ML20106D191

Response to Staff 850128 Motion for Summary Disposition of Issue 8 Re Hydrogen Control.Motion Fails to Demonstrate Absence of Genuine Issue of Matl Fact.Certificate of Svc Encl

ML20106D191
Person / Time
Site:	Perry
Issue date:	02/06/1985
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	Atomic Safety and Licensing Board Panel
References
CON-#185-506 OL, NUDOCS 8502130032
Download: ML20106D191 (34)

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ebruary 6, 1995 UNITED STATES OF AMERICA i[5; Eh NUCLEAR REGULATORY COMMISSION ha ,,

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Before the Atomic Sofety and LtcensingeBoard[$ i

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THE CLEVELAND ELECTRIC ) Docket?.Nos.CSO-440 OL ILLUMINATING CO. ET AL. ) 50-441 OL

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

OCRE RESPONSE TO STAFF MOTION FOR

SUMMARY

DISPOSITION OF ISSUE 8 I. INTRODUCTION On'Jonuary 28, 1985, the NRC Stoff moved for summary disposition of Issue #8, concerning hydrogen control. The

'bosis" for the Stoff's action is the incorrect wording of the issue. 5taff now claims that Issue #8 only congerns recomsiners, which are not designed to cope with the large amounts of hydrogen resulting from o degraded core occident.

As is demonstrotGd by the discussion below and by the ottoched offidovit of Susan-L. Hiott, the Stoff's motion is entirely lacking in merit, is woefully tordy, and is based upon a blatant misrepresentation of the facts of this case.

Intervenor Ohio Citizens for Responsible Energy (*0CRE') urges that the motion be denied.

Since'the staff has not addressed the merits of the hydrogen control system for degraded core occidents at Perry, OCRE will not address itself to these matters either, but will confine its -

response to the or.guments raised in the Stoff's motion. Should O

8502130032 850206 ..-

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Ls P ~any porty move for summary disposition of the issue on its

' merits, OCRE reserves the'right to file o substantive reply.

OCRE:olso reserves the right to respond to new faces and

'crguments which Applicants may raise.in their onswer to the n.

Staff's motion. 10 CFR 2.749 (o) .

II~.'5TANDARDS FOR

SUMMARY

DISPOSITION The'Stoff hos correctly stated that the burden of proof lies

'upon the.movo'nt for summary disposition, who must demonstrate

that no<. genuine issues of material Fact exist. Stoff's Nation

. ok 2-3. In-fact, the record and piecdings must be viewed in the ,

, light most'f'avorable to the opponents of' summary disposition.

JPublic 5ervice Co.'of New Hompshire (Seabrook Storion, Units

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-fond 2 ) ,' ' LBP-74-3 6',17 AEC 877 (1974).

In-an~ operating license pr.oceeding, where significant heoith

-ondescrety ~ or; environmental issues are involved, o Licensing

.Bcord should. grant.c. motion for. summary disposition only iflit!

isiconvinced 7 thot-the public.heoith ond'sofetytor.the ,

ienvironment-will-be;sotisfactorily. Protected. . Cincinnati Gos

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and Electric (Wm..H.'Zimmer Nucleor' station), LBP-81-2,.13 NRC-

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-3 6 ', 40-41 ( 1981 ). .

.I t' ~ olso; mus t be recolled,that summary disposition.of a safetylissue connot bel granted until:the Stoff1hos issued its L5arety1Evoluotion ReportJonEthot issue. l Duke Power Co.L(Wm. B.

Units.1 and 2), LBP-77-20, 5 NRC 680

} McGuire z Nuc' lear 15 to rion ,

(1977)..

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Finally, 10 CFR 2.749(d) states that

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(t)ha presiding officer shall render the decision sought if the filings in the proceeding, depositions, onswers to interrogatories, and admissions on file, together with the statements of the porties and ofridovits, if any, show that

'there is no, genuine issue os to any moterici fact and that the moving.porty is entitled to o decision as o mother of 10w.

Thus, the Licensing-Board must consider the eneire record on

, Issue M8 when deciding the Stoff's motion.

In light of these standards, the Stoff's motion utterly fail's - It conveniently. neglects the history of Issue M8 by

, seizing oni-the; erroneous wording'of the issue. It 0150 foils to-

'demonstrote that the'public heoith and safety Will be protected.

.III. THE STAFF'S MOTION 1IS ENTIRELY LACKING IN MERIT The Stoff has taken o narrow, literal interpretation of the wording of Issue M8,.which only specifically mentions recombiners os a hydrogen control system, in org'uing against the issue. The Stoff claims that, since.recombiners are not designed to' control large amounts of hydrogen, no issue.has been

'rcised by the contention. .The Staff further claims the

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d'is tribu te'dfigni ter system, which is. designed tooccomodate-large-amounts of hydrogen (but-is of unproven efficacy), is not-

.. p chollenged-by Issue M8,

. 'As is' demonstrated by the'ottoched offidovit, this. View

. neglects the_ hi5 tory- of :the issue'and the re, cord, especially'

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-discovery,,of this proceeding. The Commission's regulations y

expressly require-summary' disposition motions to be decided'in

, light Offthe entire ~ record. 10 CFR 2.747(d).

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'This Licensing Boord hos always taken this approach. E.g.,

Icompare the' Board's response to Staff ossertions that the Boord, in deciding'the summary disposition motion on quality assurance, had'odmitted new contentions beyond the scope of the original

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' contention:

We would also admit the Comstock ollegation at the summary disposition stage regordless of whether it were causally related to'the initial contention. Contentions set the stage for discovery. .They limit, to some extent, the scope of discovery.

However, if an intervenor discovers o genuine issue of fact that reflects on plant safety, then it con establish a genuine issue of foct for trial. The principle is similar to modern federal practice in which pleadings are considered omended as proof

' shifts.

LA less flexible rule of practice would be inappropriate for our proceedings. To throw out o genuine issue of fact, uncovered

~during discovery, on technical grounds, would be ontithetical to the Commission's. cole of protecting-the public and antithetical to the Boord's role of addressing legitimate grievances raised by on intervenor durir.9 litigation. January 28, 1983 Memorandum and Order (Reconsideration Q/A) at 7-8.

.The record on this issue. indicates that ther'e_has been discovery on the distributed igniter system, to which no-party

- -hos objected. It-is clear that the odequacy of this system hos nev'er!.been-demonstrated .os required by the Commission's new

hydrogen-rule. See OCRE's Updated Responses to Applicones'-

.Second S e e lo f Interrogatories ~ to OCRE, dated J nuary 22, 1985.

Evidencefexists that no one hos ever considered Issue M8 to Exhibit 1.(more fully explained in

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be limited to recopginers.

l0CRE's' January 22, 1985 Motion to Reword Issue M8) ' demonstrates.

that NRC management. considers' Issue M8 os encompassing

' containment hydrogen control measures.' Exhibit 2 is o hondout presented by the Hydrogen Control Owners Group, of which.

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' Applicant is'a member, at the January 23, 1985 NRC-HCOG meeting.

No te-- tha t HCOG (ond thus, Applicants) believe that degraded score hydrogen control is on issue for the Perry ASLB heoring.

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'I t: should also be noted that the ' issue' o w' defined by HCOG

includes oil rocets or the distributed igniter system design and operation', including both containment integrity and equipment survivability, Indeed, the Storr's new interpretation or Issue M8 is

toto 11y at' odds with-the. Appeal Board's ALAB-675 decision and

.the'new'hy,drogen Pule. The-Appeal Board declared, and both

..Appliconts and'~5 torr have accepted, that Issue.N8 concerns a Compare the statement'

'TMI. . .i27 type occiden't." . 15 NRC ot 1115.

in;the~s'ummary'section or the Federal Register notice or the new

-hydrogen.contro1Lrdle:

~TheEnew requirements will result in greater assurance that Jnucirfor_ power reactor containmen'ts and sorety systems 1ond components will. continue to. function properly so that. reactors con be sorely' shut down rollowing a Thera Mile; Island-type-or-ocbident._

-TCleariy,.-o contention concerned-with o TMI-type occident is not-1 cho11engingLdesign-bosis-occident hydrogen. control. This is t-precisely'Why.0CRE believes that the'present' wording or-Issue.Ns is-incorrect.- .The15 torr's sudden ossertion that Issue NS is-

, 1 1~imitedEto: design =bosis hydrogen control.measuresi:is simply o-w

'1bidtont misrepresentation.

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The:Storr:in roct odmits.that the-pre,sent wording or Issue N8cis:oitruecossertions recombiners.connot accomodate large-quantities or.-hydrogen. .Storris Hotion ot-5. However. the.

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4 stondords-for summary disposition require that the issue be decided-in OCRE's favor. A reasonable mind having as its utmost concern the'public welfare, os required by'Zimmer, supra, would inquire'obout the adequacy'of the distributed igniter system, if recombiners are inodequate. The adequacy of this system has never been demonstrated. No Stoff SER on the Perry igniter isystem has ever been issued. There is no assurance that this

-system' meets the Commission's new rule.

_An examinotion of the entire record on Issue #8 demonstrates that Issue M8 encompasses more than recombiner odequacy. A genuine issue of moterial fact on the adequocy of the Perry hydrogen. control system for degraded core occidents thus exists.

.III. THE STAFF'S MOTION IS UNTIMELY

'As is essentially admitted in the Stefano offidovit, the Stofr'.s argument on the scope of Issue M8 could have been raised

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-as early os.May 1982. However,;neither Starr nor Applicants-have'ever-claimed that Issue W8 is limited to recombiners until now. Both Stoff.and Applicants.onswered numerous interrogatories on'the distributed igniter system without-objection. No explanation has been given on why the Staff hos woited'2-1/2 years before raising this orgument.

It is.the.proccice in NRC proceedings that parties must raise

! contentions, org'uments, objections, one other claims at the earliest opportunity ortheyfare waived obsent good cause for

' untimeliness. The'5 toff's.own motion cleocly demonstrates that sood'co'use-for waiting..this long is entirely locking. Wha t-1

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probobly hoppened is that the Staff. 'hoving lost its primary objection to the litigation of the issue, that a credible

' accident scenario must be specified, With the isstonce of the new rule, has in desperation fabricated o claim which it never thought-of before. The Stoff's uitimely motion must be denied.

IV. CONCLUSION The NRC Storres motion for summary disposition of Issue He is fotolly floWec. It is based on the incorrect wording of the  ;

issue and grossly distorts the entire record, which must be considered in deciding summary dispos i tion mo tions .- It fails to demonstrate the obsence of a genuine issue of material fact or-that the public health and safety Will-be satisfactorily protected. In addition, it is inexcusably lote, raising a claim that should have been made 2-1/2 years 090 The Stoff's motion must be denied.

Re s p e c t fu l ly submitted.

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-Susan L. Hiatt OCRE Representative 8275 Hunson Rd.

Mentor, OH 44060 (216) 255-3158 O

STATEMENT OF MATERIAL FACTS AS TO WHICH A GENUINE ISSUE EXISTS 1..Stoff*s motion for summary disposition of Issue M8 is predicated on the assumption that Issue #8 is limited to recombiner odequacy. ,

2. The history.of Issue #8, os set forth in the attached o f r i d o v i t', clearly shows that Issue #8 encompasses the odequacy of all hydrogen control measures at Perry, including the

~ distributed igniter system, ,in that:

(c) discovery has been conducted on the distributed igniter system by both OCRE ond Appliconts, without-objection from any partys .

(b) ALAB-675 interpreted Issue M8 to be predicated on the

,ossumption of a THI-2 or degraded core occident (the some occident the new hydrogen rule provides protection against), for which recombiners are known to be insufficient and for which the c

distributed igniter system was designed,

3. lit is not yet certain how Applicants' distributed ' igniter s/ stem will be operated (nor are the details of its design r

certain)-and it is unclear.how components of the design basis

' comsustible gas control system will be used in o degraded core occident.

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4.:-The adequacy or Applicants' degraded core occident hydrogen

-control system'hos never been demonstrated.

.5. 'No Starr SER'hos'ever been issued on the adequacy or

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- Applicants *: degraded core occident hydrogen control system.

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AFFIDAVIT OF,5USAN L. HIATT I, Susan L. Hiott, duly sworn depose and say that:

1. Since March 1982 I have served as-the legal representative, pursuant to 10 CFR 2.713(b), of intervenor Ohio citizens For

' Responsible Energy. From June 1981 to March 1982 I was involved in the technical research ospects of this proc 2eding. I have been responsible for virtually all octivity, including pleadings, research, and discovery, on Issue M8 since the contention's admission.

The purpose of-this ofridovit is to delineote the history and scope of Issue MS.from its admission to the present time.,

The information in this offidavit is true and correct to the best of my knowledge and belief.

2. In its Horch 3, 1982 Memorondum and Order the Licensing Board

--odmitted' Issue H8, which the Board worded as follows:

Applicant has not demonstrated that the mcnuoi operation of two recombiners in each of the Perry units is adequate to assure that lorge omounts 0f hydrogen con be' safely accomodated without a rupture of the containment and a release of substantial

. quantities of radioactivity into.the environment.

This sentence is the Board's restatement or the intervenor's hechnical analysis of the odequacy of the only hydrogen control  !

System then identified in Applicants' FSAR.

Reference to-the FSAR was necessary to meet the Board's stated criterio ror admission of contentions. See Speciol Preheoring conference Memorandum and Order of July 28, 1981 at 15.

3. Recombiners are Just one sub-system of the Applicants' hydrogen control system which Was referenced in the FSAR. The

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complete system consists of hydrogen onaly ers, o " mixing" =

system consisting of purge compressors taking suction from the containme,nt atmosphere and exhausting into the drywell, recombiners .ond containment purge capability. FSAR 6.2.5. It wascour intention to cho11enge the entire hydrogen control ,

, system, including any additions or changes thereto, and the ability of the Perry Mark III' containment to withstand the effects'of hydrogen combustion without loss of integrity.

4. The first notice I received that Applicants would be using a hydrogen contr'o1 system other than that referenced in the F5AR was.the' Appeal Board's decision in ALAB-675, which denied Applicants' motion for directed certification of the Licensing Board's Order admitting Issue N8. See 15 NRC at 1116. Where the

. Appeal Boord states that "before proceeding further With Cthen]

Sunflower's contention, the Licensing Board should determine opplicants' present plans Cthe distributed igniter system 3 in this regard.ond the effect this will have on the contention here

.ot issue.' .

5.'I interpreted.,that. sentence os a directive to the Licensing _

s Board s i . e. , the Board was required to, toke the initiot'ive in

' resolving the matter. As months possed,uit become apparent'that the Licensing Board did'not shore that View.- 50 that discovery Would not be.morred by' objections to'interrogotories concerning igniters'.(since~the issue's wording mentioned only recombiners),

.I-raised the~ mother'of rewording the issue during the August 13,

1982 conference coll. Tr. 743-4.

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o The-Board.choirman' responded to this by ordering-that Issue N8 was.to be interpreted in light or ALAB-675. Although no octual

-rewording or'.the issue resulted, I believe that the Board intended by that

• orderthat Issue.N8 was not to be interpreted as only- encompassing those racets specifically mentioned in its wording.. In any event, App' lice.nis did not object to that t

• order.' Tr. 745. Nor did the Starr voice any objection.

5.-D'uring discovery, numerous interrogatories were propounded to all concerned porties that addressed, Applicants' glow plug

' ' igniter-system. Se ej e.g., OCRE*s interrogatories 5-10 through 5-18, 5-22, 5-29, 5-47, and 5-67 or OCRE's 5th-Set or Interrogotories to Applicants and OCRE*s interrogatories 6-16, 17, 6-18. and 6-24 or OCRE's 6th Set to Starr. Neither Applicants nor Storr objected to these interrogatories on the

ground that Issue N8 is limited to recombiners, although both parties have been-quick to. object to otherfinterrogatories on 1

other issues on this ground.

In roct, Applicants' Interrogatory Nie or their Second set to

'0CRE specirically' requested'information ,

'with regard to the use or igniters os a hydrogen control system

(including containment. strength and equipment' survivability)'.,

Applicants'olso asked whether OCRE believes that inerting will

' sorely control hydrogen. In rock, Applicants did not propound any .interrogotories on recombiners. OCRE did not object to Applicants' interrogatories'on~either igniters or inerting, and

.hos recent1y updated its response to interrogatory-M10 providing'

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c-o detailed discussion of the inadequacy of Applicants' igniter system.

More'recently. OCRE's'13th set of interrogatories to Applicants sought information relating to Appliconts' distributed igniter

-system. Applicants did not object to any of these interrogatories on the ground that Issue #8 only pertains to recombiners.

Applicants' voluntory answers to these interrogatories encompassed details of analyses,on containment strength, of their deflogration containment response computer code, and of the experiments 1 conducted for'the Hydrogen control owners Group regor, ding Hork.III' unique combustion phenomeno, the thermal i

environments resulting therefrom, and the effects of this environment on. equipment survivability.

6. During the November 15.' 1982 conference colle. the Board-tried to determine what hydrogen control System would be used ot-Perry. T r ~. 769. There was.then some discussion of whether

- Applicants' hydrogen contro1' system could control the Omount of-hydrogen released from on 80% metal-water reaction. Although no ,

definite answers were-given to the Board's'inquiri'es, no one roised.the objection that IssueoN8 only concerned recombiners, s

7. Believing that the Board's actions during the conference eclis<did not' fulfil the requirement of ALAB-675, and' fearing that the incorrect wording of Issue N8 would create-the opportunityffor Applicont and'. S to f f mis chie f . I formally sought _

. the' rewording of Issue #8 in February 1983.- .The Board deferred.

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oction on this motion until issuance of'the finoi hydrogen control rule, March 31, 1983 Memorandum and Order, since the new rule has now issued, I recently renewed our errort to reword the issue.

8. The Appeal Board in ALAB-675 stated that Issue M8 is predicated on the ossumption of a THI-2 type occident. 15 NRC at 1115. While the Appeal Board did not define such on occident, ,

it is clear that it concerns o degraded core occident. The new hydrogen rule specifically addresses those hydrogen control measures needed to c, ope with the quantities of hydrogen generated in such.on occident, from o 75% metal-water ,recetion.

The Licensing Board has always tied Issue N8 to the issuance of the new hydrogen control rule. See March 3, 1982 Memorondum and QPder at 8 (*We believe it to be more prudent to proceed on the

'ossumption that by the-commencement of operation of Perry, the .

requirements of'10 CFR 50,44 will be more stringent *), and Orders of March 3 and 31, 1983, in which the Board deferred further work on Issue WB until the hydrogen rule issued.

While it has been recognized by all parties that recombiners are not able to control'such lorge amounts of hydrogen, the _

obilities of the: distributed igniter system are less certain,

- Applicants have certainly not met their burden of demonstrating

. compliance with the new regulation, In fact, there is very little in the way of formol submittals on this matter on the Perry docket. No.Stoff SER has been issued on the Perry igniter l

. system.

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-It is--not-even c1cor whether portions of the design-bosis

-hydrogen' contro,1 system will be used for degraded core occident hydrogenLeontrol.- Containment response onolyses assume the

. operation of therdrywell purge compressors, It is not clear "whether the hydrogen analyzers or containment purge / vent

- capabilities will be utili:ed. It does seem clear.that igniters

'will-be substituted for recombiners os the hydrogen removal

' mechanism, buta n t.what point in'the occident this will occur is uncertain- Applicants have,not submitted operators' ,

instructions or procedures _for the use of these systems.

However,' Subtask.9.1.of Applicants # program pion for hydrogen

.~ control-(submitted!with-the July 19, 1984 letter referenced by Stof f)~ states thot the emergency procedure guideline under m development Will oddress both design basis and degraded. core

'accidentLquantities of hydrogen, 1

- 19.zIn conclusion,-the record of Issue-NO^in this proceeding .

el'aorly demonstrates thatLIssue M8 ch'o11enges all hydrogen contro11 systems 0t- PWrry, includingithe distributed igniter 1

system, that no party has ever: considered Issue N8 to beIlimited ,

to Peccabiner adequacy, 'that:discoveryLhas been' conducted on*

. hydrogen control systems other.thon recombiners (even one ehot Applicants. hove not proposed for Perry, inerting), that 0CRE's

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' . interpretation of--Issue N8 is consistent with all. previous ,

rulings of the Licensing. Board, with ALAB-675,iond with the Commission's n'ew hydrogen control. rule,

'and:that the adequoeyor:she distrib'uted igniter system hos_not

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been determined.

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susan-L, Hiatt Suorn to and subscribed before me thisi_[____doy or February

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MARLEY FG.1D E10E:!, t,ttorr.ey At Law * %Q.^

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C097tsttD 1550t5 a:P'1TTED in tach PuttTC utantnG l r a

ns Adaitted Conten'tient _

Ns== ,,e Pla a t e ad t.i c' ens e e

( 1. adequacy of Applicant's onsite emergency plan.

Cleveland ElectHe titumintatfeo Co. 2 acequacy of quality assurance program in f (Perry Nwcitar Power Plant, .

view of construction cuality of work done by , ,

nef I . Units 1 & 2) the electrical contractor. , t-3f d

3. ' adequacy of limited tests to demonstrate .

i. I that the emergency core cooling system

/ meets the requirements of the re gula tions. '~

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. 4. adequacy of design and procedures to cope Ls with a pipe brett in the scram discharge ,

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I. need for automated standby liquid f '

control system to mitigate an anticipated '# ' '

transient without scram.

6. adequacy of measures to prevent fouling '

j of cooling water intake by Asiatic clams. ,

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7. adequacy of containment hydrogen control Y <

measurtt.

8, adequacy of the environmental qualification of certain safety-related equipment and ,

components with regard to degradation of

• polymers from radiation. '

9. adecuacy of the environmental impact '

tion statement with regard to the weight given i to increased emoloyment aid tax revenues tal o as a cenefit of operation.

10. adequacy of environmental impact statement ,

thcds regard to assessment of economic effects I of a serious accident.

i 11, adequacy of protection afforded safety. c,

( related equipment against turoine missiles.

'12 reliability of Trans-American celaval y/

I' diesel generators installed at Perry.

I 13. adequacy of measures to prevent steam '

erosion of components. .,

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INTRODUCTION o HCOG approach to resolve hydrogen issue

- Program Plan

- Acceptance Criteria .

- o Agree upon schedule with NRC on program plan and acceptance criteria o Importance

- MP&L currently required by license condition to resolve hydrogen control issue by end of first refueling outage 1

- CEI fuel load scheduled for' June.1985

- Issue for ASLB hearing

- GSU fuel load scheduled for~ April 1985 I

- Single issue open requiring second ACRS subcommittee meeting ,

- 'IPC fuel load schedule,d for January 1986 o Executive participation d

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GOALS FOR 1/23/85 MEETING BETWEEN HCOG AND NRC MANAGEMENT o Discuss HCOG Approach to Resolving Hydrogen Control Issue o Review Licensing Schedule Constraints on Issue Resolution o Discuss Philosophy of Program Plan and Acceptance Criteria o Summarize Contents of Program Plan o Review St'atus of Program Plan Activities o Identify Known Key Open Issues

- . o Agree Upon Schedule for Achieving Agreement With NRC on program plan and acceptance criteria 4

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HCOG/ MARK III Hydrogen Control Background .

o HCOG formed and met with the NRC in mid 1981 to discuss goals o Emphasis of early HCOG generic efforts on demonstrating containment pressure integrity

- Developed Containment Response Code (CLASIX-3) and completed sensitivity analysis for hydrogen deflagrations o HCOG met with the NRC in September 1982 to discuss the planneJ testing program to resolve remaining open issues To resolve questions on combustion phenomena above the suppression pool, HCOG conducted visuali-zation t.ests in a 1/20 scale facility

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o H, COG met with NRC management in July 1983 to discuss test results and propose additional test-ing and analysis to resolve the issue Agreed on mechanistic approach to define hydrogen releases .

Agreed some scenarios considered by HCOG must result in hydrogen production equivalent to 75% MWR HCOG committed to 1/4 scale test

- HCOG committed to complete hydrogen generation study o Met with the NRC Staff several times since then to discuss the 1/4 scale test program, hydrogan generation study and other issues raised by the NRC o HCOG submitted a Comprehensive Program Plan and Acceptance Criteria in December 1984 A .

HCOG PROGRAMMATIC GOALS o Respond to hydrogen control rule requirements (10 CFR 50.44) o Assure containment structural integrity is maintained o Assure equipment required to survive hydrogen combustion remains functional

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o Achieve these goals within the context of:

- reco.verable degraded core accidents

- using me.chanisti,c approach to define hydrogen release

- considering Mark III unique combustion phenomena

- considering effects of plant unique features o Complete program consistent with Mark III licensing schedules and in cost effective manner

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PURPOSE OF HCOG PROGRAM PLAN AND ACCEPTANCE CRITERIA Program Plan o Provide management tool to achieve resolution o Concisely define the tasks required to resolve the degraded core hydrogen control issue o Identify interactions with the NRC in order to review HCOG work o Show relationship between tasks in the program

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o Provide basis for establishing integrated program schedule Acceptance Criteria i o Define limits on the overall program for respond-ing to hydrogen control requirements o Provide a definitive basis for evaluating completed work o Focus' review on significant issues I

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PHILOSOPHY OF ACCEPTANCE CRITERIA o Recoverable degraded core accidents are significantly less probable than, design basis events

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- Realistic assumptions.are appropriate

- Additional conservatisms need not be imposed on assumptions and analytical or test results

- Some uncertainty in results is acceptable o HCOG proposed acceptance criteria Establish reasonable levels of conservatism Specify constraints on assumptions and results Assure that results are limited to recoverable degraded core accidents

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.' WORK COMPLETED TO DATE BY HCOG ,

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o Preparation of comprehensive program plans o , Development of'a containment response analysis code to

, . evaluate the effects of deflagrations in Mark III containment (CLASIX-3) 30 Completion of extensive containment response sensitivity studies using CLASIX-3 o Preparation of a topical report documenting and verifying CLASIX-3 o Completion'of a study to define the most probable hydrogen generation event (General Electric)

,, ,,,, o Research on combustion of hydrogen in hydrogen rich, steam rich environment i

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o Research on nature of combustion in Mark III containment in small scale test facility (1/20th scale) i  !

ofInitiationof1/4scaletestprogram 3, s ,.. ,

o 1 Modification of EPRI BWR Core Heatup Code Calculation of hydrogen produ7 tion with EPRI BWR Core o, ' Heatup, Code

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O PROGRAM PLAN ~

TASK

SUMMARY

Task 1 Establish Most Probable Hydrogen Generation Event

- Specify. quantity of hydrogen to be considered

- Establish approach to define scenario

- Develop combination of probabilistic and deterministic scenario Task 2 Select Mitigation Scheme

- Establish criteria for evaluating alternate systems

- Evaluate concepts

- Select system

- Document Selection Task 3 Design Gydrogen Ignition System -

- Select common igniter

- Specify design requirements p - Establish control requirements ,

t i Task 4 Containment Ultimate Capacity Analysis

- Define containment structure ultimate capacity

- Evaluate capacity of local components

- Investigate negative pressure effects

- Determine if local detonations can occur L_.

PROGRAM PLAN TASK

SUMMARY

(CONT) .

Task 5 Selection of Containment Response Analysis Code

- Review available codes

- Select code

- Modify code

- Complete verification

- Document verification Task 6 Hydrogen Combustion Testing

- Monitor industry hydrogen testing

- Investiga^e c Mark III unique combustion phenomena

- C6mplete flammability limit tests in hydrogen rich atmospheres Task 7 Generation of Hydrogen Release Histories

- Develop preliminary hydrogen release histories -

based on MARCH results

- Calculate hydrogen release histories with BWR Core Heatup Code .

- Complete BWR Core Heatup Code sensitivity study

- Select hydrogen release histories for input into 1/4 scale test program Task 8 Containment Response Analysis

- Define generic Mark III deflagration analysis base case

- Complete generic deflagration analysis sensitivity study

- Determine if plant specific deflagration analyses are required

- Define deflagration thermal environment for equipment survivability evaluation

PROGRAM PLAN TASK

SUMMARY

(CONT)

Task 9 Diffusion Flame Thermal Environment

- Design 1/4 scale test facility

- Prepare 1/4 scale test matrix

- Complete testing

- Prepare final test report Task 10 Evaluation of D,rywe_ll_ Response to Degraded Core Accidents

- Define drywell break accident sequences

- Calculate drywell break blowdown

- Analyze drywell response using CLASIX-3

- Determine if inverted diffusion flames can occur

- Specify drywell thermal environment for equipment survivability

- Determine if pool' swell loadings might exceed design basis A van. (

• n, Task' 11 Equipment Survivability Analysis Program

- Prepare equipment survivability list

- Model equipment

- Define thermal profiles for survivability I

analysis

- Calculate thermal response of components l

- Document equipment survivability I

l I Task 12 Validation of Analytical Methods

- Develop CLASIX-3 model of 1/4 scale test c l facility

- Predict 1/4 scale deflagration test

- Include complex calorimeter in test facility

- Calculate response of calorimeter

- Compare calculated response to measured response

- Document methods validation l

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PROGRAM PLAN TASK

SUMMARY

(CONT) .

Task 13 Combustible Gas Control EPG ,

- Draft EPG

- Calculate action limits

- Define spray timing

- Review EPG directions against licensing assumptions

- Document EPG directions vs. licensing assumption review Task 14 Nevada Test Site Data Evaluation

- In9estigate NTS data

- Identify equipment features applicable to Mark III

, Compare licensing assumptions to NTS results

- Document NTS evaluation results t

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ETATUS OF HYDROGEN CONTROL PROGRAM o All Program Major Tasks in progres's o Generic work in Tasks 1 - 6 essentially complete o Task 7, Generation of Hydrogen Release Histories

- Initial hydrogen release histories presented to NRC

- BWR Core Heatup Code sensitivity study completed

- Proposed scenario presented to NRC

- Key open issues between HCOG and NRC identified o Task 8, Containment Response Analysis

- Generic containment response analysis completed

- Generic sensitivity study completed

- NRC RAI responses to be submitted in February

- An additional generic deflagration analysis planned in response to RAI o Task 9, Diffusion Flame Thermal Environment

- Test facility construction complete

- Shakedown testing in progress

--Test matrix submitted o Task 10, Evaluation of.Drywell Response to Degraded Core Accidents

- Accidents to be considered have been established

- Blowdown models under evaluatior.- .

- Criteria for existence of inverted diffusion flames under development

STATUS OF HYDROGEN CONTROL PROGRAM (CONT) o Task 11, Equipment Survivability Analysis Program

- Criteria for developing lists defined

- Generic modeling work initiated o Task 12, Validation of Analytical Methods

- Complex calorimeter designed, fabricated and installed in facility

- 1/4 scale CLASIX-3 model being developed o Task 13, Combustible Gas Control EPG

- EPG drafted

- Initial action limits drafted .

. t o Task 14, Nevada Test Site Data Evaluation

- Applicable data obtained from EPRI

- Data review in progress

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OPEN ISSUES .

o Define hydrogen release histories which can be produced by recoverable accidents Definition of recoverable accidents Accident sequences which should be considered Resolve questions on BWR Core Heatup Code o Definition of diffusion flame thermal environment

- Resolution of questions on 1/4 scale facility design

- Finalize 1/4 scale test matrix o Demonstrate equipment survivability

- Acceptability of methodology validation

- NTS data evaluation o Definition of drywell thermal environment

- Resolution of questions on deflagration analysis

- Assessment of possible inverted diffusion flames i

l o Development of combustible gas control emergency procedures guideline c 9

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I STATUS OF 1/4 SCALE ,

TEST FACILITY o Vessel construction complete o Instrumentation installation complete o Peripheral support system (i.e. boiler, hydrogen Lupply, etc.) installation complete o- Data acquisition system installation complete o Instrumentation / system checkout and testing in progress o Plan to complete initial shakedown testing involving hydrogen by mid-February o Plan to initiate Scoping Tests by late February ,

Two weeks prior to scoping test initiation o Must have agreement on hydrogen release histories which c

will be injected into facility o Must have agreement on adequacy of facility and test matrix L_ _m. _

. t-OVERALL SCHEDULE FOR AGREEMENT ON PROGRAM PLAN -

AND ACCEPTANCE CRITERIA The following schedules for NRC approval of program plan and acceptance criteria arel Ts'ed'up3 s HCOG's current completion schedule for work identified in the program plan.

o NRC acceptance of following requested by 2/4

-. Generation of Hydrogen Release Histories

- Diffusion Flame Thermal Environment o NRC acceptance of following requested by 2/28

- Equipment Survivability Analysis Program

- Nevada Test Site Data Evaluation

- Containment Response Analysis

- Evaluation of Drywell Response to Degraded Core Accidents o Issue complete Safety Evaluation Report by 3/15 I

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CERTIFICATE OF SERVICE

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JSNRC This is to certi'fy that copies of the foregoing were served by this depospt inday 8A theof U.S. Mail, first F h en4 class, postage

, 1986 toprepaid.k7heff8 those on II A10:35

. service list below. O .

LFi TE

, . . .  : 00Gttry;~( gj,J,,

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y , med F10,.6, itd's susan L. niatt SERVICEbIST

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CHAIRMAN Terry Lodge, Esq.

ff JAMES P. GLEASON,AToHIC SAFETY a LICENSING BOAR. 618 N. Michigan St.

513 GILHOURE DR. Suite 105 SILUER SPRING, MD 20901 Toledo, OH 43624 3( Dr. Jerry R..Kline

' Atomic Safety,& Licensing Board.

i U.S._ Nuclear. Regulatory Commission Washington,'D.C. 20555 ,

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pf Mr..Glenn O. Bright Atomic,' Safety &. Licensing Board .

U.S. Nuclear Regulatory Commission Washington, JD . C . -20555 Colleen P. Woodhead, Esq. -

Office'of'the' Executive Legal Director U.S.' Nuclear Regulatory Commission .

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-Washington,.D.C.- 20555 Jay Silberg, $sq.

• Shaw,.Pittman; Potts, & Trowbridge

'1800 M Street, NW

. Washington, D.C. 20036 q Docketing'& Service' Branch

.Offi'ceoof'the Secretary U.S.. Nuclear Regulatory.. Commission

' Washington, D.C.- 20555

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-Atomic. Safety.&, Licensing Appeal Boar'd' Panel -

U.S. Nuclear. Regulatory Commission

. Washington, D.C. 20555  :

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