ML20052C700
| ML20052C700 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/04/1982 |
| From: | Hodges M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20052C678 | List: |
| References | |
| NUDOCS 8205050408 | |
| Download: ML20052C700 (7) | |
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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LONG ISLAND LIGHTING COMPANY Docket Number 50-322
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(Shoreham Nuclear Power Station,
)
Unit 1)
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i NRC STAFF TESTIMONY OF MARVIN W. (WAYNE) H0DGES REGARDING CUT 0FF 0F ECCS SCContention28(a)(1)
SOC ~ Contention 7.A(1) t i
8205050408j2M22 r
OUTLINE OF TESTIMONY Intervenors contend that Applicant has failed to resolve certain generic safety issues resulting from the THI-2 accident by failing to incorporate automatic restart on loss of water level if an initiation sign is still present, which would override the operator's action.
Witness Hodges replies that a manual restart for LPCI and core spray is acceptable and actually preferable to automatic controls for a number of reasons, which include the importance of flexibility in dealing with 4
unforseen conditions, the fact that operator training emphasize water level control, and the fact that automation would increase system complexity and decrease system reliability.
(
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of LONG ISLAND LIGHTING COMPANY Docket Number 50-322
)
(ShorehamNuclearPowerStation,
)
Unit 1)
)
NRC STAFF TESTIMONY OF MARVIN W. (WAYNES) H0DGES ON SC CONTENTION 28(a)(1) AND SOC CONTENTION 7.A(1)
Q.
Please state your name and position with the NRC.
A.
My name is Marvin W. (Wayne) Hodges.
I am employed by the U.S. Nuclear Regulatory Comission as a Section Leader in the Reactor Systems Branch in the Division of Systems Integration. A copy of my professional qualifications is attached.
Q.
What is the purpose of your testimony?
A.
The purpose of this testimony is to respond to SC Contention 28(a)(i) and S0C Contention 7.A(1) which state:
Suffolk County [and SOC] contend that the NRC Staff has not adequately assessed and LILC0 has not ade-quately resolved, both singularly and cumulatively, the generic unresolved issues applicable to a BWR of the Shoreham design. As a result, the St3ff has not required the Shorehan structures, systems, and components to be backfit to current regulatory practices as required by 10 CFR % 50.55(a), 9 50.57, and 6 50.109, with regard to the following:
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, (a). LILC0 has failed to resolve adequately certain generic safety items identified as a result of the TMI-2 accident and contained in NUREG-0737, " Clarification of TMI Action Plan Requirements"(1980).
(1). The operator's decision to cut off coolant injection at THI-2 contributed to the accident sequence and fuel damage. NUREG-0737, Item II.K.3.21 requires that the major low pressure energ ncy coolings systems for BWR's (core sprav CS) and low pressure coolant injection LPCI)) incorporate an automatic restart on loss of water level if an initiation signal is still present.
Since the operator can shut off the flow from these systems at any time, there are conditions where it may be necessary to override the operator's action. LILC0 has not demonstrated that proper core cooling capability will be available for all plant conditions, namely, shutdown of the CS or LPCI systems by the operator. Thus, it has not ensured compliance with 10 CFR 50.46 and 50.55A(h).
Q.
Why is manual restart of core spray and LPCI acceptable?
A.
Manual restart is acceptable because:
(1) the interlocks and control logic necessary for automation would increase system complexity and decrease system reliability, (2) current operator training emphasizes water level control, (3) emergency procedure guidelines emphasize water level control, (4) multiple control room indications of vessel water level will alert the operator to low situations, and (5) the amount of time the operator has to correct errors is substantial.
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3-Q.
Why is manual operation of LPCI/LPCS systems necessary after a LOCA?
A.
Manual operator actions provide the plant operators with flexibility for dealing with unforseen but credible conditions requiring a particular system to be shutdown.
Examples would be systems termination on reactor high water level. The intent of this manual control feature is to prevent unnecessary flooding of the reactor vessel and steam lines.
Many BWR, transient and accident events involve significant release of reactor system energy to the suppression pool which increases the pool temperature and containment pressure. Control of these temperature /
pressure conditions is achieved by manually placing the LPCI/RHR system in the suppression pool cooling mode. This LPCI/RHR mode, in conjunction with emergency service water system operation, permits rejection of the excess suppression pool energy to the station ultimate heat sink. Much of the equipment used for this cooling function is also used for the LPCI/ECCS mode of RHR system.
Q.
What are your conclusions concerning this contention?
A.
Manual restart of core spray and LPCI is an acceptable mode of operation for the Shoreham facility. The automatic controls urged by Intervenors would increase system complexity and decrease system reliability.
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f'.arvin W. (Wayne) H:dres
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Professional Qualifications i
Reactor Systems Branch Division of Systems Integration U. S. Nuclear Regulatory Commission I am employed as a Section I.eader in Section B of the Reactor Systems Branch, DSI.
I graduated from Auburn University with a l'echanical Engineering Degree in 1965.
I received a Master of Science degree in Mechanical Engineering from Auburn University in 1967.
In my present work assignment at the NRC, I supervise the work of 6 graduate engineers; my section is responsible for the review of primary and safety systems for BWRs.
I have seryed as principal reviewer in the area of boiling water reactor systems.
I have also participated in the review of analytical models use in the licensing evaluations of boiling water reactors and I have the technical revicu responsibility for many of the r.odifications and analyses being implemented on boiling water reactors post the Three Mile Island, Unit-2 accident.
As a inaber of the Bulletin and Orders Task Force which was formed af ter the 1MI-2 accident, I was responsible for the review of the capability of BUR systcms to cope with loss of feedwater transient and small break loss-of-coolant accidents.
I have also served at the NRC as a reviewer in t!)e Analysis Branch of the NRC in the area of thermal-hydrulic performance of the reactor core.
I served as a consultant to the RES representative to the program management group for the EWR Bloudcun/ Emergency Core Cooling Program.
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Prior to joining the !;RC staff in March,1974, I was employed by E. I. DuPont at the Savant.ah River Laboratory as a research engineer.
At SRL, I conducted hydraulic and heat transfer testing to support operation of the reactors at the Savanr.ah River Plant.
I also perforc,ed safety limit ca1culations and participated in the develophent of ar.alytical m?dels for use in transient ar.alyses a'. Savannah River.
My tenure at SRL was from June 1967 to March 1974.
from Sepitabar 1965 to June 1967, while in graduate school, I taught courses in therm 3 dynamics, statics, mechanical engincering nzesurements, conputer During
. prograu:.ing and assisted in a course in the history of engineering.
the surt.:,er of 1966, I worl:ed at the Savannah River Laboratory doing hydraulic testing.
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