ML20008F698
| ML20008F698 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 04/17/1981 |
| From: | Ketchen E, Lewis S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20008F690 | List: |
| References | |
| NUDOCS 8104210513 | |
| Download: ML20008F698 (19) | |
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4 l'NITED STATES OF AMERICA MJCLEAR REGULATORY COMMISSION i
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
In the fiatter of
)
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DUKE POWER COMPANY I
Docket Nos. 50-359
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50-370 (William B. McGuire Nuclear
)-
Station, Units 1 and 2)
)
NRC STAFF RESPONSE TO "CESG'S REPLY TO APPLICANT'S MOTION FOR LICENSE AUTHORIZING UP TO 35% RATED POWER OPERATIONS" I.
STATEMENT OF THE CASE On March 24, 1981 Applicant filed a "...fdotion for License Authori-zing Operations Up to and Including 35*; Rated Power Operations". On April 2,1981 Intervenv Carolina Environmental Study Group ("CESG") filed a reply to the Applicant's motion. On April 8,1981 the NRC Staff filed a response to the Applicant's motion and a motion-for leave to respond to CESG's reply by April 17, 1981.
By order of April 10, 1981 the Atonic Safety and Licensing Board granted the Staff leave to respond and also permitted Anplicant, if it wishes, to respond by that date.
II. REFERENCE TO RULINGS Under 10 CFR S 50.57(c), if a motion for partial power operation is
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j opposed, the Licensing Board must make findings under S 50.57(a) as to those issues in controversy which are relevant to the activity to be authorized. Wisconsin Electric Power Co., et al.
(Point Beach Nuclear i
i 810.42105cs
Plant, Unit No. 2), ALAB-53, 4 AEC 899, 900 (1972); Ducuesne Licht Co.,
et al.
(Beaver Valley Power Station, Unit No.1) LBP-76-3, 3 NRC 44 and LBP-76-23, 3 NRC 711 (1976).
III. STATE.'1ENT OF THE ISSUES PRESENTED CESG raised two objections to Applicant's c.otion:
1.
That CESG contentions 3 and 4 --1/
raise matters in controversy concerning protection of the public health and safety and that an initial decision on these matters must be rendered under S 50.57(a)(3) before the partial power operation requested may be authorized.
2.
That the testimony of Mr. Muench, relied on in Applicant's motion, relates only to a replay of the TMI-2 accident and does not address the broader spectrum of loss-of-coolant accidents 2/
which are raised by CESG contention 1.
1/ Those contentions read as follows:
Contention 3 - Neither licensee nor NRC staff has demonstrated that the en,ergency planning radius of 10 miles is sufficient for protecting the public from the radioactive releases of a low pressure, ice con-denser containment ruptured by a hydrogen explosion.
Contention 4 - Licensee and NRC planning do not provide for crisis relocation which would be required as a result of containment breach and radioactive particle release.
2/ Contention 1 reads as follows:
The licensee has not demonstrated +. hat, in the event of a loss-of-coolant accident at McGuire:
1.
Substantial quantities of hydrogen (in excess of the design basis of 10 C.F.R. section 50.44) will not be generated; 2.
That, in the event of such generation, the hydrogen will not combust; and 3.
That, in the event of such generation and combustion, the containment has the ability to withstand pressure below or above the containment design pressure, thereby preventing releases of off-site radiation in excess of Part 100 guideline values.
. Although not explicitly stated, CESG has, therefore, also raised conten-tion 1 as a matter in controversy as to which findings must be made under s 50.57(a)(3) prior to authorization of partial power operation.
IV. ARGUMENT A.
Contentions 3 and 4 NRC Staff has consistently argued in this proceeding, most recently in 3!
its oroposed findings, that contentions 3 and 4-relating to insufficiency of emergency responte in the event of a breach of containment resulting from hydrogen explosion - are contingent upon a showing that such ex-plosion and resulting breach of containment are credible events, which in turn, is the specific issue placed in controversy by Contentions 1 and 2.
A firJing favorable to CESG on contentions 1 and 2 is a necessary predi-cate to the assertion postulated by contentions 3 and 4 Thus, for con-tentions 3 and 4 to be " relevant" to the partial power motion, there must be an initial determination by the Licensing Board in favor of CESG on contentions 1 and 2, to the extent those contentions are relevant to the partial power license request. The simple interposing by CESG of contentions 3 and 4 as objections to the partial power license does not raise these
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issues to the level of contentions relevant to the requested partial power i
license.
3/ NRC Staff Proposed Findings of Fact and Conclusions of Law in the Re-opened Licensing Board Proceeding Regarding Hydrogen Generation in the Form of a Supplemental Initial Decision (April 13,1981 ), pp.11-12.
. B.
CESG's Objection to Applicant's Reliance on the Muench Testimony The Muench testimony, relied on-in Applicant's motion, asserts that for the specific scenario analyzed by Mr. Muench - a loss of feedwater event (Tr. 3046), with circulation in four steam generators (Tr. 3048), with auxiliery feedwater not resumed for oser an hour (Tr. 3051), at 35 percent power operation (Tr. 3046) power operaten re-lief valves ("PORV") would not be opened. Thus, there would be no ioss-of-coolant accident (Tr. 3046). Nor would metal-water reaction beyond 25 of core inventory occur.~4/ Within the limits of this scenario, the issues raised by CESG cententions 1 and 2 are not relevant since no sub-stantial amount of hydrogen is generated.
CESG objects, however, asserting that other scenarios " roughly equivalent to a PORV which had stuck in the open position",
i.e., any small pipe break,~5/are encompassed within contention 1.
The Staff agre as that contention 1 is not limited to an exact replay of the TMI-2 loss of feedwater event, but has encompassed other small break LOCA events with significant emphasis on S2D. Our review of the Muench testimony leads us to the conclusion that, standing alone, it does not demonstrate that substantial amounts of hydrogen cannot be gen-4/ See Testimony of K. S. Canady, L. A. Reed, R. A. Muench and H. B.
Barron Regarding McGuire Nuclear Station Operation Relating to ECCS Terminetion, following Tr. 3045, question and answer 2; Tr. 3046-51, 3083.
5/ Reply, p. 3.
m e
- erated as a result of small break LOCA thence, other than the specific event addressed by Mr. Muench occurring while the facility is at 35 percent power.
Tnus, the Muencn testimony does not demonstrate that contention 1 is not' relevant to 35 per:ent power operation.
However, CESG errs when it assumes that Applicant's motion must be denied because the specific testimony cited in the motion initially is not sufficient for the Board to make needed findings.
There is an exten-sive record of evidence in this proceeding adcressed to the issue raised by contention 1 as to whether there is a credible accident sequence at McGuire which could lead to breach of containment. We believe the Li-censing Board may look to this entire record in determining whether to grant Applicart's motion. Based upon its review of the record, the Staff has concluded that the McGuire units can be operated at full power with '
reasonable assurance of the protection of the public health and safety against possible hydrogen generation and combustion resulting from accidents bearing a reasonable relationship to the accident at TMI-2. -6/
We think the Licensing Board can readily reach the same conclusion with respect to operation at 35% power.
For the convenience of the Board we have identified certain of the Staff's Proposed Findings which we believe can be used by Li-censing Board to determine the issues in controversy with respect to the Applicant's partial power motion.
[7~~~ProcosedFindincs.p.64
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V.
CONCLUSION For the reasons developed above, the Staff does not believe that the evidence cited in Applicant's Motion of March 24, 1981 provides the basis-i for Licensing Board findingt authorizing operation of McGuire Unit 1 at 35" power. The Staff does, however, believe that there is ample evi-dence already existing in the record to support issuance of a 255 partial power license, as well as a full power license.
Respectfully subnitted, L
Stephe# H. Lewis Counsel for NRC Staff ff A
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n c_cd42AW Edward G. Ketchen Counsel for NRC Staff Dated at Bethesda, Maryland this 17th of April, 19Sl.
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ADDENDU'i In addition to tne testinony cited in tne Applicant's motion, the Staff nas listed below tnose findings which it believes may be used as an initial decision authorizing operation at 35% power. Tne findings listed are taken from the "!RC Staff Proposed Findings of Fact and Conclusions of Law in tne Reopened Licensing Board Proceeding Regarding Hydrogen Generation In tne Forn of a Supplerental Initial Decision" (April 13,1951).
Footnotes in tne quoted findings have been omitted.
4
c-Froa Procosed Finding 22 Duke's first panel as3erted that the primary cause of the production of excessive hydrogen at the Three Mile Island Station, Unit 2 ("TMi")
(Tr. 2639-3034) was the premature termination / reduction in operation of the ECC5.
(Duke Panel 1, p.1; Tr. 2870). The evidence shows that measures taken at the McGuire Nuclear Station ("McGuire") after the THI accident reduce the possibility of improper operator termination of the ECCS to very low levels.
(Duke Panel 1, p.1; Tr. 2843-2891; 2920-3104).
From Propo wd Findinc 28 Sigrificant changes have been nade in the McGuire emergen:y pro:ed;res v.ni:n v.ill reca:e tne likelih0: of oremature terairation of i. :S a.: tes
- ssi
- ili:;. of inade uate ::re cc: ling.
(Dake Panel 1, :: 5-E; Tr. 2953-7,
....... t J...-i,;.
I,
_'n,'1 Procosed Finding 31 Resu :tien cf ECC5 creration - If EC:s creration has been interrurted,
- nrosen ir:rocer crerator a: ion or otherwise, tte evidence indicates that tnere 1
is an e>:ende: Deriod before significant hydrogen troda::icn c::u-s - ever t
2 n:;rs in tre event of a loss of feedwater event with cooling by circulati ?
tnros;n all fc r stear generators (Duke Panel 2, p. 2; Tr. 3046-48) and a::r:>inately 1 no;r after the rcre general 52D small break !.0:A event.
l (Staff Analjsis, ;. 2;.
Energency procedures re:;uire lo;;ing ever., 15 tinutes for I nr rs follov.ing ECCS termination of the parare:ers used in tne E CS ter-ir.a icn criteria ( Jie Fanel 2, p. 3).
If the lo; en: ries are l
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a: ve :.e sce::fie: cri:eria, e ergen:y or :edares re:; ire reini:ia:i:-
of ECC5 c; era: :..
(Daie Farel 2, ::. 2-3;.
-2 Proposed Finding 48 During the TMI event, hydrogen released to containment was ignited by existing ignition sources in containment.
Duke indicated trat it is reasonable to assume that in a similar situation inside the McGuire containment, without the igniter system, hydrogen would be ignited by existing sources (Rasin HMS testimony, p. 1).
Tne purpose of tne distributed ignition syste, is to provide additional ignition sources to assure that any hydrogen released to containment will ignite at concentrations of about 81 (Rasin HMS testinony,
- p. 1). Corbustion of hydrogen at sus... concentrations does not involve detonation (Duke Corbustion Testinony, p. 5).
proposec Findinc 53 in the event of a LOCA involving hydrogen generation, the pressure in tFe primary coolant s.vstem would cause the resulting hyPogen and steam mixture exiting through the break to enter the lower containment in the form of a high velocity turbulent jet, which would rapidly nix comoletely with air in the lower compartment.
P_rolosed Findinc 55 r
Duie Power Concany, along with other utilities, has sponsored an exoeri-rental program (Fenaal. Inc.) to determine the effectiveness of the hydrogen igniters ("glowplugs") such as those installed at the McGuire Unit 1 cuclear pc er plant, as well as at the TVA Se::uoyah facility.
(Easin DES testirony,
- p. 2; Staff Analysis, pp. 10-16).
This expericental progra-ce onstrated that ne hydrogen igniters which have been installed at M:Guire Unit I can effectively initiate a hydrogen burn.
(Easin HMS testircry, p.
2; Sta##
Analy;is, pp.10-16 ; DAe E xhibits 5A-5D).
P00R BRIGINkL
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rron Proposed rin ing o.q
.s.
Independent corbustion tests of the thernal igniter conducted by the Lawrence Livermore National Laboratory for the P.C Staff confirred the C0ility of the procosed Deke igniter to ignite cas nixtures over a range of conditions. (Staff Analysis, c.15).
Fror., rocoses,
.. d1nc to rin.
Tne
".",0.:M analysis was carried cut until 1550 pounds of hydrogen were released, correscencir.; 10 at ut ET. of the active zirceniu cla:: ding rass in "e core.
Inis is creater inan the a curt cf retal-nater reaction in tre a:t al Tr:-2 se sence, wnich involve between 3n and e05 retal-ater rea: tic.
Duke Cortustion Testincny, c. 2: Staff Analysis, po. 2, 20, 21.i r. m,.
Preocsed findinc 7S ine car.ei testified tnat, witn the igniters in creraticn, icnition and burni ::
cf nycrocen woulc c: cur by: (a} a continucus burn in the ice condenser utrer ciene area, (t} a series of Durns initiated in tre lower containrent, er (c) a co-binatien of inese tw: turning catterns (Duke Co-b;stion Testir:ny, c.1?).
iPer the nyd crer,-stea -air rixture in le-er contain ent will be:o e fla : able and be i: nite: by tne glen Olues ic:ated tnere or ne hydrogen contentration in t"e
.meer rienur of tre ice condenser will reach a prcximately S.5' and a centinuc.;s t.,rn will ens.;e in :nat regien until tre contentration existin: [in the ice condenw r falls belew nis a:Crcxirate concentratica. M., p. 11.
Tre turnin of hycrogen in tre le-er co cart ent is the enenc enen redeled by CLASIX (Tr. 5:J'.
Continse;s b.;<ning in tne ice condenser u;;er cienu, wnich D,ie c:".sicere: te e tne res: 1 i.el;. scenaric, and which would be tre scenaric if icwer cc-art e-t
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burns do not occur because of inerting, results in a containment pressure rise of only a few psi compared to t he 16 psig modeled by CLASIX (Tr. 3173, 3174, 3177,3353-3357,5084,5085).
from Proposed Finding 82 As noted above, Duke's witnesses, particulary Dr. Lewis indicated that in the event that the lower compartment became inerted, hydrogen would burn without detonation in t? e upper plum [ plenum] * *
- From Proposed Finding 83
- * *Thus, concentrations at or near detonable levels do not exist in the Lpper plenum. * *
- Procosed 'ia'ing 84 Tre re:ord also eAriered whether tFere were cor.figsrations ir. the ice c cr.:e rs e r sirilar to inese in Dr. Lee's exreri er.ts.
Tnree re;iens in the 4:e cc de-ser were discusied as areas in which transition to detor.ation rice: o::ur.
T-ese re;'c 5 were (1) the areas between the ice baskets, (2) tne ur:er cien;,
a-f (?) :-e air handlin; d; ts.
Tne evidence deronstrates that t'e areas between l
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- e ice bakes de n:t cens:itate ccnfired char els ar.d sideaays screadir: of t e c.'-ec.s
's:ure risir.; thres;* the ice condenser wasid occur.
Tr. 32f -f2.
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. P00R BRIBlE
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Fron Proposed Finding 85 The upper plenum contains periodic structures:
The intakes for the air handling ducts; and the intermediate deck doors.
Dr. Bernan analogized these to Dr. Lee's obstructions.
Tr. 5057-58.
Tne air handling intake units do not, however, represent a sufficiently high degree of blockage such as to create any possibility of transition to detonation and the inter:nediate deck doors open sideways and would not, therefore, constitute any obstacle to a flame moving horizontally around the upper plenum.
I d_.
Fron Prooosed Finding 85 Duke has, however, comittcd to trio the air handling unit intake fans coincident with actv3 tion of the igniters.
Tr. 5160, 5175.
Procosed Finding 86 C. : e casis cf tre evidence develored, we find that (1) de:ce.a S e c:r.:e.. rat": s Of hydrogen will not be approached in the ice con:enser a.:
- 2) t*ere is no configuration in tne ice condenser where a transi:icr :o ce: niv er car c::gr.
We de not perceive the nroblers assc:iated win cf igr.iters in tre urrer plenur that have been raised b;.
c a:e e :
Sardia.
Le, trerefore, consider the placerent of igniters in tre v:;er lena.
0 ~ :ne ice condensor as part of the interir hydrogen ritigation syste-for
- Lire to be apprcrr:Ste.
Fron Proposed Findina 92 Based upon its analysis, Duke concluded that the functional capability of the containments is 67.5 psig.
Priory Testimony, p. 2.
The AMES Laboretcry analysis for the staff resulted in a calculated mean functional capability of 84 psig. Sta f f Aralysis, p. 28. A standard deviation was determined and was applied to this value to determine a lower bound functional capability value.
Id. To assure high reliability of leak-tight capability at its lower bound figure, the staff reduced the 84 psig value by three standard deviations (a standard deviation being 12 in this case) te arrive at a lower bound functional capability of 4E psig.
Id.
Tr. c593 Proposed Finding 95 As noted above, the containment functional capability analyses were ur.dertaien to determine capability of the facility to withstand a TM: 2 type o f accic'?nt. As we find, infra, the peak pressures calculated fcr an 520 accident at itcGuire (taking credit for the functioning of the igniters and all safety-grade equipment) are well below the lower [ Valve]
used by the Staff of 4S psig as functional ca.pability for the McGuire containnerts.
Thus, we find t".at in the event of a IMI-2 ty;e accidert, as described above, at McGuire, the containments can withstand the associated maximum pressures without releasing offsite doses in excess of 10 CFR Part 100 limits.
4 P00R BRIGINAI.
Fron Proposed Finding 100 The equipment deemed essential in the face of hydrogen combustion falls into two categories:
- 1) systems important to maintaining containment integrity in connection with the hydrogen burn and 2) systems important to recovery from an inadequate core cool-ing situation.
Reactor and Containment Systems Perforrance Assessment, following Tr. 5435 (hereafter, " Staff Performance Assessment"), p.1; Duke Exhibit SD,
- p. 6-2.
From Preposed Finding 101 The only system required for maintenance of containment integrity in connection with the hydrogen burn condition which appears to be susceptible to impact by hydrogen combustion is the air return fan system.
Staff lerformance Assessment, p. 2.
From Prooosed Finding 101
- * * [t]here is reasonable assurance that all of the necessary ccmponents of the air return fan system will remain functional during and following a hydrogen burn.
Fron Proposed Finding 102 Of the equipment necessary to recovery from inadequate core cooling, the equipment located within containment is comprised in the main of instrumentation to sense the syuptoms of inadequate core cooling.
Id., p. 3
From Proposed Findinn 102 The representative piece of equipment actually chosen for this analysis, a Barton pressure transmitter, has been qualified in excess of 3800F, thus providing margin above either the staff's or Duke's calculated cumulative temperature.
Tr. 4566, as modified at Tr. 4717.
From Proposed Finding 107
- * *[i]t was estimated that a total of 250 pounds of polyurethane foam would be pyrolized..Tr. 5136. This 250 pounds represents a very small fraction of the total mass of 27,000 pounds of polyurethane foam installed behind the outermost panels. Tr. 5136.
__From Proposed Finding 108 The resulting total energy contribution to the containment would be a maximum of 3 million btu's, which should be compared to the 30 million btu's contributed by hydrogen burning under Duke's S20 scenario. Tr. 5118-19, 5215-16. We find that this additional energy contribution will not significantly increase the total pressure rise in containment.
Tr. 5119, 5215-16.
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. Nt Proposed Finding 110 On the basis of the evidence deveioped on this record with respect to hydrogen control, we make the following findings of fact:
(1) ine-e is reasor.able assurar.:e that the EHM syste will relia:1y ope ratz to burn in a safe manner a ny si ;ni fic a r.:
tydro;er tha; Day be generated in the even: Cf 0 :urrer:5 cf a TMI-2 fpe a:cident a: M:5; ire.
'2) ine cor.ditior.5 o f burr.in g a: ":Suire in s uch ar e.er., a-d
- .e : rfi g;ratiore cf the M:Gai re cer.tainre are s u:r a.
ce or.atior o f s u:. hy dro;en will r.:
o::ve.
(3' T s t res s ures ge r.e ra t e d by the res ul ti r.; t.rr. ir :ne .:3.i-s cc.ainrer ts will te well belee the centairre-; fun::io al ca;atility a-d will re: result ir, ary brea:5 cf cor:airre ;
(*.
T.ere is ressorable assuran:e ina; esser. ial e:uir er; i-cor: Sin ert will sur.ive burr conditior.s ar.d fu : tic-tne re a #:e r.
.ine reasures ado:te; by Duke to re.,uce :ne 0:55;:.;;.
tr.
of operator ir.;erference with auto atic ECC5 cre a-i a :
- ne raasures adopted by Dut.e inclucin; an Ererge
. j:-:;e-Mi;ica tion Syster, to deal with hydrogen cenera:i:- i# a 10.-
protability less-of-coolant accident res 1:ir; it de;ra:e: :: e conditior.s sr.culd occur, provide ade:uate a ssu a.:5 : 2: a r
se;uence of eve.:s involving substantial nyde:;5-ge era:i:r.
and brea:". of contain ent resulting fro
- ".5 : :.sti:-
tners ' will c:t c: ur.
. M, A se:.E :e cf events involving substar.tial nyeroge, ger.eratier, Orei:
of cor.tain er.t resulting from tne co.basti0n tnere:f a *.:
is n:
a credirle ever.: as that terr is use: in 10 CFR Fart ICC.
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
DUKE POWER COMPANY
)
Docket Nos. 50-369
)
50-370 (William B. McGuire Nuclear
)
Station, Units 1 and 2)
)
I CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE Tn CESG'S REPLY TO APPLICANT'S MOTION FOR LICENSE AUTHORIZING UP TO 35% RATED POWER OPERATIONS" dated Aoril 17, 1981, in the above-caotioned proceeding, have been ss ved on the followina, by deposit in the United States mail, first class, or as~ indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 17th day of Acril,1981:
- Robert M. Lazo, Esq., Chairman, Mr. Jesse L. Riley, President Administrative Judge Carolina Environmental Study Group A.onic Safety and Licensing Board 854 Henley Place U.S. Nuclear Regulatory Commission Charlotte, North Carolina 28207 Washington, D.C.
20555 Dr. John M. Barry
- Dr. Emmeth A. Luebke, Administrative Department of Environmental Health j
Judge liechlenburg County Atomic Safety and Licensing Board 1200 Blythe Boulevard U.S. Nuclear Regulatory Commission Charlotte, North Carolina 23203 Washington, D.C.
20555 J. Michael ficGarry, III, Esq
- Dr. Richard F. Cole, Administrative Debevoise & Liberman Judge 1200 Seventeenth Street, N.W.
Atomic Safety and Licensing Board Washington, D.C.
20036 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Shelley Blum, Esq.
1402 Vickers Avenue William Larry Porter, Esq.
Durham, North Carolina 27707' Associate General Counsel Duke Pcwer Company P. O. Box 2178 422 South Church Street Charlotte, North Carolina ?8242 i
O b Mr. David E. Smith
- Atomic Safety and Licensing Board City of Charlotte Panel Legal Department U.S. Nuclear Regulatory Conmission 600 E. Trade Street Washiagton, D.C.
20555 City Hall Charlotte, Norta Carolina 25211
- Atomic Safety and Licensing Appeal Panel Diane B. Cohn, Esq.
U.S. Nuclear Regulatory Commission William B. Scnultz, Esq.
Washington, D.C.
20556 Public Citizen Litigation Group Suite 700
- Secretary 200 P Street, N.W.
U.S. Nuclear Regulatory Commission Washington, D.C.
20036 ATTN: Chief, Docketing & Service Br.
Washington, D.C.
20555
% n.b... E-.
5
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r Edward G. Ketchen Counsel for NRC Staff
.