ML20070T171
| ML20070T171 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/31/1983 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | CLEVELAND ELECTRIC ILLUMINATING CO. |
| References | |
| NUDOCS 8302080234 | |
| Download: ML20070T171 (14) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Ja,nuary 31, 1983 UNITED STATES OF AMERICA .
- NUCLEAR REGULATORY COMMISSION'CCMETED
' n t F. .'
Before the Atomic Safety and Licensine Board
- '83 FEB -7 All .:07 In the Matter of )
) .
CLEVELAND ELECTRIC, ILLUMINATING ) Docket Nos. 50-440 COMPANY, Et Al. ) 50-441
) (Operating License)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
)
OHIO CITIZENS FOR RESPONSIBLE ENERGY
. NINTH SET OF INTERROGATORIES TO .APPLICAL"fS Ohio Citizens for Responsible Energy (".00RE") hereby pro-pounds its ninth set of interrogatories to Applicants, pursuant to the Licensing Board's Orders of July 28, 1981 (LBP-81-24, 14 NRC 175),' Octocar 29, 1982 (LBP-82-98, 16 NRC ), and January 5, 1983 (made during the conference call').
Issue #13 Statement of
Purpose:
The following interrogatories are designed to ascertain .the factual bases for Applicants' line of defense concerning the degree of protection against damage from urbine
- missiles afforded by the Perry design.'i.
9-1. Identify and produce all documents in the possession of Applicants or any of their agents, including A/E Gilbert o
Associates and NSSS and turbine supplier General Electric,
- 5$h 58 pertaining to. turbine missile l azards, including but not go o
gg limited to those documents listed as references in Wu OO GAI Report No. 1848, "An analysis of Low Trajectory Turbine O* Missile Hazards, Perry Nuclear Power Plant, Units 1 and 2,"
@g October 1976 (" Gilbert heport").
y 9-2. Identify' all documents Applicants intend to present as evidence or cae in cross-examination of Intervenor an4/or NRC Staff witnesses on Issue #13. Producs any such docu-ments not identified in the response to the previous in-terrogatory.
9-3. Identify all persons Applicants intend to call as witnesses on Issue #13.
(a) For each person so identified, state the person's address, title, employer, and educational and pro-fessional qualifications.
(b) State the subject matter, including the substance of facts and opinions, on which each such person is expected to testify. Identify and produce any ' docu-ments to be relied upon by each such' person in his/
her testimony.
9-4. Have Applicants or any of their agents prepared any revisions, addenda, supplements, or Updates to the Gilbert Report since October 1976? If so, produce same.-
9-5. Have there been any changes to any assumptions, data, or dimensions (e.g., design changes or differences between the design and as-~ o uilt conditions) used in the Gilbe et heport? If so, identify each such change and the portion
^
of the Gilbert Report thus affected.
9-6. Have Applicants or any of their agents at any time con-sidered any differing designs of the Perry facility with regard to arrangement of turbine-generators and the con-thinment, control complex, and auxiliary building? If so, produce all such designs, and explain why they were not
utilizied. Were any such designs contemplated specifically to reduce the hazard of turbine missiles?
9-7. Have Applicants incorporated or considered any structures, equipment, or components (e.g., barriers or shielding of safety-related targets) to lessen the risk of turbine missile damage to the Perry facility? If so, produce any such plans or designs and indicate which have been or will be incorporated into the Perry facility; for those designs not so utilizied, explain why.
9-8. List every reason why Applicants consider the risk of turbine missile damage at_the Perry facility acceptable.
(a) What do Applicants consider to be an acceptable risk with regard to turoine missile nazards" Provide the basis, including any experimental data, for this opinion.
(b) For every reason identified aoove as to why Applicants consider the risk of turbine missile damage acceptable,
' provide any bases, including any experimental data, supporting this view.
(c) To what extent are these opihions based on Engineering
\
l judgement?
9-9. (a) Have the turbine-generators, overspeed control systems, and turbine stop and control valves (or any other associated systems or components) been subject to D
i any tests or inspections, either by vendors or Ap-plicants or their agents?
i (c) If so, describe any such tests or inspections.
., u (c) If not, indicate when such tests or inspections will be performed. If no tests or inspections are planned, explain why not.
(d) Have any tests or inspections as described above revealed any flaws, defects, deficiencies, non-conformances, or other anomalies in any system, equipment, or component identified in subpart (a) above? Describe any such anomalies in detail.-
(e) For each such flaw, defect, deficiency, nonconfor-mance, or anomaly described aoove, state when and how the deficiency will be resolved, and describe the technical bases for the resolution chosen.
9-10. Have any of the equipment or components listed in Inter-rogatory 9-9(a) above oeen previously operated or used (other than in testing) in any other application or.
facility? If so, provide the complete operational history of any such component and explain why a new unit was not utilized instead.
l 9-11. Have the turoine-generators of tne size and type to be l
! utilized at PNPP been used in any other application (both nuclear and fossil fuel, and test /proto. type applications)? - .
(a) If so, state the name, location, and type of facility where such a turbine-generator is (or was) in use.
(o) Give the complete operational history of each turbine-generator at each application identified hoove, in-cluding date of initial operation, number of turbine-f I
l years in operation, and any failures, incidents, or accidents involving the turbine-generators.
> (c) Provide a complete description of any turbine failures identified above, including causes identified, cor-rective actions taken, and the consequences of any turbine failures; i.e., were missiles produced, and, if so, describe the number and size distribution and the degree of damage tney caused and range of missile trajectory.
9-12. Provide an estimate of the cost required to change the orientation and placement of the Perry turbine-generators from the tangential arrangement presently incorporated to a radial arrangement (with respect to the containment and other safety-related targets). Provide the bases for ,
this cost estimate.
9-13. Do Applicants in their defense on Issue #13 intend to take credit for:
(a) quality standards used in the manufacture of turbine discs or otner components the failure of which could produce turbine missiles; (b) inservice inspection and maintenance programs for turbine discs and other components the fad a of which could produce turbine $1ssiles; (c) turbine overspeed protection systems?
(d) If the answer to any of the above is affirmative, state the exact nature of the defense to be used and provide the applicable quality standards, in-4 service inspection programs, etc.
9-14. The Gilbert Report only considers the low-pressure stage turbines as missile sources. Why has the high-pressure
,, -, - ~,-
i a stage not been considered? Provide all bases for the answer.
9-15. Table 2-2 of the Gilbert Report presents " allowable impact momenta on final barriers." Define the term
" allowable" as used in that table. I.e., does " allowable" mean the missile does not penetrate the barrier, or that the missile does not cause spallation?
9-16. It is stated at p. 9 of the Gilbert Report that GE data on turbine missiles is " reportedly" based on experimental disc-bursting studies performed by the turbine manufac-turer. Produce this experimental data and describe the methodology used in the studies.
9-17. Provide detailed drawings of the turbine low-pressure stages, showing and identifying the turbine discs and
" wheel groups" of Tabie 2-4 of the Gilbert Report.
9-18. It is stated at p. 25 of the Gilbert Report that D frag-ments are excluded from analysis because they are assumed to be of minimal threat to the plant. Provide the basis of that assumption. What effect would the inclusion of the D fragments in the analysis have on the final prob-
~
' ability calculation?
9 -19 '. It is stated at p. 25 of the Gilbert Report that all missiles are assumed to be generated with equal indepen-dent probabilities in all directions. Provide the basis of this assumption.
9-20. (a) Does the direction of turoine rotation have any oearing on missile trajectory? Explain the bases of the answer.
& (b) What is the direction of rotation (e.g., clockwise or counter-clockwise from the perspective of an observer stationed between the two cooling towers facing plant west) of the Unit 1 turbines? Of Unit 27 9-21. It is stated at p. 23 of the Gilbert Report that a uniform velocity distribution is hasumed for ekch fragment,- re-l flecting the uncertainty in velocity datain previous turbine failures. Provide the basis for this assumption and demonstrate its conservatism.
9-22. It is stated at p. 32 of the Gilbert Report that in evaluating all targets, triple impact P3 values were I
assumed to be equal to control room values given in i
Table 3-5 because of the relatively small effect on P 4, with the exception of containment vessel targets. state the basis of this assumption and demonstrate its conser-l l vatism.
9-23. Section 10.2.1 of NUREG-0887, the Perry SER, states that the Staff's final acceptance of the inservice inscection plan for disc bores and keyways as recommended by the turbine manufacturer is contingent on a documented com-mitment by Applicants. When will Applicants submit this documentation? Produce any draft or final inservice in-f j
spection plans for disc bores and keyways.
9-24. For what steam environment (temperature,' Erossure, pH, purity, etc.) is the turbine designed? What assurance is there tnat the design steam environment will be main-tained?
I l
9-25. Section,10.2 of .JUREG-0887, the Perry SER, states that Applicants' inservice ins [oection program for turoine steam valves requires the exercising of the main steam stop and control, reheat stop, and intercept valves at least once a week.
(a) How many such valves are present on each turbine to be used at PNPP7 (b) Does the exercising of any of these valves affect the power output of the generator? By what amount?
(c) Is it not true that any load reductions necessary for valve exercising will create a disincentive for such inspections? If not, why not?
(d) .What assurance is there that the inspection schedule will oe adhered to?
Issue #14 Statement of
Purpose:
The following interrggator'es are designed to ascertain the factual bases of Applicants' opposition to the incorporation of in-core thermocouples at PNPP.
9-26. Identify and produce all documents in the possession of '
Applicants or any of tneir agents pertaining to the use of in-core or core-exit thermocouples in boiling water reactors.
9-27. Identify all documents 1.pplicants intend to present as evidence or use in cross-examination of Intervenor and/or Produce any such docu-NRC Staff witnesses on Issue #14.
ments not identified in tne response to the previous interrogatory.
9-28. Identify all persons Applicants inter.d to call as witnesses on Issue #14.
(a) For each person so identified, state the person's addre s s , title, employer, and educational and pro-fessional qualifications.
(b) State the subject matter, including the substance of
- facts and opinions, on which each such person is expected to testify. Identify and produce any documents to be relied upon by each such person in his/ner testimony.
9-29. State every reason, including cases, why Applicants oppose the use of in-core or core-exit thermocouples at PNP,P as an indication of inadequate core cooling.
l 9-30. State every reason, including bases, why Applicants oppose the use of in-core or core-exit thermocouples at PNPP as a redundant and diverse indication of reactor vessel water level.
9-31. Have Applicants at any time developed any plans or designs (including draft or preliminary plans) for usir~ 'n-core or core-exit thermocouples at PNPP? If so, produce all such plans and any supporting or related documentation.
9-32. Do Applicants 'oelieve that the incorporation of in-c6re or core-exit thermocouples at PNPP could provide infor-mation useful for dctecting propagating core damage?
Explain why or why not, and include the bases for your answer.
9-33. Do Applicants believe that tne incorporation of in-core or core-exit thermocouples could provide useful, unambiguous
& and definitive information following a loss of water inventory with no normal, emergency, or alternate makeup systems available to replenish coolant inventory? Explain wny or why not, and include the cases for your answer.
9-34. Provide a cost estimate for installing in-core thermo-couples at PHPP (assuming 4 thermocouples per quadrant, as recommended in Regulatory Guide 1.97). Provide the bases for the estimate.
9-35. Describe in detail tne vessel level monitoring capabilities and instramentation at PNPP and explain why Applicants believe these are sufficient.
9-36. What capabilities and instrumentation do Applicants intend to use at PNPP to detect inadequate core cooling?
9-37. It is stated in Section 1.11 of NUREG-0887, the Perry SER, that, as a license condition, a final report analyzing inadequate core cooling instrumentation requirements for TMI Action Plan Item II.F.2 should be submitted by July 1982.
(a) Has this report been suomitted yet? If not, state when the report is expected to be submitted. .
(b) Produce this report.
Issue #15 Statement of
Purpose:
The following interrogatories are designed to ascertain applicants' plans for protecting FNPP from the effects of steam erosion.
9-38. Identify and roduce all documents in the possession of Applicants or any of their agents pertaining to steam
e erosion and measures that may be taken to prevent, detect, assess, or mitigate the effects of same.
9-39. Identify all documents Applicants intend to present as evidence or use in cross-examination of Intervenor and/or NHC Staff witnesses on Issue #15. Produce any such docu-ments not identified in the response to the previous interrogatory.
9-40. Identify all persons Applicants intend to call as witnesses on Issue #15.
(a) For each person so identified, state the person's address, tit 19, employer, and educational and pro-fessional qualifications.
(b) .S. tate the subject matter, including the substance of facts and opinions, on which each such person is expected to testify. Identify and produce any docu-ments to be relied upon by each such person in his/
her testimony.
9-41. List every component, system, item of equipment, etc. at PNPP which is suoject to steam flow. For each i * -m iden-tified, give the applica' ole ASME ; classification.
9-42. For each item identified above, state whether Applicants believe it is vulneraole to damage from steam erosion, and provide the cases for the answer.
9-43. For each item identified aoove, produce Applicants' in-service inspection program.
9-44. Descrioe in detail any plans, provisions, designs, criteria, standards, etc. which Applicants may have for preventing i steum erosion and the effects thereof.
k 9-45. Describe in detail any plans, provisions, programs, etc.
which Applicants may have for detecting and assessing steam erosion or the effects thereof.
9-46. Describe in detail any plans, provisions, procedures, etc.
which Applicants may have for mitigating steam erosion or the effects tnereof. Include any procedures for the repair or replacement of any affected components.
9-47. What is the vendor / manufacturer of the MSIVs to be used at PHPP?
9-48. It is stated in IE Information Notice 82-22 that the Oconee licensee (Duke Power Co. ) theorized that reduced power operation and resultant lower quality steam contri-buted to accelerated steam erosion.
(a) Define the term " steam quality."
(b) Explain how steam quality is related to level of power operation.
(c) Explain how steam quality influences the, degree of steam erosion.
(d) In the responses to the above subparts, include the bases of the answers.
Do Applicants in their defense on Issue #15 intend to I 9-49.
take credit for any ote.er PNPP systems (e.g., MSIV leakage control system)? If so, identify each such system and state how it prevents or mitigates steam. erosion or the effects thereof. Include the bases for your answer.
9-50. Do Applicants in their defense on Issue #15 intend to take credit for any inservice inspection programs?
If so,
- (a) identify each such inservice inspection program; (b) state when it is to be submitted; (c) identify any codes, standards, regulatory requirements or guides to which it complies; (d) produce the inservice inspection program when available.
9-51. For each item identified in tne response to Interrogatory 9-41 above, give the pressure and steam flow rate expected in normal operation and the maximum pressure and steam flow rate for which tne item is rated.
General Interrogatory 9-52. For each interrogatory above, identify the person (s) responsible for the response and provide the professional qualifications for each such person. If any documents were relied upon in responding which were not previously identiil-4, identify and produce these documents.
Respectfully submitted, f
Susan L. Hiatt
- OCRE Hepresenta._.e 8275 Munson Rd.
Mentor, OH 44060 (216) 255-3158 O
s CEnTIFICATE OF SEdVICE This is to certify that copies of the foregoing OHIO CITIZENS FOR RESPONSIBLE ENERGY NINTH SET OF INTERROGATORIES TO APPLICANTS were served by 4ep'osit in the U.S. Mail, first class, postage prepaid, this 3/ f day of January to those on the ser vice list oelow.
?
Susan L. Hiatt SERVICE LIST Peter B. Bloch, Chairman Atomic Safety & Licensing Board Daniel D. Wilt, Esq.
U.S. Nuclear Regulatory Comm'n P.O. Box 08159 Washington, D.C. 20555 Cleveland, OH 44108 Dr. Jerr R. Kli e Ronald G. Wiley AtomicSafety&L[censingBoard CEI-PNPP U.S. Nuclear Regulatory Comm'n P.O. Box 97 Washington, D.C. 20555 Perry, OH 44081 Mr. Glenn O.. Bright Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Comm'n .
Washington, D.C. 20555 OfYice f kN xEcuhlve Legal Director U.S. Nuclear Regulatory Comm'n Jay Silberg, Esq.
l 1800 M Street, N.W.
Washington, D.C. 20036 Atomic Safety and Licensing .sppeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
(