ML20155H160
| ML20155H160 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/07/1988 |
| From: | Selleck K ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#488-7256 OLA, NUDOCS 8810180285 | |
| Download: ML20155H160 (19) | |
Text
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4 pgiED CORREsr0NOMM U??!. lip c%
Filed:
October 7, 1988 UNITED STATES OF AMERICA P3 :45 Crt o NUCLEAR REGULATORY COMMISSION 00Cni;gf.
,!I 31; :. js,.
before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
Docket No. 50-271-OLA VERMONT YANKEE NUCLEAR
)
(Spent Fuel Pool POWER CORPORATION
)
Expansion)
)
(Vermont Yankee Nuclear
)
Power Station)
)
)
FURTHER ANSWERS TO INTERROGATORIES Pursuant to 10 C.F.R. 5 2.740(f) and this Board's Memorandum and Order of September 27, 1988, Vermont Yankee Nuclear Power Corporation ("Vermont Yankee") hereby submits its Further Answers to Interrogatories Nos. 5 and 6 of the set thereof propounded by NECNP on August 3, 1988.
FURTHER ANSWER TO INTERROGATORY NO. 5:
1.
The answer previously given by Vermont Yankee to this inquiry, to the effect that Vermont Yankee intends to have the proposed Emergency Standby Cooling Sub-system designed, installed, tested and operational prior to the time when it desires to store more than 2,000 spent fuel assemblies in the spent fuel pool, but that it has no more detailed schedule for accomplishing this effort, is now, and GP10180205 881007 A
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i was at the time given (August 16, 1988), both true and complete.
Installatior. prior to exceeding 2,000 assemblies is still the only firm milestone date for accomplishing this effort.
2.
In fact, in the ordinary course, a detailed definitive schedule for a project of this magnitude could not be prepared until after certain steps have been taken, such ao the proposal and approval of funding for the detailed design of the project (as distinct from the conceptual design, which has already been accomplished), the preparation of the detailed design, approval of capital authorization for the project once the final parameters are known for certain, determination of equipment lead times, and coordination of installation with plant operations.
Vermont Yankee's final determination to undertake this project is also dependent upon resolution of these proceedings, issuance of the i
proposed liennse amendment, and issuance by the NRC Staff of an SER concluding that the project resolves all outstanding l
issues and concerns relevant to the adequacy of the VYNPS spent fuel pool cooling system.
While Vermont Yankee understands the Staff to be of that opinion, the SER has not been issued yet, and if for any reason (though none can be foreseen) this proposal were not acceptable, then Vermont Yankee would most likely propose some other course of action.
consequently, the determination by Vermont Yankee to implement the proposed enhancement to the spent fuel pool
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cooling system is as yet conditional, and rio detailed schedule is in order in the ordinary course.
3.
Because the proposed addition involves no new technological issues, because the conceptual design of the system has already been done, and because, therefore, imple-mentation of the proposed addition is considered straight-forward and the lead time to accomplish it is conservatively bounded with some degree of confidence, Vermont Yankee knows that there is no present imperative either to begin the efforts required to implement this addition, or to adopt definitive schedules therefor.
4.
Because Vermont Yankee presently has authority to store up to 2,000 spent fuel assemblies in its spent fuel pool, and because the purpose of offering the proposed enhancement was to moot the contention offered in opposition to a request to increase this inventory limit above 2,000 spent fuel assemblies, Vermont Yankee believed that its commitment was adequate to moot the contention if stated in terms of system implementation completed prior to the storage of more than 2,000 assemblies.
This is how the commitment is framed in Vermont Yankee's letter to the NRC Staff dated March 2, 1988 (FVY 88-17) and reiterated in Vermont Yankee's letter to the NRC Staff dated June 7, 1988 (FVY 88-47).
)
5.
The discussion between Mr. McElwee and the NRC Staff that occurred during the meeting of February 9,
- 1988, 1
I to which the Board has made reference in its Memorandum and f
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i Order of September 27, 1988, is in no way inconsistent with the foregoing.
What Mr. McElwee outlined for the Staff was a feasibility analysis for completing implementation of the proposed addition prior to the storage of the 2,001st spent fuel assembly in the spent fuel pool.
The purpose of this presentation to the Staff was threefold: (1) to denonstrate that the proposed addition was a feasible solution to the problem, (ii) to show that design, implementation and testing d
could be accomplished prior to storage of more than 2,000 assemblies, and (iii) to make clear to the Staff that Vermont Yankee did not intend implementation of the proposed addition until the Staff has concurred that the proposal effectively resolved or mooted concerns previously expressed.
(In that respect, we point out that, contrary to Vermont Yankee's expectations at the time of the February meeting, conceptual design was accomplished prior to receipt of the SER, and the results of that effort were eventually submitted to the Staff, with copies to the parties, on June 7, 1988.)
Mr.
McElwee projected gen 3ral milestones first in his presentation in terms of plant cycles and then in response to a Staff question in terms of estimated earliest possible dates.
Plant cycle lengths vary according to plant operating history.
Mr. McElwee did not state then, nor has it ever been the position of Vermont Yankee, that such a series of I
general milestones had been formally established as the Vermont Yankee schedule for implementation of the addition.
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i In fact, it is the present expectation of Vermont Yankee that, once the acceptability of the proposed addition has been settled, a detailed schedule will be formally established, and it is the further present expectation of Vermont Yankee that, in the ordinary course of conservative business planning, such a schedule would aim to have the proposed addition fully implemented some time before it would actually be needed to authorize the storage of the 2,001st
]
spent fuel assembly in the spent fuel pool.
a 6.
As the Board has noted, both Mr. Reid (who signed
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the prior answer to interrogatories) and one of counsel for Vermont Yankee were present at the meeting with the Staf f.
The prior answer was prepared or reviewed, as the case may be, with the recollection of what transpired at that meeting in mind (but without actually reviewing the transcript).
Since receipt of the Board's Memorandum and Order of 4
Septe:dber 27th, Vermont Yankee has reviewed the transcript, i
I and it can see where the language attributed to Mr. McElwee on pages 19-20 is susceptible of being misinterpreted if taken out of the context of the Vermont Yankee presentation, so as to suggest the possible existence of detailed schedules.
In fact, there is no inconsistency betwoon or j
among Mr. McElwee's presentation, Vermont Yankee's prior answer to Interrogatory No.
5, and the facts.
l 7.
With respect to Table A-2 of Vermont Yankoo's submission of June 7,
19P0, Vermont Yankee respectfully l
1 refers the Board and parties to the second column (entitled "Normal Refueling Discharge: Number of Bundles in Pool").
As shown there, availability of the enhanced cooling sub-system would not be required to support the offload into the spent fuel pool and the restart of the reactor until after Cycle 16.
Following Cycle 16, the spent fuel pool inventory would be less than 2,000 assemblies, but not by enough to support an additional 1/3 of the core for one more refueling.
It was on this basis that Mr. McElvee equated the end of Cycle 16 with the completion of the proposed additions.
That the two statements have always been considered to be equivalents is reflected in the use of both in Vermont Yankee's letter to the NRC Staff dated March 2, 1988 (FVY 88-17).
8.
Vermont Yankee was aware of the fact that, if it were assumed that a full-core offload might be required following Cycle 15, and if at that time the enhanced cooling system has not yet been made operational, the entirety of the core could not be placed in the pool without additional authority.
In such event, which Vermont Yankee deems unlikely, one of the coursos of action open to Vermont Yankee would be to seek temporary authority, on an emergency basis, to store more than 2,000 assemblies in the pool temporarily.
If such a request were to be made, the justificLclon for it would be that, if one assumes a full-core offload, then under this scenario there is no potential for restarting the reactor (until either 2/3 or 3/3 of the core has been taken 6-l
i out of the spent fuel pool and returned to the reactor) and i
i hence there could be no claim that any use of the RHR system to enhance spent fuel pool cooling impairs redundancy, since by definition in such circumstances there could be no need of k
any portion of the RHR system to cool the reactor.
Another 1
l alternative would be to keep the core in the reactor until j
all requirements for storage of more than 2,000 assemblies 1
had been met, recognizing that this course of action could prolong the outage.
j 9.
For the foregoing reasons, the truthful and l
complete answer to Interrogatory No. 5 as propounded on August 4, 1988, is exactly as set forth in Vermont Yankee's i
i answer to it filed August 16, 1988.
Any other answer to that i
question would have been then (and would be today) not j
accurate.
If Vermont Yankee had known at the time that I
a n s wt.
was prepared that it was necessary to dispel any 4
possible misinterpretations of the February 9th transcript, it most likely would have added to its response the substance j
of what is contained in this further answer, but the answer
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as given would have remained, as set forth, that Vermont Yankee does not (at the time the original answer was prepared, or today) have any more detailed schedule for the implementation of the proposed amendment and does not foresee 1
establishing uny such schedule until at least after the
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publication of the Staff's SER and most likely the completion i
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of these proceedings.
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FURTHER ANSWER TO INTERROGATORY NO. 6:
As Vermont Yankee understands the Board's Memorandum and Order of September 27, 1988, the question to which it is to respond is the extent to which the proposed addition to the spent fuel pool cooling system is or is not "identical" to t
such additions at other plants.
See Memorandum and Order 1
at 10.
j vermont Yankee has undertaken no detailed assossment of the spent fuel pool cooling systems at other plants, but is t
generally familiar with che techniques employed at other
[
]
plants to accomplish spent fuel pool cooling.
Based on this I
j information, Vermont Yankee further responds to this 1
{
interrogatory as follows:
1.
Vermont Yankee is not aware of any plant that has proposed an onhancement to its spent fuel pool cooling system that is identical to that proposed here.
Vermont Yankee is aware of various other systems which increase spent fuel pool I
i 1
heat transfer capacity, but not in the manner of Vermont i
i Yankee's proposal, as an omorgency standby system.
i I
2.
From the foregoing, it follows that Vermont Yankee I
l has no information about the specific equipment used in any 1
other such proposed enhancement.
As to the inquiry regarding "heat transfer capacity of the equipment, number of fuel 1
(assemblies) to be cooled" (Memorandum and Order at 11),
Vermont Yankoo has not made those specific comparisons.
Vermont Yankoo believes on the basis of general information
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-VERMONT 'IANEEG POWO P+
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= 27 e. w: e as a m that the Tech spec limitation on spent fuel pool bulk temperature at all awRs is in the range of 140'r to 150'F.
In september 1987 Verr.cnt Yankee complied information in the form of the matrix attached hereto, which while not specifically addressing the inquiries made here, does concern the general matter of plants recently expanding spent fuel pools.1 3.
The equipment to be employed in the proposed enhancement or the spent ruel Pool Cooling system, as contemp' lated in the conceptual design submitted on June 7, is not equipment specially designed for standby cooling systems.
It is, rather, equipment that might just as well be specified for "original" spent fuel poal cooling systems, and Vermont Yankee is not ava'e of any attribute of the equipment that is r
unique to the fact that, in this application, it will be employed in connection with an additional set of cooling 1
loops, to achiava enhanced heat transfer capacity.
4.
Vermont Yankes believes that the above information answers, as best it can, the interrogatory as interpreted in the soard's Memorandum and order.
I Donald A. Reid i
l 1
As to bulk tosperature, see Attachment page 2 (Nine Nils Point) which notes 125'T.
Vermont Yankee has not determined whether this is a Tech spec or Admin limitation.
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-VERMONT YAMMEC POWER PO2
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007 27 '59 15 52 R^>Es & W Y State of Vermont county of Windhan Then appeared before u.e the above-subscribed Donald A.
Meid and made oath that ha is authorised to execute the foregoing further answers to interrogatories on behalf of Vermont Yankee, that he made inquiry and bo11 eves that the foregoing further answers accurately set forth such information as is available to Vermont Yankee.
Qu$$0.NatdJ doMry Public My com:nission expires A//o/f/
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Float hereck Metrtu Emergency New Type /Ceemercist Mete =p Reptrement Fleet Operetten Bereck SES Setemic FPC Capabilitsee (Ser)
Ut11 tty Contact
- Coment e Creed Cett aart/95 S/M Tee fee Yes e Peel temperetare of 140*F rep tred.
(netL)
(IDor sad DC
( M itScatten a
fechnical Specification en limit of use tass)
Sept s ed) of augmented 808 for 30 doye.
e Techstest Spectiteettee na temperature when escoedleg 140*F.
e Witt propose FPC MDD in three te (two years for Cyclee 13-15 sad beyond.
o Emergency precedures for EDOF and single fettere of DC in place metag homes from ftre truck.
Feech Setten Bam/74 2/M me Yes No e
150*F poet temperature accepted.
IFhttedelphie (Three e Sparsere cut three to four feet below Ctectric)
Traine) water tewel.
e Ideettiled scene of coeting poet melag BBCCW BTeach. In emergency by manuel ceanett1one.
e Severet hard-piped meene of emergency make g ideettiled re p tring menuet actlene.
Millete.e If
- ts/h t/86 Tea Tee Yee e foot temperature of 140*F reptred.
tuusCO)
(Techetcet e Techancet Specificetten change re ptring SpecifIcettem 28-der decay prter to eter up.
e Changes )
e With Techalcel SpectfIcetton change, meet Ser re ptrements.
-t-21217/t.359
- Individuals' nataes and telephone numbers are redacted.
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I Plant Berock Metria (Continued) l Emergency New Type /Ceemercial hkeep kegatrement Fleet Operettee Bereck SER Setamic FFC Cep bllittee
{58P)
Utility Coatect emt e Trojas Pts /TS 4/84 No Yes Tee e Be wired procedure for emerseecy makeup I
(PGLE)
(Frecedures) to pool emetag solemic Su tie-in.
)
e Showed only needed BSS for full core etflead.
j e
Shortened opersere appronlantely elskt feet below meter level.
e ASLB heartage efter rereck offirmed j
license amendment.
e Beck tapect enjer hearing obetacle.
Meath Amme Pte/FS 12/84 No Tee No e
Bewe esperate Fuel Storage Buildlag with i
(TEFCO) cepobility to make up using itre meine.
e Emergency preceduree la place end wethed j
dcwn for makeup metag hard pipe from ftre d
asia. Avellable after solemic eventi eene ameseI actIone ao pired.
Nine Mlle sam /69 2/54 Tee fee les e Eeep peel tgratiste <!2SOF for both relet aeruel effleed (eme trata) and ebeoreal Cleears lead (two trelse).
Nhowk) e Will met commeece effleed malese FFC to able to keep temperature al2%*FI regskred if SW islet temperature is bisher then 90*F used in emelyele.
e Beergeecy makeup evellebte from two separate supplies, one of which to not hard piped. No special procedures were regstred.
e No ama tie-ia evedlebt.t. 2721T/1.159
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Fleet Sereck Metria (Contimurd)
Emergency Iseu Type /Cammercle!
Meteep Requireerst Fleet Operettee Bereck SER Setemic FPC Capabilities (Sar)
Utility Contact Ceemente leew plant uhtch rersched prior to poet St.imcte il res/83 10/94 See r % ge see ce te See Commente e
usaget met SRF for deelga for origine1 (FPGL) licemee.
e St.lmete I submittet et Inc nou.
Do not empoet to eene any modificettone (one trole of FFC le seismic).
e Tethey relst in upgrading their FFC due to rerecht in heartate.
11/S4 Yes Tee Tee e
Sun to heet lead for full core offlood.
Clems rum /79 (acLE)
((kne Trein)
Comp. Coollag Deedificetten Technical Speelficettee requires 11-day and Backup Required) decay prior to effleed of full core.
Skid and e stadtficet tene to be cglete le 1986 of Pump eeceed. solemic train of FFC uhtch allt i
delete eheve requirement.
e Use IS0*F Techalcel Specification limit with statement that sewee hours to l
get bechup coelleg timed tey; no requirements for shutdous.
Required emergency procedure in piece e
for emergency asheep males hoees, etc.
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2721T/1.159
I Pfant mereck Natrie l
(Coat loued)
Emergency New l
Type /Ce mercial hkeup Re ptresset Plant Operetten Se7ect SEE Seteele FPC Capabillttee (Sar)
UtRItty Contact F-t e Ocemee 3 Fle/74 9/83 Stet Me See Commente e Upgraded FFC to third trale due to (D=he )
Completely Specific (feedif icat tes bellies emetyste. Were limited to (Three Precedure Beaguired) erfglmet assembly locattene sentti operede Tratme) flaalleed, somever, it mee a utility deelstee for upgrade.
i e les peat temperatore Itatt to Technicet Specificettee but met Sar vetime of 1MP*F.
e setemic makeup to aweitable to pool by hard-ptped lines from BWST tank.
1 i
strCetre res/51 9/94 Yes Se
- at h
e Bedundant seleele reset poet cooling.
( Disk e )
e Itakeup cepobility avellable.
Origlmel deelse met SAP reepste m te.
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Oyeter Creek EWE /69 9/04 Yee fee he e FfC tretes seleelc prior to rerack j
(CPU)
(The Traines euhoittel.
e Emergency askeup procedure to place prior to eidmetttet.
e Only enjer toews mes seleele analyste of rerke.
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- 1 272tT/t.149 i
Fleet Eersch stetrp (Coatlamed)
Emerseecy stew I
Type /Cossorcial Nkeup Re ptreamet Fleet Operetten Berect SM Selsele FPC Capabilities (SRF)
Utility Centact Ceemente Celeert Cliffe Pts /FEFF S/82 Yee Tee Ile e h e redendent trales of solemic FFC.
t I and Il e
Amelyste ehe=e peel <t25'F.
(DG&E) e Seerseecy enheup identitled.
Yeobee Fleet FtEl&l Does la Its Sedundant 3/.
e Bereck does le stagee (i.e.. Criticality.
(TAFI)
Stagee Itoaselselc T-5. Itech. etc., embelttele ePl oest la 78-42 System separately ever a nWr of years).
e Seelge change in 1978 provideas a persement Sedundant Coelleg System (nomeeleelc ).
e Frier to thle endtficettua. se bechup une ewellebte durles shutdoue.
Farley i Pts /FFESI 4/93 fee Yes Its e h e tralee of solemic FFC.
l one il 6/82 o steheup capebility eseured by procedure.
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(5C5) e sent elegte fallere criterten of saF.
27217/t.139
~
Fleet Rereck htrtu (Coatloved)
Emergency New Type /Co m rctel htsur Se p trement Fleet Operettes terwk SER Setemic FPC Capabilities (SSP) 9ttlity Contact Commesto quad Cttlee I sum /73 4/82
, no Yes Ise e Dif fener cut three to ela feet below (Comme Edmoee)
See r-et unter level, e sewlew dose to early 19003 e Techalcel W ification changes made for Sar rew iremente.
o h ionic FFC System.
e Emergency makeup mees BSR crece-tte.
Scumswick 2 am/73 12/83 Yee moe.
me e Tehe credit for aan for ebesrael heat (CPEL)
(Two Tretes) Procedural-leade.
Imed e
- u with two selsele trelas of FPC that band adopete coetteg.
e Du!! ding Icede were mejor leC teaue.
Ft. Catheue FW/74 9/5)
Yes Yes Yee e
Septred emergency meteep capahtlity.
(m (YW Pumpe.
(Mud!!!cattee Itselficettee done to hard pipe crose-tie Pe%3tc Feuer)
One Et Es)
Rep tred) to peel from Safety lejection System.
e Caesidered usieg hoses, etc.. but mot poselble.
e root temperature llelt to 160*Ft sascherged by rereck.
4-27287/t.159
Fleet Retect Statrie (Cest iemed )
Fmergency see.
Type /Co-oretel Makeup Begelrement Fleet Operettom Berect SEL Setemic FFC Capabillttee (ESF)
Utlitty Centact Comente als Sect Bbs/63 10/04 Yee Yes Tee e
Amoedmont greeted subject to e few retet (la Cent)
(Ptediticettee conditlemo/mediticettees.
(Co - re Sept red) e B.getred reentely operated emergency Pomer) makeup time for poet (14CA emelpels).
e Zirceley/steen reacties semitted !=
heerlage. bet dismissed due to modification co miteest.
Arbenees Pte/T4 4/81 No Nome Me o
Did met meet corrent SSF criterle, only sancleer One Frecedural-showed compliance with FSAR requiremente.
and Two laed e Demeelante FFC-calculated boll-of f slee (Arkenees of leet med stated that, la that tier Feuer med Light) frame, makeup would be prowlded metag hosee, etc.
feelee Teatee Fta/F2 4/04 Yes Tee no e
FFC Systeen solemic. bet est (14f AF)
See Ceemente See r-t e afgle-fellere proof.
e Shoued time to boil med capability for meheep to that time frees.
o steheep pathe identified for rereck but de met seem to be precederelleed.
e Both hard-piped llees med tee ry meses evellable.
-1 27217/l.159
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' $[y'YN-123 ASLB Reg. Mail KGCOSR3.VY CERTIFICATE OF SERVICE 68 T 12 P3 :46 I,
Kathryn A.
Selleck, hereby certify th c o n c.:. s
-j October 7, 1988, I made service of the within docusent-iN,
j accordance with the rules of the commission by mailing a copy thereof postage prepaid to the following:
Charles Bechhoefer, Esquire, David J. Mullet, Esquire Chairman Vermont Department of Administrative Judge Public Service l
Atomic Safety and Licensing 120 State Street i
Board Panel Montpelier, VT 05602 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Glenn O.
Bright Ellyn R. Weiss, Esquire Administrative Judge Harmon & Weiss Atomic Sa23ty and Licensing Suite 430 Board Par.el 2001 S Street, N.W.
j A
U.S.
Nuclear Regulatory Washington, DC 20009 i
Commission i
j Washington, DC 20555 1
l Mr. James H.
Carpenter George B.
Dean, Esquire l
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Department of the Attorney 1
Board Panel General U.S. Nuclear Regulatory One Ashburton Place Commission Boston, MA 02108 l
Washington, DC 20555 Adjudicatory File Ann P. Hodgdon, Esquire Atomic Safety and Licensing Office of the General Counsel
]
Board Panel Docket (2 copies)
U.S. Nuclear Regulatory
]
U.S.
Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Geoffrey M. Huntington, Esquire l
Appeal Board Panel Office of 4no Attorney General U.S.
Nuclear Regulatory Environmental Protection Bureau Commission State House Annex l
Washington, DC 20555 25 Capitol Street l
j Concord, NH 03301-6397 l
I l
filla yhtfEyn'.~Selleck A
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