ML20138B075

Response to ASLB 850918 Memorandum Re Containment Coatings. Possibility of Core Blockage by Fine Paint Particles Constitutes Main Concern.Affidavits of SD Mckay,B Mann & CE Mccracken Encl

ML20138B075
Person / Time
Site:	Comanche Peak
Issue date:	03/17/1986
From:	Bachmann R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20138B082	List: ML20138B075 ML20138B107 ML20138B143 ML20138B171
References
CON-#186-459 OL, NUDOCS 8603200275
Download: ML20138B075 (4)

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\  ! March 17, 1986 00CMETED USNRC UNITED STATES OF AMERICA. ._ ._

NUCLEAR REGULATORg COMMIyf0FM 19 P3 :N BEFORE THE ATOMIC SAFETY AND LICENSING . BOARD In the Mntter of )

' )

TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445 OL.

COMPANY, et _al. _

) 50-446 OL.

)

(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

NRC STAFF CONCLUDING RESPONSE TO LICENSING BOARD'S SEPTEMBER 18, 1985 MEMORANDUM CONCERNING CONTAIF?.!_ENT COATINGS On September 18, 1985, the Licensing Board issued its " Memorandum (Water Recirculation Problems Caused by Paint)", LBP-85-37, 22 NRC 601 (1985) ("Memoran d um") . In its Memorandun, the Board inquired about 4 the S taff's conclusion draw n in - Appendix L of Supplement 9 to the Comcnche Peak Safety Evaluation Repcrt ("SSER No. 9"), to wit: that the coatings applied inside of the containment building may be exempted from the quality assurance requirements of 10 C.F.R. Part 50, Appen-dix B. 22 NRC at 602. In the Staff's " Motion to Reconsider and Response to Board Memorandum of September 18, 1985" (" Staff Response"), filed October 9, 1985, the Staff responded in part to the

. Board's inquiries. Through the appended affidavits of Conrad E.

McCracken , Bernard Mann and Samuel D. MacKay, the Staff herein completes its response to the Board's Memorandum in order to further 4

clarify the bases for the Staff's conclusion.

To briefly summarize the background of this matter, in the NRC Safety Evaluation Report on operation of Comanche Peak Steam Electrie ur ,

8603200275 860317

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, Station (NUREG-0797), the Staff found the coatings systen to be used inside the containment building acceptable based on the Texas Utilities Electric Company (TUEC or Applicants) commitment in Section 6.1.2 of its Final Safety Anclysis Report (FSAR) to apply " qualified" coatings consistent with the positions of Regulatory Guide 1.54 and ANSI N101.2.

Such coatings would be subject to the quality assurance requirements of 10 C.F.R. Part 50, Appendix B.

In January 1984, NRC's Region IV (RIV) contracted with Brookhaven National Laboratory (BNL) to provide technical assistance for onsite reviews and technical evaluation of the allegations of deficiencies related to the protective coatings program at Comanche Peak. On April 25, 1984, DNL sent an interim report on protective coatings to RIV. This report requested information from TUEC regarding the backfit test program ,

presented BNL's independent test results, and reported B NL's interim findings on TUEC's protective coatings procedures and documentation.

On June 13, 1984, BNL sent a draft " Status Report on Protective Coatings Allegations" to RIV. This report provided the current status of B NL's investigation of 60 allegations regarding protective coatings at Comanche Peak. On July 9, 1984, the Staff's Technical Review Team (TRT) assumed responsibility for completing the investigation of protective coatings allegations. By memorandum dated August 7, 1984, frce D. Eisenhut to the Licensing Board, the status of the 60 allegations under investigation by DNL were provided to the Board. These 60 allegations, plus two additional allegations, formed the basis for the TRT coatings investigation.

By letter dated June 4, ~ 1984, TUEC proposed to amend the FSAR to eliminate the commitment to apply qualified coatings. As stated in a i

a

, previously filed affidavit of Conrad E. McCracken, which was submitted to the Board as an attachment. to the October 9, 1985 Staff Response, the NRC does not have a specific requirement that coatings inside of the reactor ' containment building must be qualified. McCracken Affidavit at A4. The Standard Review Plan Guidelines Section 6.1.2 as applicable to Comarche Peak provide the option of applying and testing coatings in containment in accordance with the positions of NRC Regulatory Guide 1.54 and ANSI N101.2, g providing justification to show that debris generated under design basis accident conditions will not adversely affect the performance of post-accident fluid systems. Id. at AS.

In March 1985, the Staff issued SSER No. 9, which contained two Appendices, L and M. Appendix M presented the results of the investi-gations performed by the TRT into the allegations in the protective coatings area. In a concurrent, independent effort, other members of the Staff evaluated the Applicants' proposal that coatings applied inside of containment need not be qualified and thus would not be required to comply with the quality assurance criteria of 10 C.F.R. Part 50, Appendix B. The results of this concurrent effort are set forth in l Appendix L of SSER No. 9. In Appendix L, the Staff concluded that the A pplicants' proposal was acceptable, based on the Staff's determination that a total failure of protective coatings inside the containment building

~ would not unacceptably degrade the performance of post-accident fluid systems. Accordingly, the Staff determined that the coatings are not required to meet the standards of - 10 C.F.R. Part 50, Appendix B, and l approved TUEC's proposal to amend the FSAR to eliminate the commitment to apply qualified coatings. Appendix L, Sect. 3.0.

t.

D-In its October 9, 198b Staff Response, the Staff addressed the Board's characterization of Comanche Peak as being in "a special category with respeci ;r. Ordinary paint quality assurance requirements", and moved the Board to reconsider this characterization. Staff Response at

1. The Staff also assured the Board that cognizant Staff members involved with Unreviewed Safety Issue A-43, " Containment Emergency Sump", have been informed of the Staff's determination. -

Id. at 4-5.

Finally, the Staff committed to responding to the Board's inquiry regarding potential core blockage by fine paint particles. g.at6.

As expressed in .its September 18, 1985 Memorandum, the Board's technical inquiry with respect to the Staff's conclusion in Appendix L s

centers around the possibility of core blockage by fine paint particles.

22 NRC at 602. The Board apparently agrees with the Applicants and Staff that this possibility exists if one of the reactor ecolant pumps (RCP) were restarted following a small-break loss of coolant accident (LOCA). Id. The Board questions the likelihood of the RCP restart in the areas of operating proced ures , operator error, inadequate core cooling (ICC), and also notes that the Staff makes "no firm conclusion" as i to whether flow blockage would be extensive in the event of RCP restart.

l Id. at 603. To respond to the Board's specific questions, and to present <

I a more in-depth picture of the bases for the Staff's ultimate conclusion, j the Staff has attached the Affidavits of Conrad E. McCracken , Bernard Mann and Samuel D. MacKay.

1 Respectfully submitted l l

Richard G. Bachmann Counsel for NRC Staff Dated at Bethesda, Maryland this 17th day of March, 1986 l

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