ML20236D639

Forwards Unexecuted Responses by J Kudrick for NRC to Bridenbaugh/Sholly 890301 Affidavit Upon Which NRC Will Rely in Oral Argument on New England Coalition on Nuclear Pollution Contention.W/Certificate of Svc

ML20236D639
Person / Time
Site:	Vermont Yankee
Issue date:	03/20/1989
From:	Hodgdon A NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Bechhoefer C, Carpenter J, Linenberger G Atomic Safety and Licensing Board Panel
References
CON-#189-8325 OLA, NUDOCS 8903230201
Download: ML20236D639 (6)

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[.(;Cni. I J ~I Charles Bechhoefer, Esq. Mr. Gustave A. Linenberger, JrF I l Administrative Judge Administrative Judge l Atomic Safety and Licensing Atomic Safety and Licensing l

Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Connission 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-OLA (Spent Fuel Pool Amendment)

Dear Administrative Judges:

This letter forwards the Staff's responsive testimony in the form of an affidavit on which the staff will rely in oral argument on NECNP's contention. Mr. Kudrick is not available to execute his affidavit. He will be available at the argument.

S)ncerely,

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[ GLL Ann P. Hodgdon Counsel for ARC Staff 1

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f '# MAR 2 01989 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of VERMONT YANKEE NUCLEAR Docket No. 50-271-OLA POWER CORPORATION (SpentFuelPoolAmendment)

(VermontYankeeNuclearPower Station)

RESPONSES BY JOHN KUDRICK FOR THE NRC STAFF TO BRIDENBAUGH/SHOLLY'S AFFIDAVIT DATED MARCH 1, 1989

1. Page 6, Footnote 10 The NRC staff estimates that the normal heat generation rate is 10.1 MBtu/Hr, and the abnormal heat generation rate is 21.46 MBtu/Hr.

Response: The reference that is used was a status report dated Jan. 21, 1988. It is a correct excerpt; however, it should be noted that it represents a status report of the staff review at that time. Since that time, the licensee agreed to use the methodology of the SRP and the staff agreed that the ten day heat load was acceptable, that number is 9.1 MBtu/hr. That is the number used in the SER dated Oct. 14, 1988.

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2. Page 9, Section 16 According to an NRC Staff evaluation, the Vermont Yankee SFPCS does not have sufficient can= city to cool the normal spent fuel pool heat load and maintain the pool water temperature below 140* F in the event of a single active failure.

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Response: The reference is the staff's response to the first set of Interrogatories dated August 5, 1987. It reflected the staff's knowledge of the system at that time. However, without detailed knowledge of the system's performance, the staff had to make several critical assumptions relative to both the limiting single failure as well as the system performance considering the assumed single failure. In both cases, the staff selected all values or assumptions on the conservative side. As a result, the Staff was unable to conclude that the system was capable of cooling the pool when a conservative single failure was assumed. As indicated in our SER dated Oct. 14, 1988, the staff was still pursuing this issue when the licensee committed to the added cooling system.

3. Page 12, footnote 21 More recently, the NRC staff stated that makeup to the spent fuel pool can i

be provided by the " seismic Category I service water system"....The staff has not demonstrated, however, that the conditions required to render this i

makeup pathway fully Seismic Category I, as set forth in the preceding footnote, have been met for the existing SPFCS or the proposed enhanced j system.

Response: The staff is unable to underctand the above concern since it is 1

stated too generally to allow for a directed response. Short of a j detailed discussion of each review step, the NRC staff can only reply that q the guidance of the SRP was satisfied.

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4. Page 14. Section 27 1 It is standard NRC practice to require final design details... necessary for operation of the system.

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l Response: While the NRC staff can agree that the level of detail as described above has been followed by the staff on selected concerns, I l

cannot agree that this detailed evaluation is necessary for each concern.

The SRP clearly provides areas of consideration as well as the framework ,

that the NRC staff will follow in all reviews. The objective of this guidance is to provide sufficient detail to assure an adequate evaluation without restricting the review to a " cookbook" procedure. It is in this spirit that the NRC staff has conducted the review of all issues associated with the spent fuel pool design changes.

5. Page 15, Section 28 In effect, the NRC staff proposes to issue an amendment to the license based upon a level of design detail for which the staff would otherwise only issue a construction permit.

Response: The NRC staff has clearly identified the bases of approval in the SER dated Oct. 14, 1988.

John A. Kudrick Section Chief, BWR Systems Section, Plant Systems Branch subscribed and sworn to before me this day of March, 1989.

Notary Public My commission expires: __,

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of VERMONT YANKEE NUCLEAR Docket No. 50-271-OLA POWER CORPORATION (SpentFuelPoolAmendment) ,

(VermontYankeeNuclearPower Station)

CERTIFICATE OF SERVICE I hereby certify that copies of " RESPONSES BY JOHN KUDRICK FOR THE NRC STAFF TO BRIDENBAUGH/SH0LLY'S AFFIDAVIT DATED MARCH 1, 1989" 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 on this 20th 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 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 .I.

Atomic Safety and Licensing Board Environmental Protection Bureau U.S. Nuclear Regulatory Commission 25 Capitol Street Washington, D.C. 20555 Concord, NH 03301-6397 ,

1 Atomic Safety and Licensing Board Andrea C. Ferster, Esq.

Panel (1)* Harmon, Curran & Tousley i U.S. Nuclear Regulatory Commission 2001 S Street, N.W. ,

Washington, D.C. 20555* Washington, DC 20009 i Washington, D.C. 20009 George Young, Esq.

Special Assistant Attorney General George Dean, Esq.

Vermont Depart. of Public Service AsListant Attorney General ,

120 State Street Office of the Attorney General i Montpelier, VT 05602 One Ashburton Place, Boston, MA 02108 '

R.K. Gad, III, Esq.

Ropes and Gray Jay Gutierrez, Esq.*

One International Place Regional Counsel Boston, MA 02110-2624 USNRC, Region I 475 Allendale Road King of Prussia, PA 19406

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Atomic Safety and Licensing Appeal Docketing and Service Section*

l- . 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 m)

MA A M Ann P. Hodgdon Counsel for NRC Staff

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