ML20133F811

Motion Requesting ASLB Reconsider & Modify 850918 Memorandum to Reflect Fact That Util Not Placed in Special Category for Coatings Inside Containment,Per Sser 9 (NUREG-0797) & Consider Notification of USI A-43 Closed

ML20133F811
Person / Time
Site:	Comanche Peak
Issue date:	10/09/1985
From:	Bachmann R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20133F814	List: ML20133F811 ML20133F816 ML20133F822
References
CON-#485-741, REF-GTECI-A-43, REF-GTECI-ES, RTR-NUREG-0797, RTR-NUREG-797, TASK-A-43, TASK-OR OL, NUDOCS 8510110238
Download: ML20133F811 (6)

Text

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October 9, 1985 UNITED STATES OF AMERICA  : m NUCLEAR REGULATORY COMMISSION

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- BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .--

o (.1 ,0 P3 :22 In the Matter of ) "< ,

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TEXAS UTILITIES ELECTRIC l Docket Nos. 50-4450b [ I COMPANY, et _al.

_ ) 50-446

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(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

NRC STAFF MOTION TO RECONSIDER AND RESPONSE TO BOARD MEMORANDUM 0F SEPTEMBER 18, 1985 l

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I. Introduction On September 18, 1985 the Licensing Board issued its " Memorandum (Water Recirculation Problems Caused by Paint)," LBP-85-37

(" Memorandum"). In its Memorandum, the Board (1) requested an explanation from the Staff as to why Comanche Peak was placed in a "special category" by the Staff's Supplement No. 9 to the Safety l Evaluation Report, NUREG-0797 ("SSER") with respect to "an exemption from 1

ordinary paint quality assurance requirements"; (2) directed that those members of the Staff involved with Unresolved Safety Issue A-43 be informed of the SSER; (3) expressed its concern about the possibility of core blockage by fine particles in the event of reactor coolant pump (RCP) restart after a small break loss of coolant accident (LOCA).

The Staff hereby moves the Board to reconsider and modify (1) its characterization of Comanche Peak as being placed in a "special category" and (2) its reference to " ordinary paint quality assurance requirements."

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In this motion, the Staff also responds to the Board with respect to Unresolved Safety Issue A-43. In a future filing the Staff will respond to the Boahd's concerns about fine paint particles potentially causing core blockage.

II. Background In July 1981, the Staff issued its Safety Evaluation Report on the operation of Comanche Peak Steam Electric Station, Units 1 and 2, NUREG-0797("SER"). As part of its evaluation in the SER, the Staff found the coating systems to be used inside the containment building acceptable based on the Applicants' commitment in Section 6.1.2 of the Final Safety Analysis Report ("FSAR") to apply " qualified" coatings consistent with the positions of Regulatory Guide 1.54 and ANSI N101.2.

SER 9 6.1.2. Subsequently, the Applicants proposed to amend the FSAR to eliminate the commitment to apply qualified coatings, and supported the proposal by a number of analyses.

In March 1985, the Staff issued its SSER which contained two appen-dices, L and M. Appendix L, which is the subject of the Board's Memorandum, concluded that, based on Staff evaluation of the Applicants' analyses, there is reasonable assurance that debris generated by the failure of all coatings inside the Containment Building under desigr. tasis accident conditions will not unacceptably degrade the performance of post-accident fluid systems. The failure of coatings would not result in or contribute to causing, or increasing the consequences of, any design basis accident. Accordingly, such coatings are not required to meet the standards of 10 CFR Part 50, Appendix B.

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SSER, p. L-13.

In its Memorandum, the Board expressed concern, inter alia, that the Staff's conclusion placed Comanche Peak in a "special category,"

exempting the plant from ordinary paint quality assurance requirements.

Based on the following discussion, as supported by the attached affidavits, the Staff requests that the Board modify its Memorandum to reflect the fact that Comanche Peak has not been placed in a special category with respect to an exemption from ordinary paint quality assurance requirements.

III. Discussion A. The Staff's determination to exempt coatings inside containment from the quality assurance requirements of 10 C.F.R. Part 50, Appendix B does not place Comanche Peak in a "special category." As set forth in the attached " Affidavit of Conrad E. McCracken", ("McCracken Affidavit"),

the NRC does not have a specific requirement that coatings inside containment be safety grade. McCracken Affidavit at An5wer 4.

The Standard Review Plan Guidelines (SRP) as applicable to Comanche Peak offer an option for coatings in containment. M.atAnswer5.

Applicants may apply and test coatings ir. accordance with Regulatory Guide 1.54 and ANSI N101.2, g provide justification under design basis accident (DBA) conditions that any debris generated from failed coatings will not adversely affect the performance of post-accident fluid systems.

M. The Applicants' election to take the latter course does not require a special exemption. I_d. at Answer 6.

Moreover, Comanche Peak has not been placed in a "special category" by the Staff. _Id,. at Answer 7. Of the seventy-one plants licensed prior to 1981, sixty-nine were neither required to apply qualified coatings nor to perform analyses. M . Only two plants committed to apply qualified ,

coatings. M . It is not the intent of the NRC to compel applicants to apply only qualified coatings. M. at Answer 8. Were that the case, the clear analysis option would not be provided. M. Altnough most post-1981 applicants have opted to apply qualified coatings, Waterford and Fermi-2 have elected to submit analyses, which have been evaluated and accepted by the Staff. M . It is expected that additional plants will elect to perform these analyses rather than to commit to applying qualified coatings. M.

In view of the above, it is clear that " ordinary paint quality i

assurance requirements" (Memorandum at 4) do not anticipate that coatings inside containment must be qualified, that the analyses performed by Applicants constitute a legitimate alternative, and that Comanche Peak has not been placed in a "special category" by the Staff.

B. The Board has stated that the Staff's determination in Appen-dix L to the SSER should be brought to the attention of those members of the Staff involved with Unresolved Safety Issue (USI) A-43, " Containment '

EmergencySump."1/ Memorandum at 3-4. As set forth in the attached

-1/ The Staff is concerned that the Board's comments in this area indicate a perceived need by the Board to remind the Staff of its (FOOTNOTE CONTINUED ON NEXT PAGE)

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Affidavit of Aleck W. Serkiz ("Serkiz Affidavit"), Mr. Serkiz has the responsibility to manage the resolution of USI A-43 and also participated in the Staff evaluations found in pages L-2 to L-6 of Appendix L to the SSER. Serkiz Affidavit at Answers 2 and 4 The analysis methods used by the Applicants were based on models developed for the resolution of USI A-43 and the analysis was consistent with USI A-43 findings. Id. at Answer 4.

Therefore, the cognizant Staff members involved with USI A-43 have already been informed of the Applicants' analysis of concern to the Board, and in fact, participated in the Staff's review.

IV. Conclusion For the reasons discussed above, the Licensing Board should grant the Staff's motion and modify its Memorandum to reflect the fact that Applicants have not been placed in a "special category" with respect to (FOOTNOTECONTINUEDFROMPREVIOUSPAGE) responsibilities in the licensing review process. The Staff wishes to assure the Board that the Staff has been, and will continue to be alert to potential interactions and interrelationships among the various disciplines which become involved in the Staff's licensing review. As noted in the text of this filing, the Staff will be responding in a subsequent filing to the request by the Board for additional information. The Staff's response will encompass a number of disciplines, and every attempt will be made to ensure consultation with all components of the Staff whose particular area of expertise is affected. The Staff trusts that these assurances will preclude the need for the Board to raise such concerns in the future. See New England Power Co. (NEP, Units 1 and 2), LBP-78-9, 7 NRC 271, U9-80 (1978); Offshore Power Systems (Floating Nuclear Power Plants), ALAB-489, 8 NRC 194, 201-03 (1978).

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coatings inside containment, and that such coatings are not specifically required by the NRC to be qualified in all cases.

In addition, based on the information provided herein, the Board should consider the issue of notification of Staff personnel involved

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with Unresolved Safety Issue A-43 closed.

Finally, as noted above, the Staff will respond in a future filing to the Board's concern regarding potential core blockage by fine paint i

particles. l l

Respectfully submi m

}_ -

Richard G. Bachmann Counsel for NRC Staff Dated at Bethesda, Maryland this ,9/4 day of October,1985

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