ML20137P875

Memorandum in Response to Aslab Questions in 860103 Memorandum & Order Re Accident Scenarios & Containment Spray Sys.Sys Should Be Considered Necessary Part of Hydrogen Control Sys.Certificate of Svc Encl

ML20137P875
Person / Time
Site:	Perry
Issue date:	01/29/1986
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#186-956 OL, NUDOCS 8602050386
Download: ML20137P875 (6)

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}lf gu:rt.D 'l January 21 fg1986 U FEB; p 86r- r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

]Y, POCKETING 5 stgr.cn rSJJCII

, sunamG y Before the Atomic Safety and Licenssng Appeal Bo r @

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In the Motter of )

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THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 OL

-ILLUMINATING CO. ET AL. > 50-441 OL

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(Perry Nuclear Power Pione, )

Units 1 and 2) )

OCRE MEMORAllDUM ON APPEAL BOARD QUESTIONS In its January 3, 1986 Memorondum and order the Appeal Board posed two questions to the porties to be answered in written

.U memorando by.Jonuary 21, 1986. Intervenor Ohio Citi ens for Responsible Energy ('OCRE') hereby files its onswers to the questions.

QUESTION 1 The first question osks whether, in light of the directive of 10 CFR 50. 44 (c) (3) (vi) (B) (3) that occidene scenarios considered under the hydrogen control rule are to describe the behavior of the reactor system during and following a degraded core occident, was it proper for the Licens2ng Board, in connection with its assessment of the applicants' preliminary hydrogen control analysis, to odmit and to consider evidence concerning ossumptions related to specific details of the occident, such as contoinment spray ovoilobility, storion blockout, and the operability of the Reactor Core Isolation Cooling System? If not, does the rule nevertheless require the opplicants' final analysts to snelude o determination with respect to the oppropriateness of such assumptions?

_L[ This deodline has been extended to Jonuary 29, 1986 by the

! January 17 order or the Appeal Board grantsng the NRC Stoff's motion for on exension of time to respond.

B602050386 860129

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OCRE asserts that it was tndeed proper for the Licenszng Board to admit evidence regarding the specific detoils of the i degro'ded core scenarios, such as station blockout, contoanment spray availability, and operability of RCIC, in its assessmene of the preliminary analysis. Unfortunately, the Licensing Board I did not reolly consider the evidence it had admitted, but instead contrived excuses for ignoring the evidence.

As oddressed in OCRE's Appel10te Brier (pp. 2-12), the Licensing Board locks statutcry authority to consider anything 2 less than issues relating to o full-term, final, forty-year operating Itcense, and the hearing (and resultant decision) muse encompass all material issues raised by the requester. Union of concerned Scientists v. NRC, 735 F.2d 1437,(443 (D.C. Cir.

1984). Thus, re9ardlehs of whether Staff and Applicants censidered matters such Gs station blackout (as it concerns t

degraded core hydrogen control) to be more oppropriate for the final analysis, once OCRE raised the issue, the Licensing Board uos required to constder it in its licensing decision.

Fur'hermore, c the $upplementory Information in the Federal Register notice (50 FR 3498, January 25, 1o85) on the hydrogen i

control rule indicates thot such matters are properly considered in the preliminary analysis. At 50 FR 3502 the requirement of f

10 CFR 50. 44 (c) (3) (vz) (B) (3) is discussed, with examples of d

scenarios found acceptoble for Sequoyoh, o PWR with on ice

$ The Sequoyoh applicant initially condenser containment.

proposed one occident scenario, o small breok LOCA with loss of l

ECCS. but broadened its studzes ir. response to staff concerns, such as steam inerting, hydrogen release ofter loss of the

3 Containment heat sink (i.e., the ice had melted), and whether the steam and hydrogen release rates assumed were oppropriate for other scenorzos and the recovery Period of the occident.

The additional Sequoyoh calculotsons are said to bound 'o representoeive selection of scenarios,* including on intermediate break LOCA with loss of ECC 0510], o small break LOCA with loss of containment heot removal C52G], o transsent loss of main feedwoter and loss of all AC power CTBB23, and a transient loss of morn feedwater, loss of auxiliory feedwater and loss of the ECC CTBLDJ, Section (Vii) (B) of the hydrogen rule indicates thot the referenced onokyses for Seouoyon are apparently equivalent to the preltminary analysss, so much so that similar (i.e., PWR ice condenser) plants need not provide a prelimtnory onolysss to support operation at full power, While it is certainly true that BURS have to address different scenarios due to obv2cus differences in plant design, the 5equoyoh analyses show the general events and follures, specifically includ2ng station (i.e., containment blockout and loss of contoinment heat removal spray one/or RHR failure in the Mark III), to be considered 2n the preliminary analysts, QUESTION The second question posed by the Appeal Board asks what is the justification for opplicants' and the stoff's relionce on on onolysis thot apparently requires the operation of the containment spray system os a heat removal device sn order to maintozn containment zntegrity? Gzven this requirement, does not the containment sproy become o necessary port of the hydrogen control system and hence fall within the scope of the new hydrogen rule?

OCRE does not know why APPliconts and Staff have relied upon on analysis requiring the operation or contosnment sprays to

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maintain containment integrity, espectolly in light of the

$ toff's previous statement that 'it OPPears inconsistent to ossume thot components of a core Cooling system would be available to Provide containment spray flow" in a degraded core occident and 'ir spray avoilobility is questionoble, do not consider them in the containment analysss.' OCRE Ed. 19 at 4.

But, sznce Applicants' analysis does rely upon contatnment spray operation (see, e.g., Hotofrancesco I at 5-6; Appiz.unts' Ex. 3-1 at 28 and Appendix A, p. lo), and s t ..a e contoiament sprays, being the dominant heat transfer mechanism, are necessary to maintain contatnment integrity (see, e.g., OCRE Ex.

21 of 11 Equestionable ovoxlobility of containment sprays as o factor in Sandia's judgement of the igniter system os morganolly odequate3, 12, 17, 29, 94, and 196 C$ondio's recommendation that sprays be actiVoted along With the igniters, apparently implemented at Grand Gulf (compare Appiscones' Ex.-8-1 at 23)3),

they should be considered a necessory port of the hydrogen control system and fall under the new hydrogen rule.

Applicants in fact concede the relevance of the containment sproy and other systems to their hydrogen control onalysts.

'The conto 2nment systems relevant to the onolysis of the HCS znclude the containment structure, containment heat renovol systems, combustible gas control system, and the suppression pool make-up system,' Applicants' Ex. 8-1 at 24. Under ene Standard provided in previous litigation of hydrogen control, this conceded relevance is on admission that these systems are to be considered port of the hydrogen control system. Duke

- - , 5-Power Co. (Um, B. McGuire Nuclear Storion, Units 1 and 2), LbP-51-13, 13 NRC 652, 669-70 (1981).

the igniters work in combination with other contoinment systems, including the ice condenser system, the containment air return system, the hydrogen skimmer system, and the containment spray systemC,3 Which the Appeal Soord in ALAB-669, 14 NRC 453, 467 (1082) choroctersced as:

': h e hydrogen mitigation system consists of igniter a s s e r..b l a e s (essentially electric power ' glow plugs' similar to these used to assist initial ignition in diesel engines) strategically placed in various ports of the containment, air return fons, hydrogen skimmer fans, and containment sprays.

Thus, for Perry the containment spray system should be considered o necessary part of the hydrogen control system, contrary to the Licensing Board's finding 'LEP-85-35 at 43-44, i

55), and its ovoilabzisty is o proper matter for consideroe2cn under the new hydrogen control rule.

Respectfully submtetEd,

/

Rv s.*~ Y W suson L. Hzott OCRE Representative 8275 Munson Rd.

Mentor, OH 44060 (216) 255-3159 OATED: "N

CERTIFICATE OF SERVICE This is to certify that copies of the (Ore 90ing Wers served by dePCsit in tne U.S. flatl, first class, postase prepaid, this n

_s39_Y__ day Of _7tM L - ,

1986 to the Service List,

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,d FEB;419865 susan L. siaee  !

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