ML20067D385

Answer Supporting NRC 821109 Motion for Summary Disposition of Issue 5.Break in Piping of Scram Discharge Vol Would Not Cause Unrecoverable Loca.Related Correspondence

ML20067D385
Person / Time
Site:	Perry
Issue date:	12/03/1982
From:	Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20067D388	List: ML20067D385 ML20067D405
References
NUDOCS 8212130241
Download: ML20067D385 (2)

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December 3, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' ANSWER IN SUPPORT OF NRC STAFF'S MOTION FOR

SUMMARY

DISPOSITION OF ISSUE NO. 5 On November 9, 1982, the NRC Staff filed a motion for sum-mary disposition of Issue No. 5. Included with the motion was a Statement of Material Facts As To Which There Is No Genuine Issue To Be IIcard. The motion was supported by the Affidavit of Nicholas E. Fioravante.

Issue No. 5 alleges that:

Applicant has not demonstrated the safety of its reactor from an unrecoveiable loss of coolant accident, which could occur from a pipe break in the scram discharge volume.

See NUREG-0785.

As set forth in the Staff's Statement of Material Facts and in the Fioravante Affadavit, a pipe break in the scram discharge volume at Perry would not lead to an unrecoverable loss of coolant accident.

The facts set forth by the Staff are fully supported by the attached Affidavit of Monty A. Ross, a manager in the Plant Systems Ohohkko .'

PDR t i

Design organization of the General Electric Company. Mr. Ross was General Electric Company's lead technical contributor to the eval-untion of the NUREG-0785 concerns regarding scram discharge volume pipe break. As with Mr. Fioravante's affidavit, Mr. Rosa' state-ment demonstrates that the scenario described in NUREG-0785 is not applicable to the design of the Perry reactors and that a break in the piping of the scram discharge volume, even if it did occur, i would not cause an unrecoverable loss of coolant accident.

For these reasons, Applicants respectfully request that the NRC Staff's Motion for Summary Disposition of Issue No. 5 be granted.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE f

BY: ~

/k AY E. SILBERG, P.7 ounjielforApplicahts 1800 M Street, N.W., Ste. 900tS e Washington, D.C. 20036 l (202) 822-1063 DATED: December 3, 1982 l

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