' intake structure 'itself are too large to be blocked by Corbicula.
i 4-6. FSAR Section 9.2.1.2 states that the intake of water for the ESWS can be taken from the discharge structure if the j normal intake becomes unavailable. What is the probability of this occurring?
'._-- . . _ . .~ - . . _ - , __ _ _ . - , _ ._ _
Response
' Use of the discharge structure as an intake for the Emergency Service Water System would occur only if the intake tunnel were blocked due to a seismic event. Because the intake structure is safety grade, it is designed to withstand seismic events equal to or less than the magnitude of the safe shutdown earthquake.
4-7. Does the discharge contain any screens or any other features to prevent the intake of adult Corbicula? Describe these features, including the mesh size of any screens.
Response
The discharge structure itself has no screens. There, however, are vertical traveling screens in the emergency service water pumphouse. These screens are described in Table 9.2-13, at page 9.2-62, of the PNPP FSAR.
4-8. During such circumstances in which the discharge would be used for water intake, do the Applicants intend to chlorinate the ESWS to kill any Corbicula larvae that might enter?
Response
Applicants have no plans to use chlorination to control Corbicula.
. ~ . _ _._-,._.:..,_ -
4-9. Describe the provisions Applicants will employ to prevent the accumulation of sediment within the intake, discharge, and ESWS.
Response
The intake and discharge tunnels are designed such that sedimentation presents no problem. The flow rate in the Emergency Service Water System is too fast for sedimentation to occur.
4-10. Will non-safety-related service water systems be subject to Corbicula monitoring and control? List every such system '
and give the degree to which it will be monitored.
Response
The flow and pressure of the Fire Service System will be tested annually. While not conducted for the purpose of discovering Corbicula, these tests will indicate if Corbicula are blocking the System. Additional monitoring has been identified in Applicants' response to question ASB-9 of the NRC Staff. (See letter from Davidson to Schwencer dated April 29, 1982.) Applicants' response already has been sent to the service list.
4-11. Provide a detailed description of the lake bottom near PNPP, including that near the intake and discharge structures.
~
Response
A detailed description of the lake bottom near PNPP is contained in a memorandum from Nugent to Zucker, dated September 22, 1982. A copy of the memorandum will be supplied for examination at PNPP.
4-12. Describe in detail all plans for chlorination of the ESWS and intake / discharge flows. Have chlorination cycles been designed to coincide with Corbicula spawning seasons in Lake Erie?
Response
Chlorination is provided for both the Service Water and the Emergency Service Water Systems to control microorganisms in the water. No chlorination of the water is planned for
, Corbicula control.
4-13. Will the Corbicula monitoring program (including ESWS surveillance testing) for PNPP be continued throughout the construction of the plant and during maintenance outages after the plant begins operations?
Response
Beginning this year, the Lake monitoring prog' ram for ;
I Corbicula will be continued indefinitely. Such monitoring will take place twice each year. Flow monitoring of the Emergency
- Service Water System will take place whenever the System is in operation. Visual monitoring of certain potential locations j for Corbicula blockage will take place during maintenance outages or when the plant otherwise is not in operation.
Commitments to monitor yarious points in the plants' water systems are detailed in Applicants' response to question ASB-9 of the NRC Staff. Applicants' response already has been sent to the service list.
4-14. Provide detailed, legible drawings of the ESWS; include the diameter of all piping, the location of flow meters and i differential pressure indicators, and chlorination paths.
l
Response
Drawings of the Emergency Service Water System will be made available for examination at PNPP.
4-15. Provide a detailed description (and drawings) of the RHR heat exchangers. Specifically discuss the similarities and differences of the Perry heat exchangers with those of the Brunswick plant and Pilgrim I.
Response: ,,
- 'A drawing of the RER heat exchanges will be made available for examination at PNPP. The RER has two loops, A and B, each of which has two heat exchangers connected in series. Each heat exchanger is a vertically mounted single-pass shell and double-pass U-tube type heat exchanger. RER system flow is into the A or B heat exchanger shell through the penetration at
~
the top and out through the shell penetration just above the Ibe sheet. The system flow then goes into the downstream C or D heat exchanger in the same manner. The shell of the upstream heat exchanger in each loop has nine one inch penetrations along its vertical axis which are connected to a common vent line. Two other penetrations are connected to a level trans-mitter. The tubes and tube sheet cladding are BWG Stainless Steel. The shell is carbon steel. Overall size of each heat exchanger is approximately 4. feet in diameter and 29 feet high.
Total heat transfer rate is designed to satisfy the require-ments of 1) shutdown cooling operation 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> after shutdown t
with the reactor 125'F and service water 10*F below maximum allowable temperature, 2) steam condensing operation one and one-half hours after shutdown with maximum service water temperature, or 3) containment cooling operation with maximum I service water temperature. The maximum rate of heat transfer across both heat exchangers in either loop is limited to 150 x 106 BTU /Hr in the steam condensing mode. Both the tube and
\ .
shell sides are designed for operation over the temperature .
range from 40*F to.480*F and at pressures up to 500 psig.
Applicants do not have sufficient information about the Brunswick or Pilgrim I heat exchangers to compare Applicants' heat exchangers with those of Brunswick or Pilgrim I.
4-16. . Are the RER heat exchangers ac.ltiple pass? If so, does the potential for internal bypass leakage exist (see AEOD Report on Service Water System Flow Blockages by Bivalve Mollusks at Arkansas Nuclear One and Brunswick (February 1982) at p. 33)? Provide all plans Applicants have proposed for measuring heat exchanger performance, in terms of heat transfer coefficient (i.e., other than flow / pressure measurements).
1 i
Response
6 The RER heat exchangers are two-pass on the tube side and one-pass on the shell side. There is no possibility of bypass
- leakage between the tube and shell. The heat ~exchangers are hydrotested on both the shell and tube sides to ensure heat exchanger integrity. Heat exchanger performance will be evaluated periodically using flow, temperature and pressure measurements. Any significant deviations between the measured performance and design data will be corrected.
.-=y---. . -. , . - . ,--,---v,- e,.,.-,,y- ,.m.,,,,-w.,,.%..w-- . . - . - - - . - - . - * - - , , - - - , - , - -----------r,.,,--,- , - ,,m,-- ----- - -
4-17. Will surveillance testing of the ESWS be conducted with -
the system aligned to its. post-accident mode, as recommended by the AEOD Report?
Response
One loop of the three loops in the Emergency Service Water System will be surveillance tested each month. The System will be aligned in a post-accident mode.
4-18. Are the RHR heat exchangers at such an elevation and the ESWS piping to same configured (sic] such that they would become a trap for any debris swept into them?
Response
There is a " dead spot" directly below the location of the heat exchanger inlet and outlet. This area is drained, however, when the Emergency Service Water System is shut down.
The area is then refilled with demineralized water, 4-19. Describe the metallurgical composition of the ESWS
, pumps, piping, and components, including that of any screens or j cladding. Specifically, is Cu-Ni (or any other substance that j might be toxic to clams) used?
i l -
l
.- =_
Response: ,,
' The Emergency Service Water System is composed of various grades of carbon steel and stainless steel, leaded red, brass and aluminum bronze. No Cu-Ni is used in the System. Because Applicants do not know which substances conceivably could be toxic to Corbicula, Applicants cannot identify "any other substances that might to toxic to clams."
4-20. Describe the metallurgy of RER heat exchangeribaffle plates and water boxes (and any welds therein). I.e., is carbon steel or Cu-Ni used? Compare the strength of f the PNPP RHR heat exchangers with those at Brunswick / Pilgrim I.
Response
The RER heat exchangers are composed of various grades of carbon steel and stainless steel, and copper. No Cu-Ni is used in the heat exchangers. Applicants do not have sufficient
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information about the Brunswick or Pilgrim I heat exchangers to
compare Applicants' heat exchangers with those of Brunswick or _
Pilgrim I.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE a
By: , r Jay E. Silberg, P.C.
Robert L. Willmore Counsel for Applicants 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 Dated: September 28, 1982 i
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, , , . .. _._,.y._ ,-_ _ . _ _ _ _ , _ _ - . , __,..,.__..--__m_,_,, . .
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THE CLEVELAND ELECTRIC ILLUMINATING COMPANY CLEWLAND, OHIO
,f Richard A. Pender , being duly sworn according tc, law, deposes that he is Lead Mechanical Engineer Nuclear Analysis and Design Section
, of The C(eveland Electric lifuminating Company and that the facts set forth l
in the foregoing Applicants' Answers to Ohio Citizens for Responsible Energy interrogatories 4-24 through 4-20 dated September 7,1932 ,
are true and ccrrect to the best of his knowledge, information and belief.
A Sworn te and subscribed 4-before me this / h. day of '/MM //flL 3
b d - 4 ,
l C4P0UNE h. W110!
Ndery Public. StaM of Ohio Mycomn.%,bottes Api!17,1385 ,
(Ree:rrded in Lake County) i i
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THE CLEVELAND ELECTRIC ILLUMINATING COMPANY CLEVELAND, OH10 Raymond F. Zucker, Jr. , being duly sworn according to law, deposes that he is Chemical Engineer , Nuclear Design and Analysis Section of The Cleveland Electric illuminating Company and that tha facts sat forth in the foregoing Applicants' Answers to Ohio Citizens for Responsible Energy Interrogatories 4-1 through 4-13. dated September 7,1982 ,
are true and correct to the best of his knowledge, information and belief.
s T,hldk' f N Sworn to and subscribed before me this N day of 7
Ab31 )$
M .. .
QROLINE M. WILDE Notary Publu:, $nte el Ohio My Commission Ezphes April 17,1985 (Recorded in bke County) b
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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
)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Answer to Ohio Citizens For Responsible Energy Fourth Set of Interrogatories to Applicants," were served by deposit in the U.S.
Mail, First Class, postage prepaid, this 28th day of September, 1982,.to all those on the attached Service List.
Rob 6rt L. Willmore Dated: September 28, 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. ) .Do'cket Nos. 50-440 ILLUMINATING COMPANY . ) .
50-441
)
(Parry Nuclear Power Plant, ) ,
Units 1 and 2) )
SERVICE LIST Pator 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 Wcchington, D.C. 20555 Washington, D.C. 20555 Mr. Frederick J. Shon James M. Cutchin, IV, Esquire Atomic Safety and Licensing Board Office of the Executive U.S. Nuclear Regulatory Commission Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt Appeal Board OCRE Interim Representative i U.S. Nuclear Regulatory Commission 8275 Munson Avenue l Washington, D.C. 20555 Mentor, Ohio 44060 1
Dr. John H. Buck Daniel D. Wilt, Esquire Atomic Safety and Licensing Post Office Box 08159 Appeal Board Cleveland, Ohio 44108 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Donald T. Ezzone, Esquire Assistant Prosecuting Attorney Gary J. Edles, Esquire Lake Cciunty Administration Center Atomic Safety and Licensing 105 Center Street Appeal Board Painesville, Ohio 44077 U.S. Nuclear Regulatory Commission .
Washington, D.C. 20555 John G. Cardinal, Esquire Prosecuting Attorney Atomic .3afety and Licensing Ashtabula County Courthouse Boa!.d Panel , Jefferson, Ohio 44047 U.S. Nuclear Regulatory Commission Wachington, D.C. 20555 Terry Lodge, Esquire 915 Spitzer Building Toledo, Ohio 43604
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