PY-CEI-NRR-0049, Forwards Response to R Bimber Ltr Re Salt Cavity Storage Area.Encl FSAR Changes Will Be Incorporated Into Future FSAR Amend

Forwards Response to R Bimber Ltr Re Salt Cavity Storage Area.Encl FSAR Changes Will Be Incorporated Into Future FSAR Amend

ML20076G403
Person / Time
Site:	Perry
Issue date:	06/01/1983
From:	Edleman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
PY-CEI-NRR-0049, PY-CEI-NRR-49, NUDOCS 8306140661
Download: ML20076G403 (4)

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P.O BOX 5000 - CLEVELAND OHIO 44101 - TELEOHONE (216) 622-9800 - ILLUMINATING BLDG, - 55 PUBLIC SOUARE l

Serving The Best Location in the Nation MURRAY R. EDELMAN VICE NIESIDENT NUCMAR June 1, 1983 PY-CEI/NRR-0049 L Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to Letter from Russell Bimber Pertaining to the Perry Nuclear Power Plant (Units 1 and 2)

Dear Mr. Youngblood:

As requested by your letter dated January 31. 1983, we have reviewed Mr. Bimber's letter and have addressed any inconsistencies claimed. The enclosed attachments are set up in a statement-response format. Mr. Bimber's letter was broken down into individual statements and each statement is followed by our response. The physical data on mine or well, size and location was obtained from direct contact with Morton Salt, Lake Underground Storage and Lake County Engineering personnel. Any FSAR changes that will be made have been noted in the enclosed response. These FSAR changes will be incorporated in a future amendment.

Very truly yours, Murray R. Edelman Vice President Nuclear Group MRE/kf DW77/E/1 Attachments cc: Jay Silberg, Esq.

John St2fano Max Gildner k 0306140661 830601 PDR ADOCK 05000440 i A PDR

1) The size and location of the Morton Salt Mine is substantially misrepre-sented in both the FES (Page 9-15) and in the Final Safety Analysis Report, where Figure 2.5-16 shows it as being entirely under Lake Erie.

Morton's Chief Engineer, Mr. Patel, told me it also extends 6000 to 7000 feet south of the mouth of the Grand River and 5000 to 6000 feet west.

Response

According to Morton Salt Company's mine progress map, the mine does extend 5800 feet south from the mouth of the Grand River. This southern extension moves west about 3800 feet. The FSAR Figure 2.5-16 does not show this and will be revised. FSAR Figure 2.5-16 was never intended to be a precise mapping of salt mines and gas fields in a 15 mile radius.

Its function is to show general locations in relationship to each other.

2) The FSAR denies any knowledge of Lake Underground Storage (LUS) on Page 2.5-59 when it says the only reported gas storage in the Salina formation in Ohio is near Canton.

Response

There is no mention in Section 2.5.1.1.8.2 on Page 2.5-59 about LUS. The section will be updated to reflect this.

3) The attached letter shows the AEC learned of it (Lake Underground Stor-age) in 1973 and said it should be documented in the PSAR and considered in the evaluation of postulated accidents in the vicinity of PNPP.

Response

According to the Atomic Energy Commission's letter in December 1973, the AEC nsked the applicant to consider the storage of volatile fuel in abandoned solution cavities as~part of the evaluation of postulated accidents. This was done as documented in the PSAR Section 2.2.3.2.2.2 and the FSAR Section 2.2.3.1.1.3. The accident postulated for the underground storage of liquid propane was an above ground release assun-ing a complete shearing of the well head to allow maximum discharge from the cavity. Maximum gas cloud formation was assumed. This was con-sidered to be the worst accident scenario that had credibility.

4) Page 2.5-59 also errs in saying, " Presently no potential salt cavity storage areas are located adjacent to the site or within a five mile radius." There are many wells extending through the salt, which should be considered potential salt cavity storage areas, already documented in the FSAR. Table 2.5-6 and Figure 2.5-17 show several examples, not under CEI control, yet within a mile of PNPP, contrary to a statement on Page 9-15 of the FES.

Response

The salt cavity storage areas referred to on Page 2.5-59 of the FSAR are solutioned salt mined cavities which can be used as an underground cavity to store volatile fluids such as liquid propane. The wells shown in Table 2.5-6 and Figure 2.5-17 of the FSAR which Mr. Bimber refers to are gas wells. Gas wells do not fulfill the technical requirements needed to store liquid propane. The fundamental concept for cavern storage requires the availability of an underground cavity such as one which might be created by a solution salt mine well. There are none of these wells within a 5 mile radius, therefore, the statement on Page 2.5-59 in the FSAR is correct.

5) Also note that CEI does not control the mineral rights under the Neff Perkins Company's 20 acre site, commencing about 3000 feet west of the PNPP reactors (FSAR 2.15-5, Am. 4 (10/2/81]).

Response

This statement is correct but CEI does own underground volatile fuel storage easement rights which prevents Neff Perkins from storing volatile fuels below ground. Neff Perkins is prohibited from drilling for oil and gas on its property by state law. The state requires that 20 acres of mineral rights be owned befcre one well can be drilled. Neff Perkins property is not 20 acres. Since CEI owns all mineral rights around Neff Perkins, Neff Perkins is prohibited from drilling a well for oil and gas.

6) Can you tell me why the Neff Perkins land is erroneously shown as part of a "U.S. Reservation: in Figure 2.1-2 of the FSAR?

Response

At one time, Neff Perkins land was a U.S. military reservation. The Federal government appropriated the land in 1954 for use by the U.S.

Navy. It was bought by Neff Perkins in 1967 and part of this reservation was sold to CEI in 1968. The U.S.G.S. map used in Figure 2.1-2 was never revised by the U.S.G.S. to eliminate the labeling of U.S. Reservation.

The map was used to show topography which it does correctly.

7) The northerly extension of LUS's underground propane storage cavities, from the wells, is likely to exceed 587 feet because the same factor that causes the morning glory shape--fresh water being less dense than salt brine--also causes the cavity to grow more up-dip, where the Morton Mine is, than down-dip. I expect the propane cavities may extend 1000 feet from the wells toward the Morton Mine.

Based on the estimated 7900 foot separation of the mine shafts and wells, the underground separation of the mine cavity and the propane might be 2900 feet.

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Response

Location of the LUS well was mapped using a sonar device. The diameter was determined to be 250 feet. The accuracy of the sonar device was quoted as 1 to 2% of the total distance (Atomic Energy Commission letter to CEI dated December 13, 1973). The location of the Morton Salt Mine is found by using certified surveyors. Mapping the locations of the Morton Salt Mine and the LUS storage well gives an approximate separation of 5700 feet.

DW77/E/4/kf i.