ML20033A833
| ML20033A833 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 11/20/1981 |
| From: | Woods N CITIZENS ACTION FOR SAFE ENERGY, FELDMAN, HALL, FRANDEN, REED & WOODWARD |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-CP, NUDOCS 8111300006 | |
| Download: ML20033A833 (6) | |
Text
i DOCKETED U1Nra UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIdN '81 h0V 23 P5:24 ATOMIC SAFETY AND LICENSING BOARD
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Before Administrative Judges Sheldon J. Wolfe, Chairman e
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Dr. Paul W. Purdom
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Frederick J.
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In the Matter of
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a Public Service Company of Oklahoma,
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cifQpey Associated Electric Cooperative, Inc.
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s Western Farmers Electric Cooperative
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Docket NoY.'j. 72,j p [N/
and
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STN 50-556CP'-
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STN 50-557CP (Black Fox Units 1 and 2)
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INTERVENORS ' PROPOSED CONTENTIONS FOR THE CONTINUED RADIOLOGICAL AND SAFETY HEARINGS RELATING TO HYDROGEN CONTROL ISSUES Pursuant to the Board's Orders of October 14, 1981, and November 12, 1981, Intervenors respectfully propose the follow-ing contention in light of the Applicant's Amendment No. 18 to'the Black Fox Station (BFS) Preliminary Safety Analysis Report (PSAR).
Intervenors submit that the following Contention should be the subject of evidentiary hearings in view of the Applicant's Amendments in response to NRC licensing require-ments arising out of, inter alia, the TMI-2 accident.
Inter-venors also understand that the NRC may impose additional TMI-mo3 s
lI Bl111300006 811120 PDR ADOCK 05000556 G
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sr related requirements (as identified in NUREG-0660) on NTCP applicants in the near future and this contention is without prejudice 'to Intervenor's right to challenge the sufficiency of Applicant's response to any such additional requirements.
HYDROGEN CONTROL MEASURES The Applicant has not demonstra*.ed that the hydrogen con-trol measures intended for use at Bla ; Fox will safely accommodate the equivalent of a 100% fuel-clad metal water reaction as identified by NUREG-0718, II.B.8 and as required by 10 CFR 50.34 (e) and - 50. 35 (a).
Specifically, there are concerns regarding:
1.
The time rate of hydrogen generation within the degraded core.
2.
The rate at which the hydrogen would be re-leased to containment.
3.
Verification of the hydrogen migration model.
4.
Acceptability of the manual initiation control system..
5.
Qualification of the ignitors and associated components.
6.
Qualification of in-containment safety-related equipment to withstand the conditions associated with repeated hydrogen burns.
2
+
7.
Qualification of the containment ii.nelf to with-stand repeated hydrogen burns.
8.
Effectiveness of the distributed ignition system (DIS) surveillance testing to assure a fully operable system.
The preliminary nature of the verification program is evidenced by, among other things, the list of ongoing and planned veri-fication tests contained in Table (2) (ix)-1 of Amendment 18.
Since the proposed DIS system is still under development, it obviously has not been demonstrated to be fully effective for the control of a large hydrogen release.
Respectfully submitted, FELDMAN, HALL, FRANDEN & WOODARD By g:fm
/1 Nancy 1. Woods 816 Enterprf'se Building Tulsa, OK 74103 s
DATED:
November 20, 1981
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00LKETED ushRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'81 NW 23 P5:24 ATOMIC SAFETY AND LICENSING BOARD SM
..I C:- SICliETARY
,,;ntimG & SERVICE BRANCH In the Matter of
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Public Service Company of Oklahoma,
)
Associated Electric Cooperative, Inc.
)
and
)
Western Farmers Electric Cooperative
)
Docket Nos.
)
STN 50-556CP (Black. Fox Units 1 and 2)
)
STN 50-557CP CERTIFICATE OF SERVICE I, Nancy L. Woods, one of the attorneys for Citizens Action for Safe Energy
(" CASE"), certify that copies of the following pleadings have been served on the persons shown on the attached list by United States Mail, postage prepaid, on this 20th day of November, 1981:
1.
Intervenors' Proposed Contentions for the Continued Radiological and Safety Hearings; 2.
Intervenors' Reply to Applicants and NRC Staff's Motions to Reopen; 1
3.
Intervenors' Supplement to Motion to Reopen the Radiological and Safety Hearings; 4.
Intervenors' Errata.
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Nancf L. Woods
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Sheldon J. Wolfe, Esq.
Andrcu T.
Dalton, Esq.
Atomic Safety and Licensing Attorney 'at Law Board Panel 1437 South Main Street United States Nuclear Room 302 Regulatory Commission Tulsa, Oklahoma 74119 Washington, D.C.
20555 Mrs. Ilene Younghein Mr. Frederick J. Shon 3900 Cashion Place Atomic Safety and Licensing Oklahoms City, OK 73112 Board Panel United States Nuclear Mrs. Carrie Dickerson Regulatory Commission Citizens Action for Washington, D.C.
20555 Safe. Energy P.
O.
Box 524 Dr. Paul W. Purdom Claremore, Oklabcma 74017
- Director, Environmental Studies Group Joseph Gallo, Esq.
Drexel University Martha E. Gibbs 32nd and Chestnut Streets Isham, Lincoln & Beale Philadelphia, Pennsylvania 19104 1D50 17th Street, N.W.
Washington, D.C.
20036 Docketing and Service Section Office of the Secretary of the Michael I. Miller Commission Isham, Lincoln & Beale United States Nuclear One First National Plaza, Regulatory Commission Suite 4200 Washington, D.
C.
20555 Chicago, Ill. 60603 (20 copies)
Mr. Maynard Human Atomic Safety and Licensing General Maanger Board Panel Western Farmers Electric United States Nuclear Cooperative Regulatory Commission P.
O. Box 429 Washington, D.
C.
20555 Anadarko, Oklahoma 73005 Atomic Safety and Licensing Mr. Gerald F.
Diddlc Appeal Board Panel Associated Electric United States Nuclear Cooperative, Inc.-
Regulatory Commission P.
O.
Box 754 Washington, D.
C.
20555 Springfield, Missouri 65801 Mr. Clyde Wisner Mr. Lawrence Burrell NRC Region 4 Rt.
1, Box 197 Public Affairs Officer Fairview, Oklahoma 73737 611 Ryan Plaza Drive Suie 1000 Dr.
M.
J. Robinson Arlington, Texas 76011 Black & Veatch P.
O.
Box 8405 Kansas City, Mo.
64114
u Dr. John Zink Public Service Company of Oklahoma P. O. Box 201 Tulsa, Oklahoma 74102 Mr.
T. N. Ewing
]
Public Service Company of Oklahoma P. O. Box 201 Tulsa, Oklahoma 74102
~ Hon.. Michael Bardrick Assistant Attorney General State of Oklahoma
[
State Capitol Building Oklahoma City, Oklahoma 73105 Mr. Gregory Minor MHB Technical Associates 1723 Hamiton Ave.
Suite K San Jose, CA 95125 Samuel J. Chilk Secretary of the Commission United States Nuclear Regulatory Commission Washington, D.C.
20555 4
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION y
ATOMIC SAFETY AND LICENSING BOAR,D'
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BRAtlCH O
Before Administrative Judges D
Sheldon J. Wolfe, Chairman j/h g[1[j[{p Dr. Paul W. Purdom fsf 9
Frederick J.'Shon fl0V~3 u.
I 1981u. --6 In the Matter of
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Public Service Company of Oklahoma,
)
Associated Electric Cooperative, Inc.
)
,//2fTT f '
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i and
)
Western Farmers Electric Cooperative
)
Docket Nos.
)
STN 50-556CP (Black Fox Units 1 and 2)
)
STN 50-557CP l
INTERVENORS' PROPOSED CONTENTIONS FOR THE CONTINUED RADIOLOGICAL AND SAFETY HEARINGS RELATING TO HYDROGEN CONTROL ISSUES Pursuant to the Board's Orders of October 14, 1981, and November 12, 1981, Intervenors respectfully propose the follow-ing contention in light of the Applicant's Amendment No. 18 to the Black Fox Station (BFS) Preliminary Safety Analysis Report (PSAR).
]
Intervenors submit that the following Contention should be the subject of evidentiary hearings in view of the Applicant's Amendments in response to NRC licensing require-ments arising out of, inter alia, the TMI-2 accident.
Inter-venors also understand that the NRC may impose additional TMI-po3 s
alo
~
1 related requirements (as identified in NUREG-0660) on NTCP applicants in the near future and this contention is without prejudice to Intervenor's right to challenge the suf ficiency of ' Applicant's response to any such additional requirements.
HYDROGEN CONTROL MEASURES The Applicant has not demonstrr,ted that the hydrogen con-trol measures intended for use at Black Fox will safely accommodate the equivalent of a 100% fuel-clad metal water-reaction as identified by NUREG-0718, II.B.8 and as required by 10 CFR 50. 34 (e) and 50.35(a).
Snecifically, there are concerns regarding 1.
The time rate of hydrogen generation within the degraded core.
2.
The rate at which the hydrogen would be re-leased to containment.
3.
Verification of the hydrogen migration model.
4.
Acceptability of the manual initiation control system.
5.
Qualification of the ignitors and associated components.
6.
Qualification of in-containment safety-related equipment to withstand the conditions associated with repeated hydrogen burns.
2
e-
+6 7.
Qualification of the containment itself to with-stand. repeated hydrogen ~ burns..
8.
Effectiveness of the distributed ignition system (DIS) surveillance testing to assure a fully operable system.
The preliminary nature of the verification program is evidenced by, among other things, the list of ongoing and planned veri-fication tests contained in Table (2) (ix)-1 of Amendment 18.
Since the proposed DIS system is still under development, it obviously has not been demonstrated to be fully effective for the control of a large. hydrogen release.
Respectfully submitted, FELDMAN, HALL, FRANDEN. & WOODARD By h CT Nancy 1. Woods
/4.,
816 Enterpri'se Building Tulsa, OK 74103 s
DATED:
November 20, 1981