ML20246L400

Summary of 890627 Meeting W/Util in Rockville,Md Re Combustible Gas Control for Plant.List of Individuals Attending Meeting,Proposed Meeting Agenda,Matl Used by Util in Discussion & Condensed History of Gas Control Issue Encl

ML20246L400
Person / Time
Site:	Oyster Creek
Issue date:	07/10/1989
From:	Dromerick A Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8907180427
Download: ML20246L400 (30)

Text

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July 10, 1989-a t

Docket No. 50-219 LICENSEE:-

GPU Nuclear Corporation Jersey Central Power and Light Company FACILITY:

.0yster Creek Nuclear Generating Station 1

SUMMARY

OF THE JUNE 27, 1989, MEETING WITH GPU NUCLEAR CORPORATION (GPUN) TO DISCUSS COMBUSTIBLE GAS CONTROL FOR OYSTER CREEK On Tuesday, June 27, 1989, at NRC, One White Flint North, Rockville, Maryland, representatives of the NRC met with representatives of GPUN to discuss Con.bustible Gas' Control at Oyster Creek. Representatives of other interested nuclear power generation facilities and of the State of New Jersey Department of Environmental Protection also attended the meeting.

The meeting was called pursuant-to an NRC request transmitted to the licensee by letter dated May 1, 1989. The objective for the meeting was discussion of the Oyster Creek Combustible Gas Contnl Systems, the requirements of 10 CFR 50.44, and comparative aspects of Nitrogen-Containment Atmosphere Dilution

' Systems-(CAD) and Air-CAD systems versus regulatory requirements.

It was concluded that the staff would issue to the licensee a clarification of regulatcry requirements as they specifically relate to Oyster Creek.

In the meantime the licensee is welcome to submit additional descriptive information which might aid the staff in its clarification. is a list of individuals attending the meeting. Enclosure 2 is a proposed Meeting Agenda included in the May 1, 1989, letter to the

. licensee. contains material used by the licensee in his discussion. Enclosure 4 is a condensed history of the Oyster Cre6k Combustible Sas Control issue from the licensee's perspective as provided by the. licensee at the meeting.

/s/

Alexander W. Dromerick, Project Nanager Project Directorate I-4 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosures:

As stated' cc w/ enclosures:

See next page

[DC. 50-219]

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• SEE PREVIOUS CONCURRENCE LA:PDI-4*

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July 10 1989 0

i Docket No. 50-219 LICENSEE:

GPU Nuclear Corporation Jersey Central Power and Light Company i

FACILITY:

Oyster Creek Nuclear Generating Station

SUMMARY

OF THE JUNE 27, 1989, MEETING WITH GPU l

NUCLEAR CORPORATION (GPUN) TO DISCUSS COMBUSTIBLE GAS CONTROL FOR OYSTER CREEK On Tuesday, June 27, 19893 at NRC, One White Flint North, Rockville, Maryland, representatives of the NRC met with representatives of GPUN to discuss Combustible Gas Control at Oyster Creek. Representatives of other interested J

nuclear power generation facilities and of the State of New Jersey Department i

of Environmental Protection also attended the meeting.

j The meeting was called pursuant to an NRC request transmitted to the licensee by letter dated May 1, 1989. The objective for the meeting was discussion of the Oyster Creek Combustible Gas Control Systems, the requirements of 10 CFR 50.44, and comparative aspects of Nitrogen-Containment Atmosphere Dilution Systems (CAD) and Air-CAD systems versus regulatory requirements.

It was concluded that the staff would issue to the licensee a clarification of regulatory requirements as they specifically relate to Oyster Creek.

In the meantime the licensee is welcome to submit additional descriptive infonnation which might aid the staff in its clarification. is a list of individuals attending the meeting. is i

a proposed Meeting Agenda included in the May 1,1989, letter to the licensee. Enclosure 3 contains material used by the licensee in his discussica. Enclosure 4 is a condensed history of the Oyster Creek Combustible Gas Control issue from the licensee's perspective as provided by the licensee at the meeting.

/s/

Alexander. W. Dromerick, Project Manager Project Directorate I-4 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/ enclosures:

j See next page l

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[DC. 50-219]

9

• SEE PREVIOUS CONCURRENCE

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4 Mr. E. E. Fitzpatrick Syster Creek Nuclear Oyster Creek Nuclear Generating Station Generating Station ec:

Ernest L. Blake, Jr.

Resident Inspector Shaw, Pittman, Potts and Trowbridge e/o U.S. NRC 2300 N Street, NW Post Office Box 445 Washington, D.C.

20037 Forked River, New Jersey 08731 J.B. Libermen, Esquire Commissioner Bishop, Libennan, Cook, et al.

New Jersey De;iartment of Energy 1155 Avenue of the Americas 101 Commerce Street New York, New York 10036 Newark, New Jersey 07102 Jennifer Moon.. Acting Chief Regional Administrator, Region I New Jersey Departnent of Environmental U.S. Nuclear Regulatory Commission Protection

-475:Allendale Road Bureau of Nuclear Engineering King of Prussis, Pennsylvania 19406 CN 415 Trenton, New Jersey 08625 BWR Licensing Manager GPU Nuclear Corporation i Upper Pond Road Parsippany, New Jersey 07054 Deputy Attorney General State of New Jersey Department of Law and Public Safety 36 West State Street - CN 112-Trenton, New Jersey 08625 Mayor Lacey Township 818 West Lacey Road Forked River, New Jersey 08731 Licensing Manager Oyster Creek Nuclear Generating Station Mail Stop: Site Emergency Bldg.

P. O, Box 380 Forked River, New Jersey 08731 l

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ENCLOSURE 1 OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO.s50-219 l

MEETING - JUNE 27, 1989 LIST OF ATTENDEE 5 NAME ORGANIZATION John F. Stolz NRR/PDI-4 Frank Orr NRR/PDI-4 Jack Kudrick NRR/ DEST /SPLB Charlie Tinkler NRR/ DEST /SPLB Bernard M. Bordenick NRC - OGC Stu Brown NRR/PDI-2 Rita Stols Commonwealth Edison Thomas J. Korach Commonwealth Edison Walter Butler NRR/PDI-2 Loyd Nesbror GE. Sys. Eng.

Bruce Churchill Shaw Pittman (GPUN)

Nicholas D1Nucci State of N J. DEP/BNE Suren Singh N.J. State Dept. of Env. Prot.

Thomas M. Dempsey GPU Nuclear Philip S. Smith GPU Nuclear Arthur H. Rone GPU Nuclear John L. Sullivan Jr.

GPU Nuclear Michael Laggart GPU Nuclear Gary.Capodanno GPU Nuclear Don Grace GPU Nuclear i

R. L. Long GPU Nuclear i

Ashok Thadani NRR/ DEST i

Byron Siegel NRR/DRSP/PDIII-2 i

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V ENCLOSURE 2' l

MEETING AGENDA FOR DISCUSSION OF PLANT SPECIFIC DESIGN OF ACTIVE COMBUSTIBLE GAS CONTROL SYSTEM 1.

INTRODUCTION BY NRC STAFF II. MEETING OBJECTIVE To provide sufficient design details of the Nitrogen Injection Capability for each plant to determine if the provisions are adequate to meet the intent of 10 CFR 50.44

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III. AIR-CAD SYSTEM

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NRC staff will provide the basis for concluding that the syst'em should not be used for combustible gas contro1~.

Represents an air source per GL 04-09 guidence Potential misuse of system Impact of deinerting on course of the accident IV. LICENSING BASIS AND BWR EPG'S Reconcile any conflicts between original licensing basis and Rev. 4 to the EWR EFG's.

When will CAD be used (under what system conditions)

Is the E0P consistent with FSAR assumptions V.

PLANT SPECIFIC DESCRIPTION OF INERTING SYSTEM i

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The objective is to identify all essential components, design conditions, instrumentation, and power supply for the normal inerting system to determine under what post LOCA conditions the system could be expected to function as a combustible gas control 'ystem.

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A.

System / component description

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All components required to operate under post LOCA conditions should be described.

Design specification (i.e. seismic, redundancy, quality group, etc) for a parameter where the component has not been designed for, such as seismic, but is expected to survive, provide the basis

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Location I

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2 l-H Design pressure and temperature Maximum containment conditions for component operability'should i.

also be noted a

Design flow rate as a function of containment pressure B.

5ystem Instrumentation Instrumentation.necessary to operate the system post LOCA should be identified. f Identify each sensor, number and location

- Location of instrument readout If outside control room, determine accessability post LOCA System use of sensor output What is sensor used for (automatic valve operation? ornot)if operator information only, indicate what type of action is-anticipated (flow change, systestshutoff, etc)

C.

Operational requirements post LOCA Identify those actions that will be required to initiate system 9pei'ation and those necessary for monitoring operation. Fer each.

action, identify whether it is from the control room or at a remote site.

Instrumentation needed for startup Instrumentation needed for operation Power supply (off site and diesel?)

D.

Nitrogen capacity (onsite and time to get added supply)

E.

Identification of deviations from GDC 41,42, and 43 F.

Modifications to eliminate deviations from (e)

G.

Operational, maintenance, and surveillance history objective is to obtain some basis for determining system availability D

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ENCLOSURE 3 l

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GPUN/NRC MEETING 1

COMBUSTIBLE GAS CONTROL JUNE 27, 1989 AGENDA o

INTRODUCTORY REMARKS ~

R.L. L'0NG o

GPUN COMPLIANCE POSITION M.W. LAGGART o

RESPOND TO NRC AGENDA ITEMS P. SMITH (E0Ps & NITROGEN SYSTEM)

T. DEMPSEY o

CONCLUSIONS R.L. LONG E

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'4 GPUN LETTER DATED MAY 31. 1988 TO NRC ADDRESSES:

OYSTER CREEK COMPLIANCE WITH 50.44 (s)

OYSTER CREEK COMPLIANCE WITH 50.44 (c)

(3)

(II)

NRC'S. SAFETY EVALUATION OF MARCH 13, 1987 AND THE UNCERTAINTIES WHICH EXIST WITH P.EGARD TO THE REGULATORY AND TECHNICAL BASIS OF THE STAFF'S CONCLUSIONS.

REQUESTED MEETING WITH STAFF TO DISCUSS ISSUES AT TH$IR CONVENIENCE.

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T t-l; GPUN COMPLIANCE, POSITION o

OYSTER CREEK'S INERTED CONTAINMENT SYSTEM IS:

SAFE AND EFFECTIVE AND PROVIDES FULL' COMPLIANCE WITH THE REQUIREMENTS OF 50.44.

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l COMPLIANCE WITH -50.44(a) o' 50.44 (a) REQUIRES A COMBUSTIBLE GAS CONTROL SYSTEM DESIGNED TO CONFORM WITH THE GENERAL-REQUIREMENTS 0F CRITERIA 41, 42, AND 43 0F APPENDIX A.

o OYSTER CREEK INERTED CONTAINMENT IS IN l

COMPLIANCE WITH-GDC 41, 42 AND 43 IN ALL APPLICABLE RESPECTS.

o NRC 0FFICE OF GENERAL COUNSEL LETTER DA'iED L

AUGUST 31, 1987 TO THE BWR OWNERS GROUP-I l

L IT IS REASONABLE TO INTERPRET 10 CFR 50.44 (a) AND 50.44 (c)

(1) SO AS NOT TO PRECLUDE A TECHNICALLY ACCEPTABLE INERTED CONTAINMENT SYSTEM FROM SATISFYING THESE REGULATIONS.

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4 RESOLUTION OF USI A-48 NRC RESOLUTION OF USI A-48 REGARDING HYDR 0 GEN o

CONTROL (SECY-89-122 DATED 5-31-89) FOR MARK I CONTAINMENTS "THE BWR MARK I AND MARK II REACTOR CONTAINMENTS HAVE OPERATED FOR A NUMBER OF YEARS WITH AN INERTED ATMOSPHERE...WHICH EFFECTIVELY PRECLUDES COMBUSTION OF ANY HYDR 0 GEN GENERATED."

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NED0-22155

" GENERATION AND MITIGATION OF' COMBUSTIBLE GAS MIXTURES IN INERTED' MARK I CONTAINMENTS" o

FOR 50.44 EVENTS, THE ADEQUACY OF THE INERTED CONTAINMENT FOR COMBUSTIBLE GAS CONTROL HAS BEEN DEMONSTRATED IN THE BWR OWNERS GROUP REPORT.

o SHOWS THAT FOR BWR MARK I PLANTS WITH INERTED CONTAINMENTS PEAK CONTAINMENT OXYGEN CONCENTRATIONS ARE MAINTAINED BELOW R.G. 1.7 COMBUSTIBLE GAS LIMITS WITHOUT REQUIRING:

CONTAINMENT VENTING CONTAINMENT REPRESSURIZATION HYDR 0 GEN RECOMBINERS o'

THE METHODOLOGY (WHICH USES A MECHANISTICALLY DERIVED OXYGEN GENERATION RATE) IS CONSISTENT WITH THE GUIDANCE OF R.G. 1.7 (HEI YIELD OF GASES GENERATED).

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s OYSTER CREEK CONSERVATISM OYSTER CREEK IS BOUNDED BY NED0-22155 PLANT SPECIFIC FEATURES PROVIDE ADDITIONAL CONSERVATISM WHEN COMPARED TO NED0-22155 ANALYSIS.

NED0-22155 0YSTER CRF.EK REFERENCE' PLANT CORE POWER 1971 MWT 3359 MWT CONTAINMENT VOLUME 180,000 FT 159,000 FT 9

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i STAFF CONCERNS WITH NED0-22155 o

STAFF EXPRESSED CONCERNS WITH UNCERTAINTIES ASSOCIATED WITH:

DURATION OF BOILING WITHIN THE CORE DEGREE OF FULL ROD DAMAGn EFFECT OF WATER CONTAMINATION ON THE OXYGEN GENERATION PROCESS-o SINCE 50.44 (D)

(1) REQUIRES AN ASSUMED METAL WATER REACTION OF APPROXIMATELY 1% FOR OYSTER CREEK, THE STAFF'S CONCERNS WOULD APPEAR TO RELATF.

T0 MATTERS BEYOND THE SCOPE OF 50.44 AND INVOLVE.

SEVERE ACCIDENT SCENARIOS.

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o THE NEDO REPORT CORRECTLY REFLECTS THE EFFECTS OF FUEL R0D DAMAGE AND WATER CONTAMINATION OF THE OXYGEN GENERATION PROCESS.

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LICENSING BASIS i

0 LICENSING BASIS (INCLUDING 50.44) DOES NOT REQUIRE NITROGEN REPRESSURIZATION FOR COMBUSTIBLE GAS CONTROL.

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POST-LOCA COMBUSTIBLE GAS CONCENTRATIONS:

OXYGEN CONCENTRATION < 5% IN 1000 DAYS (NED0-22155) o COMBUSTIBLE HYDROGEN & OXYGEN CONCENTRATIONS ARE NEVER REACHED 1j o

PURGING.IS NOT REQUIRED'FOR LICENSING BASIS l

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NO ACTION VENT & PURGE E

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USENITROGENCbNTINGENTUPON CONTAINMENT WATER LEVEL o'

NO CONFLICT BETWEEN E0Ps COMBUSTIBLE GAS CONTROL AND~ LICENSING BASIS o-VENTING ON HIGH HYDROGEN /0XYGEN CONCENTRATIONS BENEFICIAL DEFLAGRATION COULD FAIL CONTAINMENT CONTROLLED RELEASE. PREFERABLE TO UNCONTROLLED, UNISOLATABLE RELEASE SCRUBBING.0F EFFLUENT 1

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o PURGE WITH AIR WOULD OCCUR UNDER EXTREMELY

- RARE CIRCUMSTANCES o

PURGE WITil NITROGEN WOULD OCCUR 0NLY WHEN AIR SUPPLY IS INCAPABLE OF PURGE- (FLOODED UP) o SAFETY. GRADE NITROGEN PURGE SYSTEM. PRODUCES INSIGNIFICANT REDUCTION IN RISK.

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OYSTERLCREEK PLANTiSPECIFIC DESCRIPTION:

,1 0F CONTAINMENT INERTING SYSTEM o

ONLY REQUIRED DESIGN BASIS FUNCTION 10F-SYSTEM POST LOCA IS FOR CONTAINMENT ISOLATION VALVES

-(CIVs) TO CLOSE (VALVES ARE SAFETY GRADE AND R

REDUNDANT)-

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TO: RESPOND TO NRC's REQUEST WILL PRESENT SYSTEM DESCRIPTION AS FOLLOWS:-

A.

SYSTEM COMPONENT DESCRIPTION.

B.

SYSTEM INSTRUMENTATION-C.

OPERATIONAL REQUIREMENTS D.

NITROGEN CAPACITY E.

COMPARISON TO GDC 41,-42 AND 43 F.

OPERATIONAL, MAINTENANCE AND-SURVEILLANCE HISTO,RY O

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. CONTAINMENT INERTING SYSTEM A. -

SYSTEM /CCS/0NENT DESCRIPTION o

NITROGEN: SUPPLY SYSTEM (FOR DRYWELL & TORUS) e LIQUID NITROGEN TANK AND VAPORIZERS PIPING, VALVES, INSTRUMENTATION MANUAL CONNECTION FOR TUBE TRAILER HOOK-UP COMMERCIAL GRADE COMP 0NENTS COMPONENTS LOCATED OUTD0 ORS o

NITROGEN PURGE SYSTEM /MAKE-UP SYSTEM PURGE /MAKE-UP THROUGH AIR OPERATED VALVES TO DRYWELL AND TORUS

-ELECTRICAL POWER TO SOLEN 0ID' PILOT

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VALVES ON CIV's FROM VITAL AC POWER PANEL VACP-1 VACP-1 BACKED UP BY REDUNDANT VITAL AC POWER SOURCE CIV's FAIL CLOSED 0N LOSS OF AIR OR ELECTRICAL POWER NON-SAFETY RELATED AIR SUPPLY FOR CIV's FAILED CLOSED ON LOSS OF AIR CIV's CANNOT BE OPENED WHILE ISOLATION SIGNAL IS STILL PRESENT WITHOUT BYPASSING INTERLOCKS COMPONENTS LOCATED INSIDE THE REACTOR BUILDING ui

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VENTING SYSTEM (FOR DRYWELLc& TORUS)

PATH THROUGH' REACTOR BUILDING VENTILATION.

SYSTEM.0R STANDBY GAS TREATMENT-SYSTEM (SBGTS)

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. AIR OPERATED ISOLATION VALVES 1FOR DRYWELL VENT

-AIR OPERATED-VALVES FOR' TORUS VENT ELECTRICAL POWER TO SOLEN 0ID PILOT-

-VALVES FROM VITAL AC POWER PANEL VACP VACP-1 BACKED UP BY REDUNDANT VITAL-AC POWER.' SOURCE

' VALVES FAIL CLOSED ON LOSS OF AIR OR ELECTRICAL.-POWER NON-SAFETY RELATED AIR' SUPPLY FOR AIR OPERATED VALVES; FAIL CLOSED. ON LOSS. OF AIR CONTROL. ROOM BYPASS' SWITCH FOR ISOLATION SIGNAL BYPASS OF VALVES V-23-21, :22 AND V-28-18 AND 47 TO ALLOW VENTING WHILE ISOLATION SIGNAL STILL PRESENT VALVES V-27-1 AND 2 CANNOT BE OPENED WHILE ISOLATION SIGNAL IS STILL PRESENT WITHOUT BYPASSING INTERLOCKS COMPONENTS L0CATED.INSIDE THE REACTOR

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SYSTEM INSTRUMENTATION-l 1

o INERTING. SYSTEM NOT REQUIRED FOR DBA; IF SYSTEM WERE TO:BE USED. POST-LOCA, INSTRUMENTATION TO. MONITOR PERFORMANCE IS-AVAILABLE IN THE CONTROL ROOM:

VALVE POSITION It!DICATIONS NITROGEN TEMPERATURE NITROGEN FLOW-C.

OPB ATIONAL REQUIREMENTS POST.LOCA o

CIV's CLOSED D.

NITROGEN CAPACITY

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o TANK CAPACITY - 11,000 GALLONS o

ADDITIONAL N2 SUPPLY.WITHIN 24 HOURS

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COMPARIS0N TO GDC 41, 42, 43 t

o GDC'S SATISFIED FOR.INERTED CONTAINMENT -

NO MODS REQUIRED i

o MODS REQUIRED FOR OC INERTING SYSTEM TO MEET GDC 41, 42, 43 AS A NITROGEN CONTAINMENT ATMOSPHERIC DILUTION SYSTEM ("NCAD"):

PROVIDE REDUNDANT FLOW PATH AND VALVES FOR MAKEUP AND VENTING SYSTEMS PROVIDE REDUNDANT CLASS 1E POWER SUPPLY AND NITROGEN SUPPLY TO OPERATE THE AB0VE REDUNDANT MAKEUP AND VENTING VALVES.

UPGRADE THE NON-SEISMIC DESIGNED PIPING AND COMPONENTS TO SEISMIC CLASS 1.

MAY NEED TO ADJUST PIPE / COMPONENT SIZING 0F MAKEUP SYSTEM TO MEET NCAD CAPACITY REQUIREMENTS.

MAKE PROVISIONS FOR INSPECTION AND TESTING.

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OPERATIONAL. MAINTENANCE AND SURVEILLANCE HISTORY o

MINOR MAINTENANCE, RELIABLE OPERATION'ON.

i MAKEUP SYSTEM o

MAKEUP AND VENTING SYSTEMS ARELNORMALLY' 1

OPERATED TO. MAINTAIN CONTAINMENT PRESSURE BETWEEN 1.1 TO 1;3 PSIG.

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r CONCLUSIONS

- o OC INERTED CONTAINMENT; MEETS 50.44 REQUIREMENTS-o OC: RELIES ON ISOLATION TO MAINTAIN INERTED CONDITION.FOLLOWING A LOCA - CIV's ARE SAFETY GRADE AND REDUNDANT

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' NITROGEN INERTING SYSTEM NOT:USED FOR 50~.44~

POST-LOCA COMBUSTIBLE GAS CONTROL o

UPGRADING NITROGEN INERTING SYSTEM WOULD RESULT IN INSIGNIFICANT REDUCTION IN RISK TO o

PUBLIC HEALTH AND SAFETY p

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• ENCLOSURE 4 OYSTER CREEK NUCLEAR GENERATING STATION COMBUSTIBLE GAS CONTRQL o

November 27, 1978:

10 CFR 50.44 became effective o

June 10, 1980 In response to NUREG 0578, GPUN committed to provide an operationally single failure proof vent and purge system.

o December 2, 1981: 10 CFR 50.44 amended to require hydrogen recombiners.

o August 12, 1982: BWROG provided NRC -NEDO-22155 entitled; " Generation and Mitigation of Combustible Gas Mixtures in Inerted BWR Mark I.

i Containments".

o December 15, 1982: GPUN provided evaluation demonstrating applicability of NEDO-22155 to Oyster Creek, o

May 8, 1984: Generic Letter 84-09 issued; "The Commission has determi.ned that a Mark I BWR plant will be found to not rely upon j

purge /repressurf:ation systems as the primary means of hydrogen control, if certain technical criteria art satisfied."

o August 14, 1985:

GPUN demonstrated compliance with Generic Letter 94-09 technical criteria and determined hydrogen recombiners not required. CPUN also stated that the primary means of combustible gas c crol consisted of the containment Inerting System.

o September 24, 1985: GPUN requested cancellation of the vent and purge system upgrade based on NEDO-22155.

o April 3, 1986: Meeting held, (in support of cancellation request) between GPUN and NRC to address any concerns the Staff may have with the NEDO Report and its specific applicability to Oyster Creek. GPUN presented the following conclusions at the meeting:

l G.L. 84-09 supports determination that Hydrogen Recombiners are not needed at Oyster Creek.

- Oyster Creek combustible gas control is a passive oxygen based approach with no venting required.

BWROG Report supports determination that venting is not required for combustible gas control at Oyster Creek.

- 10 CFR 50.44(g) addresses the acceptability of non-safety grade purge systems.

Non-safety grade venting system is available.

o The staff stated the following at the April 3, 1985 meeting:

- Acceptability of the Containment Inerting System as the primary means of combustibio gas control must be made on the basis of Reg. Guide 1.7.

- With respect to G.L.

84-09,.the uncertainties of NEDO-22155 were acceptable when compared to the installation costs and the remaining levels of defense.

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4 No new or unique information has been presented which would warrant reconsideration of the staffs original NEDO-22155 determination.

Staff will not issue an SER for G.L.

84-09 until safety grade. vent and purge issue resolved.

GPUN's request for cancellation will be denied because Reg. Guide 1.7 was not the basis of NEDO-22155.

o May 5, 1986: NRC requires that GPUN commit to provide a safety-grade combustible gas control system (e.g., a containment purge and/or

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repressurization system) by 12R.

o June 16, 1986: GPUN notified NRC that it does not agree with its conclusion that Regulatory Guide 1.7 was required to be used for 10CFR50.44(g). A safety-grade purge and/or repressurization system was not required.

o January 20, 1987: GPUN participated in a BWROG Committue meeting with NRC which presented the BWROG position on compliance with 10CFR50.44.

The BWROG position is es follows:

10CFR50.44(c)(3)(Li)

Utilities have addressed the 3 criteria in Generic Letter 84-09, therefore hydrogen recombiner capability is not required.

10CFR50.44(g)

Regulation does not limit the option to hydrogen recombiner or a purge repressuriz'at.on system that meets criteria 41, 42 and 43 Appendix A.

Inerted Mark I containments constitute a means of combustible gas control ha required by 10CFR50.44(g) o March 13, 1987: Based on BWROG meeting, NRC requested Oyster Creek to submit its plent-specific position on compliance with.10CFR50.44(g).

NRC also stated that an inerted containment is not sufficient alone to meet 10CFR50.44(g), an active system is requ, ired.

o March 13, 1987: NRC safety evaluation concerning G.L.

84-09 concluded that Oyster Creek should; Provide a Nitrogen Containment Atmosphere Dilution System capable of pressurizing containment with nitrogen and redundant valves to isolate air from cointhinment.

Alternatively, install recombiner capability The staff stated that this is consistent with G.L. 84-09 and is necessary to demonstrate compliance with 10CFR50.44.

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June 23, 1987: BWROG requested NRC's (Office of General Counsel) review and comment on its position that Section 50.44(g) does not preclude the use of an inerted containment system to satisfy combustible gas control requirements. Oyater Creek was includad in the plants considered.

o August 31, 1987:

NRC's Office of General Counsel stated that they are prepared to agree that, on balance, it is reasonable to interpret 10CFR50.44(g) and 50.44(i) so as not to preclude an inerted containment system from satisfying these regulations, provided the inerted containment system is ladeed found to be technically acceptable. NRC stated that they are now awaiting licensee's submissions.

o May 31, 1988:

In response to NRC's March 13, 1987 letter, GPUN provides plant-specific information concerning Oyster Creek's compliance with 10CFR50.44(g) and responses to staff's SE concerning G.L.

84-09.

GPUN informa NRC that modifications will not be perforttied during 12R.

o November 15, 1988: BWROG submits basis for compliaace with 10CFR50.44.

o May 1, 1989: Staff states GPUN information previously supplied is not adequate to resolve issue of containment air dilution related 10CFR50.44.

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