ML20079R133

Answer to First Set of Interrogatories Re Pressurized Thermal Shock in BWRs

ML20079R133
Person / Time
Site:	Limerick
Issue date:	06/15/1983
From:	Lewis M LEWIS, M.
To:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
REF-GTECI-A-49, REF-GTECI-RV, TASK-A-49, TASK-OR NUDOCS 8306220043
Download: ML20079R133 (2)

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ANS'4ER TO APPLICANT"S FIRTT SET. OF INTERROGATORIES TO MARVIN I. IE4IS. 43er-4 7 Intervenor Iewis received above request and Interrogatories on 6-.6-83. How #3 domument was dated 6-3-83 Considering AIJ Brenner's schedule,14 days for answer requires that I answer by LSMail by'6-20-83.

I have great difficulty picking up Express Mail. If you believe that the document rust be sent Express , also send a copy by First Class. I will start the schedule count from the document that I receive first. I prefer that all documents be sent First Class. It is chaeper and faster than Express for me.

Interrogatory 1. Answer: I do not presently - intend to call any expert witness.

However, I respectfully reserve my right to call expert witnesses. I shall send the requested information on witnesses as soon as I determine that I shall have an expert witness.

Interrogatory 2. Answer  : I do not depend on any document as a basis that FIS is a problem in RS. Conversely, I do depend upon many documents to show in the negative tha , s not been considered a problem in B'4Rs and therefore has not been investigated sufficiently in BWRs.

If you wish the documents for the negative of this interrogatory please state so in your second round of discovery.

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i Interrogatory 3. Answer : See answer to Interrogatory 2.

l Interrogatory 4 Answer: This contention is not based upon any study or calculation. The research and analysis is mine and it leads me to tre conclusion I that no- , numerical study or calculation has been performed to prove that FTS is not a problem in B'4Rs.

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l Interrogatory 5 Answer: I have had conversations with various individuals'and experts, but the contention and answers to hterrogatories are mine.

Interrogatory 6. Answer: I do not know of any GDC or Ngulabby requirement that woul d not apply. However , the most important requirements would be the GDCs that involve the reactor pressure temperature boundary GDC31 thru 45 and Appendix G. Any regulatry requirement that involved theRPV wall and the assurance of a pressure temperature boundary would apply. That is because FPS endangers the RPV wall arxi temp pressure boundary.

Interrogatory 7. , I don't know. I will try to determine mi send info when I find out.

Interroagtory 4. nswer: From 1-1 of Enclosure A t6 SECY 82-465

" Transients can occur in IMR s characterized by severe overcooling causing thermal chock to the vessel, concurrent with or followed by repressurization(that is, PTS)"

The remainder of the quote is not necessary to my definition of FTS.

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rHMA, fm I.CM Interrogatory 9. Answer: Generally , I assert that not enough or no actum1 numerical calculations have been made to determine that FIS is not a danger to integrity of BWR's. In other words, my basis for my contention is a lack of basis for the NRC and Licensee's answers ** that PIS is not a problem

• in BWRs.

I also assert that the NRC ard the Licensee has not explored all the pertinent modes and operational emergencies that could possibly cause the Limerick reactor to be endangered by FFS.

Again the Applicant requests that the intervenor point to concrete examples , and I reply that the contention exists because of a lack of concrete examples, studies analysis and calculations.

Interrogatory 10 . Answer:Again the contention exists because the pc and applicant have not performed these studies. See answer to {nterrogatpery 9 Interrogatory 11. Answer : The neutron flus that would have to exist in the Limerick i reactor would have to be sufficient to degrade the actual materials used in the I

construction to the point where they would be sufficiently embrittled so that they

'would fail during a transient involving a temperature pressure gradients found in Limerick during such a transient.

Interrogatory 12. Answer: Same answer as Interrogatory 9 and 10.

Interrogatory 13. Answer I know of no such incidents in BWRs. However, are we supposed to ignore danger until we have another TMI#2 accident?

Interrogatory 14 Answer . Again I state that this contention rests upon a l

lack of facts and studies and work and not upon any specific fact or study.

Again I state that this contention would not be in ite present form if the

. licensee, NRC or various Boards were doing their homework and looking at the dangers apparent in IHRs.

General Answer toall interrogatories: The Applicant has asked for studies and analysis wh%h show that FIS is a problam in BWRs. I respectfully point out that if the Applicant knows of such studies it is his duty to bring them to the attention*

of the NRC staff and Board mostly under the requirenants of 10CFR Part 2).

I shall have this in the mail to the present Limerick Mailing List including *

updated addresses. * '

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M I Certify that this will be mailed on on-hmtase 6-1M.

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