ML20133H516

Response to NRC & Applicant Answers to Motion to Reopen Record & Submit New Contention.New Contention Could Not Be Submitted Before Close of Record Due to Time Constraints of Hearing.Certificate of Svc Encl

ML20133H516
Person / Time
Site:	Perry
Issue date:	08/05/1985
From:	Hiatt S CLEVELAND ELECTRIC ILLUMINATING CO., OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	Atomic Safety and Licensing Board Panel
References
CON-#385-145 OL, NUDOCS 8508090375
Download: ML20133H516 (14)

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4J August 5. 1985 s UNITED STATES-OF AMERICA  ;

ffhIED C

NUCLEAR REGULATORY COMMISSION ,,

Before-the Atomic forety and Licensing BocPd 15 AUG -8 Pl2 :082 rn ene.noever or >

OFFICE 0::ECRETAP [L 3-THE CLEVELAND ELECTRIC ) Docket Hos. 50-440 Obhd,;#EPyn:f;s  ;

ILLUMINATING CO. ET AL.

) 50-441 OL i

)

(Perry Nuclear Power Pione, ) .

. -Units 1 and 0) ) ,

OCRE RESPONSE TO STAFF AND APPLICANT ANSWERS TO OCRE'S MOTION TO REOPEN THE RECORD AND TO SUEMIT A NEW CONTENTION .-

Pursuant to the Licensing Board's August 4, 1981 Order ,

y (offirmed i n LEP o' 2-89, 16 HRC 125' (1980)) requiring 8 7

Y intervenors to respond to the answers of 5 toff and Appisconts a

when filing new contentions, Intervenor Ohio Citi: ens for j Responsible Energy ('00RE')_hereby responds to the legal and L hl factuoi orsuments of Starr and Applicants in their onswers to CCRE's Motion to. Reopen the Record and to Submst a New I

contention, filed July 5, 1985.

\

Both Stoff and Applicants allege that CCRE has noe met the Etondordt for reopening the record and for Submitting a late-filed contention. They particularly claim that CCRE's filing is i n e >t c u l a b l y late and coulo have been filed earlier. Applicants in fo t claim that 'the information hof lon3 been o'io l l a b l e which OCRE could have used to rocculate its untimely concention, l

citing NUREG-0123, the scandard Technical Specifications for ,

BWRs 'like Perry,' available an 1978. Appisconts' Answer at 9.

B50009 75 8 PDR A M0 0

• =

393

00RE hos o copy of Revision 3 of flUREG-0123, dated December 1980; ses title as 'stondord Technical specifications for General Electric Bailing Water Reactors (BWR/5).* The BWR/5 utslizes the tiork II containment cesign. Perry is a BWR/6 witn the Mark III containment. Thus, NUREG-0123 oddresses BWRs which are uniske Perry, and that document could not form the basis of a contention CPPlicable .co Perry.

Appliconts also claim that the vortous drafts of the Perry technical specification 5 should have cierted OCRE to the exemption from airlock testin9. However, the only nention of the GWemption is in a terte footnotes there is no explanation of W r. y the exemption is needed or of its safety consequences. It would not hove been posbible to formulate o contention having a basis ' set forth with reasonable s peci f ici ty ' - (10 CFR 2. 714 (b ) )

with.such poltry information. Furthermore, the rovssions and marked up pages of these drafts illustrate their ephemeral natures it was not possible to determine whether, in the end, the exemption Would be oppiscoble to Perry.

The Staff correctly states that 0CRE could not have rotsed its contention prior to the filing of Applicants' opFlic3 tion for the exemption. itoff Response at 9-10. However, ene seaf' claims thoE good cause is lacting for waiting until Ju1*/ 5 to file the contention. The application for the exemption, though Itled April 3, 1935. was not received in the LPOR (and thus was rio t available to CCRE) until April 25, At that tinie GCpE was

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preoccupied with preparation for the evidentiary hearsng which beg'an 5 days later. It would have been impossible to submit the new contention before the close or the record due to the time ,

s constroints of the hearing. It also would not have mode sense 3

to file the contention then, as it was not known whether the Stoff would grant the exemption. Ho ever. OCRE did not merely sit b o'c x and watt for the stoff to act; OCRE inseeod used the meons W

ovoilable to and filed comments with the Stoff. opposing the exemptson. Had OCRE not done so, o positive showing could not be made on Factors (ii) and (iv) of 10 CFR C. 714 (o) (1) , as Other, unutiliti:ed means would exist for protectsng OCRE's Anterests, Since OCRE had no reoson to believe that these meons 1 I

would be unsuccessful, delaying filing of the contention until ,

the staff submitted its Environmental Assessment and Finding of tio 51gnificont Impact was on entirely rational action, Indeed, filing the contention any earlier creocea the possibility of cousing the ecors and parties much unnecessary work nod OCRE's informal comments been successful. Ie must therefore be Con 01uded that 00RE's motion was ttmely, c

Applicant & ond Stoff clotm thoc OCRE's conteneton rolls ihort of the '513nsfacont stBuW' leandord needed for reopensng the record. They ponne out enot the stoff has routtnely granted lu0h exemptions for Qther fo0ilities, What the Stoff ho& done

$n other cases is not relevant heres silegally granting exenprions at other plants does not relieve the $ toff of its ,

responstbiltty to enforce the Commtaston's regulottons at this

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facility.

Contrary to Storf and Applicant assertions, 10 CFR 50.10 does not authorine the granting of such exemptions, unless they have.been authori:ed by low. Claiming that 10 CFR 50.10(o) itself gives sufficient exemption authority is circular Had this been the intent of that regulation, there j reasoning.

would be no need for the qualifer "outhoriced by low.'

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Regulations, of course, are not lowss use of the word ' low' clearly indicates that CCngressional authority is needed for the graneing of exemptions, no such authority as found in the ,

Atomic Energy Act.

Applicants and Stoff rely upon United States v. Allegheny-Ludium Steel Corp , 406 U.S. 742, 755 (1970) for the proposition tnot ogencies have the inherent authority to grant exemptions from their regulations. That decisson concerned rostrood freight Cor service rules promulpdud by the Interstote , Commerce Commission, and thus is of dubious relevance here. The portion of that decision upon which Applicants and Staff rely is illustrative:

The Commisston, acceding to the arguments of shtppers and rostroods on rehearing, agreed that t.1 o n d a t o r y total compitonce with the rules promulgated would be i rt.p o s s t b l e an view of th(

, tremendous number of units involved, and, occordingly a procedure by Which GWeeptions might be opplied for was estabitshed. How the provision fur #HCeptions will be administered in practice is o matter about which we could only speculate at present. It ts well established that on agency's authority to proceed in a complew 0r00 such as car-service regulation by moons of rules of general opplication entonis a ,

concomitont aufhority to provade ewemption procedures to allow for special c i r c u n, s t a n c e s , parmion Basin Aroa pote cases, 390 U,$. 747, 754-706 (1960). 406 U.S. at 715.

Clearly the 5upreme Court's ruttng on opency authortty to Grant 4xemptions appitet onl/ to conplex regulaetons of on

r economic noture, such as freight Car service rules or ratemoking matters, When mondatory total compliance is impossible. The decision does not apply to the NRC's heoith and sorety regulations. Even ir' this cose Were round to ce relevant, the, term *special circumstances

• points to 10 CFR 0.758 os the oppropriote standard, ,

The Starr osserts that 10 CFR 0.758 does not preclude o party to o proceeding,from sesktng ovenues or relier from the Commission's regulations other than a petition to' Waive o rule.

This interpretation is, or course, preposterous, as nothing would then prevent on opplicant or o licensee from evading o Licensing Board's decision by simply seeking on exemption from the Starr. Surely the Commission would not Want the decisions or its adsudicatory boards so easily (an errect) overturneds )

this distinct possibity is why 10 CFR 2.759 opplies to o party j to o proceeding seeking Waiver or a regulation.

The Storr's interpretation or 10 CFR 0.758 as a ' mechanism by Which a party may Challenge of ottock on HRC regulation .g, ,

Crother than a Woy] in which o party may be relieved from

omplionce With a regulation Whtch it odmits 11 Volid and opplicotle' (Storr Response at 14) is inconsistent With the ruling of the Appent Board in Vermont vonkee Hueleor Power Corp; (Vermont yonkee Nucleor Power station), ALAB-138, 6 AE0 320, 529 (1973):

it connot be orgued that, #Ven though the reactor does not comply With the critectoi at should reces /e on unres tetC ted full-power e full-term license on the grourd that there is reasonoole ossurance tnot it con operate isthout odVersely otracting the public heotth and sorety. Such on argument might be roctually supportable, but Would constitute on' indirect ottack on the oppitcoble Commission regulations. Again, the ponne to be mode is o,stmple onei reactors moy not be licensed unless they comply with all opp 11coble standards.

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The cose low on-this point is clear ( no party to a proceeding is permitted to argue that a facility is sore anyway af o porticular regulation is not met, os such on orgument is contomount to o challenge (albeit sndirect) to the regulation.

prohibited by 10 CFR 0.758. Vermone Yonkee, 6,AEC at 528. The only legal mechanisms for challenging a Commission regulation are the procedures set forth in 10 CFR 0.758(b), (c), and (d). I L

Thus, contrary to Stoff and Applicant assertions. OCRE*5 contention is monirestly consistent with Commission low and ,

practice.

o Applicants and Stoff allege that the Commission may consider financial burdens associated with regulatory compliance in  ;

a r.iting exemptions, citing tne Commission's recently proposed changes to 10 CFR 50.10. The Commission's utterances in o l proposed rulemaking con be given no weights rather e the present rate and its adjudicatory interpretations are controlling, j While on ogency may amend its regulations. At is not free to l 1

ignore or violate its regulations while they remoan in effect.

l Urited States v. liixon, 410 U.S. 603, 693-696 (1974)s Service v. [

Dulles. 354 U . ,5 . 363 (1957).

contrary to stoff and Appiscont assertions, the Commission ,

is prohibsted from considering financial burdens of licensees in o

tes regulation of nuclear power reactors) the Commission itself admitted that "public lorety is the firste lost, and a permanent constuerotion in ony ,decaston on the assuonce or o constructton permte or a license to operate o nuclear racilsty.' power Peactor Development Co. v. Internotsonal Union of Electricole podio. and Hochine Workers, 367 U.S. 396 400 (1961s. The 4

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-. commission is absolutely denied any authority' to consider a utility's investment in its licensing decissons, Id. at 415.

It is hardly consistent for this high standard to be open to compromsse in post-licensing activity, such as the granting or exemptions, It economic hardships could be c~onsidered by the Commission, r

Public sorety would not be o ,' permanent consideration,' but rather o transitory one. The roct is that the Atomic Energy Act does not permit a boloncing or Costs and benertts in questions or regulatory compliances the standard instead is unconditionoi compliance with the Commission's sorety regulations.

The Storr's argument that these rulings do anot preclude granting exempeions where the requisite sorety findings have been mode' (Storr Response at is, rootnote 15) is osain circutor reasoning, os the recuisite sorety findings spectrically include compliance with the commission's regulations. 10 CFR 0,104 (c) :

10 CFR 30.57(o). . . .. .

Applicants otto orgue that the exemption will not have o significone adverse erriet on containment integrity or the Duelle health and soret., As explained in OCRE's Motion, the

f. r i n c i p a l danger from tre exempeton ta that the atriock doors wall not be closed and 13terlocka restored at the end or periods when con-oinment tntegritY 18 not required. Con 61dering the odverse operating experience ossow* toted with containment atriocks (see, e.g., HUREC/ CP-CO Se) , this is hardly on smproboble occurrence. If both otriock doors roit to close and

( lotch, on opening as large at OS squore feet (calculoted from l

Figure .1A of Applicants' Ex. 9-4) would be ovoiloble for fission

8-

. Product transport out i

or contoinment. This hardly constitutes insignificant leokoge. $

os claimed by Applicants (Answer at 15).

Applicants try to obfuscate OCRC's analysts of FSAR data *

[

r regarding the airlock seal testing design. Applicants' Answer ,

at 16. OCRE,hos ottpched FSAR pages 3.8-55. 3.8-550, and 3.8-56 (Attochment 1). As con be IGen, there is no basis to

, t Applicants' claim that there are two types of interlocks. Nor s.. . i.

is it apparent that indications and alorms in the control room ,

will not be bypassed With the interlock.

e Applicants and Staff finally argue that OCRE hcs not met Factors (iii) and (v) of 10 CFR 0. 714 (o) (1) . As for Factor (iii), they claim that OCRE hos '19nored' the Appeal Board's

• observation' that a petitioner should address this criterion ,

I with particularity, including the identification of prospechtve ,

o witneases with summaries of their proposed testimony (citing Missassinoi pnwer

• liche (Grand Gulf Nuclear Station, Unies 1 .

and 2), ALAB-704, 16 NRC 1705 (1980), voshington public power supply System (WPP55 Nuclear Project No. 3), ALAB-747. 18 NRC ,

1147 (1983), and Long Island Lightin? Co. (Shoreham Nuclear Power Scotton), ALAB-743, 13 NRC 387 (1983)). Appitcones' C

Answer at 19.

These cases are of questionoule opplicobtlity, since they all concern o late-filed peettton to &ntervene, not tote-filed contentions filed by,on olevady-admitted intervenor. In any ovent, since OCRE's contention rotsen more of o queseson of low than of fact, it ts not clear that it is oppropriate to,discust prospective #Hpert witnesles. Qf courle. depend &ng on the

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l Board's determinotton on the matter, questtons of fact may be matertall if this is found to be the cose. OCRE would likely subpoeno certain knowledgeable persons, whom OCRE would pref er-not to identify now as identificotton may compromise their avotlobility. It should also be'recolled that this Licensing Board has interpreted uppss, supra, (spectricolly the concurring opinion of Nr. Edles) as not'{equiring on intervenor to identify prospective witnesses if it has demonstrated the ability to contribute to the development of the record in other ways (e.g., throuGh effective

ross-examination, UPp%5, 18 NRC at 1182-83). LPB-83-80, 18 HRC 1400 (1983) (footnote 14).

As for Factor (v), Appiscones complain thoe tne admission of the contention could well delay Appisconts' fuel load dote, w n't e n as supposealy scheduled for September 1985. Applicants

• Answer at 00. The NRC Stoff hos recently admitted that the fuel lood dato could be os for oway os the first quarter of 1986, due to the problems identified in Attachment 3 to CCRC's July 15, 1985 letter to the Licenstng Board. See Attachment : hereto.

Their continuing erouble with preoperottonot testing (uttness ene failed drywell 6eructural sneegrity test) wall delay fuel lood even further, Arp16 cones' fears are thus unfounded.

As demonstrated b'f the foregoing, 5 toff and Applicant orguments agonnst th,e [amission of OCRC's new contentson ore lacking in morte, ocRC thererore respectfully requests ehot the Licensing 000rd'roopen the record and admit the contentton for

-la-1itt90t100, Respectfully submitted, 4% fY Susan L. Haote OCRE Representative 8275 Hunson Rd, Mentor. CH *4060 (216) 255-3158 b

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. 3.8.2.1.2 Plate Thickness gqg Final design p ate thickness of the containment vessel cylinder and dome is 1-1/2 inches. T is is increased to three-inch thick plate aroun the penetrations in the suppression pool region to provide loc Vreinforcement for containment vessel pr sure loads as well as penetrat'en loads. Base liner plates are 3/8 inch thic carbon steel wnere the re covered by concrete, and half inch thick stainless ad where they ar xposed to the suppression pool water.

j 3.8.2.1.3 Test Channels n Te Assemblies Steel test channels are provided along we ds of the steel liner of the foundation mat so that local leak testing of walds can be performed. The channels are segmented by are One plug fitting is providdd for each area and extends through any cov ing material, including concrete.

s 3.8.2.1.4 Personnel Access Air Locks s

Two personnel access airlocks with an outsido diameter of 9 feet - 7 inches are provided, one at elevation 599'-9", the other at elevation 689'-6".

' The personnel access airlocks are welded stool assemblics with double doors, each f equipped with double gaskets and designed to provide the capabillty of leak rate i tasting t'ho airlock between doors and the cavity between door seals at a pronsuro 1 of Pa (11.31 psig). Automatic leak rato Instruments are located outside tho - h containment end. Sinco personnel alrlock door seats must be tested after each opening, an automatic leak rato monitor (ALRM) is connected to the seal test point on the Inner door and outor door of cach airlock. The monitors are j im supplied with inttrumont air and upon activation of the door interlock swltch, 17 the test cycle begins by pressurlaing the cavity betwoon each palr of seals to $

the preset test pressure. At the presot test pressure, the automatic sequence will proceed to tho test modo and indicato a pass or fall condition. This result is remotely displayed as an alarm in the control room. After the test cycle, the monitor automatically rust:ts to a ready stato for the next door closure. The I

seal test system is shown schematically in Figure J.8-100. The airlock doors ero '

3.0-55 Am. 18 (4-10-85)

5 designed as pressure seating doors. Since both doors swing towards the reactor, any positive pressure buildup in the containment will tend to close the doors against their door jambs. When pressure testing between door seals, the doora $

are prevented from opening by means of the two latch cylinders mounted on each door. Llhen pressurizing the entire airlock for a structural integrity or leak rate test, fc test clamps must be installed on the airlock side of the reactor end door. These test clamps con.sisting of steel bars and clevis pins, engage clevises on the door and the door jamb to mechanically secure the door.

Additional details of the locks aret

a. The doors are interlocked to prevent both being opened simultaneously.

Interlocks are connected so that one door must be completely closed and sealed before the opposite door can be opened.

b. Remote open/ closed indication lights are provided in the control room to C%

indicate the position of any personnel access air lock door. A special 7 remote alarm is provided whenever both doors in an airlock are not locked [

3 closed.

3.8-55a Am. 13 (1-31-84)

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. c. Locks have an interior lighting system which is capable of operating from

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'~ the emergency power supply.

d. Locks have an emergency communication system.

e. Provisions are made to permit bypassing the door interlocking system to allow doors to be left open when,the plant is shut down.

f. The floor system is designed so that it can be easily removed.

g. The locks are designed, fabricated, tested, and inspected in accordance with the ASME Code,Section III, Class NC.

h. Lock hinges are capable of independent three-dimensional adjustment to assist proper seating.

i. Equalizing valves are provided.

j. Provisions are made for in-service leak testing of the door bulkhead penetration gaskets at 11.31 psig (Pa). l 3.8.2.1.5 Equipment Access F.'atch An equipment access hatch with a clear inside diameter of 20 feet is provided at elevation 620'-6" to allow passage of large equipment and components into the containment v,essel. The flanged joint between the hatch and cover is domigned to accommodate double seals. Parlodic leak testing of the hatch is accomplished by i pressurising the space between the seats.

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! 3.8-56 Am. 18 (4-10-85) i

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Nhd A.1 . h elt is.1935_. , ! 44 P ges E ba (N5eensa . **w .

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oGRC says sloppy tests; )

c7 reyealediat Pe.rry ph. nt J .

By BillSammon '.'- ,

. are appealing the test results. Mearhehile, CEI lsh he*sewaid siert wnier . . ,

.rcemamining its traininNrogram not pass theto try totest, NRC's deter b

• i In a frantic race to begin operating the North mine why more people '

.e

- Perry Village nuclear power plant by the end of the Coleman said. ,, whl' c h,CEI has 9 *

• T here are 9,000 ltems in the plant year, the plant's builder h.is shpped into seriomfy deficient testing procedures and 7,.m o a = not yet resolved to the NRC's satisfaction. Most of. ,

g wdi not meet its own deadline, p M%! '

the items are smell, such as an identification tag no{ . '

being placed on a valve, Coleman said.

4 (cdcralofficials said yesterday.

Top brass of the Cleveland Elec.

f f 1 "They're severely ' impacted .by ' their own ,

I tric illuminating Co., the plant's ) I schedule," Keating said, '"They're tripping over.' '

builder, were " called in on the V  ?;, their feet getting to that point. They would hke to I

tarpes" last month by the U.S. ,

have fuel loaded this year because it would help ,

NusIvar Regulatory Commission's

• wM) d'[ their financial situation eM their bond rahng,

/ ottae in Chicago, said Dale /q primanly." .

I Keaung, one of two NRC resident

'.I.

4 t

_J King said he did not know what,if any, specific I inspectors at the $6.4 billion Perry essi ne financial benefits CEI would gain by compleur g the

• plant. The CEI officials included Chairman Roberi plant by the end of the year, except that the lon;ger la' ,

I drass ori, more money will be spent.

M. Ginn,. Esecutive Vice Preudent Harold L. . .! ' , '

ofTpreoperationapecially he NRC is es

?

Withams and Nuclear ylce President Murray R.

)

' e tests at the plant,uniti w hichover must be CEl's handling '

LJetman. '

"We're telling them it (pre.cperational testing)is comnfeted before the plani can go on hne, rj a serious problem and they're going to have a more CLI has failed to document testing procedures. . g serious problem if they don't do something about and has not conducted certain tests the way it pro ,

11" keatmg said "We're kind of surprised they ago, mised in documents submitted to thea NRC Keating said,

• +e years er .',-

w,ould have this problem because they're usually ,

f very situta and icarn from others' mistakes." "They've got some glitthes and drinkles and y

! CEI spokesman William Kies said: "We 'are kinks in here and they've got to get them worked ', ' , ' I' aware that there are areas where we need improve. i out because they can impact and becomg critical. '

rn.nt There are some soft arest but we have shown when it comes to licenairig " said Keating, noling '

reccntinonsider able improvement," ,

that CLI has not yet rettived an operaung hcense, Yet the folluwing problems were revested yeuer' The NRC inipection report of the Perry plant I d.y by Keahnt, a recent NRC Inspection report, pales that "nine ef the 13 procedures reviewed thus.

j amt hkC Commissioner hines Angelinne,,who f ar by the N kC were deficient," ,

I toured the Perry plant yesterday: Improper testing procedures led to such mishaps ' '  ;

[ *Ihe NRC "caushi"CElimproperly changing a ' as the inadvertent spraydunn of the containment ',

,, int tnueval instead of correctmg problems which budding and the overpressuritanon of a heat en-o sunfheted with the manual, Keating said. After- changer eather thit year, the report iald, a matJa, CEl simply deleted the changes from the lhe seport also cites an "escessive number of nianual. . ,iolanone," oinadequate proceJures,"J '

hans s. lid last alght he did not know enough to "misivadin g statemenis/ commitments," and comment on the maner. "inadequaie, unumery correcilve schons." lt said

'CCI mill not be ready to load nuclear feelinto the NFLC "luks conhdence in quahry of test pro.

e lhe first of 'wo reactors at the plant unhi neal ear, gram. Imrarbate management attenhon meeded

.r poiobly as late as March, the NRC said, CE of. , , , "

a fidats sull mamtain they will load fuel try 001 has appointsJ e special manssement team to }

a hepsmber and begin generating elestriday by ihe confrorI the problem, Keating said. The team is '

enJ ol the year, reshuffhng managernent respenubillues to better "We are absolutely dedicated 10 meeting those handle the problem, said NRC resident insputor%' ' '

/ dates but anything in the world een happen at anF John Orobe. ,,i t Hme f* king said. ','We are moving with d.ipaith. Yeuerday mathed'the first time that one of the f '

g We ceriamly aren I waning any time, flut thal NkC's five commisuonert toured the Perry plani, t ,

ilosin't hecessar6t y mean we're rvihing?' ,'

i eA thifd of CLI employees who were blred to alpuls Austuine said of the he was impreited'with severall

plant, coerate the plant thros;h the control room'have pogo,e features instuJed fire protecoon, a torV flunkeJ the NRC's operating enam. At other trol room omulator and safety fesiures which were .' k ania, such as the l'armi eucisar power plani in ruummended after the IM9 Three hide IslanJ j 14bigan,9) per(ent of the operatofs palleJ the nuclear accidentin Pennsylvania ,

IHL liut Anielinne said be advised CrI," don't let a t "We give them about 2Ai0 hours of tram, rig, deadline push things faster than you can handle l whists le the equivalent of a colleJe edvestio<., and them. 0el the job done riahi the Orte time "

then we send them (10 Chicago) for the teu," said 41,g ,,ishing the in depth tour, whish induded Ct.1 sponetman Wilham Coleman. "We sent 12 shmbs up steep ladders and dettents into selJom f pseple and )) pained. We're not happy with it." toured lutinns of the plant, were 190 logel AnH+ f Colernen said tome of the employees who faded p,gi,ar un,i,ie, , ,

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