ML20065F512

Seventh Set of Interrogatories.Certificate of Svc Encl. Related Correspondence

ML20065F512
Person / Time
Site:	Perry
Issue date:	09/27/1982
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8210010366
Download: ML20065F512 (8)

Text

- - - - - - - - - - - - - ' - - - - - - -

U v

r , aELATED CORRESM ,

LOCHETED Saptember 27,1982 U3PRC l '

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '82 Ep 39 P1 10  :

Before the Atomic Safety and Licensing Board - , . _ _

t, g ,

e . -

In the Matter of

) ' . Jr

)

CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50-440 COMPANY, Et A1. ) 50-441

) (Operating License)

(Perry Nuclear Power Plant, ) ,

Units 1 and 2) )

)

OHIO CITIZENS FOR RESPONSIBLE ENERGY SEVENTH SET OF INTERROGATORIES TO NRC STAFF Ohio Citizens for Responsible Energy ("0CRE") hereby propounds its seventh set of interrogatories to the NRC Staff, pursuant to the Licensing Board's Memorandum and Order of July 28, 1981 (LBP-81-24, 14 NRC 175).

Issue #4 Statement of

Purpose:

The following interrogatories pertaining to Issue #4 constitute a follow-up on various matters addressed in the request for admissions.

7-1. Have there ever been any instances in operating BWRs (both foreign and domestic) in which the ECCS core spray flow and/or distribution has been insufficient? If so, provide all details.

7-2. Has the ECCS ever been suoject to a true system demand in which inadequate core spray flow and/or distribution

. might become apparent? If so, provide all details.

7-3. Has the Staff considered the effects on core spray flow and/or distribution due to the thermal properties of hydrogen (high specific heat and thermal conductivity) 0210010366 820927 PDR ADOCK 05000440 0 X-__-___-__-___ .

kb

which might be present following a LOCA? If so, provide all such analyses. If not, why not? .

7-4. In the December 11, 1981' memorandum for the Shoreham ASLB from R. Tedesco, Division of Licensing, concerning Japanese core spray distribution, tests, it is stated that

"(t)here is some possibility that the new data contradict conclusions from 3600 air-water tests in the U.S. for a BWR/6 configuration." Explain the bases of this statement, and generally indicate the relevance of the Japanese tests to Perry. Provide any further information on the Japanese tests that is available.

7-5. Describe Counter-Current Flow Limiting (CCFL) phenomenon (mentioned in the response to Request for Admissions) and its causes, duration, and effects on core spray flow and/or distribution.

7-6.

Is it not true that the only way in which the ' adequacy of BWR ECCS core spray flow and/or distribution will be known with certainty is to conduct tests on a large, operating reactor in a situation where there is a true  ;

l

! l demand on the ECCS (i.e., an actual accident)? Explain why this is or is not true.

l 7-7. Assuming that the SLCS is actuated and borated water is injected tnrough the HPCS sparger, would the presence of 2

coron in the spray affect the core spray flow and/or 3

distribution? Provide documentation supporting the answer. j l '

Issue //6 -

I Statement of

Purpose:

Tne following interrogatories concerning Issue 96 constitute a follow-up on previously addressed matters

3 pertaining to ATWS mitigation.

7-8. NUREG-0460, Vol. 4 at 61 states- that . the only -

experience with boron cleanup from inadvertant SLCS operation at BWRs was at Dresden, while Vol. 3 at 29 refers to such an event at Quad Cities.

Please clarify this discrepancy.

7-9. In their responses to IE Bulletin 80-17 some BWR licensees stated that parallel two pump operation of the SLCS is not feasible due to problems in NPSH, piping system design, boron mixing, excessive degree of modification required, general disagreement, possible reduct ons in safety, etc. Explain further these concerns and state whether the Staff considers them to have merit.

7-10. Wny has the Staff not required LWRs to have a true back-up scram system (as is used in the Hanford N reactor)?

7-11. Have any full-scale, realistic ATWS event experiments been conducted to verify the computer codes (e.6., REDY and ODYN) used by Applicants to analyze ATWS events?

If so, descrios. If not, why not?

7-12. Have any full-scale reactor-destructive tests been per-formed to assess the consequences of an unmitigated ATWS or the ability of the RPT and/or SLCS to mitigate ATWS?

If so, describe. If not, why not?

7-13. Produce AEC Report WASH-1270, " Technical Report on Anticipated Transients Without Scram for Water-Cooled Power Reactors."

7-14. Assuming failure of the RPT, can the SLCS pump head overcome the high RPV pressure and make the reactor

. _4 suberitical?

7-15.

NUREG-0460 Vol. 4 at 21 states that the automatic actua-tion circuitry for the SLCS may include a two minute time delay to decrease tne frequency of false actuations.

Why does the Staff consider this delay acceptable?

Show proof that a two minute delay (a) does not pro-vide an opportunity for operators to deactivate the SLCS when it is truly needed, and (b) does not lead to unacceptable offsite radiological consequences in any ATWS event.

7-16. According to the " Electric Utilities ' Petition for Rulemaking on ATWS" (PRM-50-29), the implementation of an automatic, high capacity SLCS at BWRs would require that the Automatic Depressurization System (ADS) be inhibited. Does the Staff agree? Explain why this would or would not be needed. If an ADS inhibit is required, would this have any safety im-plications? .

7-17.

Does the Staff consider GDC 21 to 10 CFR Part 50 ap-p11 cable to the SLCS? If so, does the parallel two i pump operation of the SLCS to achieve 86 gpm flow rate violate the redundancy requirement?

7-18. l Has General Electric submitted the additional information :_

sought by the Staff as listed in Section 2.4.3 of Vol. 4

~of NUMEG-04607 If so, has the submittal met the Staff's requirements?

7-19. 'w Produce the February 15, 1979 letter from R. Mattson, "

NRC, to all NSSS vendors concerning generic ATWS docu-

. -S-mentation needs.

7-20. Produce the generic letter to all B'#R licensees dated January 8, 1979 requiring the installation of RPT .

before November 1, 1979.

7-21.

Does the Staff consider the' cost, estimates given by Applicants for the downtime:and cleanup of an inadvertant SLCS actuation ( see Applicants ' response to Interrogatory 23 of Sunflower's Second Set) to be reasonably accurate?

If not, explain why the Staff considers them unreasonable.

7-22. The Staff's answer to Interrogatory 47 of Sunflower's First Set states that the Perry control rods are designed to be inserted individually. Describe how individual control rod insertion 's to be accomplished.

7-23.

The Staff's response to Interrogatory 49 of Sunflower's First Set states that "(c) ore meltdown is a likely result only for the most severe ATWS events in a BWR." Specify which ATWS events are the most severe and most likely to result in a meltdown.

7-24. The Staff's answer to Interrogatory 49 of Sunflower's First Set states that core melting occurs in an ATUS only if the suppression pool overheats. OCRE assumes  :

that this is true only if the RPT functions properly, g What consequences are expected in an ATWS if the RPT 4 does not function? If SLCS also fulls? What is the =

probability of hPT failure?

h 7-25.

The Staff's answer to Interrogatory 49 of Sunflower's First Set states tnat "(a)utomation of a properly sized J W;

SLCS would reduce the chance of a core melt resulting "

V

, . from an ATWS . . .

Does the Staff consider the SLCS Applicants plan to install in PNPP to be properly sized?

If not, what is a properly sized SLCS?

7-26. Does the Staff consider power oscillations, such as are described on p. A-67, Vol. '4, NUREG-0460, to be more likely or more severe in a BWR with a manual rather than an automatic SLCS? If so, describe the effects of power oscillations on fuel and containment integrity and any other affected system at PNPP.

7-27. In the proposed rule on ATWS (46 FR 57521, November 24, 1981), in proposed 10 CPR 50.60 (b) (3), it is stated that ATWS mitigating systems mus t be automatically initiated unless it can be demonstrated that the operator would have adequate information and would reasonable be expected within the time available to take the proper corrective action. Does the Staff feel that any BWR licensees or applicants would be able to demonstrate this for the SLCS? If so, explain why, listing any criteria the Staff may have for proving such a demon-stration.

7-28. Proposed 10 CFR 50.60 (b) (1) (iii) states that 1% of radioactivity in the fuel rods of a PWR may be released to the reactor coolant during an ATWS but that 10% is allowable in a BWR. Explain the difference.

7-28. Produce the following documents. Refer to the March 18, 1981 letter from J.M. Felton to A.F. Earley (FOIA-80-587) which was provided by Staff to counsel for Sunflower Alliance on July'9, 1982; the numbers listed below t

-7 correspond to the numbering of the documents listed in Appendix A of said letter: '

20, 24, 38, 56, 60, 85, 101, 106, 114, 148, 159, 164, 168, 181, 182, 200, 2'0 4, 207', 218, 222, 230, 232, 237, 268, 272, 305, 327, 353, 354, 370, 374, 379, 390, 398, 400, 411, 430, 462, 463, 480, 481, 485, 496, 497, 509, 510, 511, 512, 520, 521, 559, 574, 575, 580, 581, 582, 624, 629, 632, 634, 639, 642, 651, 653, 669, 683, 722, 738.

Respectfully submitted, y So -

Susan L. Hiatt OCHE Hepresentative 8275 Munson Rd.

Mentor, OH 44060 (216) 255-3158 e

so L

1

V

, ~

CERTIFICATE OF SERVICE ft j@ 30Hf0 ' I' This is to certify that copies of the fore CITIZENS FOR RESPONSIBLE ENERGY SEVENTH INTERROGATORIES SET OF" go TO NRC STAFF were served by deposit in the U.S. Mail,2first '

class, postage prepaid, this 27th day of Septebp*st b 19S24t0'- r l

those on the service list below, ERANCB Susan L. Hiatt SERVICE LIST Peter B. Bloch, Chairman Daniel D. Wilt, Esq.

Atomic Safety and Licensing Board P.O. Bok 08159 U.S. Nuclear Regulatory Comm'n Cleveland, OH 44108 Washington, D. C. 20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D. C. 20555 Frederick J. Shon Atomic Safety and Licensing Board -

U.S. Nuclear. Regulatory Comm'n Washington, D. C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Comm'n Whshington, D.C. 20555 Stephen H. Lewis, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Jay Silberg, Esq.

1800 M Street, N.W.

Washington, D.C. 20036 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 L-