ML20052A307

Responds Further to ASLB 800616 Order,Question 1.FW Madden Affidavit Summarizes Applicant Methods for Handling Amount of Hydrogen in Containment Structure

ML20052A307
Person / Time
Site:	Comanche Peak
Issue date:	04/19/1982
From:	Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Cole R, Mccollom K, Mark Miller Atomic Safety and Licensing Board Panel
Shared Package
ML20052A308	List: ML20052A307 ML20052A311
References
NUDOCS 8204280180
Download: ML20052A307 (3)

Text

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DEB EVOIS E & LIBERMAN

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N TcLEpNCNC (2C2) e$7* 9800 April 19, 1982.

Marshall E. Miller, Esq. Dr. Kenneth A. McCollom Chairman, Atomic Safety and Dean, Division of Engineering, Licensing Board 7xchitecture and Technology U.S. Nuclear Regulatory Oklahoma State University Commission Sti'.1 water, Oklahoma 74074 Washington, D.C. 20555 Dr. Richard Cole Member, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Texas Utilities Generating Company, et al.

(Comanche Peak Steam Electric Station, Units 1 and 2), Docket Nos. 50-445 and 50-446 Gentlemen:

By Order of June 16, 1980, the Atomic Safety and Licensing Board (" Board") directed Texas Utilities Generating Company, et al. (" Applicants") and the Nuclear Regulatory Commission ("NRC" or " Commission") Staff to provide informa-tion regarding three issues raised by the Licensing Board, viz., hydrogen generation (Board Question 1), operating quality assurance (Board Question 2), and Safety Issue TAP A-9 (ATWS) (Board Question 3). Information in response to Board Question 2 was provided during the evidentiary hearings in December 1981. To further respond to the Board Questions, Applicants provide the following information regarding Question 1. Applicants will file information in response to Board Question 3 in the near future.

Board Question 1.

Describe in detail the planned method for handling any hydrogen gas in the CPSES containment structure.

Applicants' methods for handling the amount of hydrogen required to be considered by pertinent Commission regulation (i.e., 10 C.F.R. S50.44) are set forth in detail in Sections G50*r

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i 6.2.5 and 6.2.5A of Applicants' FSAR.and are summarized in the attached Affidavit of Fred W. Madden, Jr. The NRC Staff review and acceptance of Applicants' analyses are set forth in Section 6.2.4 of the Staff's Safety Evaluation Report

• I (July 1981).

4 There is ongoing research in this area (e.g., NUREG/

CR-2017, " Proceedings of the Workshop on the Impact of Hydrogen on Water Reactor Safety, January. 26-28, 1981" (1981) and the proposed rulemaking regarding, inter ~alia, consideration of additional hydrogen control measures (46 Fed. Reg. 62281 (December 23, 1981)). The Commission has stated that it is unlikely that for large PWR contain-ments (such as that at Comanche Peak) , such activities will require additional hydrogen control systems (4 6 Fed. Reg. at 62283). Nevertheless, Applicants of course will comply with any new requirements that may be imposed.

Beyond that, we invite the Board's attention to the Appeal Board's decision in October 1981, in which it discussed the Commission's generic considerations of hydrogen control.

In Sacramento Municipal Utility District (Rancho Seco Nuclear Generating Station), ALAB-655, 14 NRC 799 (1981), the Appeal Board in addressing an issue related to a licensing board question regarding hydrogen generation stated as follows:

But, as the Licensing Board observes, the Commission now has under consideration the consequences of the generation of large amounts of hydrogen within the containment following a TMI-2 event. In this circum-stance, we. rely on our prior holding that

" licensing boards should not accept in

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individual license proceedings contentions which are (or are about to become) the subject of general rulemaking by the Commission." Potomac Electric Power Co.

(Douglas Point Station, Units 1 and 2),

ALAB-218, 8 AEC 85 (1974). We thus leave the matter of hydrogen control at Rancho Seco to the Commission's consideration in the ongoing rulemaking and refrain from any explicit comment or judgment'on this portion of the Board's decision. [ Footnote omitted. 14 NRC at 816-7.]

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So postured, and given the information supplied in Mr. Madden's affidavit, Applicants submit that Board-Question 1 has been answered fully and that the taking of additional evidence at the forthcomin hearings is unnecessary. ,

Sincere!y, l6 i

Nichola! S. 1:eynolds DEBEVOIS & ,IBERMAN 1200 Se nt nth Street, N.W.

• Washington, D.C. 20036 (202) 857-9817 NSR/er Attachment cc: Service List 0

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