Similar Documents at Perry |
---|
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 ML20217J0661998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Dqe, Inc & Allegheny Power System,Inc ML20216G3821998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Duquesne Light Co & Allegheny Power Systems,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 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 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 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 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 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 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 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 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 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 1999-09-30
[Table view] |
Text
.- -
UW?*
December , @8h
- 1. c m sE v ar 1 '
Tjj s SEggr UNITED STATES OF AMERICA ""Ni NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
THE CLEVELAND ELECTRI;C ) Docket No. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441
)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
APPLICANTS' ANSWERS TO SUNFLOWER ALLIANCE, l
INC. ET AL. SECOND SET OF INTERROGATORIES, NOS. 20, 28 and 31 Pursuant to the Licensing Board's November 8, 1982 Memorandum and Order (Concerning Motion to Compel: Standby Liquid Control System), Applicants file these answers to Interrogatories 20, 28 and 31 from the second set of interrogatories to Applicants filed I by Sunflower Alliance, Inc., et al. on April 30, 1982.
In addition to the answers set forth below, Applicants will -
make available for examination at Perry Nuclear Power Plant ("PNPP")
a copy of SOP-C41, the draft system operating procedure pertaining 1 1/
Ohio Citizens for Responsible Energy ("OCRE") has replaced Sun-flower Alliance as the lead intervenor for Issue No. 6, to which these interrogatories are addressed. See Memorandum and Order (Concerning Procedural Motions), dated September 17, 1982.
l l
r
] 8212160251 821213 PDR ADOCK 05000440 0 PDR OD
to the Perry standby liquid control system ("SLCS") that was furn-ished to the BWR Owners' Group during its evaluatiod of the Perry control room in January 1982. See Memorandum and Order, November 8, ,
1 1982, slip og. at 4. Arrangements to examine the draft procedure can be made by contacting Mr. Ron Wiley of The Cleveland Electric Illuminating Company at (216) 259-3737. At OCRE's request, Applicants will provide a copy of the document at Applicants' cost of duplication. Arrangements for obtaining a copy of the document can be made with Mr. Wiley. o RESPONSES
- 20. Describe in detail the manual scram capabilities at PNPP.
What is the sequence of operation? What is the speed of rod in-sertion? How much time clapses from the initiation of the manual scram until its completion? When is manual scram used?
Response
The Perry design provides actuation circuitry and operator controls to effect a manual scram of the reactor. The manual scram system is designed to perform the same function as the automatic scram system, namely, the simultaneous insertion of all control rods into the reactor core. The Perry physical design for manual I scram includes three separate controls that the operator can use to effect a manual scram. All of these controls are located on the operator's main control panel in the control room. The first consists of a set of four push button manual scram switches. The second control capable of initiating a manual scram is the reactor system mode switch. The third control is a set of four push button redundant reactivity control system ("RRCS") switches.
1
O V
l The four push button manual scram switches are connected to l
the four channels of the Perry Reactor Protection System ("RPS"). l The actuation circuitry for this system is described in 57.2.1.1.11 of the Perry FSAR. To perform a manual scram using this method, the operator would activate all four switches by turning the collar !
on each switch to the " arm" position and depressing the push button for each switch.
The reactor system mode switch is a four position switch which establishes the conditions under which the reactor may nor-mally operate. When the operator places the switch in the shutdown position, a scram signal is actuated which is designed to insure that all control rods are inserted into the core. See Perry FSAR S7.2.1.1.12.
The RRCS is one of the Perry systems used to mitigate the potential consequences of an ATWS event. The four push button RRCS switches are connected to two channels in each of the two redundant divisions of the RRCS. To perform a manual scram using this method, the operator would activate all four switches by turning the collar on each switch to the " arm" position and depressing the push button for each switch. The actuation circuitry provides that only two channel switches from the same division are required to activate the manual scram. Depression of all four switches thus provides redundant scram actuation capability.
Whenever plant conditions reach automatic scram limits, the automatic scram system will be initiated and the control rods will be inserted into the core. In addition, when control room indica-tors show plant conditions requiring a scram, the operator will i
e
e l
}<
turn the reactor mode switch to the shutdown position. In these circumstances, the operator will perform this action whether or not the control indicators show that an automatic scram has occurred.
Thereafter, if the average power range monitors ("APRMs") on the main control console indicate that scram has not occurred, the operator would immediately arm and depress the four manual scram switches as a backup procedure to effect scram actuation. If the APRMs indicate that scram still has not occurred, the operator would then immediately arm and depress the four RRCS switches as c a second backup procedure to effect scram actuation. -
Plant technical specifications and operating instructions, which are currently being written, will describe other situations in which manual scram would be used. In all of these situations, manual scram would be accomplished by using the four manual scram switches, with the reactor mode switch as a primary backup in-itiating method and the four RRCS switches as a secondary backup initiating method. In addition, the training program for Perry operators instructs operators that the manual scram system should be activated whenever in the judgment of the operator a reactor scram is warranted to protect the public health and safety or plant personnel or equipment.
The average speed of rod insertion using either the four man-ual scram switches or reactor mode switch for initiating scram is approximately six feet per second. The average speed of rod inser-tion using the RRCS method is approximately 1.2 feet per second.
With the first two initiating methods, two seconds would elapse from
(
l
.e the initiation of the manual scram until all rods are fully inserted I into the reactor core. Using the RRCS method, approximately 25 seconds would elapse from initiation to full rod insertion. This includes a 15 second delay before the start of control rod insertion.
- 28. What provisions will be made to ensure that, after SLCS activation, the boron will not be diluted by the ECCS to such an extent that recriticality may occur (see NUREG-0460, V.ol. 4, P. A-69)?2/
Response: ,
There is no differential risk that boration would be defeated by subsequent dilution when a manual SLCS is cmployed, as contrasted to when an automated SLCS is employed.
- 31. Has the use of different chemicals as neutron poisons, e.g., gadolinium, been investigated? If not, why not? If so, with what results?3/
Response
Applicants are not aware of any investigations of the use l
of different chemicals as neutron poisons for light water reactor 2/
In its decision on OCRE's Motion to Compel, the Licensing Board ruled that "[i]n response to interrogatory 28 applicant should i
provide information on the differential risk, if any, that boration would be defeated by subsequent dilution when a manual SLCS is employed , as contrasted to when an automated SLCS is employed." Memorandum and Order, November 8, 1982, slip op. at 3.
l i 3/
l In its decision on OCRE's Motion to Compel, the Licensing Board ruled that " applicant should respond to interrogatory 31 by explaining whether the expected cost of inadvertent activation of an automated SLCS could be reduced by using a different neutron poison, other than boron." Memorandum and Order, November 8, 1982, slip op. at 4.
-- w ,e- - - - --- - ------..---e. -,,---w- , , - , - . - - , - - - - - - - - - - - , , . - --- ,.- - - - - - - , - - , - . ,y -- - - - - - -
l l
l SLCS applications. Applicants have no information as to whether the expected cost of inadvertent activation of an automated SLCS would be reduced by using a neutron poison other than toron. The nuclear industry has had extensive experience with boron, which has been demonstrated to be an effective neutron poison. The compatability of boron with water and boron's material and metal-lurgical effects are now understood. Because of this experience, Applicants did not consider other neutron poisons. o Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: Iv1 Jay (ilbedg, P.C. ]
Har HI Glasspiegel /
l Counsel for Applicants 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 Dated: December 13, 1982 i
e :
l l
THE CLEVELAND ELECTRIC ILLUMINATING COMPANY CLEVELAND, OHIO Robert A. Stratman, being duly sworn according to law, deposes that he is General Supervisor, Nuclear Services Section of the Cleveland Electric illuminating Company and that the facts set forth in the foregoing Applicants' Answers to Sunflower Alliance, Inc. et al, Second Set of Interrogatories, Nos. 20, 28 and 31, dated December 13, 1982, are true and correct to the best of his knowledge, information and belief.
i fJ Sworn to and subscribed before me this /J d day of 6464 ntj u. L. / 9 l l W kL-sts / N VV
.=
- a. es , . y a g [g*Ldddh g hh, ghp,I' M . U,IN
e r
December 13, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board c
In the Matter of } _
)
THE CLEVELAND ELECTRIC ) Docket No. 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' Answers To Sunflower Alliance, Inc. et al. Second Set Of Inter-I rogatories, Nos. 20, 28 and 31"were served by deposit in the United States Mail, First Class, postage prepaid, this 13th day of December, 1982, to all those on the attached service list.
% - 55 HARRY H. GLASSPIEGEL ' F DATED: December 13, 1982 1
i
a
,)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
THE CLEVELAND ELECTRIC ) Docket los. 50-440 ILLUMINATING COMPANY ) 50-441
)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
SERVICE LIST Peter B. Bloch, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel U.S. Nuclear Regulatory Conmission U.S. Nuclear Regulatory Commissio$
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 Commissio9 Washington, 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 Commissiod Washington, D.C. 20555 Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt Appeal Board OCRE Interim Representative U.S. Nuclear RE.alatory Commission 8275 Munson Avenue Washington, D.C. 20555 Mentor, Ohio 44060 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.O. 20555 Donald T. Ezzone, Esquire Assistant Prosecuting Attorney Gary J. Edles, Esquire Lake County Administration Center l
Atomic Safety and Lipensing - 105 Center Street Appeal Board Painesville, Ohio 44077 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 John G. Cardinal, Esquire Prosecuting Attorney Atomic Safety and Licensing Ashtabula County Courthouse Board Panel Jefferson, Ohio 44047 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Terry Lodge, Esquire 915 Spitzer Building Toledo, Ohio 43604
.