ML20067B263
| ML20067B263 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/30/1982 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8212060108 | |
| Download: ML20067B263 (9) | |
Text
REIATED ConRESPONDENCD 6,
,Nov:m'oer 30COSOS@D UNITED STATES OF AMERICA 'UE NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensine Boar 2 EC -2 f.10 :07
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In the Matter of )
)
^
CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50-4'40 COMPANY, Et A1. ) 50-441 (Operating License)
)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
)
OHIO CITIZENS FOR RESPONSIBLE ENERGY RESUBMISSION OF SIXTH SET OF INTERROGATORIES.
TO STAFF WITH THE PhhSIDING OFFICER AND MOTION hEQUESTING THE PnESIDING OFFICER TO REQUIRE THE NRC STAFF T0 aNSUER. SAME I. Introduction On September 13, 1982, Intervenor Ohio Citizens for Responsible Energy ("0CRE") filed its Sixth set of Inter-rogatories, pertaining to Issue #8, to the NRC Staff. By letter dated October 29, 1982, counsel for Staff informed OCRE's Representative that the Staff would not voluntarily answer any of the interrogatories, claiming that they are oeyond the scope of Issue #8, as defined by the Appeal Board in ALAB-675, 15 NRC 1105 (1982). During the conference call held on November 15, 1982 in an attemot to resolve this con-Y troversy between OChb and the Staff, the Licensing Board deter-
_1/ OCRE does not believe that tnis conference call totally solved the dispute. An accident scenario still has not
'ocen determined, nlthough tnere was some discussion of an accident scenario involving a worst-case small break LOCA, with defeat by plant operators of all make-up water and heat removal systems, entailing an 80% metal-water reaction, no conclusions were made either to adopt this scenario or to solicit filings from the parties as to the 8212060108 821130 PDR ADOCK 05000440 (continued next page)
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'k mined that, in order to compel discovery on the Staff, OCRE would h&ve to refile the interrogatories, pursuant to 10 CFR 2.720(h)(2[(11), and make the showings required therein before
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the Board cduld direct the Staff to answer the interrogatories.
The Licensing Board accepted OCRE's suggested deadline of November 30, 1982 for this filing.
OCRE hereby resubmits the interrogatories (attached) and
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moves the presiding officer to require the Staff to answer the ,
interrogatories specifically identified in'Part III below.
II. The Standards for Discovery Against the NRC. Staff <
10 ~ CFR 2.720(h)(2)(ii) governs discovery by means of interrogatories against the staff. In order to compel'the Staff to answer interrogatories, a two-fold test must be men:
first, that the answers to the interrogatories are necessary 4
to a proper decision in the proceeding, and, second, that.
the answers to the interrogatories are not reasonably obtainable from any other source. OCHE will demonstrate that both of these criteria have been met in Part III below.
Some of the interrogatories are in fact document requests.
Document requests to the Staff are governed by'10 CFR 2.744.
Subpart (d) to that section again defines two criteria for the
_1/ continued. suitability or credibility of the scenario.
It is OCRE's position, in accordance with the explicit dire ctives of ALAB-675, that it is the Licensing Board's responsioility to define the scenario. OCRE would appreciate tne Board's prompt attention to bhts-matter, as counsel for Staff has indicated to OCHE's Representative the possible intention of the Staff to move for summary disposition of Issue #8 if such a scenario is not promptly determined.
This would obviously prejudice OCHE if it were deprived.
of the right to litigate such an important issue.
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production of Staff documents; first, that the document is relevant to the proceeding, and second, that the information is'not reas6 nab,le obtainable from any other source. However,
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the decision in' Consumers Power Company (Palisades Nuclear Power Facility), ALJ-80-1,12 NHC 117 (1980) held that document requests against the Staff must be enforced where relevancy has been demonstrated unless'~ production of the document is exempt under 10 CFR 2.790. In that case, and only then, must it be demonstrated that disclosure is necessary for a proper decision in the proceeding. The Staff has not claimed that.any
- of the documents requested by OCRE are exempt under 10 CFR 2.790; OChE will therefore only demonstrate relevancy in its document requests.
Although the regulations do not specifically rddress this issue, OCRE feels that it is incumbent upon the Licensing Board to consider the public interest in compelling discovery against the Staff. OCHE is a public interest group with lim 3'ed financial resources; it cannot be expected to participate.
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meaningfully in tnis proceeding without access to NRC documents.
Indeed, it is essential to fairness and justice that the Board, by compelling discovery against the Staff, alleviate to some
_2/ Counsel for Staff has repeatedly informed intervenors-tnat NRC documents are availaole for inspection and copying at tne NHC's Puolic Document Room in Washington, D.C. However, OChE members do not live ih #ashington.
It oecemes rather inconvenient to drop by the PDR to examine documents wnen one lives in Ohio. If OCRE members are forced to journey to Washington to obtain documents, this can only result in' the delay of this proceeding.
w degree the disadvantage at which OCRE finds itself due to
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. tne vast disparity of resources between Staff and Applicants,
~' on one hand, and intervenors, on the other.
III. Discussion of Specific Interrogatories Interrogatories 6-1, 6-2, and'6-25: These interrogatories must be answered by specific individuals on the Staff; the information requested is not available otherwise. Counsel for Staff has admitted. that Interrogatory 6-1 is relevant to Issue #8 (see letter dated October 29, 1982 from James M.
Cutchin IV to Susan L. Hiatt); however, the Staff refused to answer the interrogatory properly (under oath or affirmation) as required by 10 CFR 2.740b(b). All 3 of these interrogatories concern accident scenarios, the determination of which, ac-cording to the Appeal Board in ALAB-675, is the first step in the litigation of Issue #8. This information is thus necessary for a proper decision in this case. ,
Interrogatories 6-3 and 6-4: These interrogatories concern the MARCH code, a methodology which is capable of analyzing many plant conditions and parameters as a function of time for different accident sequences. Rate and quantity of hydroger production are among the items calculated; such information is obviously relevant to 1ssue #8. Indeed, the Staff, by refusing to release this information, places OCHE in a Catch-22 situation the Staff expects OCHE to define the TMI-2 type accident scenar for Ferry, yet will not provide OCHE with the information neces-to do so. FitRCH code calculations for Perry (or Grand Gulf,
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if the Staff has not performed calculations for Ferry) would obviously aid the Board in the selection of a scenario and would he ,'nscessary for the subsequent litigation of the adequacy of PNPP hydrogen control methods once the, scenario is selected.
It is also important to know the limitati'ons of the MARCH code to ensure tnat the data being rel.ied upon is accurate. OCHE is not aware that this information is available from any other source.
Interrogatories 6-5, 6-12, 6-13, 6-26, and 6-30: These inter-rogatories pertain to the strength of the Mark III containment used at PNPP. OCRE considers this concern to be of centr'al
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importance to Issue #8; this information is tnus necessary to a proper decision and must be provided by individual members of the NRC Staff.
Interrogatories 6-6, 6-7, and 6-10: These interrogatories pertain to the suitability and efficacy of the various hydrogen control systems proposed for the BWR Mark III containment. It is vital that the Staff's position on these methods be fully delineated and explained. Obviously this information cannot ce obtained from any other source than the particular Staff members responsible for same. (OCRE would note that the fact that this same information was requested of Applicants does not
. nullify the showing on the second criterion of 10 CFH 2.720(h)
( 2 ) ( 11 ) , i . e . , that the information is not availaole elsewhere.
It is the Staff's perspective that OCRE seeks, and this may well oe vital to a proper decision in this proceeding. )
Interrogatories 6-8, 6-14, 6-15,-6-32, and 6-34: These inter-rogatories deal with the effectivenes,s and safety of using
.. ~. '... ' .
V Although recombiners to control nydrogen in the containment.
recombiners are intended for use during the design basis LOCA,
- rather thah.a degraded core accident, OCHE is unsure whether
'the'recombiners-mightEbe used during.the early phases of such an accident. (Applicants' procedures for the hydrogen control system are not yet developed.) If in fact recombiners are used and the hydrogen generation in early phases of a severe accident, rate increases rapidly, it is possible that the rate of hydrogen production will exceed the capability of the recombiners; it ,
is even possible, under such circumstances, that the recombiners will trigger an expolsion. Information concerning the effective range of H2 concentrations of the recombiners and the degree to which they might become ignition sources, including data on biners exploed ons in off-gas systems ,w'hich might be due to the recom OCHE believes that used therein, becomes relevant to Issue #8.
this information must be provided by individual Staff members.
These interrogatories deal with Interrogatories 6-9 and 6-11:
the proposed hydrogen control rule and the ongoing research It is important for OCRE to be aware of referred to therein. t to i
both regulatory developments and new research pert nen this information is available Issue #8. OCHE is not aware tnat elswhere.
Interrogatories 6-16, 6-17, 6-18, and 6-24: These interrogatories concern the safety and efficacy of using glow-plug igniters as Applicants have proposed the use a hydrogen control method.
of igniters at Perry to c,ontrol hydrogen resulting from a de-graded core accident. It is therefore obvious that the in-
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formation requested herein in necessary for a proper decision in this case and that this information must be supplied by
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particulas~.Sfaff members.
- Interrogatories 6-19 and 6-21: These interrogatories question whether the Perry hydrogen control system (including igniters) meet all NRC regulatory requirements. This information is nece'ssary for a proper decision in this case and cannot be obtained from any source other than the NRC Staff.
Interrogatory 6-20: This interrogatory pertains te sources of ignition within the Perry containment. This information is' relevant to Issue #8, as at low concentrations (less than 18 vol-%) an ignition source must be present to cause burning of hydrogen. OCHE maintains that this information must be supplied by individuals on the Staff.
Interrogatory 6-22: This interrogatory concerns the qualification for accident environments of the hydrogen analyzers to be used at PNPP. Use of the analyzers is the first step in the hydrogen
- control sequence at Perry; the timely initiation of the analyzers may be dependent upon the environment to which they will be ,
exposed. This interrogatory must be answered by individuals l on the NnC Staff.
Interrogatories 6-23, 6-31, and 6-33 : These interrogatories pertain to tne hydrogen mixing system to be employed at Perry.
Although the mixing system is primarily designed for the design basis accident, OChE is unsure whether they might be used along with the igniters' for a more severe accident (Ap-l plicants have not yet developed , procedures addressing this
5 matter). Also, it is possible that the mixers would be used at the early phases of an accident which later ' escalates to
'a more severe condition. The effectiveness of the mixcrs could
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'^ affect later stages of the accident, with regard to containment integrity . The information is thus relevant to Issue #8 and must be supplied by the Staff.
Interrogatories 6-27, 6-28, and 6-29: These interrogatories concern the pressure and temperature transient experienced by the Perry containment as a result of hydrogen combustion.
Such information is necessary to a proper decision in this case, and must be provided by individual Staff members.
Interrogatory 6-35: This interrogatory questions whether the Staff has found the manual initiation of the Perry hydrogeri .
s control system to be acceptable. OCRE suspects.that manual actuation of this system may be unreliable due to the chance of operator error. The hydrogen control system cannot be -
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effective if it is not initiated in a timely manner. Thus) i this information is vital to a proper decision inthis satter.
Only the Staff can provide this information.
Interrogatory 6-37: This is a general interrogatory, the answer l
l to which may provide OCRE with informa' tion that is necessary .
t to a proper decision in this proceeding. It can only be answered
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by memoers of the Staff. (
1 Respectf,ul2y Us ubmitted, r
Ak M Susan L. Hiati c ,
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s~ 'OCRE Representative .
GE75 Munson hd.
5 1
Ekntor, OH 44060 '
"I' (216) 255-3158~.
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00LKETED u CE.qTIFICATE OF SERVICE USt!RC This is to certify that copies of the foregoing OHIQ CITIZENS F0h RESPONSIBLE ENERGY RESUBMISSION OF SI7182 89 O N gg INTERROGAT0 HIES TO STAFF WITH THE PRESIDING OFFICER AND MOTION REQUESTING THE PRESIDING OFFICER TO REQUIRE THE NHC HTAFF 50r. ~ 7
,, ANSVIER SAME were served by deposit in the U.S. Mail? lfirst'USO;n"CE class, pogtag6 prepaid, this 30th day of November, 1982 4622 those on the service list below. .
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. Jerry R. Kline Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Frederick J. Shon 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 i Washington, D.C. 20555 ,
James M. Cutchin, IV, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Comm'n 4
Jay Silberg, Esq.
4 1800 M Street, N.W.
t Washington, D.C. 20036
(
Atomic Safety & Licensing Appeal Board Panel 3-U.S. Nuclear Regulatory Commission Washington, D. C. 20555 c.
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September 13, 1982 00LKETE0 UNITED STATES OF AMERICA ** E NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board'82 DEC-2 N0:08
)
- in the Matter of )
e ;-: . . IEcpETAR i '
)
Decket Nos. 50-440r.u g ,g m I CLEVELAND ELECTRIC ILLUMINATING 50-441' " "
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COMPANY, Et Al'. )
) (Operating License)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
)
OHIO CITIZENS FOR RESPONSIBLE ENERGY SIXTH SET OF INTERROGATORIES TO NRC STAFF Ohio Citizens for Responsible Energy ("0CRE") hereby pro-pounds its sixth set of interrogatories to the NRC Staff, pur-suant to the Licensing Board's Memorandum and Order of July 28, 1981 ( LBP-81-24, 14 NRC 175).
Issue #8 Statement of
Purpose:
The following interrogatories are designed.
to ascertain the Staff's assessment of the hydrogen control features to be implemented at Perry and the ability of the Perry containment to withstand a hydrogen explosion.
5-1. What does the Staff consider to be the equivalent of a TMI-2 accident at Perry? Provide the probability of its occurrence and Enorough description of its consequences, including fuel failure modes, effect on containment in-tegrity, and off-site doses to the public at 2, 5, 10, and 50 miles from PNPP.
6-2. What does the Staf,f consider to be the worst-case accident Provide the probability in terms of H 2 generation at Perry?
of its occurrence and a thorough description of its con-E a Cl',LO5 0 ? -
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sequences, including fuel failure modes, effect on contain-ment integrity,: and off-site doses to the public at 2, 5,
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- 10, -and 50 miles from PNPP.
Has the Staff (or anyone on its behalf or to its knowledge) 6-3. ,
'perfonned MARCH code calculations specific to Perry for any accident sequences? If so, produce these analyses.
,..4 If Perry-specific calculations have not been perforked, produce all MARCH code analyses performed for Grand h If t
(most useful are graphical presentations of the calculated parameters versus time; e.g., pp. C-13 to C-44 of NUREG/CR-1659, Volume 4).
6-4. Describe in detail the capabilities and limitations of the MARCH code. Discuss any approximations and assumptions and their bases. Specifically, can the MARCH code account for the effects of steam concentration on hydrogen flam-mability, effects of containment structures or equipment- on flame fronts, effectiveness of the hydrogen control system,
' and effects of deliberate hydrogen ignition on the con-tainment and equipment therein?
6-5. Commissioner Gilinsky has stated that the Mark III .is a weak. containment that should be required to be stronger.
(47 FR 2300, January 15, 1982). How could the Perry j
containment be strengthened? Include a cost estimate of l
l all measures that could strengthen the Perry containment.
6-6. SECY-80-107A contains view-graphs presented by General Electric to the NRC which state that containment incrting, hydrogen ignition, recombiners, and parging are all tu-Ioes practical for significant rates of H2 production.
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the Staff agree? If not, why not?
6 ,7. .' The Commission has stated that hydrogen control' methods
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thaE d not involve burning. provide protection for a wider spectrum of accidents than do'those that involve. burning (46 FR 62282, December 23, 1981).. Wha't are the bases for
, _. this statement? _.
j6-8'. NUREG/CR-1561 at p. 49 states.that spont'aneous. hydrogen
, deflagrations or detonations have' occurred in the off-gas ~
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, systems (handling quantities of H2 due to radiolysis)'off lof several BV!Rs (Cooper, Browns Ferry 3, Millstone l[.
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(a) What were the magnitudes and consequences of these explosions?
(b) 'Did these incidents occur because of the failure or.
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inadequacy of the recombiners?
Tc) Did the recombiners provide the igniti'on source? -
(d) Are these recombiners similar to those to be used at Perry? ,
6-9. What is the status of the proposed rule to 10 CFR Part 50,
" Interim Requirements Related to Hygrogen Control," 47 FR 62281, December 23, 19817 6-10. What types of hydrogen control systems are available for preventing H2 buildup and/or explosion in Mark III containments? Briefly discuss each system, listing the advantages and disadvantages of each. Which system is favored by the Staff? Why?
6-11. It is stated in the discussion of the proposed rule (46 FR 62282) that there are ongoing programs of research pertaining to hydrogen generation, release, burning, and
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- j. control. Please list all'such research programs. '@
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'[Briefly describe the status ior each, ' along with any-7;.;
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- . 3p,in,terim findings and . the expected dat.e . of completion s,-
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. 'C'V'and publication of result's.
.6-12'. . SECY-80-107 at p. 30 states that the Staff b'elieves'that ,
the Mark III containment has a failure pressure of at e
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.'least twice the design pressure.- .
.,?
. (a) Is this es'timate based on static or' dynamic pressures?
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4 (b) Provide a'11 factual bases andIe~xper'imental' evidence
. supporting.this bell'ef. '
6-13. Has the Staff performed any analyses on the -ultimate '
strength of the Perry containment? If.so, produce them.
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' Discuss all assumptions, judgements, and approximations
'made~1n the analyses and the bases [for.them.
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6-14. At what range of concentrations (volume-%) of H2 are recombiners of the type'to be used at PNPP effective in reducing the H2 concentration below flammable limits?
6-15. If the recombiners were' ineffective in' reducing H2 con-centrations, would the recombiners become an ignition hazard? At what H2 concentration?
l 6-16. At what range of H2 concentrations (volume-%) are glow plug igniters effective in reducing H2 concentrations below flammable limits?
6-17. Does the Staff believe that the igniters could pose a l
l hazard to the integrity of the containment and the
- equipment therein by causing severe detonations?
6-l8. Does the Staff believe that the normal, expected operation -
of the ignit'ers (controlled ignition) could pose a threat
V .
. to the integrity of the cont'ainment or,the equipment
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. therein by causing high temperatures and cyclic pressure
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....;Kpuises.?
'6-19. In the Staff's opinion, has the Perry' hydrogen control 3 ,
system met the requirements of GDC 41, 42, and 43 of
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3 '10 CFR Part 50?
Listall. criteria'not[ met. ,
6-20.
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Has the Staff a'nalyzed the Perry containment f or- sourc'es .,-
. .of ignition? If so, produce.the results of the' analysis..'
6-21.. Has the Staff' analyzed the. Perry hydregen control system against all applicable regulations, regulatory guides,
. branch technical positions, and'other standards? If so,
' produce the results of this analysis, especially describing o n '
3 < any instances in which criteria and guidelines 5have: nbt
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been met. If this analysis has.not been performed, when does the Staff intend to do'so?
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6-22. FSAR Section 6.2.5.2.1 states that delaying the start of the analyzers until 15-60 minutes following the LOCA will avoid exposing the analyzer to severe sample con-ditions. In the Staff's opinion, can severe conditions persist beyond 15-60 minutes after the LOCA? After transient sequences?
6-23. In the Staff's opinion, for containment H2 concentrations above 4 vol-%, would the mixers accelerate combustion by providing a uniformly combustible atmosphere in the containment? Why or why not?
6-24. In the Staff's opinion, could the ignition of hydrogen by the glow plugs produce missiles that could damage the containment or equipment therein? .
o' -
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6-25., Provide off-site radiation d$ses (whole body and thyroid)
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. ,- to the public.at'2, 5, 10, and 5'O miles from PNPP re-
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" sul' ting from containment purge' follbwing each of the
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following accidents: .
. _;, (a) what the Staff considers'to be the equivalent of a
. TMI-2 accident at Perry;. .. ,
(b)~ what.the Staff considers'tb be the' worst-case accident
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in tenns of H2 generation,for. Perry;' _. ,
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the following accidant sequences'as d'efinediin
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.' (c)
NUREG/CH-1659, Volume 4 (RSS Methodology. applied to Grand Gulf): ' -
(1) AI -
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4
'4 (2) A2 N
. (3). AC .
(4) SI -
(5) SC (6) SE -
(7) T 1PQI .
(8) T PQE 1
(9) T 23PQI (10) T 23PRE (11) T QVI y
(12) T QUV 1 .
(13) T1C (14) T QUW 1 .
(15) T230 .
(16) T234W (17) T23QUW
9 (18) T23QUV 6-26. In the Staff's opinion, would overpressure from H2 PPO-duction alone -(no explosion) be sufficient to. rupture the containment? -From what' % metal-water reaction?
6'-27. Describe the pressure and temperatuhe~ transients which<
would be experie'nced by the containment from the com-plete combustion of the following concentrations of I hydrogen (vol-%, assume abundant oxygen) r
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(a) 4% .
(b)'6% ,
(c) 9%
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(d) 12%
(e) 18%
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(f) 24%
(g) 33% ,
6-28. Are the results given above based'on any experimental data or studies specific to either th'e Perry or the
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generic Mark III containment? Produce all such studies.
6-29. List any assumptions made in the preparation of such studies, e.g., regarding the quenching effects of steam /
humidity or the effect of containment structures and equipment on flame fronts.
6-30. If the Staff has performed any analyses of the Perry
. containment, did this analysis consider containment If.not, penetrations as possible points of rupture?
why not? .
6-31. In the Staff's opinion, could blowdown through the suppression pool or direct drywell-to-containment
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_a_
leakage exceed the capac'ity of the' mix'ers?
6-3'! } In the Staffi s . opinion, could direct .drywell-to-contdin-
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. ;. ~. [ .zhdnt' leakage dissipate hydrbgen,.outside the . area from -
which the recombiners take sucti.on. or outside the regions.
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where the igniters are located? . '
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6-33. 'In' the Staff's opinion', .w'ould the', drywell-to-contain ..
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ment differential pressure - ever - be great enough ( e.g. , ,
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after upper pool dump) that 'the mixer compressor. head is'
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. insufficient to. clear the upper auppression c . pool v.ents?-
In the Staff's opin16n, could the recombiners produce
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6-34.
" hot spots" which could adversely affect the containment or' equipment therein?. .. ..
. 6-35. Does,the Staff consider the manna'l actua' tion of all; components of the Perry H2'" control" system acceptabl'e? -
If so, how can this be justified,cs'ince:large' amounts of H2 can be produced within minutes of. core overheating (NUREG/CR-1651, pp. 36-37; SECY-80-107, p'.;6)?
6-36. NURE0/CR-1561 at pp. 36-37 states that once the core
- temperature exceeds 14000K,-only minutes remain before significant quantities of H2 are produced. 14000K corresponds to 2061 F. 10 CFR 50.46(b)(1) limits the cladding temperature to 22000 F. Does this mean that, even if the ECCS Evaluation Model meets this criterion, substantial hydrogen could still be generated? Are 10
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CFR 50.46 (b)(2) and (b)(3) consistent with the amounts of hydrogen exp'ected to be generated when the cladding
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temperature reaches 22000F7 6-37. List all documents relied upon in answering the above
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interrogatories, and list all perso1s$ responsib le for
- the answers, along with. their profess'ional qualifications.
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Respectfully submitted,-
. Y-Susan L.~Hiatt OCRE Representative '
,. ,~ 8275 Munson Rd.
i'. Mentor, OH 44060..
-(216) 255-3158
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