ML20070T259

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

ML20070T259
Person / Time
Site:	Perry
Issue date:	01/31/1983
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8302080269
Download: ML20070T259 (9)

Text

.

P January 31, 1983 WTED u,. #"""

00CETED UNITED STATES OF AMERICA UW NUCLEARREGULATORYCOMMISSIpNFEB -7 All :07 Before the Atomic Safety and Licensing Board ~

In the Matter of )

)

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

~

) 50-441

) (OL)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

OHIO CITIZENS FOR RESPONSIBLE ENERGY NINTH SET OF INTERh0GATORIES TO NRC STAFF FILED PUdSUANT TO 10 CFR 2.720(h)(2)(ii)

Intervenor Ohio Citizens for Responsible Energy ("0CRE")

hereby files ,its ninth set of interrogatories to the NRC Staff, J .In accordance with this pursuant to 10 CFR 2.720(h)(2)(11[${li t '

provision, OCRE is submitting tne,sel n errogatories to the

- 1; presiding officer and also moves the bresiding officer to require the Staff to answer them. OCHE , hope's that the Staff will volun-tarily answer these interrogatories and thereby avoid unnecessary delay of tnis proceeding and needless burdening of the 'icensing Board. .

In order to require th[e NRC Staff to answer interrogatories under 10 CFR 2.720(h)(2)(ii), a two-fold test must be met: first, that the answers to the interroCatories are necessary to a proper decision in the proceeding, and, second, that the answers to the interrogatories are.not reasonably obtainable from any other aource.

These interrogatories concern Issues 13, 14, and'15, ach

~

of which is based to at least some degree on the Staff's SER 8302080269 830131 A PDR ADOCK 05000440 0 PDR ,

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- - -_ . _ ~ . _

r' for Perry, NURIG-0887. Since the Staff's publications can be said to be the source of OCRE's contentions, it is reasonable to consider answers to interrogatories requesting clarification or further information'on the Staff's positions in those pub-lications to be necessary to a proper decision in this proceeding.

OCHE would also affirm the Board's remarks in its December 23, 1982 Memorandum and Order (Concerning Discovery from the Staff on Eydrogen Issue) concerning the meaning of "necessary" and would suggest that the answers to these interrogatories are just as necessary as are the Staff's answers to interrogatories on hydrogen control.

These interrogatories must be answered by specific persons on the NRC Stkff. Although information from the Public Document Room may provide some background information relevant to the contentions, this type of information cannot substitute for answers, made under oath or aff.~.rmation, to specific interrogatories which concern specific issues in this proceeding. (OChE would again state that simply oecause similar information has been requested of Applicants does not nullify the showing on the second criterion of 10 CFR 2. 720( h) ( 2 )( ii) , i . e . , that the information is not available elsewhere. It is the Staff's answer that OCRE seeks, and this may De vital to a proper decision in this proceeding. )

OCRE thus oelieves that a positive showing has been made on

'coth factors of 10 0?n 2.720(h)(2)(ii); the Staff must respond to these interrogatories.

INTERROGATORIES Issue #13 Statement of

Purpose:

The following interrogatories are designed to ascertain the Staff's reasons for considering the issue of turbine missile protection at PNPP- an open l' ssue in the SER and the Staff's regulatory position on turbine missile hazards.

9-1. Why,has the Staff reopened the issue of turbine missile nazards at PNPP at the OL sthge when this issue was con-sidered resolved at the CP stage? ,

9-2. Has tne Staff made any interim or preliminary findings as to the risk of turoine missile hazards at PNPP7 If so, produce same.

9-3. Why did tne Staff at the CP stage consider the Perry design acceptaole with regard to turoine missile hazards when the Staff's estimates of combined strike probability (1.4 x 10-2/ year) and overall probability for damage (5.5 x 10-7/ year) exceeded the values given in Regulatory Guide 1.115 (1 x 10-3/ year and 1 x 10-7/ year,respectively)?

(The Staff's estimates were stated in Supplement 5 of tne SEH-CP.) i.

9=4. Has the Staff taken any . regulatory position concerning the preferred orientation of turbine generators (i.e. ,

tangential vs. radial) with respect to safety-related structures? If so, produce the document expressing this position.  ?,

s 9-5. Does the Staff have any preferred methods for calculating prooabilities of turbine missile damage? If so, describe any such methods in detail and explain wny they L.e preferred.

9-6. It is stated in '.A Reassessment of Turbine-Generator

• K-Failure Probability" by S.H. Bush,5 Nuclear Safety, Vol. 19, No. 6, Nov.-Dec.1978 at 681 that any reassessment of P , the pro ability of significant damage to components 3

and structubes from a missile strike, must await the completion of jet-sled missile tests sponsored by the Electric Power Research Institute (EPRI). If such tests are now completed, and if the Staff possesses the results of such tests, produce said results, and explain how these results affect prooability calculations for determining turoine missile hazards.

9-7. Explain in detail how the probability estimates given in Supplement 5 of the Perry SER-CP were calculated, 9-8. Explain the bases for the Staff's use of the probability l values (1 x 10-3/ year for comoined strike probability

- and 1 x 10-7/ year for overall turbine missile hazards) given in degulatory Guide 1.115.

I 9-9. Describe in detail each and every portion, statement, or methodology ir GAI Report No.1848, "An Analysis of Low Trajectory Turoine Missile dazards, Perry Nuclear Pov{er Plant, Units 1 und 2," October 1976, which the Staff finds unacceptable or of questionable basis, and indicate why.

i 9-10. If Applicants have suDmitted any other, additional docu-mentation concerning turbine missile hazards, identify such documentation and describe each and every portion of any such documentation which the Staff finds unacceptable or of questionable basis, and explain why.

- Issue #14 Statement of

Purpose:

The following interrogatories are designed to ascertain the Staff's position concerning the use of in-core thermocpuples in BWhs.

9-11. Explain why the Staff no longer requires'in-core thermo-couples in BWhs, as indicated by Section 4.4.7 of NUREG-0887, the Perry SER.

9-12. What types of instrumentation does the Staff consider acceptable for the detection of inadequate core cooling in BWhs?

9-13. Did the Staff at any time have any specific requirements for the placement of in-core thermocouples, for thermo-couple' ~ characteristics or any other criteria? If so, produce same.

9-14. SECY-81-582 states that the ACRS supported the use of in-core thermocouples in BWRs. Does the ACRS support the Staff's new policy of not requiring thenmocouples?

Provide documentation of the AChs position.

9-15. (a) Has the Staff reviewed the document " Therm, .nalysis of In-Core Thermocouples in Boiling Water Reactors" prepared for the BWh Owners Group by S. Levy, Inc.

(November 1981)?

(o) If so, does the Staff agree with the calculations, arguments, and conclusions prcsented therein?

(c) Describe e,try calculation, statement, argument, or conclusion in the document with which the Staff disagrees, or finds unacceptablo or of questionable

F basis, and explain why.

9-16. (a) das the Staff reviewed the document " General Electric Evaluation of the Need for B?lR Core Thermocouples" dated November 16, 19817.

(b) If so, does the Staff agree with the calculations, arguments, and conclusions presented therein?

(c) Describe every calculation, statement, arbument, or conclusion in the document with which the Staff disagrees, or finds unacceptable or of questionable basis, and explain why.

Issue #15 Statement of

Purpose:

The following interrogatories are designed to ascertain the Staff's position and research efforts concerning steam erosion.

9-17. Has the Staff formulated any regulatcry policy, statement, criteria, plans, or other position concerning steam erosion and its effects, causes, prevention, detection, or mitigation? If so, produce same..

9-18. Has the Staff (or anyone to its knowledge or on its behalf) conducted any research or studies in an attempt to determine the causes, effects, and means of prevention, detection, and mitigation of steam erosion? If so, pro-duce any suca researen or studies.

9-19. It is stated in IE Information Notice 82-22 that the Oconee licensee (Duke Power Co.) theorized that reduced power operation and resultant lower quality steam contri-bnted to accelerated steam erosion.

s (a) Does the Staff accept this explanation?

(b) If not, why not?

(c) Define the term " steam quality."

(d) Explain how steam quality is related to the level of power operation.

(e) Explain how steam quality. influences the degree of steam erosion.

9-20. (a) Does the Staff believe that appropriate inservice inspection and maintenance programs of licensees can detect or mitigate the effects of steam erosion?

(b) Explain the bases for the answer to (a), above.

(c) What does the Staff consider to be an " appropriate" inservice inspection or maintenance program?

(d) What measures (regulatory and enforcement) can be taken to insure that inspection and maintenance programs will be adnered to?

9-21. (a) Has the Staff identified any deficiencies in the 1

i inservice inspection or maintenance programs of the licensees mentioned in IE Information 1. ces 82-22 and 82-23 with respect'60 the ability of these programs to detect or mitigate steam erosion?

(b) If so, thoroughly describe any such deficiencies.

(c) Describe any enforcement action which may have been taken against the licensees mentioned in IE Infor-mation Notices 82-22 and 82-23 (or any other licensee) as a result of steam erosion problems.

c, General Interrogatories 9-22. For each interrogatory above, identify the person res-ponsible for the answer, and provide his/her professional qualifications.

9-23. Identify all documents relied upon in answering the above interrogatories, and produce all such documents not

.available in the NRC's Public Document Room.

9-24. If there are any persons on the NRC Staff who disagree with the answers given to the above interrogatories, identify each such person and describe the nature and extent of the disagreement.

Respectfully submitted, Y

Susan L. Hiatt OCHE Representative 8275 Munson Rd.

Mintor, OH - 44060 (216) 255-3158

W CERTIFICATE OF SEhVICE This is to certify that copies of the foregoing OHIO CITIZENS FOR HESPONSIBLE ENEhGY NINTH SET OF INTEhh0 GAT 0 HIES TO NhC STAFF FILED PURSUANT TO 10 CPR 2.720(h)(2)(ii) were served by deposit in the U.S. Mail, first class, postage prepaid, this R/31 day of January 1983 to those on the service list below.

2 Susan L. diatt SERVICE LIST Peter B. Bloch, Chairman Atomic Safety & Licensing Board Daniel D. Wilt, Esq.

U.S. Nuclear Regulatory Comm'n P.O. Box 08159 Washington, D.C. 20555 Cleveland, On 4410e Dr. Jerry R. Kline Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Mr. Glenn 0. Bright Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 sq.

0$ceofthe xe'cu i've Legal Director U.S. Nuclear Regulatory Comm'n ,,

Jay Silberg, Esq.

1800 M Street, N.W.

Washington, D.C. 20036 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear hegulatory Commission Wushington, D.C. 20555