ML20128G837

Package of Affirmation Response Sheets Re SECY-83-357, Amends to 10CFR50 Re Hydrogen Control

ML20128G837
Person / Time
Issue date:	01/12/1984
From:	NRC COMMISSION (OCM)
To:
Shared Package
ML20127B435	List: IA-84-577, Forwards Addl Questions Re Hydrogen Rule ML20127B432 ML20127B449 ML20128G817 ML20128G837 ML20128G855 ML20128G866 ML20128G884 ML20128G957
References
FOIA-84-577 NUDOCS 8505300327
Download: ML20128G837 (8)

Text

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T0: SAMUELd.CHILK,SECRETARYOFTHECOMMISSION FROM: CHAIRMAN PALLADINO -

SUBJECT:

SECY-83-357 - AMENDMENTS TO 10 CFR PART 50 RELATED TO HYDROGEN CONTROL K

DISAPPROVED" ABSTAIN"'

APPROVED' REQUEST DISCUSSION NOT. PARTICIPATING l ,

COMMENTS:

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/ /%- ( f1) Alt SECRETARIAT NOTE: PLEASE ALSO. RESPOND TO. AND/OR COMMENT ON 0 MEMORANDUM IP ONE HAS BEEN ISSUED ON THis PAPER.

NRC-SECY FORM DEC. 80

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COMMISSIONER GILINSKY

SUBJECT:

SECY 83-357 - AMENDMENTS TO 10 CFR PART 50 RELATED TO HYDROGEN CONTROL ,

APPROVED i s MODirIED . DISAPPROVED ABSTAIN

. '.;, NOT PARTICIPATlNG REQUEST DISCUSSION

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SECRETARIAT NOTEi PLEASE ALSO. RESPOND TO AND/OR COMMENT ON.0GC MEMORANDUM IF ONE HAS BEEN ISSUED ON THIS PAPER.

NRC-SECY FORM DEC. 80

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s COMMISSIONER GILINSKY'S VOTE SHEET FOR SECY 83-357

1. Paragraph 50.44 (c) (3) (v) 'should apply to all LWRs that do not rely upon an inerted atmosphere as a hydrogen control means.

2 .- The hydrogen control systems required by this amendment should be automatically initiated based on plant parameters deemed acceptable by the NRC staff. OGC-should determine whether this revision to the rule, if agreed to by the Commission would have to be issued in proposed form rather than as a final rule.

3. The plant-specific insert proposed by Commissioner

- Roberts is inconsistent with the preceding two sentences in the statement of considerations. Instead, I would suggest the insertion of the following paragraph from the EDO's December 28, 1983 memorandum:

"It should be noted that results of research and analyses performed by an NRC contractor, by EPRI and by the industry show that the surface temperatures for most electrical equipment will not exceed the surface temperatures achieved during qualification testing for LOCA/MSLB events.

Because of this, qualification testing for design basis accidents demonstrates qualification for a hydrogen burn environment for those situations where hydrogen burn analyses show that the equipment surface temperatures are less than those achieved during qualification testing. Thus far,

' only one item of equipment, some cable, has required testing specifically to address its ability to function in the burn environment. This

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additional testing was needed because analyses for l

hydrogen burn events indicated that the surface

! temperature would exceed the qualification l

temperature for.LOCA/MSLB events."

l l 4. The statement of considerations regarding sequoyah, on i

page 16, should be clarified to indicate that only a selection of hydrogen burn scenarios have been found to be bounded by the MSB/LOCA environments. In particular, the staff is still reviewing whether the MSB/LOCA environment adequately envelops the thermal l

response of electrical equipment during a hydrogen i burn.

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5. The phrase " safe cold shutdown" should be retained from the proposed rule since the final rule is inconsistent with the licensing bases for most Mark III BWRs and ice condenser PWRs which require systems and components to

' be provided for " safe cold shutdown." Exemptions for '

f older plants which were licensed for " safe shutdown" should be granted on a case-by-case basis. .

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g p p g g y g 3 :g: 99 RESPONSE SHEET T0: SAMUEL J. CHILK, SECRETARY OF THE COMMISSION FROM: COMMISSIONER ROBERTS

SUBJECT:

SECY-83-357 - AMENDMENTS TO 10 CFR PART 50 RELATED TO HYDROGEN CONTROL APPROV DISAPPROVED ABSTAIN' NO ARTICIPATING REQUEST DISCUSSION COMMENTS:

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NRC-SECY FORM DEC. 80

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' 13 [7590-01]

ti v in a manner acceptable to the Commission using a combined approach of analys.is sand testing. Thus, an acceptable thermal analysis would have to be performed for the containment in order to determine the thermal response of the components

.during a hydrogen burn. This thermal response should then be compared to the thermal response the components had during their qualification testing. The licensee should then demonstrate that the qualification thermal response envelops

the thermal response during a hydrogen burn. Selected tests should also be performed at predicted hydrogen burn conditions (or, other tests previously performed may be referenced if demonstrated to be applicable) to reasonably assure the Commission that the systems and components are qualified to perform f

their functions during and following a hydrogen burn. /A/$ g 7-}

' Paragraph 50.44(c)(3)(v)appliestothoseMarkIllBWRsandicecondenser PWRs that do not have an inerted containment atmcsphere for hydrogen control.

At present, this iricludes all Mark III BWRs and ice condenser PWRs, since no applicant or licensee has as yet elected to use the inerting option for these plants. The systems and components that must be qualified for a hydrogen burn are those needed (a) to shut down the reactor and bring it to and maintain it in a safe shutdown condition, and (b) to prevent loss of containment integrity.

These systems and components can be further categorized as follows:

a. Systems and components mitigating the consequences of.the accident;

b. Systems and components needed for mainteining integrity of the containment pressure boundary;

c. Systems and components needed for maintaining the core in a safe condition; and Enclosure "F"

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• g The demonstrations of survivability accepted by the staff for Sequoyah ar.1 McGuire without more testing, analysis or documentation are equivalent to demonstrations of qualification for a hydrogen burn event, and the staff does not require any other submittal from the licensees except for the previously identified confirmatory items.

• From DecembeF 28, 1983 memo fron W. J. Dircks to Comissioners e

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RESPONSE SHEET T0: S MUEL J. CHILK, SECRETARY OF THE COMMISSION FROM: COMMISSIONER ASSELSTINE

SUBJECT:

SECY-83-357 - AMENDMENTS TO 10"CFR PART 50 RELATED TO HYDROGEN CONTROL Asrowmb APPROVED' -

DISAPPROVED ABSTAIN NOT PARTICIPATING REQUEST DISCUSSIOR COMMENTS:

1. Paragraph 50.44 (c) (3) (v) should apply to all LWR's that do not rely upon an inerted atmosphere as a <<

e hydrogen control means.

2. The hydrogen control systems required by this .

amendment should be automatically initiated based- .

on plant parameters deemed acceptable by the NRC staff.

OGC should determine whether this revision to the rule, if agree.d to by the Commission would have to be issued in, proposed forirrrather than as a final rule.

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SECRETARIAT NOTE: PLEASE ALSO RESPOND TO.AND/OR COMMENT ON OGC/0PE MEMORANDUM IF ONE HAS BEEN ISSUED ON THIS PAPER.

NRC-SECY FORM DEC. 80 l

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A F F I R M A~T T 0 N RESP 0NSE SHEET T0: SAMUEL J'. CHILK, SECRETARY OF THE COMMISSION FROM: COMMISSIONER BERNTHAL

SUBJECT:

SECY-83-357 - AMENDMENTS TO 10 CFR PART 50 RELATED TO HYDROGEN CONTR APPROVED"I DISAPPROVED ABSTAIN' NOT PARTICIPATING' REQUEST DISCUSSION COMMENTS:

1. While I approve exclusion of large-dry containments from the specific requirements 'of this rule for the present, I believe the Comission should reserve judgment on equipment survivability for

- large-drys until the referenced research programs are completed in the fall of 1984. At that time, the Commission should detennine whether to expandsections50.44(c)(3)(v)and(c)(3)(vi).toincludeequipment survivability for large-dry containment types.

2. Inreferenceto(c)(3)(vi)(B),theroleofNRCstaffin approving the choice of accident scenarios and licensee analysis required for such scenarios needs to be clarified. The controlling cases (for determining equipment survivability or containment capability with hydrogen control) should either include the "75 percent riterion" case, or state why the cases chosen are much more severe than 7cident scenarios that would yield "75 percent criterion" hydrogen production. .

3. Thoug'h I still believe that in circumstances such as this, staff should opt for automatic systems initiation and control, in this case staff's argument is sufficiently pursuasive. I therefore would not require automatic initiation of hydrogen control systems if that would mandate a further coment period on the proposed rule; I concur in Ma'c request for a ruling by OGC.

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SECRETARIAT NOTE: PLEASE.ALSO-RESPOND.TO.AND/OR COMMENT ON OGC/0PE MEMORANDUM IF ONE HAS BEEN ISSUED ON THis PAPER.

NRC-SECY FORM DEc 80

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