ML19312D839
| ML19312D839 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 05/01/1980 |
| From: | Donohew J Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| ISSUANCES-SP, NUDOCS 8005050195 | |
| Download: ML19312D839 (12) | |
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3005050/95-0 UNITED STATES OF AMERICA 5/1/80 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of SACRAMENTO MUNICIPAL UTILITY
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Docket No. 50-312 (SP)
DISTRICT
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(Rancho Seco Nuclear Generating
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Station
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NRC STAFF TESTIMONY OF JACK N. DON 0 HEW ON CHANGING THE SYSTEMS OUTSIDE CONTAINMENT TO VENT INTO CONTAINMENT BUILDING (CEC Issue 5-1)
Q1.
Please state your name and your position with the NRC.
A1.
My name is Jack N. Donohew.
I am an employee of the U. S. Nuclear Regulatory Commission in the Operating Reactor Assessment Branch, Office of Nuclear Reactor Regulation.
Q2.
Have you prepared a statement of professional qualifications?
A2.
Yes. A copy of this statement is attached to this testimony.
Q3.
Please state the purpose of this testimony.
A3.
The purpose of this testimony is to supplement the testimony of James Wing on California Energy Commission Issue 5-1,which poses the following question:
Whether those systems identified as contributing to releases of radioactivity during the TMI accident, which are outside containment, should be changed to vent into the containment building?
Q4.
Have you reviewed the NRC Staff Testimony of James Wing on Changing the Systems Outside Containment to Vent into Containment Building (CEC Issue 5-1), Tr. following 2740, and the answers given by Dr. Wing under cross examination and questioning by the Board, Tr. 2741-2778?
A4.
Yes, I have.
Q5.
Do you have any clarifications and additions to offer to that testi-mony?
AS.
Yes, I do.
Q6.
What is the present status of SMUD's compliance with Short-Term Lessons Learned requirements 2.1.4 (containment isolation) and 2.1.6.a (inte-grity of systems outside containment)?
A6.
As documented in the NRC Staff's " Evaluation of Licensee's Compliance with Category 'A' Items of NRC Recomendations Resulting from TMI-2 Lessons Learned" for Rancho Seco, SMUD has satisfied these require-ments.
The Staff does, however, have under further review the isolation provisions for certain systems.
Verification of the implementation of SMUD procedures and of the plant modifications required will be done by the Office of Inspection and Enforcement.
Q7.
Please describe the actions taken by SMUD in response to requirement 2.1.4.
A7.
The NRC lessons learned requirements concerning containment isolation direct the licensee to: a) determine whether systems penetrating con-tainment are considered essential or non-essential to safety; b) modify containment isolation circuitry to automatically isolate all non-i essentiai systems by diverse parameters; and c) modify containment M-
isolation circuitry to assure that clearing of the containment isola-tion signals does not cause the inadvertent opening of containment isolation valves.
In addition, the isolation system was reviewed to ae'ure that certain systems which are isolated but might be desirable to use following an accident or transient, can be reopened; and to assure that operator controls of containment isolation are not ganged to reopen multiple systems with a single operator action.
The licensee has identified the essential systems as a) those systems required immediately after a Safety Features Actuation Signal (SFAS) and b) those systems whose continued operation will not cause acci-dent recovery problems and whose continued operation may aid in acci-dent recovery. Non-essential systems are those not required intnediate'y after an SFAS signal.
Systems incluoed in category (b) above are the RCP seal supply lines, the component cooling water (CCW) inlet and outlet lines and the con-trol rod drive (CRD) cooling water lines. The RCP seal supply and the CCW provide cooling for RCP seals to prevent seal damage that could result in a small LOCA. The seal return is isolated and check valves prevent back flow from the seal injection line. Thus, primary coolant would not be released via this route. The CCW and CRD cooling water systems are closed systems not in contact with primary coolant, with capability for manual isolation if required.
As described in the Rancho Seco FSAR, the isolation provisions of the CCW, CRD supply and return, and the RCP seal injection include automatic
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isolation on SFAS. The licensee subsequently, under the provisions of 10 C.F.R. 6 50.59, which do not require prior Comission approval of certain proposed changes, eliminated the automatic isolation por-tion of these systems. The Staff is presently reviewing whether the licensee will be required to reestablish automatic isolation of these systems. Because of the special requirements for use of these systems following certain upset conditions, isolation based on a minimum of a single parameter may be acceptable.
The SFAS signal which isolates all other non-essential systems is generated by diverse parameters: a) RCS pressure less than 1600 psig or b) containment pressure greater than 4 psig.
Penetrations controlled by remotely operated voives receive contain-ment isolation signals, whether they are open or closed during normal operation.
Penetrations controlled by local manual valves which are closed during normal operation are locked closed. The containment isolation valves do not reopen automatically if the containment iso-lation signal clears. Manual action is required.
The automatic containment isolation valve controls utilize a manual /
automatic mode select switch and an open/close select switch mounted together for each valve.
Following containment isolation, the operator can reopen any valve by first selecting manual mode and then pushing the open button. This is possible whether or not the containment iso-lation signal has cleared.
Selection of manual mode does not in itself open the valve.
1 Q8.
What are the NRC Staff's specific conclusions with respect to the acceptability of SMUD's actions under requirement 2.1.4?
A8.
We conclude that the licensee has satisfied the requirements of this item.
Review of the CCW, CRD supply and return, and RCP seal injec-tion isolation provisions is continuing. Verification of the adequacy of the procedures will be performed by the Office of Inspection and Enforcement and will be documented in an appropriate inspection report.
09.
Please describe the actions taken by SMUD in response to requirement 2.1.6.a.
A9.
The licensee has listed the plant systems outside containment which would or could contain highly radioactive fluids during a serious transient or accident. These systems are the makeup and purification system, decay heat removal system, high pressure injection system, reactor building spray system, waste gas system, reactor coolant sampling system, hydrogen purge system and appropriate parts of the miscellaneous radwaste system and coolant radwaste system. The li-censee has implemented an immediats leak reduction program for these systems to reduce their present leakage. The licensee has mr.asured and reported the "as-corrected" leakage for these systems e?. cept for the makeup and purification system, high pressure injection system and the reactor coolant sampling system. The licensee will measure the leakage from these three systems before startup from the present refue'ing outage and will repcrt the measured leakage within two weeks of startup.
The licensee has established a permanent leak reduction program to keep future leakage from the above systems to levels which are as low as reasonably achieva.ble. This program includes integrated leak rate tests once per refueling cycle, identification of leakage by means of visual surveillance by plant personnel and responses of area and effluent radiation monitors, and the plant preventive maintenance program.
The licensee has reviewed the plant design for potential release paths from the above systems due to design and operator deficiencies. As a result of this review, the licensee will make two changes to the plant. The relief valves for the make-up filter and the reactor coolant pump seal return will be routed to more suitable tanks or sumps instead of to open floor drains and the grade level of the Auxiliary Building will be changed in a manner to prevent contaminated water from a spill from leaving the building. These changes should be completed by January 1981.
4 Q10. What are the NRC Staff's specific conclusions with respect to the acceptability of SMUD's actions under requirement 2.1.6.a?
A10. Based on the above considerations, we conclude that the licensee has met the requirements of this item. Verification of the procedures which implement the licensee's permanent leak reduction program and the plant modifications discussed above will be performed by the Office of Inspection and Enforcement and documented in an appropriate inspection report.
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Q11. Does the licensee's compliance with lessons Learned requirement 2.1.6.a mean there will be no leakage during an accident from systems outside containment that might contain high radioactivity?
All.
No, some leakage may occur.
2.1.6.a was imposed to assure that leakage would be as low as practicable and definitely lower than was the case at TMI-2.
Q12.
Is the Rancho Seco Radwaste System designed for a Design Basis Acci-dent?
A12. No. The radwaste system was not designed for design basis accidents, cg., loss-of-coolant. The assumption was that containment isolation would prevent radioactive fluids from travelling outside the contain-ment during an accident to add to whatever burden was on the radwaste system prior to the accident.
Implementation of requirement 2.1.4 at Rancho Seco (certain of whose provisions were already met by the facility) will lend greater assurance that containment isolation will prevent an undue burden being imposed on systems outside containment which may contain radioactivity.
Q13. Would the radwaste system at Rancho Seco be capable of accommodating the quantities of waste that were produced at TMI-27 A13.
I believe the Rancho Seco radwaste system would be capable of accommo-dating these quantities of waste.
This belief is based on the fact that compliance with requirement 2.1.4 will prevent the uncontrolled pumping of water from the containment sump into the radwaste system.
This source of water was a large contributor to the radwaste system at TMI-2 and contributed to the overflowing of several tanks. This circumstance should not occur at Rancho Seco because containment will isolate earlier (on low reactor coolant system pressure or high con-tainment pressure) and it requires two manual actions to reopen con-tainment penetrations following the clearing of a containment isolation signal. Additionally, compliance with requirement 2.1.6.a should assure that leakage from systems outside containment that might contain high levels of activity will be lower than that which occurred at TMI-E.
Q14.
What is the status of the proposal te vent back into containment systems outside containment which may contain radioactivity as a result of an accident?
A14.
The Staff has proposed to the Conunission that the possibility of having the capability to vent certain systems outside containment back into containment be considered as part of a coordinated program aimed at exposure reduction following accidents. The Staff proposals are still in the process of revision, but it can be said that they oc longer specifically focus on the letdown / makeup system nor the concept of placing that systei within an enclosure with venting back to con-tainment, as did Task III.D.2 of the December 10, 1979 Revision 1 of Draft NUREG-0660. Wh3tever conclusions are reached on this aspect of the proposed study will have to take account of the associated back-fit problems for operating plants. The Staff is proposing that the Commission include radwaste system improvements growing out of the study described above in its proposed rulemaking on degraded cores.
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j Q15. Do you believe that systems outside containment at Rancho Seco, which were identified as contributing to releases during the TMI-2 accident, should be changed at this time to vent back into containment?
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A15. No.
It is not clear at the present time that venting back into con-tainment should be imposed as a requirement. A determination on whether to impose such a requirement should be made as part of the coordinated review of all actions that could reduce releases of radioactivity during an accident, as described above in the answer to question 14.
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JACK H. DON 0llEW, JR.
PROFESSIONAL QUALIFICATIONS DIVISION OF OPERATING REACTORS 4
0FFICE OF NUCLEAR REACTOR REGULATION My name is Jack N. Donohew, Jr.
I am a Senior Nuclear Engineer in the Operating Reactors Assessment Branch in the Division of Licensing, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission (NRC).
My duties include the review of rad-waste treatment systems and engineered safety feature ventilation systems for operating reactors.
I received a Bachelor of Engineering Physics Degree from Cornell University i
in 1965, a Master of Science Degree in Nuclear Engineering from Massachusetts Institute of Technology in 1968, and a Doctor of Science Degree in Nuclear Engineering from Massachusetts Institute of Technology in 1970.
I received my Professional Engineers License in Nuclear Engineering from the Common-wealth of Pennsylvania in 1974.
After graduation, I worked for Stone and Webster Engineering Corporation as an engineer in the Radiation Protection Group.
I was responsible for estimating source terms, release rates and resulting doses for the Safety Analysis Report, Environmental Report and response to NRC questions for boiling water nuclear reactors.
I was also responsible for shielding de-sign for the reactor water cleanup system.
In February 1973, I became a Power Engineer in the Process Engineering Group, Stone and Webster En;ineering Corporation.
I was the responsible process engineer for the Shoreham Project and the equipment specialist for all Stone and Webster nuclear plants for the containment iodine spray removal system, ventilation filter assemblies, and gaseous waste treatment system.
In June 1975, I joined the Nuclear Regulatory Comission as a senior nuclear engineer in the Effluent Treatment Systems Branch.
I was involved in rad-
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waste system licensing reviews of nuclear power plants.
I have conducted generic studies of the degradation of charcoal adscrbers in ventilation filter assemblies.
In December 1975, I jo'ied the Environmental Evaluation Branch in the Divi-sion of Operating Reactors.
I am now a member of the Operating Reactors Assessment Branch of the Division of Licensing.
Between October 1979 and the present time, I have been a member of the Lessons Learned implementation team for Babcock & Wilcox operating reactors.
In this capacity I have visited all of the B&W operating units to determine compliance with the Category A short-term Lessons Learned requirements within my area of competence.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of SACRAMENTO MUNICIPAL UTILITY Docket No. 50-312 (SP)
DISTRICT Rancho Seco Nuclear Generating Station CERTIFICATE OF SERVICE I hereby certify that copies "NRC STAFF TESTIMONY OF JACK N. DON 0 HEW ON CHANGING THE SYSTEMS OUTSIDE CONTAINMENT TO VENT INTO CONTAINMENT BUILDING" and " PROFESSIONAL OVALIFICATIONS" of Jack N. Donohew, in the above-captioned proceeding, have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this Ist day j
of May, 1980.
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o Elizabeth S. Bowers, Esq., Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Dr. Richard F. Cole Atomic Safety and Licensing Board Panel Chr'stopher Ellison, Esq.
U.S. Nuclear Regulatory Commission Dian Grueneich, Esq.
Washington, D.C.
20555 California Energy Commission 1111 Howe Avenue
- Mr. Frederick J. Shon Sacramento, California 95825 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Herbert H. Brown,.Esq.
Washington, D.C.
20555 Lawrence Coe !.anpher, Esq.
Hill, Christopher and Phillips, P.C.
David S. Kaplan, Esq.
1900 M Street, N.W.
General Counsel Washington, D.C.
20036 Sacramento Municipal Utility District P. O.
Box 15830 Mr. Michael R. Eaton Sacramento, California 95813 Energy Issues Coordinator Sierra Club Legislative Office Thomas A. Baxter, Esq.
1107 9 Street, Room 1020 Shaw, Pittman, Potts & Trowbridge Sacramento, California 95814 1800 M Street, N.W.
Washington, D.C.
20036 i
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'* Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Y. key L
Sf' phen H. Lewis e
Counsel for NRC Staff p
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