ML20062H583

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Affidavit in Support of Summary Disposition of Jf Doherty Contention 38B Re Cold Shutdown within 24-h.Reactor Can Achieve Cold Shutdown in Less than 24-h.Prof Qualifications Encl.Pp 253-260
ML20062H583
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 07/29/1980
From: Fray J
GENERAL ELECTRIC CO.
To:
Shared Package
ML19331C559 List:
References
ISSUANCES-CP, NUDOCS 8008190198
Download: ML20062H583 (8)


Text

O V:iITED STATES Or AMEaICA fiUCLEAR REGULATORY CCtHISSI0tl e

BEFORE THE ATOMIC SAFETY A'lD LICEftSIrlG BOARD In the 'G tter of HOUSTO'l LICHTIilG S POWER CCMPAllY

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Occket tio. 50-466 (Allens Creek fluclear Generating

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Station, Unit ilo.1)

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I AFFICAVIT OF JOSEPH FRAY State of California f

County of Santa Clara I

I, Joseph Fray, Principal Licensing Engineer, within the Safety and Licensing j

Coeration of the General Electric Company, of lawful age, being first duly sworn, upon my oath certify that the statements contained in the attached pages and accompanying exhibits are true and correct to the best of my knowledge and belief.

l Executed at San Jose, California l

July 29,1980

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s Subscribed and sworn to before me this 29 day of July, L9 0.

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8008190190 4

I UNITED STATES OF Zd'. ERICA NUCLEAR REGULATORY CO:OiISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAD In the Matter of S

S HOUSTON LIGHTING S POWER S

COMPANY S

S Docket No.53-466 (Allens Creek Nuclear S

Generating Station, Unit S

No. 1)

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Affidavit of Joseph Fray My name is Joosph Fray, I am employed at General Electric Company as Principal Licensing Engineer.

I served in this capacity for two years.

A statement of my e::perience and qualifications is set out in Attachment 1.

This affidavit addresses Coherty Contention No.

j 38(b) which alleges that the ACNGS reactor cannot be brought to " cold shutdown" within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.~1/

The phrase ":old j

l shutdown" means that the reactor coolant temperature is f

below 212 ? at atmospheric pressure and the reactor mcde 1

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Item 2.2.3 of NUREG-0579 recommended revisions to Technical Specifications which would require that "the reactor be placed in a hot shutdown condition within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and in a cold shutdown condition by licensee within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of any time that is found to be or to have been in operation Chis recom-with a complete loss of safety function.

mendation in NUREG-0578 is a proposal for an administrative penalty upon loss of a safety system (NUREG-0579 a: A-63).

The only import of this as yet unadopted recommendation is l

whether or act the ACNGS design has the capacity ta bring the reactor from the state of full operation (normal condi-tions) to a cold shutdown.

As discussed infra, the ACMGS design has a cooldown capacity far in excess of this re-quirement.

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switch is in the shutdown position.-2/

The initial phase of nuclear system cooldown for ACNGS is accomplished by dumping steam from the reactor vessel to the main condenser.

When nuclear system pressure has decreased to a point where steam supply pressure is not sufficient to maintain the turbine shaft seals, vacuum in the main condenser cannot be main-tained and the Residual Heat Removal (RHR) System is started to complete the task of placing the reactor in cold shutdcwn.

The RHR system has several modes of operation, but the mode of concern to achieve cold shutdown is the Shutdown Cooling and Reactor Vessel Head Spray mode.

In this mode, reactor coolant is pumped from the recirculation loops by one of the RHR pumps and is discharged to one of the RER heat exchangers where cooling occurs by transferring heat to the service water.

The RHR heat exchangers are sized for l

operation in the RHR mode of Suppression Pool Cooling following a Loss of Coolant Accident (LOCA).

Because the heat load is 1

much greater for this mode than for Shutdown Cooling, the RHR system is considerably oversi cd for achieving a normal cold shutdown condition.

To determine the effectiveness of the ACMGS design to achieve cold shutdown, decay heat load

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must be determined.

The maximum decay heat load af ter 2/

Cold shutdown is defined by SUREG-0123, "BWR Standard Technical Specifications," Table 1.2. 255

l reactor shutdown calculated for ACNGS is derived from the 1971 American Nuclear Society formula as required by 10 CFR 50, Appendix K. ~3/

Using this decay heat load, General Electric has determined that the main condenser will cool the system to a temperature of approximately 344*F at 110 psig in two hours.

The system is maintained at this tempera-ture and pressure for an additional two hours while the R3R system is flushed with reactor grade water.

At this point, i

one loop of the RHR system is placed in service.

At this 6

l time the heat load is 284.6 x 10 BTU /hr and decreasing.

With the temperature difference between reactor coolant and 4/

service water that exists at this time,-

one RHR heat exchanger is capable of removing approximately twice the amount of heat being generated.

Based on analysis for comparable heat exchanger systems used on BWRs, the RER system is fully capable of achieving a reactor coolant temperature of less than 212*F in seven hours with two hours conservatively allowed for flushing of the RHR system.

Significantly, only one loop of the redundant RHR system is 3/

As an extra measure of conservatism, Appendix K requires that an additional 20% heat load be added to the decay heat load determined by the ANS formula.

4/

Service water is assuned to be 95*F, thereby making the difference in reactor coolant and service water temperatures equal to 249"F. 256

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i il needed to achieve v.his cooldown rate.

Thus, even assuming any single failure in one of the Pl!R cooling loops, the AC:iGS reactor can achieve cold shutdown in much less than 44 y

hours.

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257

i ATTACHMENT 1 t

EDUCATIC::AL AND PROFESSIC:!AL QUALIFICATIC::S JCSEPH FRAY PPlNCIPAL LICENSING E:GINEER NUCLEAR ENERGY EQUIPME!iT CEPARTMENT I

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,0 GE:rEPE ELECTPlc COMPA'IY

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1 My name is Joseph Fray. My business addrers is General Electric Company, 175 Curtner Avenue, San Jose, California; and I am employed by General Electric Company.

I am presently a Principal Licensing Engineer, a position held since J

June, 1978 and in this capacity I am responsible for all licensing activities associated with several projects.

I graduated frca the Faculty of Technology, Manchester University (England) with the A.M.C.T. degree in Electrical Engineering in 1946.

In 1963 I obtcined a Higher National Certificate in Pure and Applied Physics at the Harris Technical y

l College, Preston, England.

In 1961 I ccepleted the full-time reactor physics i

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course held at the Royal Technical College, Salford.

In the United Kingdom I am professionally qualified as an Electrical Engineer (C. Eng. M.I.E.E.) and a Physicist (M. Inst. P. ).

I am licensed as a Nuclear Engineer in the State of i

California.

Following work in a junior capacity with a utility engaged in electrical power distribution, I joined the Central Electricity Generating Board in 1943 as a General Assistant Engineer in the technical section at Manchester, England.

Curing the subsequent ten-year pericd, I progressed frca General Assistant Engineer to Regional Technical Engineer in a regicn cenprising eight cower stations and numerous EHV transmission substations. The work of the technical section 258

4 consisted of preparing all test proceduree and conducting the startup tests for i

all new generating plant and transmissior equipment within the region.

i In 1958 I joined the United Kingdem Atomic Energy Authority as the Werks Electrical Engineer at the Chapeleross nuclear power site in Annan, Scotland.

In this capacity I was responsible for the startup testing and routine 1

maintenance of all electrical equipment asacciated with the four gas-ccoled reactors at the site.

I transferred to the Industrial Powc-3 ranch of the Atomic Energy Authority at Risley, Warrington, England in 1960 te verk on the design of power reacter f

control systems. Frca 1960 to 1968 I war engaged on the study of reactor core performance and analysis as related to cc.,. trol systems both for magr.cx reactors and the advanced gas-cooled reactor concept. Curing this period I spent nine

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months in 1963 on the startup physics testing of the prototype Advanced Gas-Cooled Reactor at Windacale.

f I have served as a part-time lecturer in Electrical Engineering at the Blackpool Technical College and also as a lecturer on reactor cor. trol at the G

Calder Hall Operations School at Windscala.

I joined the Cencral Electric Company at San Jose in 1968 in the Field Engineering section. I was temporarily assigned to the Licensing and Safeguards Unit where I was employed in the preparation cf Technical Specificatiens for the Tarapur and Brown's Ferry plants. Subsequently, I worked en the preparation of the startup test procedures for the Cresden 2 plant, later going to that site as Lead Engineer responsible for implementing the startup test program. Cn return frca the Cresden site I compiled the startup test report for that plant and worked on the preparation of several sections of the General Electrie

uclear Engineers Manual.

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I returned to the Safety and Licensing Cperation in 1971 where I undertcok responsibility for the licensing of the Hatch 1 and 2 plants. In addition, I i

was responsible for the initial developnent of the SWR Standard 2echnical l

Specification Review Group in 1975, and represented G2 in all the associated review activities. Subsequently, I have been responsible for all licensing, development and preparation work related to technical specifications fcr G2 a

donestic and overseas projects.

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