ML20039G251
| ML20039G251 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/08/1982 |
| From: | Wilt D SUNFLOWER ALLIANCE, WILT, D.D. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8201150422 | |
| Download: ML20039G251 (7) | |
Text
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DOCKETED y c' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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Before the Atomic Safety an Board
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In the Matter of flECEIVED p
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CLEVELAND ELECTRIC ILLUMINATING ;
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MOTION TO RESUBMIT CCNTENTION 7 Intervenor Sunflower Alliance el al. hereby moves the Board to grant it leave to resubmit its Contention 7, " Hydrogen Control,"
in this proceeding.
Contention 7, which was originally submitted in Sunflower's March 1981 " Petition for Leave to Interven6," was not admitted as an issue because the contention was not of the form I
required by Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1), CLI-80-16, 11 NRC 674 (1980'); i.e.,
a cred-ible LOCA scenario entailing hydrogen gent, ration was not proposed.
That deficiency is correcte'd herein; in. addition, it will be shown thdt this. filing satisfies the " good cause" requirements of 10.CFR 2.714 for late filings of contentions.
Hydrogen Control Cont ention Sunflower's original hydrogen control contention (Seventh ground of intervention) reads, in part:
Petitioners allege that tnere is insufficient documentation' cf,the ability of the containment structures of said facilities to safely inhibit a hydrogen explosion of the nagnitude and type which occurred at Three Mile Island Unit 2 near Harrisburg, Pennsylvania and of which the Ocmaission is cware.
These Intervenors still allege this; epecifically, they allege that 8a01150422"020107 p58$
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1 the conditions set fortn in 10 CFR 50.44(c)(1) have not been met, 1
and consequently the containment should be inerted, as required by paragraph (c)(2) of that section.
The Applicant in its FSAR makes no claim that the containment could " withstand the consequences of uncontrolled hydrogen-oxygen rccombination without loss of safety function."
Although the Applicant does claim that such an uncontrolled reaction would not occur prior to the effective operation of the combustible gas control system, this claim lacks proper substantiation, since the Applicant han not considered all possible factors pertaining hereto.
The Board in its Special Prehearing Confcrence Memorandum and Order (p. 53) points out that the Commission in Metropolitan Edison Company stated that hydrogen gas control should be litigated, not under 10 CFR 50,44, but rather under 10 CFR Part 100, if it can be demonstrated that a credible LOCA scenario exists that would entail hydrogen generation and combustion and resultant breach of containment leading to offsite radiation doses exceeding Part 100 guidelines.
It would seem that litigation under Part 100 would be attacking site suitability, which the Board has prohibited in regard to the emer6ency plannin6 contention (SPC Memo. and Order at 25); however, Sunflower Alliance et al. will follow the' Commission decision and provide the required scenario..
This Intervenor almost hesitates'to do so, for fear that.it will be limited to one accident scenario when there exist many such.
credible scenarios.
It objects to the limitation of acci. dents to the LOCA, when in fact other accident sequences (e.g., ATWS) can also lead to fuel clad melting and subsequent hydrogen ccn6 ration.
Nevertheless, since the languaEe of CLI-80-16 and 10 CFR 50.44 A
m,
. specifies the LOCA, this limitation will be adhered to.
Accor' ding to the Reactor Safety Study (EASH-1400), successfpl mitigation of a LOCA depends upon[:
1.
availability of electrical power, either offsite or onsite (standby);
2.
successful actuation of the Reactor Protection System; 3.
proper functionine of the vapor suppression system; and 4.
ECCS actuation and functionability.
The failure of any one of these systems results in core melting and/or a loss of containment integrity by one of several mechan' isms (melt-through, overpressure, leakage, steam explosion, or hydrogen explosion).
The mechanism of interest here is the hydrogen explosion.
An example of a specific accident scenario is:
1.
a pipe break in the reactor coolant pressure boundary chuses a LOCA, as defined by 10 CPR 50.46(c)(1).
2.
failure of the ECCS to maintain coolant inventory.
The cause of this failure may be: electrical or mechanical component failure; common mode failures resulting. from the LOCA; design deficiencies which undermine ECCS effectiveness; and/or operator error.
3.
the Zircaloy fuel cladding melts; the zirconium reacts with water, 11berat,ing hydrogen gas.
4.
.the hydrogen concentration within the containment increases to the, flammability limit before the combustible gas control system becomes. effective, or said system never operates effectively.
5.
uncontrolled hydrogen-oxygen reaction (explosion) occurs.
6.
containment is breacned; a substantial fraction of the core inventory of fission products 'is released to the atmosphere, rcsulting in offsite doses at the LPZ boundary which exceed the 10 CFR 100.11 guidelines of 25 rces whole body and'300 rems thyroid.
This scenario is admittedly lacking in minute details.
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was unclear as to the degrce of detail required for a litigable scenario, and as stated above, this Intervenor hesitates to
-. - - - - - - - + ~.,
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commit itself to one highly detailed and specific scenario when doubtless there are other routes leading to the same end.
It is questionable whether the hydrogen gas control system at Perry will be operated in a timely and effective manner.
- First, all components of this system (analyzers, mixers, recombiners, and puree capability) are activated manually by the operator (FSAR, Section 6.2.5).
Relying on manual operation during the stressful emergency situation follewing a LOCA would likely increase the possibility of operator error.
The o,peration of the hydrogen analyzers, the first step in the hydrogen control sequence, may be delayed for 15 minutes to one hour af ter the LOCA (FSAR, Section 6.2.5.2.1).
This delay seems inappropriate, especially in li ht E
of the standard of 10 CFR 50.44(d)(1):
"A time period of 2 minutes shall be used as the interval after the postulated LOCA over which the metal-water reaction occurs."
Secondly, the effectiveness of hydr 6 gen recombiners is questioned in Regulatory Guide 1.7 (p. 1.7-4): " Hydrogen recombiners can process the containment atmosphere at a limited rate of 100-150 scfm per recombiner.
Therefore, an inordinately large number of recombiners would be required to control the hydrogen concentration thEt is postulated to be Eenerated in the first 2 minutes of the~
LO CA. "
Perry uses 2 recombiners per unit; each reccmbiner ic sized for a 100 scfm flow rate (FSAR, Section 6.2.5.2.3).
This Intervenor considers containment purging as a hydrogen control measure to be unacceptable, as this results in radioactive relcases to the environment.
Section 2.714 Requirements for Late Filings On Decemoer 2, 1981 the l@C published its final rule on
-5 l
" Interim Requirements helated to Hydrogen Control" (46 FR 5848'4).
This rule requires inerting of Mark I and Mark II E7iR containaents, hydrogen recombiner capability, and high point vents in the reactor coolant. system.
The proposed rule, published on Octocer 2, 1980 (45 FR 65466), included 12 items; eight of these items were also included in a proposed OL rule (46 FR 26491, May 13, 1961) and therefore were not considered in this final rulemaking.
Of the four remaining items, only one would directly address the Perry i
plant design: ite= 2, requiring design analyses for Mark III B? irs and P7ths.
This item was not incorporated into the final rule; indeed, it is not even given further mention in the Federal Register notice.
This failure of the Commission to act definitively on this matter, wnich had been under consideration fcr at least a year,_ clearly indicates that the rulemaking process is not adequately addressing this issue.
Plant-specific litigaticn is therefore appropriate; this Intervenor intends to pursue this avenue and for this reason moves to resubmit Centention 7.
The recent notice of final rulemaking and its lack of applicability to the Perry case constitut'e " good cause" for this late filin5s as required by.sub-paragraph (1) of 10 CFR 2.714(a)(1).
Sub-pdragraph (ii) of that section addresses "the availability of other means rehereby the petitioner's. interest will be protected."
As discussed a'ocve, rulemaking is not effectively resolving the hydrogen control issue, especially as it concerns PNPP.
Sunflower Alliance et al. is intervening in this spccific case; this is the only fprum which can properly address its interests concerning FKPP.
Involvement in a generic rulemaking proceeding would:
and 1.
divert its nearce reecurces frc= the Perry case,
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2.
probably not produce a timely resolutien of the probler..
Safety issues are appropriately addressed before the plant begins operation.
The criteria of sub-paragraphs (iii), (iv), and (v) are likewise satisfied by this Intervenor, whose participation on l
this otherwise neglected issue will surely aid in developing a sound record.
Although OCRE had a similar contention, it too was rejected by the Board, and OCRE has not filed.for its resub-mission.
Thus, no other party is pursuing this issue.
The inclusion 1
of this contention will broaden the issues, but the degree of delay, if any, caused thereby is highly speculative.
These factors clearly favor the adn.ission of this contention in this proceedinE, and Sunflower Alliance e al. prays that the Board is so moved.
Respectfully subnitted, M
jf)aniel D. Wilt, Esq _
Attorney for Sunflower Alliance, Inc et al 7301 Chippewa Rd.
l Brecksville, Ohio 44141 (216) 526-2350 PROOF OF SERVICS l
A copy of this Motion to Resubmit Contention 7 has been sent to all persons on the attached Service List 'on this 8th day
- January, 198
[O J
f pnielD. Wilt,Esq, l
Attorney for Sunflower Alliance, Inc I
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SERVICE LIST - -
Bloch, Chairman Dr. Jerry R. Klein -
Peter B.
Atomic Safety & Licensing B'odrdStill P3D4Xtomic Safety & L'icensing Board Nuclear Regulatory Commission (OS's Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 e.:,
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?"4 Mh Jay Silberg, Esq.
Frederick J. Shon Atomic Safety & Licensing Board 1800 M Street N.W.
Nuclear Regulatory Commission Washington, D.C.
20036 Washington, D.C.
20555 Daniel J. Herron, Esq.
Donald T. Ezzone, Esq.
Assistant Prosecuting Attorney Assistant Prosecuting Attorney Ashtabula County Courthouse
- 105 Main Street Jefferson, Ohio 44047 Painesville, Ohio 44077 Jeff' Alexander Tod J. Kenney 228 Scouth College St.
Apt. A 920 Wilmington Ave.
Bowlin6 Green, Ohio 43402 Dayton, Ohio 45420 Robert Alexander Terry Lodge, Esq.
2030 Portsmouth St.-Apt. 2 915 Spitzer Elds.
Toledo,' Ohio 43604 IIouston, Texas 77098 Atomic Safety & Licensing Appeal Board Docketing & Service Section Office of the Secretary Nuclear Regulatory C6mmission Nuclear Regulatory Conmission Washington, D.C.
20555 Washington, D.C.
20555 Charles Barth, Esq.
Nuclear Regulatory Commission Washington, D;C.
20555 9
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