ML20039C235

Response to NRC & Applicant Responses to Contentions Re Hydrogen Control Issues.Contention Should Be Accepted by Aslb.Certificate of Svc

ML20039C235
Person / Time
Site:	Black Fox
Issue date:	12/22/1981
From:	Farris J CITIZENS ACTION FOR SAFE ENERGY, FELDMAN, HALL, FRANDEN, REED & WOODWARD
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-CP, NUDOCS 8112290096
Download: ML20039C235 (6)

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UNITED STATES OF K4 ERICA -

E'T NUCLEAR REGULATORY COMMISSION b hp 9, '

i BEFORE THE ATOMIC SAFETY AND LICENSING-rBOARD ~Lf ant i .u a BC $0.

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In the Matter of the Application of ) ,

Public Service Company of Oklahoma, ) , - gess4T 88 p' j ss .

Associated Electric Cooperative, Inc. )

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and ) ,

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Western Farmers Electric Cooperative } Docket Nos. N =

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) STN 50-556CP s 's (Black Fox Units 1 and 2) ) STN 50-557CP .

m N  %~ ,-] 4 INTERVENORS' ARGUMENTS IN RESPONSE 6 '

TO NRC STAFF AND APPLICANT'S RESPONSES ,

Te CONTENTIONS CONCERNING HYDROGEN CONTROL ISSUES m On November 20, 1981, the Intervenors proposed certain ^

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Hydrogen Control Contentions in response to the Applicant'd Amendment No. 18 to the PSAR. Both Staff and Applicants ' ,

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filed responses to these proposed contentions on December Bj 1981. Pursuant to oral application of the Intervenors, the' Board decided at the December 19, 1981, prehearing conference s

to accept Intervenors' written arguments on this issue within" ,

fourteen (14) days of the prehearing conferen,ce. The following are Intervenors' comments and arguments in respon~se to the ,

-s staff and Applicant: u e

A. Response to Applicant & Staff Responses Staff argues that there is insufficient basis for the i

Intervenors contention and that it requires the Applicant to ,

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do more'than the Applicant is compelled by the proposed rule

(S taf f at' p. 6) . Tne proposed rule defining hydrogen control

issues,'and_ design analyses for BWR Mark III containments has not yet been issued (see SECY-81-245A) and thus there is no basis to evaluate whether intervonors have required more or

" less. The information provided to date does not provide the necessary information to satisfy the needs for preliminary design informatioh in the areas detailed in the intervenors' contention.

_ B. Issues Supportive of Intervenor Contention on Hydrogen Control

~There i.a insufficient preliminary design data provided to insure that'the Applicant has considered the worst case accident (and potential for local concentrations) in terms of hydrogen

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generatiori and release rate and its effect on the containment and

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safety.related equipment potentially subjected to repeated hydrogen burns. 53r has the Applicant described the nature and accepta-u.

. bility of'the decision criteria to be used by the operators in determining.when to activate the DIS. There is insufficient

- preliminary ' design data to show that the ignitors and other safety.-related equipment (such as containment penetrations) will be qualified to assure the ability to withstand all potential l ' . '

I dent conditions. There is insufficient preliminary design

.nformation to-chow how the Applicant plans to verify that the requireil surveillance tests and procedures will in fact insure the op.erabil'ity and functionability of the DIS for the full range m -

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Further,' there are features of the Mark III containment which introduce safety related equipment to a different accident l

environment than previous containment designs. An example is

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' the_ location of the Hydraulic Control Units. The Applicant

,;, f j? ' , has not included adequate consideration of the potential effects of hydrogen burns on these critical safety-related com-47 ponents.

In addition, the Applicant described research and development R- u j

./ programs to be performed by many different organizations.

How-g ever, there is no assurance that they have provided the necessary V ,_ ;

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e integration of the projects to produce the desired results and to j ,

fcomply'with the necessary Quality Assurance Criteria (10 CFR 50

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.. ; i Appendix B).

.o ; CONCLUSION

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j. 3 Intervenors respectfully submit, therefore, that their l Hydrogen Control Contention (and all subparts thereof) should be accepted by the Board pursuant to 10 CFR S 2.714.

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JOSEPH R. FARRIS NANCY L. WOODS l FELDMAN HAL ,F DEN & WOODARD

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[ Aos/dph R. Farris 816 gaterprise Building

+ Tulsa, OK 74103 918/583-7129 ATTORNEYS FOR INTERVENORS f

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

,BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of the Application of )

Public Service Company of Oklahoma, )

Associated Electric Cooperative, Inc. )

and )

Western Farmers Electric Cooperative ) Docket Nos.

) STN 50-556CP (Black Fox Units 1 and 2) ) STN 50-557C; CERTIFICATE OF SERVICE I, Joseph R. Farris, one of the attorneys for Citizens Action for Safe Energy (C. A.S .E . ) , certify that copies of the following:

"Intervenors' Arguments In Response to NRC Staf f and Applicant's Responses to Contentions Concerning Hydrogen Control Issues" have been served on the persons shown on the attached list by United States Mail, postage prepaid, this 22nd day of December , 1981.

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W92 Joseph R. Fa rris ' ~

Sheldon J. Wolfe, Esq. Andrew T. Dalton, Esq.

Atomic Safety and Licensing Attorney at Law Board Panel 1437 South Main Street United States Nuclear Room 302 Regulatory Commission Tulsa, Oklahoma 74119 Washington, D.C. 20555 Mrs. Ilene Younghein Mr. Frederick J. Shon 3900 Cashion Place Atomic Safety and Licensing Oklahoma City, OK 73112 Board Panel United States Nuclear Mrs. Carrie Dickerson Regulatory Commission Citizens Action for Washington, D.C. 20555 Safe Energy P. O. Box 924 Dr. Paul W. Purdom Claremore, Oklahoma 74017 Director, Environmental Studies Group Joseph Gallo, Esq.

Drexel University Martha E. Gibbs 32nd and Chestnut Streets Frederick C. Williams Philadelphia, PA 19104 Isham, Lincoln & Beale 1120 Connecticut Ave.,N.W.

Docketing and Service Section Washington, D.C. 20036 Office of the Secretary of the Commission Michael I. Miller United States Nuclear Phillip P. Steptoe Regulatory Commission Isham, Lincoln & Beale Washington, D. C. 20555 One First National Plaza, (20 copies) Suite 4200 Chicago, Ill. 60603 Atomic Safety and Licensing Board Panel Mr. Maynard Human United States Nuclear General Manager Regulatory Commission Western Farmers Electric Washington, D. C. 20555 Cooperative P. O. Box 429 Atomic Safety and Licensing Anadarko, Oklahoma 73005 Appeal Board Panel United States Nuclear Mr. Gerald F. Diddle Regulatory Commission Associated Electric Washington, D. C. 20555 Cooperative, Inc.

P. O. Box 754 Mr. Clyde Wisner Springfield, Missouri 65801 NRC Region 4 Public Affairs Officer Mr. Lawrence Burrell 611 Ryan Plaza Drive Rt. 1, Box 197 Suite 1000 Fairview, Oklahoma 73737 Arlington, Texas 76011 Dr. M. J. Robinson Black & Veatch P. O. Box 8405 Kansas City, Mo. 64114

Dr. John Zink Public Service Company of Oklahoma P. O. Box 201 Tulsa, Oklahoma 74102 Mr. T. N. Ewing Public Service Company of Oklahoma P. O. Box 201 Tulsa, Oklahoma 74102 Hon. Michael Bardrick

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Assistant Attorney General State of Oklahoma State Capitol Building Oklahoma City, Oklahoma 73105 i

Mr. Gregory Minor MHB Technical Associates 1723 Hamiton Ave.

Suite K San Jose, CA 95125 i

Samuel J. Chilk

Secretary of the Commission United States Nuclear

> Regulatory Commission Washington, D.C. 20555 i

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