ML20247Q679

Provides Response to Section a to Requesting Informal Discovery.Sections B,C,D & E Fall Outside of Scope of Board 890718 Memorandum & Order & Further Response to Sections Deemed Unnecessary.Related Correspondence

ML20247Q679
Person / Time
Site:	Limerick
Issue date:	07/28/1989
From:	Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Elliot C ELLIOTT, C.W.
References
CON-#389-8973 OL-2, NUDOCS 8908070222
Download: ML20247Q679 (3)

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' g { g.LE ADDREBL ATC'MLAW Charles W..Elliott, Esq.

.Poswistilo,.Elliott & Elliott Suite 201.

1101 Northampton Street Easton, Pennsylvania 18042 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Unit Nos. l and 2)

' Docket Nos. 50-352 and 50-353-CU 2-

_ ( Severe Accident Mitigation Design. Alternative)

Dear Mr. Elliott:

In response to your June 27, 1989 letter requesting informal discovery in the captioned matter, I am providing the attached information to respond to Section A of your request. As Sections _B, C, D and E fall outside the scope of the admitted contention as defined in the Atomic Saf tty and Licensing Board's July 18, 1989 Memorandum and Order, no further response to those: sections is necessary.

The provi'sion of this information as informal discovery should not be deemed an admission that the Company would be required to produce it under the NRC's Rules of Practice or that the information is relevant or material. Its provision is also without prejudice to any objection that may be made regarding its admissibility as evidence in this proceeding. .

Your specific requests and th9 information provided are as.follows:

A. (1) calculations supporting PECO's l assertion that the 6" diameter hard pipe is adequate to remove containment heat under .the dominant accident scenarios for Limerick l

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Chnrlos W. Elliott, Ecq.

July 28, 1989 Page 2 The requested calculations contained in PECO Trip Analysis, Analysis File 2, Project 7918, Venting Analysis for NUS 5002 are provided in Attachment 1.

A. (2) the procedures by which venting is implemented (e.g., the TRIP proce-dures and/or other procedures used by plant operators to respond to severe accident The requested procedures for Units 1 (Procedure T-200, Rev.

2, 2/8/89) and 2 (Procedure T-200, Rev. 1, 6/3/89), both entitled Primary Containment Emergency Vent Procedure, are being provided as Attachments 2 and 3. As noted in my July 24, 1989 letter to you, the referenced flow chart is proprietary and will be transmitted to you upon receipt of the executed " Agreement Regarding Disclosure of Confidential Commercial Information."

A. (3) P& ids for the 6" dia. hard pipe A package of P& ids relating to the 6" diameter hard pipe containing Drawing No. M-57 (6 sheets) and Drawing No. M-60 (2 sheets) is attached as Attachment 4.

A.(4) any human factors evaluritions which have been made of the venting procedures, with an estimate of the time required to implement venting via the 6" hard pipe and the reliability of doing so under loss of AC and/or DC power conditions In response to this request, NUS Report No. 5002 ) revised 2/15/88) entitled " Incorporation of TRIP Proceudres into the LGS PRA - Phase 2 ATWS and Containment Venting" is provided as Attachment 5.

A. (5) demonstration that this venting pathway can indeed be used under the dominant accident sequences The evaluation demonstrating the manner in which this venting pathway may be used is also contained in the NUS report provided as Attachment 5.

A.(6) evaluations (if any) of running the pipe to an elevated release point

Ch2rics W. Elliott, Erg.

July 28, 1989

. Page 3 There have been no evaluations done regarding running the 6" hard pipe to an elevated release point.

Sincerely, Mark J. Wetterhahn Counsel for Philadelphia Electric Company MJW:sdd Enclosures cc: Morton B. Margulies, Esq. (w/o enclosures)

Dr. Jerry L. Kline (w/o enclosures)

Dr. Jerry Harbour (w/o enclosures)

Atomic Safety and Licensing Board Panel (w/o enclosures)

Frederick J. Shon (w/o enclosures)

Atomic Safety and Licensing Appeal Panel (w/o enclosures)

Ann Hodgdon, Esq. (with enclosures)

Edward J. Cullen, Esq. (w/c enclosures)

Angus Love, Esq. (w/o enclosures)

Michael B. Hirsch, Esq. (w/o enclosures)

Docketing and Service Section (w/o enclosures)

Gregory E, Dunlap, Esq. (w/o enclosures)

Mr. Ralph Hippert (w/o enclosures)

Theodore G. Otto, Esq. (w/o enclosures)

Adjudicatory File (w/o enclosures)

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