ML20235V668

Forwards NRC Testimony in Form of Unexecuted Affidavit on Which NRC Will Rely in Oral Argument on New England Coalition on Nuclear Pollution Contention Scheduled for 890322-23.Certificate of Svc Encl

ML20235V668
Person / Time
Site:	Vermont Yankee
Issue date:	03/01/1989
From:	Hodgdon A NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Bechhoefer C, Bright G, Carpenter J Atomic Safety and Licensing Board Panel
References
CON-#189-8216 OLA, NUDOCS 8903100277
Download: ML20235V668 (8)

Text

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-t- pun g k; UNITED STATES

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, Charles Bechhoefer, Esq. Mr. Glenn 0. Bright '

• l Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Dr. James H. Carpenter Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of VERMONT YANKEE NUCLEAR POWER CORPORATION  :

(Vermont Yankee Nuclear Power Station)

Docket No. 50-271-0LA (Spent Fuel Pool Amendment)

Dear Administrative Judges:

This letter forwards the Staff's testimony in the form of an affidavit on which the Staff will rely in oral agrument on NECNP's contention scheduled for March 22, 23, 1989. The affidavit is not executed because the affiant is on travel. When he returns, an executed copy will be provided.

Sincerely, W '

Ann P. Hodgdon

, Cour.sel for NRC Staff cc: Service List j

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Dx F.E ID UmH UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 89 W -2 P2 28 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1

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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 Amendment)

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(Vermont Yankee Nuclear Power )

Station)

AFFIDAVIT OF JOHN KUDRICK ON BEHALF 0F THE NRC STAFF REGARDING NECNP'S CONTENTION 1 I, John A. Kudrick, being duly sworn, state as follows:

My position is Section Chief, BWR Systems Section, Plant Systems Branch, and I am responsible for revied and oversight of reviews involving aspects of spent fuel storage, including spent fuel pool cooling, under 10 C.F.R. Part 50.

NECNr'S Statement of Contention 1:

The spent fuel pool expansion amendment should be denied because, through the necessit removal system (RHR)y to use to in addition one thetrain of fuel spent the cooling reactor's residual system in orderheat to maintain the pool water within the design limits of 150 F, the single failure criterion as set forth in the General Design Criteria, and particularly Criterion 44, will be violated. The Applicant has not established that its proposed method of spent fuel pool cooling ensures that both the fuel pool cooling system and the reactor cooling system are single failure proof.

i My response to Contention 1:  :

The Staff has reviewed the thermal adequacy of the spent fuel pool cooling system periodically during the course of the Vermont Yankee license, the first time being the time of the original licensing. At that time, i - - - - - - - - - _ - _ - - - _ _ _

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1 the Staff found that the spent fuel pool cooling system, considering the  !

single failure criterion, could maintain the pool water temperature below the TS limit of 150*F. The Staff's review of spent fuel pool cooling has focused on a satisfactory response to two concerns: the operability of all system components within the TS pool temperature limit and assurance through analysis that a non-boiling condition will exist within the pool for all credible events.

In response to these two concerns, the Licensee stated in a submittal dated April 9,1987, that the spent fuel cooling system was qualified to operate at pool temperatures up to the TS limit of 150'F.

However, in order to prevent degradation of the demineralized resin, the Licensee committed in a submittal dated June 11, 1987, to isolate the demineralizers, as a further precaution, when the inlet temperature to the spent fuel cooling system reaches 140 F.

The L'icensee also evaluated the important design consideration of minimum net positive section head (NPSH) for pumps of the spent fuel pool cooling system. The Licensee concluded that there is at least a 20 foot margin beyond the required 25 feet up to pool temperatures of 212 F. The Staff has found the above justification sufficient to support a TS pool temperature limit of 150 F.

The last t'ime the Staff rereviewed the spent fuel pool cooling system resulted in issuance of an SER dated October 14, 1988. Each rereview was necessitated by the Licensee's proposal to increase the allowable number of spent fuel assemblies stored in the pool. Although the review covered many areas, I will focus only on the area identified within Contention 1.

That issue is the ability of the spent fuel pool cooling system to i

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l maintain the pool temperature below the TS limit while considering a single active failure.

Any consideration of the adequacy of spent fuel pool cooling l l

capability for the currently authorized storage limit was resolved in the 1 course of our review. The Staff has concluded that the spent fuel pool cooling system is capable of removing the heat load from the maximum 1 number of spent fuel assemblies allowed by the current TS (i.e., 2000 assemblies). For this condition there is no reliance on the RHR system I

for spent fuel pool cooling nor is there any need for TS limitations on the RHR system in this regard. The reviews included consideration of single active failure as defined within the General Design Criteria, particularly Criterion 44 and SRP Section 9.1.3, " Spent Fuel Pool Cooling and Cleanup System." In this regard, the SRP further defines what is meant by complying with the above GDC. The following is extracted from the SRP Section 9.1.3.

The design meets the requirements of General Design Criterion 44 regarding decay heat removal redundancy and power supplies, since the system has the capability to remove decay heat from the spent fuel under both normal operating and accident conditions. The system has redundancy so that decay heat can be removed assuming a single active failure coincident with a loss of all off-site power, and is designed with isolation capability of system components and piping, if required, such that the ability of the system to remove decay heat will not be  !

compromised. I However, for the most recent Licensee's proposal of the storage of 2870 assemblies, the Staff found that there was insufficient information on the record to determine the adequacy of the spent fuel pool cooling system to maintain TS limits within the pool. As a result, the Staff pursued this lack of information with the Applicant. Questions took on

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many forms including questions concerning the conditions and procedures for the possible use of RHR in the spent fuel pool cooling mode.

The Staff fully intended to continue its review until all questions regarding the heat removal capability of the spent fuel cooling system were resolved. However, in the middle of the review process, the Licensee committed to enhance its SFPCS by installing an Emergency Standby System. As proposed, this system will be more than capable of maintaining the pool below the TS spent fuel pool temperature limit. The Staff evaluation, the operational restrictions, and acceptance of this system are discussed in our SER dated October 14, 1988. Because of the applicant's commitment to enhance its SFPCS by installing the Emergency Standby System, the Staff found it unnecessary to pursue the answers to the detailed questions that had been asked when only the spent fuel pool cooling system was assumed to be available. The review of the capability of the existing spent fuel pool cooling system to accommodate the heat load from 2870 fuel assemblies was terminated because it was superseded by the June 9, 1988 commitment.

Finally, in Contention 1 there is an identified concern about the use of the RHR sy. stem for spent fuel pool cooling. I do not believe it is necessary to add to the above information for most operating modes. The Staff, through its review process, is satisfied that the available spent fuel cooling systems will be capable of maintaining the spent fuel pool within allowable temperature limits without the assistance of the RHR system.

However, there is an operating mode in which it is appropriate for

• RHR to cool both the primary system and the spent fuel pool. This mode is 1

t during refueling, when the head is removed and the spent fuel pool is joined with the ieactor cavity into one fluid system. During this operational phase, the RHR system is more than capable of accommodating the heat loads from both the primary system and the spent fuel pool. 'It is important to note that the primary function of the RHR system, reactor core cooling, is maintained while in the spent fuel pool cooling mode. As i

a result, the TSs allow this type of operation. Also, it is only in this configuration that the TSs permit the RHR to be used to cool the pool.

The Staff relies on the following documents, all of which have been filed in this proceeding:

1. The Staff's SER dated October 14, 1988;

2. The Staff's response to NECNP's first and second set of interrogatories dated December 23, 1988 and January 31, 1989;

3. Standard Review Plan Section 9.1.3, the acceptance criteria for GDC 44, meeting the requirements of single failure criteria. l I

dohn A. Kudrick Section Chief, BWR Systems l Section,  !

Plant Systems Branch l l

Subscribed and sworn to before me this day of March, 1989 l

l Notary Public My commission expires:_

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'89 yp 2 P 2 .'M BEFORE THE ATOMIC SAFETY AND LICENSING BOARD nn In the Matter of C

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VERMONT YANKEE NUCLEAR Docket No. 50-271-OLA POWER CORPORATION ) (Spent Fuel Pool Amendment)

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(Vermont Yankee Nuclear Power )

Station)

CERTIFICATE OF SERVICE I hereby certify that copies of " AFFIDAVIT OF JOHN KUDRICK ON BEHALF 0F THE NRC STAFF REGARDING NECNPS CONTENTION 1" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the. Nuclear Regulatory Commission's internal mail system, or as indicated by a double asterisk by use of Facsimile Machine, this 1st day of March, 1989:

Charles Bechhoefer, Esq.* Gustave A. Linenberger, Jr.*

Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board g U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. James H. Carpenter

• George Dana Bisbee, Esq.

Administrative Judge Senior Assistant Attorney General Atomic Safety and Licensing Board Environmental Protection Bureau .

U.S. Nuclear Regulatory Commission 25 Capitol Street l Washington, D.C. 20555 Concord, NH 03301-6397 j l

Atomic Safety and Licensing Board Andrea C. Ferster, Esq.** l Panel (1)* Harmon, Curran & Tousley U.S. {

Nuclear Regulatory Commission 2001 S Street, N.W.  !

Washington, D.C. 20555* Washington, DC 20009 {

Washington, D.C. 20009  !

George Young, Esq.

Special Assistant Attorney General George Dean, Esq.

Vermont Depart, of Public Service Assistant Attorney General 120 State Street Office of the Attorney General l Montpelier, VT 05602 One Ashburton Place, Boston, MA 02108 R.K. Gad, III, Esq.**

Ropes and Gray Jay Gutierrez, Esq.*

225 Franklin Street Regional Counsel Boston, MA 02110 USNRC, Region I 475 Allendale Road King of Prussia, PA 19406

l Atomic Safety.and Licensing Appeal Docketing and Service Section*

Panel (5)* Office of the Secretary U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Adjudicatory File *

' Atomic. Safety and Licensing Board U.S. Nuclear Regulatory Comission Washington, D.C. 20555

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Anri P. Hodgdon Counsel for NRC Staff Q

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