ML20235H182

Responds to Request for Review & Comments on Whether or Not Technically Acceptable Inerted Containment Sys Could Satisfy Provisions of 10CFR50.44(g).NRC Awaiting plant-specific Submittals on Compliance,Per 870120 Meeting

ML20235H182
Person / Time
Site:	Quad Cities
Issue date:	08/31/1987
From:	Dorian T NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Janecek R BWR OWNERS GROUP, COMMONWEALTH EDISON CO.
References
NUDOCS 8709300402
Download: ML20235H182 (2)

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Mr. Robert F, Janecek, Chairman BWR Owners' Group

-c/o Commonwealth Edison Company Rm. 34 FN East P.O. Box 767 Chicago,11 60690 Re: BWROC-8737 Inerted Contalmnment Systems Dean- Mr. Janecek:

You rsesntly sent me a letter requesting my review and written comments about whether or not a technically acceptable Inerted containment system c0uld satisfy the provisions of 10 CFR 50.44(g). In that letter you stated that "BWROC maintains that paragraph 50.44(g) does not preclude the use of a technically acc3ptable inerted containment system to satisfy combustible gas control requirements" and that HBWROC submits that 10 CFR 50.44(c)(1) may 4 be satisfied by an Inerted containment system."

We it 13havv reviewed reasonabla to your analysis Interpret to CFR and50.44(g are prep)ared to agree that, and 50.44(c)(1) on not so as balance, to prx!ude an insrted containment system from satisfying these regulations, provided the inerted containment system is indeed found to be technically -

acceptabla. The measura of " acceptability" must be high, however -- as i sxplained to you a few days ago over the phone, a " bare bones" measure will not suffice -- because the staff's evaluations of the technical merits of licansras' submissions involve plants that are not of the most recent vintage as well as scme of the most complex and difficult issues in the prevention and "

mitigation of accidents highlighted by the accident at Three Mlls Island.

With respect to the issue of technical acceptability, staff members of the Offica of Nuclear Reactor Regulation held a meeting on January 20, 1987, in Esthasda, Maryland, with representatives from CPU Nuclear, Commonwealth Edison, Northeast Utilities, and Nebraska Public Power District on the systams used in their Mark l containment plants for combustible gas control.

I belleve a summary of that meeting was sent to each participant in late April, 1987. The summary called for each lleansee to subm't its plant-specific position about its compilance with 10 CFR 50.44(g) on a schedule to be determined with NRR's project managers: that position, by the way, was

" supposed to be tha licensee's justifiestion of the reliability of its containment Inarting system. The submittal was to include a discussion of the assumptions made by the licent,se to justify its position on 10 CFR 50.44 (the staff's position was and continuas to be that Regulatory Culde 1.7 should be used to calculate the generation of combustible gases during a foss of coolant accident and that the submittal of Northeast Utilities is unacceptable at present), the Information discussed during the meeting on the reliability and 8709300402 070831 PDR ADOCK 05000254 -

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-capability of the containment lnerting system and on the window of accident ]

sequences for which this system would be effective in controlling combustible i gases, and an analysis of the time period and the licensee's actions needed for the existing system to respond to the increasing combustible gas radiofysis of water before the concentrations in th'e containment from acceptable limits are exceeded.

I have discussed this matter with the cognizant NRR staff, and we are now awalting the licensees' submissions.

I hope that this addresses your concerns, if you have any questions or wish to discuss the matter further, please feel free to call me at (301) 492-8690.

Sincerely, Thomas F. Doria Office of the General Counse!

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