ML20052F594
| ML20052F594 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/07/1982 |
| From: | Hodges M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20052F540 | List: |
| References | |
| REF-GTECI-A-09, REF-GTECI-SY, TASK-A-09, TASK-A-9, TASK-OR NUDOCS 8205130224 | |
| Download: ML20052F594 (6) | |
Text
I UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!VIISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TEXAS UTILITIES GENERATING C0fiPANY, Docket Nos. 50-445
_ET _AL.
50
6
)
(Comanche Peak Steam Electric
)
(Application for Operating License)
Station, Units 1 and 2)
)
AFFIDAVIT OF MARVIN W. H0DGES I, Marvin W. Hodges, being dulv sworn, do depose and state:
Q.1.
By whom are you employed, and what is the nature of the work you perform?
A.1.
I am employed as a Section Leader in the Division of Systems Integration, Reactor Systems Branch ("RSB"), U.S. Nuclear Regulatory Comission. A copy of my statement of qualifications is attached to this affidavit.
l Q.2, What is the nature of the responsibilities you have regarding the Anticipated Transients Withoit Scram ("ATWS")?
Q.2.
One of my responsibilities as a member of the RSB is the evaluation of the 1:cplementation of ATWS requirements for l
all light water commercial power reactors.
l 9205130224 820507 PDR ADOCK 05000445 G
F Q.3.
What is the subject matter of your affidavit?
A.3.
I will address Board Question 3, which requests:
Describe the status of Safety Issue TAP A-9
( ATWS) as it relates to CPSES 1 and 2.
In particular, I will discuss whether the licensing and interim full power operation of CPSES will present an unacceptable risk to the public.
Q.4.
What is Unresolved Safety Issue ("USI") TAP A-97 A.4.
USI TAP A-9 is titled, " Anticipated Transients Without Scram."
USI A-9 involved the ATWS issue which is currently the subject of a Commission rulemaking proceeding. 46 Fed. R3 57521 (Nov. 24, 1981). This rulemaking resulted from and supersedes the Staff recommendations published in Volume 4 of NUREG-0460 except for the interin measures relating to procedures and training for responding to anticipated transient without scram events. The Applicants will be required to conform to the requirements of any final Comission rule on ATWS.
Q.5.
Does the licensing and interim full power operation of CPSES pending resolution of the Commission's rulemaking proceeding on ATWS present an unacceptable risk to the public?
A.S.
No, the licensing and interim full power operation of CPSES pending resolution of the ATWS rulemaking proceeding will not
F pose an unacceptable risk to the public. As stated in Section 15.3.9 of the SER for CPSES:
[As discussed in NUREG-0460, Volume 3], the Staff has maintained since 1973 (for example, see pages 69 and 70 of WASH-1270)... that the present like-lihood of severe consequences arising from an ATWS event is acceptably small and presently there is r,o undue risk to the public from ATWS. This conclusion is based on engineering judgment in view of:
(a) the estimated arrival rate of anticipated transients with potentially severe consequences in the event of a scram failure; (b) the favorable operating experience with current scram systems; and (c) the limited number of operating reactors.
In view of these considerations and our expectation that the necessary plant modifications will be implemented in one to four years following a Com-mission decision on anticipated transients without scram, we have generally concluded that pressurized water plants can continue to operate because the risk from anticipated transient without scram events in this time period is acceptably small.
To further reduce the risk from ATWS events during the interim period prior to the Applicants' implementation of any final Commission rule on ATWS, the Staff has required that:
(i) emergency procedures for ATWS be developeo, and (ii) operators be trained to recognize and properly respond to ATWS, in accord-ance with the developed emergency procedures. These require-ments are set forth in NUREG-0460, Volume 4.
Satisfactory implementation of the emergency procedures and operator training requirements of NUREG-0460, Volume 4, provides an acceptable basis for interim full power operation of CPSES.
In addition, the Commission has stated that the likelihood of severe consequences from an ATWS event during the two to four
F year period required to implement a rule is acceptably small.
The Commission's judgnent was based on:
(1) the favorable experience with operating reactors; (ii) the limited number of operating nuclear reactors; (iii) the inherent capability of some of the operating PWRs to partially or fully mitigate the consequences of an ATWS event; and (iv) the interim steps, set forth in NUREG-0640, Volume 4, taken to develop procedures and train operators to further reduce the risk from some ATWS events. On the basis of these considerations, the Commission concluded that there is a reasonable assurance of safety for continued operation of nuclear power plants until implementation of a final ATWS rule. 46 Fed. Reg. at 57522.
The above statements and opinions are true and correct to the best of my personal knowledge and belief.
0/L Y
(
Marvin W. Hodges '
g Subscribedgndsworntobefore me this 78 day of May, 1982.
).j-a n-i x' ' L v7 L ( GL
}
&/ 7/ D Notary Public (/
My Comission expires:
Marvin'W. (Wayne) Hodges Professional Qualifications Reactor Systems Branch Division of Systems Integration U. S. Nuclear Regulatory Commission I am employed as a Section Leader in Section B of the Reactor Systems r
Branch, DSI.
f I graduated from Auburn University with a Mechanical 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 review respons,ibility for many of the modifications and analyses being implemented on boiling water reactors post the Three Mile Island, Unit-2 accident.
As a-member of the Bulletin and Orders Task Force which was formed after the TMI'-2 accident, I was responsible for the review of the capability of BWR systems 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 the 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 BWR Blowdown / Emergency Core Cooling Program.
Prior to joining the NRC staff in March,1974, I was employed by E. I. DuPont at the Savannah River Laboratory as a research engineer.
At SRL, I conducted hydraulic and heat transfer testing to support operation of the reactors at the Savannah River Plant.
I also performed safety limit calculations an.d participated in the development of analytical models for use in transient analyses at Savannah River.
My tenure at SRL was from June 1967 to March 1974.
From September 1965 to. June 1967, while in graduate school, I taught courses in thermodynamics, statics, mechanical engineering measurements, computer programming and assisted in a course in the history of engineering.
During the summer of 1966, I worked at the Savannah River Laboratory doing hydraulic testing.
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