ML20070F036
| ML20070F036 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/15/1982 |
| From: | Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20070F039 | List: |
| References | |
| NUDOCS 8212200061 | |
| Download: ML20070F036 (3) | |
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q$P December 15, 1982 37 [EP,16 N UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing board 5
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)
)
APPLICANTS' ANSWER IN SUPPORT OF NRC STAFF'S MOTION FOR
SUMMARY
DISPOSITION OF ISSUE NO. 4 On November 5, 1982, the NRC Staff filed a motion for summary disposition of Issue No. 4.
Included with the motion was a Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard.
The motion was supported by an' Affidavit of S.
B. Sun.
Issue No. 4 alleges that:
The safety of the Applicant's emergency core cooling system has not been demonstrated with appropriate experimental data because a full scale 30 degree sector steam test has not been performed.
The Special Prenearing Conference Memorandum and Order, LBP-81-24, 14 N.R.C.
175 (1981), also stated that the 30 degree sector steam test 1 503 8212200061 821215 PDR ADOCK 05000440 0
a l
' appears to be required by Appendix K [to 10 CFR Part 50], Part I,,1D6, which requires that " convective heat transfer shall be cal-culated using coefficients based on appropriate experimental data".
14 N.R.C.
at 216.
The Staff's Statement of Material Facts and Dr. Sun's affidavit demonstrate that the 30* sector steam test is not speci"ically required by Appendix K, that General Electric has in fact performed the 30* sector steam test for a simulated BWR/6 core, and that the distribution of core spray flow (the subject of the 30' sector steam test) is not a safety issue for Perry since there will be adequate core cooling even if all of the water from the core sprays bypasses the fuel rods.
The facts set forth in Dr. Sun's affidavit and the Staff's Statement of Material Facts are fully supported by the att"7hed Affidavit of Dr. W. A.
Sutherland, manager of General Electric Company's LOCA Systems Te,chnology organization.
,Dr. Sutherland' was responsible for core spray design methodology development, spray nozzle testing and the program to confirm the core spray design methodology at the Sector Steam Test Facility.
Dr.
Sutherland's Affidavit describes General Electric's core spray design methodology, the 30* sector steam test facility and the results of those tests.
As Dr. Sutherland po.ints out, the 30*
sector steam tests confirmed GE's core spray design methodology.
l Dr. Sutherland's Affidavit also responds to the criticisms and,
l
questions raised by intervenors during the course of the dis-covery process and denonstrates that none of these raises any substantial questions concerning the 30* sector steam tests or the core spray design methodology.
Perhaps most importantly, Dr. Sutherland's Affidavit confirms Dr. Sun's conclusion that core spray distribution at Perry is not a safety issue.
For all these reasons, Applicants respectfully request that the Staff's motion be granted.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE I'
BY:
A, f/
YfE. SIL' BERG, P.g '.
J Counsel for Applicants Suite 900 South 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1063 DATED:
December 15, 1982 l
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