ML20114A629

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Motion to Revise Wording of Issue 8 Re Hydrogen Control, Aligning Wording W/True Intent & W/Commission New Hydrogen Control Rule for Degraded Core Accidents.Certificate of Svc Encl
ML20114A629
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 01/22/1985
From: Hiatt S
OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
Atomic Safety and Licensing Board Panel
References
CON-#185-260 OL, NUDOCS 8501280324
Download: ML20114A629 (19)


Text

{{#Wiki_filter:n. -. 1 ' pho i } January 22,'1985 E, ' UNITED STATES OF AMERICA E[U-NUCLEAR REGULATORY COMMISSION N '23 U. BeFore the Atomic Sofety and Licensing Board

q In the Motter of

) 1 ~ ' THE CLEVELAND ELECTRIC Docket Nos. 50-440 OL. ILLUMINATING CO. ET AL. ) 50-441.0L,-t ) 's (Perry Nuclear Power Plant, ) Units 1 and 2) ) MOTION TO REWORD ISSUE M8 1 Intervenor Ohio Citizens for Responsible Energy ('0CRE') 'hereby moves to revise the wording of Issue N 8, on hydrogen control, so os to clign its wording witn its true intent and Ewith the Commission's new hydrogen control rule for degraded core occidents. This~ motion is necessitated by Applicant and Storf, who, in .o complete reversal of their previouw pos tions, have seized upon the. incorrect wording of Issue M8 in a baseless attack.on this vital safety issue by claiming that the Commission's new

  • hydrogen rule and Applicants' use of a distributed igniter g'

? system purporting'to meet the requirements of said rule require that Issue M8 be dismissed, as its erroneous wording only mentions recombiners. Tr. 1990, of December 7, 1984 conference j,0 . coll. The Board's action is required to end this senseless i controversy 50 that the litigation of-Issue #8 con proceed on w. its merits. 115 \\t GBILO Issue NS is presently worded as follows: Applicant has not demonstrated that the manual operation of two recombiners in each of the. Perry units is adequate to assure .that'large amounts of hydrogen, con be safely accomodated without

l -g-I o rupture of the containment and a release of substantial i quantities of radioactivity into the environment. This is the Wording that was adopted by the Licensing Board in its March 3, 1982 Memorandum and Order admitting the contention. The references to manual operation of recombiners resulted from the intervenor's analysis'of the adequacy of the only' hydrogen control systems identified in the F5AR at the time the' contention Was submitted. After the contention was admitted, Appliconts announced that o distributed igniter system, which consists of diesel engine glow plu9s Placed throughout the containment and drywell, to be energi ed during and ofter o degraded core occident, for the purpose of supposedly burning off the hydrogen at low concentrations, would be used for hydrogen control at Perry. See ALAB-675, 15 NRC 1105, 1116, wherein the Appeal Board Stated that the Licensing Board should, before proceeding further with the conte 9 tion, determine the effect this chon92 in Applicants' system would have on the contention. 'It Wos OCRE's interpretation of this passage that the next move on Issue M8 Would be up to the Licensing Board. That determination, however, Was never mode, and soon become ov'ershadowed by a controversy raised by the Staff orising out of another ' instruction

  • of the APfeol Board in ALAB-675, involving the specification of a credible TMI-2 type occident scenario.

In its March 3, 1983 Memorandum or.d Order the Licensing Board deferred the question of specifying on occident scenario ..d e m_.

as it then seemed that the new hydrogen control rule would be issued soon. Indeed, in its March 31, 1983 Memorandum and Order, the Board stated all further work on Issue N8 (including its rewording, first sought by-0CRE in February 1983) would not be productive until either the new hydrogen control rule was 'ssued.or it become evident thot the rule had been deferred. (1) i On December 10, 1984, the Commission voted to opprove the Jhydrogen control rule for PWR ice condenser plant and BWR Hork III plants. According to Stoff counsel's letter to the Board dated December 10. the version of the rule opproved was that contained in SECY-83-357A, with some modifications os to implementation dote. t By letter dated January 16, 1985, stoff counsel provided to the Board and parties the implementation modifications opproved by the Commission. OL opplicants must have o hydrogen control system. Justified by o' suitable program of experiment and analysis, capable of handling the amount of hydrogen resulting .from o-75% metal-water reaction without loss of containment (1) In September 1984 Applicants.ottempted to revive the Stoff>s argument that a credible occident scenario had to be specified before proceeding with the issue, on the grounds that the hydrogen rule had been deferred. Since that rule has now issued, Appliconts' motion must now be denied as moot. t . --_ _._ ~ l

r integrity, before 5% power operation. Since the appropriate criteria for hydrogen control are now those contained in the new rule, OCRE moves that the wording of Issue M8 be changed to: Applicants have not complied with 10 CFR 50. 44 (c) (3) (iv), (v), and (vi), in thot: A. the Perry hydrogen control system has not been-Justified by a suitable program of experiment and onolysiss B. the Perry hydrogen control system is not capable of handling the amount of hydrogen generated from o 75% metal-water reaction without loss of containment integrity 1 C. Structural integrity of the Perry Mark III containment has not been demonstrated by a technique that odequately describes the containment response to the structural loads involveds Sp'D,,' systems and components inside the contoinment necessary to establish and maintain safe shutdown and to maintoin containment integrity are not capable of performing their functions during and ofter exposure to the environmental conditions created by the burning of hydrogen, including those environmental conditions caused by local detonations of hydrogen; E. AP,plicants have not analyzed sufficient and oPPropriate occident scenarios involving hydrogen generation from a metal-Water reaction (up to and including o 75% metal-water. reaction), and their scenarios (and evoluotions thereof) do not adequately describe the behavior of the reactor system during and following

o. degraded, core occident.

The reasons for OCRE's belief that' Applicants cannot meet the new hydrogen control rule are those contained in OCRE's answer to Applicants' Interrogatory ~#10 in OCRE's Updated Response to Applicants' second Set of Interrogatories to OCRE, filed contemporaneously. During the December 7, 1984 conference coll. Applicants and Stoff claimed that any rewording of Issue.M8 would be tantamount to a new. late-filed contention subject to the requirements of 10 CFR 2.714. Tr. 1190-1192. (2) This view neglects the I f "iW- %9'*-m -e w - & & wMQ ,,a M.m

history of Issue N8 and is a radical departure from previous Stofr, and Applicant positions. When admitting Issue W8, the Licensing Board specifico11y stated its belief that 10 CFR 50.44 will be more stringent by the. time PNPP wi11 be ready"to operate. Tnis belief wAsin f o'5t'~' ~~ ~ one of the Board's reasons for admitting the issue. March 3: 1982 Memorandum ond. order at 8. .The Board's two March 1983 Orders also indicated its great reliance on the new hydrogen rule os the basis of Issue M8. Therefore, a rewording of Issue N8 so os to olign it with the Commission's new hydrogen rule connot possibly be construed as eXPonding the issue beyond what - was originally admitted. OCRE-first formally sought rewording of Issue M8 in February 19833 OCRE's motion was deferred pending issuance of the new hydrogen rule. H5 Wever, the Effect of Issue N8's Wording in light of the 2. . Applicants also stated that the issue would be beyond the scope of this proceeding due to the scheduling provisions of.the rule. While OCRE will thoroughly address this Point in its response-to the motion for dismissal which Appliconts intend to file, it con be stated here that such on argume7t is a distortion of low and fact, and the Licensing Board will be violating the Atomic Energy Act and numerous Commission and Appeal Board directives should the Board side with Applicants. .. ~.. ~*-5,---+-

distributed igniter system used by Applicants for degraded core occidents was touched upon informally on two previous occasions. At no time did either Staff or Applicants raise the objection -that Issue NS is limited to recombiner odequacy and that igniter. i odequacy is beyond the scope of the issue and requires a new q contention, os they do now. During the August 13, 1982 conference call OCRE raised the question or rewording Issue M8. Tr. 743. OCRE's specific concern at that time was that discovery might be. limited to recombiners if the issue were not reworded. Tr. 744. The Board's response was that it ordered Issue M8 to be interpreted in light of the ALAB C-675] decision (id.); although this was not explained, it is apparent that the Board d i'd not consider Issue N8 limited to recombiners. Applicones did not object to this ' order.' Tr. 745. Nor did Applicants object to interrogotories posed by OCRE concerning the distributed igniter system (e.g., Interrogotories 5-10, 5-11, 5-12, 5-13, 5-14, 5-15, 5-16, 5-17, 5-18, 5-22, 5-29, 5-47, 5-67 also, much of OCRE's 13th Set deoit W i '; h analyses of the distributed igniter system). Applicants ho've frequently objected to interrogatories on other issues which they felt stroyed from the strict Wording of the issue,_but.no such objections were seen here. In fact, Applicants posed on interrogatory on igniters (Interrogatory N10 of Applicants' 2nd Set to OCRE, dated Sept. 22, 1982), to which OCRE did not object., f j %.. +

] l

  • Likewise, OCRE posed interrogatories to the NRC Staff concerning igniters _(Interrogatories 6-16, 6-17, 6-18, 6-24),

+ that Issue M8 ond no specific objection to these on the ground , concerned recombiners only was ever voiced (although the Staff i -did object to answering all of OCRE's 6th Set to Staff on other grounds and was overruled by'the Board). The lock of objections tocit admission that the to interrogatories on ignikers is o scope of Issue,M8 is brooder than its wording,

===->-=*e =w-This controversy was briefly addressed, but not resolved, in the November 15. 1982 conference coll, where'in the Board posed a question to Appliconts and Starr regarding the adequacy of the PNPP ' hydrogen suppression system.' Tr. 768. The chairman then asked Applicants what hydrogen control hould be used. Tr. 769. Applicants declined to answer the first question, as t h t' 4 incomplete, but did state dlstributed ignition system design was that Tacombiners would not be adequate for the degree of hydrogen generation specified by the Board. Tr. 773. This would have been on ideal opportunity for Applicants and Stoff to raise the object.on they claim now, that Issue #8 is limited to-recombiner adequacy, but no such objections were mode. Having foiled-to raise this objection at the earliest opportunities, Applicants and Stoff connot now be heard. There'is yet further evidence that the NRC Stoff did not J9 l' consider' Issue M8 limited to recombiner adequacy. Exhibit 1 L. _a

c- _g_ consssts of material token from Congressional oversight hearings 4 6 'before the House Subcommittee on Energy and the Environment. In b response to questions posed by the Committee chairman, NRC . Chairman-Fo11odino provided as on ottochmeric to his prepared 3 testimony a list of the contested issues in operating license proceedings. The list for Perry is included. It should be noted that, while the numbering of the issues does not track. 'those the Board hos assigned the issues, the wording of the issues closely follows that used by the Board. e .The only exceptions are Issues 1 and 8 (numbe r 7 in the list). t The mistake on Issue M1 is probably attributable to its incorrect wording, which the Board recently corrected (see-i below). The NRC's representation of Issue N8 to Congress,. however, mentions nothing about recombiners, but merely statas " adequacy of containment hydrogen control measures.' Obviously NRC.monagement-does not consider Issue M8 to be limited to its erroneous wording, i The history of' Issue N8 clearly demonstrates that no one t (Staff, Applicants, OCRE, or Board) ever believed that Issue j i N8 was limited to recombiners. Since the admission of the contention was tied to the Commission's rulemaking, the filing of this motion is on oppropriate action now.that that rule if i-final. Thus, this motion connot possibly be construed as l' Qeeking.odmission of o new or lote-filed contentions the 5 .J factors lof 10 CFR 2.714 ore not opplicable. 1 The action sought by OCRE is merely that of oligning the I. L.

e: Wording of Issue MS with what everyone hos believed to be its ' scope. This is entirely analogous to the Board's action in its July 26, 1984 Memorondum and Order (Particulari=otion of -Emergency Plonning contention), rootnote' 1.- Therein the Board changed the Wording of Issue #1, which was erroneous. to match what had been challenged by the intervenor. No one has claimed that the Board's action made Issue M1 o new or late-filed contention. The Board should find it as easy to change Issue

  • gs.true scope.

M8's - Wording to fit i OCRE Proys.th'ot.the.Boary.is so moved,, Respectfully submitted, Susan L. Hiott OCRE Representative 8275 Hunson Rd. Mentor. OH 44060 (216) 255-3158 i .= m _

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k%t)') $~ W G? ="%":::.;P I, ed.)& E'~4.:.= Q i) - - - ~ 2T CN THE ~~ ' {'. I e g p THE "NRC The Honorable Nunsio Palladino ..d F tr.M1', P Q 4.! N,,i i d' 7,Ml t Chairman united States Nuclear Regulatory Commission ' i THE Washington, D.C. 20$55 4.yF-@l bJ-y/ D*** " Ch*I'"*"'

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!riUCLEAR The Subcommittee on Energy and the Environmentin an oversight l' Yk 't WY 1984 Commission to participate on February 9, fiscal years 1984 and 6hjhp i-hearing on the NRC's Dudget request for i ?' 0.,4t NO CHANGES

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As you know, on May 11, 1983 the House Interior Comaittee pl .f c ;i favorably reported a bill (H.R. 2510s Report 98-103, Part 1) i 1984 and FY i,g' (,8, 10LE. 'l tl? authorizing appropriations for the NRC during FYthe House, and a '/D in )N'* legislation still is pending 1985. That is under active consideration in the Senate. i the Congress will complete action on this d'y. b' / companion bill

  • It is my hope that MIC s tIO'-

The hearing on February 9th legislaton sometime this Spring. will provide an opportunity for the subcommittee to review M M (,'* recommendations included in 4 Report 98-101, Part 1. The Subcommittee will be interested to ) .DETAILET with the Commission the budget thinking on the applicability at ryhh py.'" .ag i. g h.';, hear the Commisson's carrent agency's funding needs during the l' p ",5 4 Jg those recommendations to thefiscal year 1984 and during fiscal year 1985. utkE3 LLRING res.ainder of if the it would be helpful to the Subcommittee In addftion, Commission's written testimony addresses the questions f,;,e U s., .AT!vE P.EANS 6i - and in keeping with Committee rules, please h [q( hy'j attached to this letter. i j gh .Ei,1l. iton. CUR As in the past, file a written statement of the Commission's proposed b y Gi ) least 24 hours in advance 41; Qt 3 testimony with the subcommittee at Also, please be prepared pd ,O' )? of the hearing on February 9, 1984. 451 DERAT 10N OF at the hearing to make a brief oral summary of the @t,'t The Subcommittee also statement. Commission's writte. welcomes any separate or dissenting remarks that might be p 4

0T INCLUDED IN offered by individual commissioners;,.

e'. :. - 1 N si, 'a f+7,.,., 45 a.m. on February 9, The hearing is scheduled to begin at 9: I appreciate y b, in 1327 Longworth House Of fice Building. your attention to these matters, and look \\, forward to your 1984 seating with the Subcommittee. g ted ulp,E. [I Sincerely, th h i he p.c-{g, MORRIS K. U Da f F- . k, ' 2 p,p' l fif., b !T $ f)'. kl, A Rb &$;6..

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. Q. hazards! h I i QUESTIONS ATTACHED TO CHAIRMAN UDALL*S JANUARY3 / LETTER TO THE NGCLEAR REGU!ATORY COMMISSION 5 generat k 11.. I 11. What er ((NN I I E__ ) Wh.at are the views of the individual commissioners on the 'gJjf' l' whethorl f '$1- . _d h. ! 1. need to extend the Commission's authority to issue j i allowed' r j , ;g q j,. temporary operating licenses? yJ [ ,j MI,N 12 71 ] When was the Commission informed that NRC staff had - ' nji '!3f,M ~. What er whetherj h 'I l j d ordered a reinspection of the Byron nuclear station? Atomic Safety and Licensin'gi ?.M ' be allo 2. y ,(, f I (J Prior to the January 13, 1984 UT . ]t ',, P. ' 13. For all that the Board, J ( Board decision, was the Commission aware A i regarded the successful completion of that reinspection j [N but no hT { j l' to be a necessary condition for the issuance of an 4 which e A *l' y .1 licenso operating license? ') Y"'d'* j. 5 '1 3 Environ '?, i e >! 'f is the present status of the NRC's response to the y' ' g' (estima l m @4 questions regarding the Waterford nuclear plant posed by What 3. The Cambit_ in October 31, 1983 letters to Mr. Richard

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.~ q ;h (j s ] f each pu ,O J y DeYoung (Director, Office of Inspection and Enforcement),

== k.* - publi.: 'q r a J .O N y, and Mr. John Collins (Administrator, NRC Region IV)? W, b' emergien h I d licente 'p ! What are the views of individual commissioners on the NRC [h)_ complet N'Oj d [b 4 [ f staff's proposals to change emergency planning.

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} 4. p;. 5 constr ) j regulations to require a " graded response" within a T date o I j N t"kg 7, t.,, } ten-mile radius of commercial nuclear reactors? N f/kii estima. j; t n ,3 $b d f is the status of the Commission ls study' of existing ,j g, 9,. j f' g$ : ' and alternative programs for improving quality assurance What 5. hg fi r and quality control in the construction of commercial Y i .i> nuclear powerplants which was required by Section 13 of m'Mp [h When does the Commission expect h,.i to a 'ec g j . lsJ, Public Law 97-4157 submit a final written report to the Congress on this p" j,','.1,/ i 1 '; I k ql matter. 15 }' ; does the Commission project to be the number of new ') ' t; ' )% I 6. What operating licenses that will be issued for powerFY 1985 and in ' 1

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reactors during the remainder of FY 1984, f,b ,T s - FY 19867 t d .f t ' 'frfN!p ' t Please provide a status report on the' Commission's O. dTi [! '(ir 7. efforts to-bring about an interim consolidation of NRC 1 N PAb. e V ' W ?,Mh headquarters staffe. including a discussion of the ir n agency's collaboration with the General Services I ' i! Q!" $1, In addition, please provide a current f;b' -[/i;d.M

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estimate of the cost in both dollars and efficiency that l' y Z %p building situation. a ' 1:b_ );jff g[ the Commission believes is attributable to the existing Tl' 5 I 'l ' ' t l What are the most significant findings that have emerged 8. N 5 in 1983 from NRC supported research? _ f. >)- Please provide a statement on the extent to which 9

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483 . MW P"'i y s.3 : ' s b I, l ) 10. When does the Commission expect to make a significant ] p! l H hazards consideration determination pertaining to steam g.,. generator repairs at Three Mile Island Unit 17 f. 'f 2. ,f the 11. What criteria does the Commission use to determina k, y whether or not a licensee has sufficient integrity to be - g Q> allowed to operate a nuclear power plant? ll a f 1 ; criteria does the Commission use to determine ! J[qh /;. * +t 12. What whether or not the licensee has sufficient competence to ,I , P p.e h;.' ' be allowed to operate a nuclear power plant? b? '1 r,ing yp M 'g h )/. t ik 13. For all nuclear plants with valid construction permits, j rd ,f I'$ ; i l but no operating license as yet, please provide a table nn 0.y, g . 4 i5,, ; m,.d w wh h cnntains the following informations plant names J 11 nsee name; (estimated) completion date of Final Environmental Impa,ct Report (with Supplements, if known); l [ }{ .; [ ' (estimated) completion date of ACRS review; status of h.? l' ? t'fL g* a list of contested issues admitted in by lN 4%-( public hearings; each public hearing; (estimated) completion date of M. J. l.N J I. public hearings; current status of FEMA review of nt), 'f.!,, - [

  • the reactor siter 4

emergency preparedness planning around g-t (, ; licensee's current estimated date of construction 3 I; .3 .f[.) completion; NRC's r.taff's current estimated dated date of L

HHC construction completion; licensee's current estimated

.. !? t date of comtr.arcial operation; and, NRC's staff's current l 'j $ ' L estimated date of commerctal operation. . i tk.,.

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.e i... ;. e.,,. I ft ci.4,',- U f i a/Vl j;.y[M.(j:. i 519 .gg. DC,! j. Spp p :. e . p ~fi f f[ gf Y OH USE TO DETERMINE QUESTION 13,_ FOR ALL NUCLEAR PLANTS W11H VALID CONSTRUCTION Mdl'; [hg y '),91'., i ( BUT NC, OPERATING LICEhSE AS YET, PLEASE W,:4 SUFFICIENT

PERMITS, I

J .A,...- PROVIDE A TABLE WHICH CONTAINS THE FOLLOWING ']l]f'E:p RATE A NUCLEAR ?;@j../.',* INFORMATION: PLANT NAME; LICENSEE NAME; (ESTIMATED) CCMPLETION DATE OF FINAL ENv!RONMENTAL l, ' ip((p. li' j,a:.', i IMPACT REPORT (WITH $UPPLEMENTS, IF KNOWN); STATUS i (ESTIMATED) COMPLETION DATE OF ACRS REVIEW; O$5.. CONTAINED IN FI : R

0731, OF PUBLIC HEARINGS; A LIST OF CONTESTED ISSUES Pii(

4D IECHNICAL ADMITTED IN EACH PUBLIC HEARING; (ESTIMATED) t- [I ',"

P'CNT)" (SEPTEMBER COMPLET10N DATE OF PUBLIC HEARINGS; CURRENT STATUS 7g. i y.}f,

t OF FEMA REVIEW OF EMERGENCY PREPAREDNESS PLANNING

SUED IN A FINAL IN NUREG-0737, AROUND THL REACTOR SITE; LICdNSEE'S CURRENT l

NRC'S '" (NOVEMBER 1980), ESTIMATED DATE OF CONSTRUCTION COMPLETION; i j h,.,,:. ; - REVIEW OF SAFETY STAFF'S CURRENT ESTIMATED DATE OF CONSTRUCTION l .i t f.T:.'., COMPLET!CN; LICENSEE'S CURRENT ESTIMATED DATE OF ' bhdI .CW FOLLOWS THE COMMERCIAL OPERATION; AND, NRC'S STAFF'S CURRENT l l(QV ' '4 . 2 0F THE STANDARD ESTIMATED DATE OF COMMERCI AL OPERATION. .:.x kf) D TO YOUR STAFF. p+n,. .c $gh. ' e 1 b,!!s 3 a ti, q.' L. 2m.9,,,..,C.. . x!, ' ,] r, s m.:.,,: en-

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' W) - (ESTIMATED)Cl 7 fi[ P.

ANShTR, IMPACT REPORT

,w f TWO TABLES (SUBMITTED FOR THE RECORD) HAVE BEEN PREPARED IN 0F TABLE 1. TABLE 1, " LICENSING SCHEDULES FOR ALL RESP 9NSE TO THIS QUESTION: f } } PENDING OL APPLICATIONS," AND TABLE 2, " CONTEST 2D ISSUES ADMITTED , D)~ (ESTIMATED) ( IN EACH PUBLIC HEARIN_G." THE REQUESTED INFORMATION HAS BEEN a i. !{ 0F TABLE 1 l' IIf 3 1 I j !NCLUDED IN THESE TABLES AS FOLLOWS: [{I'[. I MEETING TO l hjg NOT INCLUDED IN'

yg (A) PLANT NAME - COLUMN (1) 0F TABLE 1.
  • ,.,yg (E) STATUS OF P ZIMMER, RIVER BEND 2 AND HARRIS 2.

THl3 TABLE ARE: e

  • INDICATES 1 WHICH WERE ALL RECENTLY CANCELLED 3 HARTSVILLE Al AND COLUMN (6)

Iu A2, WNP-1 AND YELLOW CREEK 1 AND 2, WHICH ARE (p.[ ] INDEFINITELY DEFERREDJ AND MARBLE HILL 1 AND 2 WHICH THE HEARIN !M Nih / COMPLETION THE PRINCIPAL OWNER, PUBLIC SERVICE OF INDIANA, NAS ' E,{f.i; 8f i h (13 W.h, j; ANNOUNCED ITS INTENTION NOT To PUR$UE PLANT COMPLETION. y ' jQ* 2y L (F) A L!si 0F ' - ' h; or . /. 6,[$ HEAR!t;G - 11lEyL l!CENSEE NAME - COLUMN (2) 0F TABLE 1. g [hf'*h (B) .f t ."js{%j ff Q. h, ' c i8m W:: ik2 "y , WMl,..fM Wb ].}asn w$bilkk$

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',j h{jh ConitSTED ISSUES a alTTED 14 (404 PU6LIC NCAAl.tG ?, ~ %d I l u .t 4 I ad7 tted Conten'tions 4 1tsttions ie'. ha.me of Plant and licensee

{9'.'.,

v. adequacy of App 1(cant's onsite emergency plan. i 1 1. Clevelaad fleftrie illumintetiro Co. adequacy cf quality assurance program in l g

p. (g 2.

sed 3,y,,a t, view of construction quality of work done by IFerry huclear Power Plant. M,.' ' 'fr9 i l .tinits 1 & 2) the electrical contractor. i p df 1 of 2 fairer

3. ' adequacy of limited tests to demonstrate

} meets the requirements of the regulations. yt; j;g ? .' t .3 II.3 of l that the errergency core cooling system r 4 4g. 7,t t - Part 53; retight 4 adequacy of design and procedures to ecce Jag j,, f,:l i. to the Ltel nuts with a pipe break in the scram discharge - [ N:ith y. in the I v olur e. '..'t < cling S. need for automated standby liquid ! %h ..f; }j]g. g itake f control system to mitigate an anticipated r F h f,y d..[' ', i - that t transient without scram. q '.ted in '[ 6. adequacy of measures to prevent fouling u 4 I of cooling water intake by Asiatic class. J'$d9: 7. adequacy of containment hydrogen control Y. w f#[9p ji '6 ale tray l. 8. adequacy of the environmental Gustification g(, p,p.j measures. ,'i.4 of certain safety-related equipment and N3i.. Of cor'ponents with regard to degradation of N h 7Qg'];> polymers from radiation. i adequacy of the environmental impact n. inspection statement with regard to the weight given 'k ' gMi $,$ I ' 9. 2 ,, b*- ICG Cf to increased em?loyment eid tax revenues g f' Ps a seal

  • as a benefit of operation.

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10. adequacy of environmental impact statement p

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ion methods regard to assessment of economic effects

,( 9-M.vf +, cf a serious accident. L

11. adequacy of protection afforded safety-9 [g.$,j e n i

1 ?f C7 related eqaipment against turbine missiles. f h., M ;. 12 reliability of Trans-Ainerican Delaval g ..W. (' c ( k t diesel generators installed at Perry. '^ -l u x.' A n I

13. adequacy of measures to prevent steas

,h f f h.f,~ ?? i erosion of components. > b i ) w ip G!,N [h. 4 . Y. l YWQ l h; he.i.. ( 7 kII ~ l Mb t t y b-s i Wr' : .frvy*ip,- i.. j 1mp g., q. ? p.. ..j ' .f .,Q. ;^9 W. .. '(,1 1, ' ' ^, '. ag I '},4 ', w A A;4.w, q f&, '

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!j p',y;.I ~ p...' > 'a i CERTIFICATE OF SERVICE i, This is to certi~fy that copies of the forego'ing were served by deposis.in the U.S. Mail, first class, posta'ge prepaid, this G3 d day of bm ,19 86, to tholse on the > i service' fist below. g 7 i. i* ,4

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yg i. Susan L; Hiatt t t,. g. .v, ~~ ~ . ;.e ~ ~ .. _...d.&,..' ! X ~, . 4,(*;,. SERVICE. LIST ..g ,3ljg,., _ y. -..i l. JAMES P. GLEASON, CHAIRMAN ~ ' Terry Lodge, Esq.' ATONIC SAFETY & LICENSING BOARD 618 N. Michigan St' SILUER SPRING, MD 20901 Suite 105 ^ 513 GILHOURE DR. , Toledo, OH 43624 Dr. Jerry R..Kline ..-..--..~.a+..y-- r Atomic Safety.& Licen. sing Board. ,3 U.S. Nuclear. Regulatory Commission - i. .y;,. G' Washington, D.C. .20555 - r

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. g' " c'.j,'f @:4 9 '. L. t Mr..Glenn O. Bright Yll Atomic Safety &. Licensing Board

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'.G. U.S. Nuclear Regulatory Commission, i, .! y,Y, Washington,. D.C. 20555 e .o. ' c ', "

. Colleen P. Woodhead, Esq. < ~j Office *bf-the' Executive Legal Director

.l.,.. ~ ,'i' U.S'. Nuclear. Regulatory Commission Washington,.D.C. 20555 f. S Jay.-Silberg, Esq. . Shaw, Pittman; Potts, & Trowbridge p; . 1800 M Street, NW i s . Washington, D.C. 20036 y n I i l Docketing & Service Branch ~' .Offi'ce of'the. Secretary ' ; 4.p. 3vJ U.S.. Nuclear Regulatory. Commission i',M. Washington, D.C. 20555 -Atomic, Safety.&, Licensing. Appeal Bo'ar'd Panel. ^1 t..'.' ],,,.(,i U.S. Nuclear. Regulatory-Commission .i. gl. Washington, D.C. 20555 ,}}