ML20235V478
| ML20235V478 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 02/28/1989 |
| From: | Paul Bergeron, Hansen C, Herron J, Reid D, Thayer J VERMONT YANKEE NUCLEAR POWER CORP., YANKEE ATOMIC ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20235V455 | List: |
| References | |
| OLA, NUDOCS 8903100203 | |
| Download: ML20235V478 (21) | |
Text
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UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COMMISSION before the
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j ATOMIC SAFETY AND LICENSING BOARD i
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In the Matter of )
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VERMONT YANKEE NUCLEAR ) Docket No. 50-271-OLA POWER CORPORATION )
) (Spent Fuel Pool (Vermont Yankee Nuclear ) Expansion)
Power Station) )
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Sworn Written Testimony of Donald A. Reid, John T. Herron, Jay K. Thayer, Christopher H. Hansen, and Paul A. Bergeron, Submitted by Vermont Yankee Nuclear Power Corporation Pursuant to 10 C.F.R. 5 2.1113(a)
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Pursuant to 10 C.F.R. f 2.1113(a) and this Board's Memorandum and Order of January 12,1989, the Licensee, Vermont Yankee Nuclear Power Corporation, submits the within sworn written testimony of Donald A.
Reid, John T. Herron, Jay K. Thayer, Christopher H. Hansen, and Paul A. 1 Bergeron, in support of its position that Contention 1 in this proceeding is without merit. l 8903100203 890229 i DR ADOCK 050 1
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I. Identification of the Witnesses l
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Mr. Reid is employed by Vermont Yankee Nuclear Power Corporation and is Operations Suppon Manager. He holds a Bachelor of Science Degree in Mechanical Engineering and is licensed as a Professional Engineer in the State of Vermont. Mr.
Reid has 14 years experience in the nuclear industry at Vermont Yankee, where his positions have included Engineering Support Supervisor, Technical Services Superintendent, and Operations Superintendent.
Mr. Herron is employed by Vermont Yankee Nuclear Power Corporation and is Operations Supervisor. He holds a Bachelor of Science degree in Business Management. Mr. Herron has 16 years experience in the nuclear industry: 10 years at Vermont Yankee plus 6 years in the United States Navy Nuclear program. He has held such positions as Reactor Operator, Senior Reactor Operator, Shift Supervisor, and Technical Program Manager. Mr. Herron currently holds an NRC-issued license as a Senior Reactor Operator at Vermont Yankee.
Mr. Thayer is employed by Yankee Atoraic Electric Company and is the Engineering Manager for the Vermont Yankee Project. His responsibilities include direction of a staff of approximately 30 engineers, who perform design changes and engineering reviews and evaluations covering all aspects of plant design, modification, maintenance, licensing, and outage support. Mr. Thayer holds a Bachelor of Science degree in Electrical Engineering and has worked in the nuclear power field for 15 years, including operations and engineering positions at several pressurized weter and boiling water reactors throughout New England.
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Mr. Hansen is employed by Yankee Atomic Electric Company and is a Senior Engineer assigned to the Vermont Yankee Project. His responsibilities include Spent Fuel Pool Cooling system design and analysis. Mr. Hansen has 15 years experience in nuclear electric power generation stations and 6 years experience as a United States Navy Nuclear Propulsion Plant operator. Prior to joining Yankee Atomic Electric Company, Mr. Hansen was employed by Stone & Webster Engineering Corporation, I
l where he was responsible for initial plant design of various nuclear systems and '
equipment for the Beaver Valley Nuclear Power Station, Unit 2, including spent fuel l pool cooling, fuel pool liners, fuel elevator and the reactor containment liner. During plant construction, Mr. Hansen was assigned to the Beaver Valley Nuclear Station, Unit 2 site Engineering Office, where his pdmary responsibility was the installation of the NucIcar Steam Supply System equipment and its interface with the balance of plant systems.
Mr. Bergeron is employed by Yankee Atomic Electric Company and is the Manager of the Transient Analysis Group in the Nuclear Engineering Department. His responsibilities include direction of a staff of 15 engineers who perform steady-state and transient thermal-hydraulic analysis of nuclear systems in support of the Yankee plants. Mr. Bergeron holds a Bachelor of Science degree in Mechanical Engineering and a Master of Science degree in Engineering. He is licensed as a Professional Engineer in the State of Massachusetts. Mr. Bergeron has 19 years experience in the nuclear industry and 15 years at Yankee Atomic Electdc Company. Prior to joining Yankee Atomic, Mr. Bergeron was employed at the Knolls Atomic Power Laboratory where he was responsible for the thermal-hydraulic analysis of Naval Reactor systems.
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II. Spent Fuel Pool Cooling at Vermont Yankee The Vermont Yankee spent fuel pool contains those fuel assemblies that have been removed from the Vermont Yankee reactor after use in the reactor as fuel. Spent fuel assemblies continue to generate a comparatively low level of heat following the shut-down of the nuclear reaction, which heat is commonly referred to as " decay heat". The function of the spent fuel pool cooling system is to remove this heat so as to maintain the water in the spent fuel pool at or below a given temperature.
To eliminate any confusion regarding the cooling systems that are required during the various modes of plant operation, the following describes the cooling functions relating to spent fuel both during reactor operation and during refueling.
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A. The Mechanics of Refueling The Spent Fuel Pool (SFP) is a water-containing vessel located adjacent to the reactor cavity. Joining the SFP and the reactor cavity is a canal, the floor of which j is above the top of spent fuel in the pool. (Plan and elevation views of the spent fuel pool, the reactor cavity, and the refueling canal are contained in the " Vermont Yankee Spent Fuel Storage Rack Replacement Report", dated April,1986, as Figures 1-1 and 1-2, respectively t.) While the reactor is operating, the SFP and the reactor are separate fluid systems, each serviced by separate cooling systems.
The cooling system dedicated to the spent fuel pool is known as the " Spent Fuel Pool Cooling System" and the cooling system that cools the reactor during periods of shutdown is known as the " Residual Heat Removal System" ("RHR").
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Refueling of the plant requires the following steps: First, the nuclear reaction is shut-
, down by insertion of the control rods. As the temperature and pressure of the reactor coolant decreases, one train of RHR is started to remove decay heat from the
) fuel assemblies in the reactor. Once the reactor is cooled, the head is removed from the reactor vessel. The level of water in the reactor is then increased to fill the reactor cavity and the canal, which are located directly above and become an
. extension of the reactor fluid system. The gates in the canal separating the reactor l
cavity and the SFP are then removed, thus joining the reactor, reactor cavity, canal, and SFP into a single fluid system. It is by this means that a spent fuel assembly can be removed from the reactor and placed in the SFP while being kept continuously under water.
As long as the reactor cavity and SFP fluid systems are joined, the RHR System, which would have been started prior to removal of the reactor head in order to remove the residual heat in the reactor, remains running. The RHR system has two trains, each with two pumps (four RHR pumps total). Either RHR train has a heat removal capacity to remove the entire heat load of both the fuel assemblies in the reactor and the spent fuel assemblies in the SFP, so that the capacity exists to allow one to shut off the SFP cooling system without affecting heat removal adequacy in either the reactor or the SFP. (The SFP cooling system is usually left on, but this is for purposes of maintaining water chemistry and visibility, not cooling capacity.)
In this mode of operation, both RHR trains are available for heat removal and either RHR train is capable of removing the full heat load. Additionally, in this mode, only one RHR pump is required to be in operation.
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j The Vermont Yankee RHR does have the design features to allow switching the suction and/or discharge point for RHR Train A to the SFP, and in this mode RHR Train A could be used to augment SFP cooling. However, the RHR has never j been used to make up for an SFP cooling system heat removal capacity deficiency p {,
) since the plant went into operation in 1972. On one occasion (in October,1985), I l
RHR Train A was aligned to the SFP, but the purpose of doing so was to facilitate I draining the refueling cavity (following a full core discharge) during the outage for j i
replacement of the reactor recirculation piping, not to augment SFP cooling heat j i
removal capacity.
J The design objective of the SFP cooling system is to be able to rer.iove the heat load I l
generated by the spent fuel assemblies in the spent fuel pool, plus the freshly discharged fuel assemblies from a normal refueling (approximately 1/3 of the core is discharged to the SFP as a result of a normal refueling), so that the reactor can be restarted (which cannot occur under the Vermont Yankee Technical Specifications l
unless both of the RHR trains are dedicated to the reactor). The discharge of more
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1 fuel assemblies to the SFP than are discharged during a normal refueling would introduce a greater heat load into the SFP than would be created by a normal l refueling. A scenario of this nature may occur to support such activities as l
maintenance or repairs to the reactor vessel pressure boundary, or in the unlikely !
event that the whole core or significant portions thereof needed replacement.
Regardless of the scenario, however, the reactor cannot be restarted (per Technical Specifications) until both trains of RHR are dedicated to the reactor and, in addition, it would be demonstrated prior to restart (by routine, periodic SFP temperature checks) that the SFP cooling system was capable of removing 6
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sufficient heat load from the SFP to maintain its temperature within Technical k
Specification limits.
B. The Existing SFP Cooling System.
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The existing SFP cooling system at Vermont Yankee consists of two pumps, two heat exchangers, and piping sufficient to connect either or both of the heat exchangers to either of the pumps. The system can operate in any of three modes:
(i) Two pumps and two heat exchangers; (ii) One pump and two heat exchangers; and (iii) One pump and one heat exchanger. The heat exchangers and piping are considered passive components, while the pumps are considered active components. Given the most critical single active failure, the configuration of the system is one pump and two heat exchangers.
In order to determine the sufficiency of the SFP cooling system, one has to know three parameters; (i) the heat removal capacity of the cooling system (in its various modes, since more than one is possible), (ii) the heat load imposed by discharged spent fuel assemblies at relevant times after shutdown of the nuclear reaction (since the decay heat generated by a spent fuel assembly decreases with the passage of time after the shutdown of the nuclear reaction), and (iii) the amount of time physically required to accomplish refueling (that is to say, the number of days of decay available before reliance upon the SFP cooling system will be required).
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- 1. Heat Removal Capacity The heat removal capacity of the existing system, in each of three possible modes of operation and at the reference temperatmes as provided in the J
Vermont Yankee Final Safety Analysis Report (FSAR) 2, has been calculated to be as follows:
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Table 1: k I
J 1 Pump,1 Heat Exchanger............ 2.23 MBtu/hr @ 450 gpm 1 Pump, 2 Heat Exchangers........... 3.56 MBtu/hr @ 450 gpm 2 Pumps, 2 Heat Exchangers.......... 4.46 MBtu/hr @ 900 gpm Note that the above heat removal capabilities are based upon a nominal inlet temperature from the fuel pool of 125*F, and a heat exchanger cooling water inlet temperature of 100*F. However, the heat removal capacity of any typical heat exchanger increases as the temperature differential between the two fluids L
increases; thus, as the fuel pool temperature increases to the limiting value of 150*F 3, the heat removal capacity of the existing system likewise increases.
This significant difference, when combined with a cooling water temperature based on actual plant operating history of 85'F 1, results in an increase in temperature differential from 25'F (upon which the values of Table 1 above are based) to a more realiwie temperature differential of 65'F. Thus, the heat removal capacity of the existing SFP cooling system at a 150*F fuel pool water inlet temperature and an 85*F cooling water inlet temperature, in the same three possible modes of operation, has been calculated to be as follows:
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L-Table 2:
) 1 Pump, I Heat Exchanger......... .. 5.7 MBtu/hr @ 450 gpm 1 Pump, 2 Heat Exchangers........... 9.1 MBtu/hr @ 450 gpm 2 Pumps, 2 Heat Exchangers........... I1.5 MBtu/hr @ 900 gpm i
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Note that the Vermont Yankee SFP cooling system (except demineralizers, which are isolable from the balance of the system and are not required to perform heat removal functions) has a design temperature of 150*F. The NRC
! has determined this design temperature to be acceptable for Vermont Yankee in its Safety Evaluation Report (SER) 4 regarding the proposed SFP expansion.
I 2. Spent Fuel Pool Heat Loads The total heat load in the SFP can be broken up into two components. One component of SFP heat load is from spent fuel discharged in previous cycles.
The other component is from fuel discharged from the most recent refueling.
Both components have been calculated using the Branch Technical Position ASB-9-2, " Residual Decay Energy for Light-Water Reactors for Long-Term Cooling", as described in Standard Review Plan 9.1.3 (NUREG-0800)5. In addition, conservative assumptions were made to predict the pool heat load from these two components. These include:
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[ a. A cumulative capacity factor of 100%.
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- b. Reactor power rating at 1665 MWt.
- c. Eighteen-month operating cycle at full power.
I A cumulative capacity (CCF) factor of 100% implies the reactor operates at its rated power indefinitely and is never shutdown for refueling. Although not possible in operation, using this assumption in calculations maximizes the fuel pool heat load for design purposes. For comparison, Vermont Yankee's CCF to date is approximately 71%.
A reactor power rating of 1665 MWt is also conservative since Vermont Yankee's current licensed power level is 1593 MWt. Assuming a rated power of 1665 MWt adds additional conservatism to short and long term heat load projections in the spent fuel pool.
The assumption of an eighteen-month operating cycle at full power is used to bound current projections of Vermont Yankee's future fuel cycles. By definition, an eighteen-month operating cycle typically includes 16 months of operation and 2 months of refueling outage. As such, using this assumption in calculations is conservative for it maximizes the fuel pool heat load by assuming full power operation during the outage when in fact no power was being generated.
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L The component of heat dissipated to the pool from the newly discharged fuel is significantly greater than that attributable to fuel discharged to the pool in previous cycles. This is illustrated in Exhibit 1. Exhibit I shows pool heat load projections as a function of time as spent fuelis added to the pool. The i
j heat load spikes represent new discharges to the pool from each successive normal refueling (136 assemblies assumed for a normal refueling). The spike
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at the end of Cycle 22 represents the heat load including a full core discharge to fill the pool to its 2870 assembly storage capacity.
The peak heat load associated with each spike occurs at 10 days after reactor shutdown. Exhibit I demonstrates that the cumulative heat load on the SFP cooling system increases slowly over time as fuel bundles are added to the SFP. The heat load peaks, corresponding to discharges to the SFP at planned refueling, drop off rather quickly as the fission products in the fuel decay.
Exhibit 2 shows this decay for both a normal ref 2eling and a full core discharge when the pool is full.
Assuming a value of 10 days since shutdown of the nuclear reaction, SFP heat loads, including the normal refueling core offload, have been calculated to be 8.12 MBtu/hr given a resulting SFP inventory of 2,000 assemblies and 9.1 MBru/hr given a resulting SFP inventory of 2,870 assemblies.
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l 3. Effect of Time Required to Accomplish Refueling i
j The number of days that are required to accomplish refueling has a significant effect on the actual amount of decay heat that is added to the SFP total heat l
l load. The decay heat generated by freshly discharged spent fuel assemblies at 10 days after reactor shutdown are often used to conservatively calculate such heat loads. It should be observed that while values of 10 days are often used for such calculational purposes to determine heat loads, an actual refueling outage requires a significantly longer amount of time to accomplish due to the physical activities that must be performed to shutdown, open, defuel, refuel, and ready the reactor for restart. Refueling outages at Vermont Yankee have historically averaged 44 days in duration and typically include,in addition to refueling the reactor, many maintenance, modification, and inspection activities.
The shortest normal refueling outage in Vermont Yankee's history was 25 days in duration, and included few additional activities of the type that would have added to the length of the outage. The shortest outages involving the movement of spent fuel in Vermont Yankee's history (not normal refueling outages ) range from l$ to 21 days. Thus the use of heat loads at 10 days after shutdown in heat load calculations provides an extra margin of conservatism.
The number of days from shutdown of the nuclear reaction required to reach the heat removal capacity of the existing SFP cooling system in each ofits three modes of operation is as follows:
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Table 3:
No. of SFAs in Days Decay to Capacity of:
Pool After Refuel 1 Pump,IHx 1 Pump,2 Hxs 2 Pumps,2 Hxs 2,000 43 6-7 3 2,870 69 10-11 4-5 l (SFA= Spent Fuel Assembly; Hx= Heat Exchanger) j Since the heat load from a normal refueling decays to the level where it can be removed by the existing SFP cooling system in a degraded mode (i.e. after any single active failure) more quickly tnan refueling can be accomplished (and therefore more quickly than the SFP system will be required to perform this function),it follows that reliance upon any additional cooling capacity will not occur. (This also explains why use of the capacity of RHR Train A to augment SFP cooling has never actually been employed.)
C. The Enhanced SFP Cooling System The proposed enhanced SFP cooling system will provide a new, independent means for cooling the spent fuel pool. The enhancement will result in the formation of two subsystems within the SFP cooling system: (i) the Normal Fuel Pool Cooling Subsystem, and (ii) the Emergency Standby Subsystem. The Normal Fuel Pool Cooling Subsystem will consist of the existing SFP cooling system as described above, and will continue to provide sufficient pool cooling to maintain pool temperatures within specified limits during refuelings (normal one-third core discharge) and plant operations. The new Emergency Standby Subsystem is described below.
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The proposed Emergency Standby Subsystem 6 would be utilized in an instance where both trains of the Normal Fuel Pool Cooling Subsystem are inoperable. The Emergency Standby Subsystem could also be utilized in an instance of high spent fuel decay heat load in the SFP, such as the addition of more than the ncrmal core i
discharge from refueling, so that both trains of RHR can remain dedicated to the reactor vessel and which in turn could allow for a more timely reactor restart.
The Emergency Standby Subsystem will serve as a standby system that can be remotely placed in operation from the Control Room, and will be designed to Safety Class 3 and Seismic Class I requirements. It will consist of two pumps and two heat exchangers which would be normally lined up as two parallel trains in a standby mode to the Normal Fuel Pool Cooling Subsystem. Each train will have a capacity of 11MBtu/hr, for a total subsystem capacity of 22MBtu/hr. It should be observed that the configuration of the Emergency Standby Subsystem will be similar to that of the Normal Fuel Pool Cooling Subsystem,in that the subsystem could be aligned in a one pump, two heat exchanger mode in an instance of failure of one pump to operate. In this operating mode, a heat removal capability significantly higher than 11MBtu/hr but less than 22MBru/hr could be achieved, the actual value of which will be determined by the final system design.
The Emergency Standby Subsystem will be designed to meet the applicable criteria set forth in Standard Review Plan 9.1.3 5. It will be designed to provide pool cooling under all licensed plant conditions, and will be located in such a manner as to prevent common mode failure from fire, flooding, or missiles. The Nuclear 16
I i
k Regulatory Commission has issued a Safety Evaluation Report 4 which concludes l
that the design for the proposed Emergency Standby Subsystem is acceptable for
- the proposed SFP expansion to 2870 spent fuel assemblies.
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III. Contention Iis Without Merit.
I-A. The SFP cooling system at Vermont Yankee meets the single failure criterion as it presently exists. As set forth above, the most demanding function that the SFP cooling system is required to perform occurs when the refueling cavity gate is installed following a nonnal refueling. The existing system, even after degradation on account of the most critical single active failure, has the capacity to remove the SFP heat load and maintain pool temperature at less than 150*F after 10 days of fuel decay, whereas the shortest normal refueling outage in Vermont Yankee's history was 25 days. Therefore, the necessity to use one train of the RHR system to augment the SFP cooling system in order to maintain SFP water temperature below 150*F does not exist by design and historically has never occurred at Vermont Yankee. Both trains of the RHR system must be dedicated to the reactor in order to commence reactor startup following an outage.
B. Additionally, Contention 1 is made moot by Vermont Yankee's commitment to enhance the SFP cooling system by the installation of an Emergency Standby Subsystem. Such an enhancement will eliminate reliance on the RHR System should both trains of the existing SFP cooling system become inoperable.
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] 14:52 FPOM Vermont Yankee ver 2!24 TO UY PPCJ BOLTON P.02 c~' d\ O w T O
Donald A.Reid I $M1 s -
J T. Herron hEv act 4.--
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Paul A.Bergeron
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Then personallyappearedDonald
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. .the foregoing statements are true, this of February,1989, before me: , made oath that
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of Vannonc Then y appearedJohn T.H n, who bein the fore gstatements are true, this of February, ;.989,gbefore first duly me: sworn, made oath that w m
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Then personally appeared Jay K. Thayer, who being first duly sworn, made oath that the foregoing statements are true, this >_2. of February,1989, before me:
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My Commission expires A>-/4 -9)-
Commonwealth of Massachusetts:
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Then personally appeared Christopher H. Hansen, who being first duly sworn, made oath that tie foregomg statements are true, this 32__ of ,1989, before me:
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My Commission expires /o-/4-9#
Commonwealth of Massachusetts:
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Then personally appeared Paul A. Bergeron, who being first duly sworn, made oath that :he foregoing statements are true, this .22 of February,1989, before me:
f Yhsa$ -Af)LL Notary Public' "
My Commission expires /O-/4 -9>
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l REFERENCES l
1 " Vermont Yankee Spent Fuel Storage Rack Replacement Report", dated April,1986 (attachment to Letter FVY 86-34, VYNPC to USNRC, dated April 25,1986).
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2 VYNPC to USNRC/ASLB," Memorandum of VYNPC In Response to Memorandum and Order of 10/24/88 and Motion for Leave to File the Same", dated November 10, 1988.
3 Vermont Yankee Final Safety Analysis Report, Section 10.5.5.
4 Letter NVY 88-223, USNRC to VYNPC, " Spent Fuel Pool Expansion Safety Evaluation" (TAC No. 69179), dated October 14,1988.
l 5 NUREG 0800, Standard Review Plan 9.1.3, Rev.1, July 1981.
6 The proposed Emergency Standby Subsystem is described in greater detail in Letter FVY 88-47, VYNPC to USNRC, dated June 7,1988.
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Ct.n i:
VYN-123 ASLB - Reg. Mail CERTIFICATE OF SERVICE D crri I, R. K. Gad III, hereby certify that an ara '
February 28, 1989, I made service of the within document in accordance with the rules of the Commission by mailing a copy thereof postage prepaid to the following:
Charles Bechhoefer, Esquire, Samuel H. Press, Esquire Chairman George E. Young, Esquire Administrative Judge Vermont Department of Atomic Safety and Licensing Public Service Board Panel 120 State Street U.S. Nuclear Regulatory Montpelier, VT 05602 Commission i Washington, DC 20555 j l
Gustave A. Linenberger, Jr. Andrea Ferster, Esquire I Administrative Judge Anne Spielberg, Esquire I Atomic Safety and Licensing Harmon, Curran & Tousley l Board Panel Suite 430 U.S. Nuclear Regulatory 2001 S Street, N.W.
Commission Washington, DC 20009 ,
Washington, DC 20555 l l
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Mr. James H. Carpenter George B. Dean, Esquire l
Administrative Judge Assistant Attorney General l Atomic Safety and Licensing Department of the Attorney Board Panel General U.S. Nuclear Regulatory One Ashburton Place Commission Boston, MA 02108 Washington, DC 20555 Adjudicatory File Ann P. Hodgdon, Esquire Atomic Safety and Licensing Patricia A. Jehle, Esquire Board Panel Docket (2 copies) Office of the General Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 Atomic Safety and Licensing Geoffrey M. Huntington, Esquire Appeal Board Panel Office of the Attorney General U.S. Nuclear Regulatory Environmental Protection Bureau Commission State House Annex Washington, DC 20555 25 itol Street C ncor , NH 033 - -e.5 %
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R '. K. Gad III g/ '
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