ML20198H919

Affidavit of a Notafrancesco Responding to Questions in Aslab 860103 Memorandum & Order Re Hydrogen Control Rule. Certificate of Svc Encl

ML20198H919
Person / Time
Site:	Perry
Issue date:	01/28/1986
From:	Notafrancesco Office of Nuclear Reactor Regulation
To:
Shared Package
ML20198H899	List: ML20198H897 ML20198H919
References
REF-GTECI-A-44, REF-GTECI-EL, TASK-A-44, TASK-OR OL, NUDOCS 8601310133
Download: ML20198H919 (7)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )

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CLEVELAND ELECTRIC ILLUMINATING ) Docket No. 50-440 OL COMPANY, ET AL. ) 50-441 OL

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF ALLEN NOTAFRANCESCO I, Allen Notafrancesco, being duly sworn, do depose and state as follows:

I am employed by the Nuclear Regulatory Commission in the Plant Systems Branch, Office of Nuclear Reactor Regulation. A statement of my professional qualifications is attached to this affidavit.

The purpose of my affidavit is to respond to questions in the Atomic Safety and Licensing Appeal Board Memorandum and Order dated January 3,1986

1. The first question asked by the Appeal Board refers to the requirement in 10 CFR 950.44(c)(3)(vi)(B)(3) that applicants submit analyses of their hydrogen control systems which use accident scenarios acceptable to the NRC Staff which "must be accompanied by sufficient supporting justification to show that they describe the behavior of the reactor system during and following an accident resulting in a degraded i

core."

2. The question of the Appeal Board is:

l 8601310133 860129 PDR ADOCK 05000440 0 PDR

In light of this directive, was it proper for the Licensing Board, in connection with its assessment of the applicants' preliminary hydrogen control analysis, to admit and to consider evidence concerning assumptions related to specific details of the accident, such as containment spray availability, station blackout, and the operability of the Reactor Core Isolation Cooling System? If not, does the rule nevertheless require the applicants' final analysis to include a determination with respect to the appropriateness of such assumptions?

3. In testimony before the Licensing Board, it was explained that two accident scenarios were choser, by Applicants and accepted by the staff for analysis of the hydrogen control system at the Perry plant.

These scenarios are identified as (1) a transient that results in a loss of all makeup water sources and a concurrent stuck-open relief valve (SORV) and (?) a small break loss-of-coolant accident (LOCA) inside the drywell with concurrent loss of all makeup water sources. These two scenarios characterize two different hydrogen release paths into contain-ment and consequent threats to containment integrity.

4. The applicants' preliminary hydrogen control analysis assumed the cperation of one of the two redundant containment spray systems.

This implies both the availability of water supply for the sprays as well as A.C. power for the sprav pumps. The availability of A.C. power is also implicit in the operation of the igniters, as designed and installed at Perry. A station blackout event is one way in which a transient in the first scenario can be initiated, and can also be one reason why makeup water sources that depend upon motor driven pumps may not initially be available in either scenario.

5. Recovery from a degraded core condition implies timely recovery of a source of makeup water. In the analysis of the hydrogen control system, various assumptions can be introduced into the analysis in the

form of parameters, such as rates of hydrogen generation, timing of the l recovery phase, rate of injection of makeup water during recovery, and availability of water for containment sprays compatible with postulated injection parameters.

6. The final analysis will employ the same scenarios considered appropriate in the preliminary analysis but will consider a broader range of parameters associated with each of the scenarios. The ranges selected for such parameters can be based in part upon postulated systems availability. Information needed for the final analysis is being developed by the Mark III Hydrogen Control Owners' Group (HC0G) and includes empirical data from a quarter scale test facility. The Staff accepted the accident scenarios in the preliminary analysis sub-mitted by the Applicants as technically reasonable, based on available data, but more limited in some assumptions than the Staff will require for the final analysis, after completion of ongoing tests by the Hydro-gen Control Owners Group (HC0G). The final analysis is intended to confirm the conclusions reached by the staff based on the preliminary analysis.

7. The second Appeal Board question is as follows:

Taking into account your answer to Question 1, as well as the requirement of section 50.44(c)(3)(vi)(B)(5)(i) that containment structural integrity must be maintained throughout the hydrogen generation and control scenario, what is the justification for the applicants' and the staff's reliance on an analysis that apparently requires the operation of the containment spray system as a heat removal device in order to maintain containment integrity? Given this requirement, does not the containment spray become a necessary part of the hydrogen control system and hence fall within the scope of the new hydrogen rule? See LBP-85-35, 22 NRC 514, 542 (1985).

8. The staff believes the containment spray is beneficial to reduce the containment pressures and temperatures produced by hydrogen burning.

Although the Applicants' preliminary analysis assumed containment sprays are available, it has not been demonstrated that the operability of containment sprays are necessary for degraded core accident scenarios in which the hydrogen ignition system is required. The staff is reasonably confident that proper operation of the Perry hydrogen control system even without sprays available will prevent failure of the containment by combustion generated over-pressure. The ongoing experimental testing and analysis performed by the HCOG will provide empirical information regarding local temperature effects produced by burning a large amc of hydrogen in centainment. The effects of sprays or lack of them relating to containment temperatures will be investigated. This information will be provided in the final analysis. The staff does not believe the containment sprays will prove to be a necessary part of the hydrogen control system. Mitigating alternatives could be devised at the Applicants' discretion, if needed.

I attest that the foregoing is true and accurate to the best of my knowledge and belief.

M Allen Notafrancefco Mechanical Engineer Plant Systems Branch Division of BWR Licensino Office of Nuclear Reactor Regulation Subscri and sworn to before me this day of January, 1986 Me L fEttler Notary Pu)lic My commission expires: I

PROFESSIONAL QUALIFICATIONS OF ALLEN NOTAFRANCESCO PLANT SYSTEMS BRANCH DIVISION OF B0ILING WATER REACTOR LICENSING U. S. NUCLEAR REGULATORY COMMISSION I am a Mechanical Engineer in the Plant Systems Branch, Division of Boiling Water Reactor Licensing, Office of Nuclear Reactor Regulation.

I have been with the NRC since June 1981.

I serve as a staff reviewer in the area of containment systems (BWRs).

This involves performing reviews and evaluations of specific portions of the licensing applications for which the branch has responsibility to assure public health and safety.

I received a Bachelor of Science degree in Nuclear Engineering from the Polytechnic Institute of New York in 1976, and a Master of Science degree in Mechanical Engineering from the Polytechnic Institute of New York in 1980.

Other training among various short courses taken includes: BWR/6 Technology Course - 1982 (NRC sponsored) and BWR/6 Simulator Course - 1982 (NRC sponsored).

From 1979 to 1981, I was employed as an Equipment Engineer by International Business Machines (IBM), East Fishkill, New York. My responsibilities included executing and controlling the building of new equipment for manufacturing semi-conductor components.

From 1976 to 1979, I was employed as a Thermal-Hydraulics Analyst by Ebasco Services, Inc., New York. My responsibilities included performing safety related containment analyses pertinent to the licensing of various nuclear power plants, preparing responses to NRC questions and writing appropriate sections of safety analysis reports.

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l UNITED STATES OF AMERICA j y 3 g yf C NUCLEAR REGULATORY COMMISSION "; ~ ., _

hr BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD ,A 7

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CLEVELAND ELECTRIC ILLUMINATING Docket No. 50-440 OL COMPANY, ET AL. ) 50-441 OL

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

CERTTFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO APPEAL BOARD QUESTIONS CONCERNING THE HYDROGEN CONTROL RULE" in the above captioned prcceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 29th day of January,1986:

• Dr. Jerry R. Kline

• James P. Gleason, Chairman Administrative Judge Administrative Judge Atomic Safety and Licensing Board 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, MD 20901 Washington, DC 20555

• Mr. Glenn 0. Bright Donald T. Ezzone, Esq.

Administrative Judge Assistant Prosecuting Attorney Atomic Safety and Licensing Board 105 Main Street U.S. Nuclear Regulatory Commission Lake County Administration Center Washington, DC 20555 Painesville, OH 44077 Jay Silberg, Esq. Susan Hiatt Shaw, Pittman, Potts and Trowbridge 8275 Munson Road 1800 M Street, NW Mentor, OH 44060 Washington, DC 20036

• Atomic Safety and Licensino Poard Terry J. Lodge, Esq.

U.S. Nuclear Regulatory Commission 618 N. Michigan Street, Suite 105 Washington, DC 20555 Toledo, OH 43624 John G. Cardinal, Esq. Janine Migden, Esq.

Prosecuting Attorney Ohio Office of Consumers Counsel Ashbabula County Courthouse 137 E. State Street Jefferson, OH 44047 Columbus, OH 43215

• • Atomic Safety and Licensing Appeal Board i

U.S. Nuclear Regulatory Comission Washington, DC 20555

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• Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Comission Washington, DC 20555 i

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Colleen P. Woodhead Counsel for NRC Staff b

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