ML20236D794
| ML20236D794 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 03/17/1989 |
| From: | Sherman W VERMONT, STATE OF |
| To: | |
| References | |
| CON-#189-8304 OLA, NUDOCS 8903230271 | |
| Download: ML20236D794 (20) | |
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l$ . UNITED STATES'OF AMERICA '89 tic 20 P3 :20 -
I NUCLEAR' REGULATORY COMMISSION nrno .
ATOMIC SAFETY AND LICENSING' BOARD d0CEliW .. : f i .Ir ,
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Before Administrative Judges Charles Bechhoefer, Chairman Gustave A. Linenberger, Jr.
James H. Carpenter-l l In the Matter of- ) ,
) '!
VERMONT YANKEE NUCLEAR ) Docket No. 50-271-OLA -
I POWER CORPORATION -) (Spent Fuel Pool- ,
.) Amendment)' l (Vermont Yankee Nuclear )
Power Station) )
)
Sworn Written Testimony of William K. Sherman, Nuclear Engineer, State of: Vermont, in opposition to the Testimony of Donald A. Reid, et. al.,
Vermont Yankee Nuclear Power Corporation, '
submitted pursuant to 10 CFR 2.1113(a)
Pursuant to 10 CFR 2.1113(a) and this Board's Memorandum and Order of January 12, 1989,'the State of Vermont submits the within sworn written testimony of William K. J Sherman responding in opposition to the Testimony of .
Donald.A. Reid, et. al., Vermont Yankee Nuclear Power Corporation (" Applicant's Testimony") and in support'of Contention 1 admitted in this proceeding that the spent fuel pool cooling system (SFPCS) does not meet the single failure criterion. q l
8903230271 890317 PDR ADOCK 05000271 T PDR i Page 1 i
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yr.' w L I. Identification of Witness
, Mr. Sherman is employed by the State of Vermont, 1
Department of Public Service, as a staff nuclear ,
engineer. He holds a Bachelor of Science Degree from The University of Michigan and is licensed as a Professional Engineer in the States of California, Massachusetts, and Connecticut. Mr. Sherman has 21 years of nuclear related experience, which include 13 years with Stone & Webster Engineering Corporation, 2 years with EDS Nuclear, Inc.,
2 years of private nuclear consulting, and 4 years-in the U.S. Nuclear Navy. He has held supervisory positions for i I
a number of nuclear plants in the licensing, design and !
engineering, and construction phases.
II. The Requirement for the SFPCS To Meet the Single Failure Criterion It is well established that the SFPCS must meet the single failure criterion. The single failure criterion is defined in the Introduction to 10 CFR 50, Appendix B, as:
i A single failure means an occurence which results in I the loss of capability of a component to perform its intended safety functions. Multiple failures resulting from a single occurence are considered to be a single failure. Fluid and electric systems are considered to be designed against an assumed single Page 2
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, failure if neither (1) a single failure of any I
active component (assuming passive components function properly), nor (2) a single failure of passive components (assuming active components function properly), results in a loss of the ,
capability of the system to perform its safety '
function.
i This criterion is amplified in footnote 2:
The conditions under which a single failure of a passive component in a fluid system should be considered in designing the system against a single failure are under development.
The application of the single failure to the SFP cooling system is brought by General Design Criterion (GDC) 44, which requires, in part:
Suitable redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that for onsite electrical power system operation (assuming offsite power is not available) *** the system safety function can be accomplished, assuming a single failure.
The Nuclear Regulatory Commission (NRC) staff applies these requirements through the Standard Review Plan (SRP),
NUREG-800, particularly SRP 9.1.3, II.d.(2): .
Suitable redundancy of components so that safety functions can be performed assuming a single active failure of a component coincident with the loss of all offsite power.
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l III. The Existing SFPCS Does Not Meet the Single Failure Criterion The Applicant's Testimony concludes that the existing SFPCS meets the single failure criterion by reliance on l
two spent fuel pool heat exchangers in parallel .
Applicant fails to account for one single failure that would not enable the full-flow use of two SFPCS he'at exchangera. A detailed single failure analysis or 2
failure-mode-and-effects analysis , which the Applicant did not provide (nor were requested by the NRC staff to provide), would have identified the loss of one diesel generator, coupled with loss of offsite power (required by GDC 44), as the most limiting single failure. In this case, one fuel pool cooling pump, one reactor building closed cooling water pump and two 3
service water pumps would be inoperable . The heat 1
- Applicant's Testimony, at 17.
2 Single failure analyses or failure-mode-and-effects analyses are analyses which would identify each potential single failure which could affect a system, and would provide an explanation of the method by which the system function is performed assuming that failure. SRP 9.1.3, III.1, identifies this requirement with the words, "The reviewer, using the failure modes and effects analysis, determines that the system is capable of sustaining the loss of any active component."
3 Heat is removed from the SFPCS by the reactor plant closed cooling water system in the spent fuel pool heat Page 4
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removal rate of 9.1 MBtu/hr is-not correct for this 5
scenario . Since correct information is not provided for the loss of one diesel generator single failure, one must consider the one pump, one heat exchanger case to evaluate meeting the single failure criterion. According to the Applicant's Testimony,'the existing one pump, one I
heat exchanger configuration requires 43 days decay with 2000 fuel assemblies and 69 days with 2870 fuel -
assemblies before the single failure criterion is met 6 The single failure criterion is not met until exchangers. Heat is removed from the reactor plant closed cooling water system by the service water system in the reactor plant closed cooling water heat exchangers. While capability exists to cross connect the heat exchangers in the separate trains of these systems, the degraded flow resulting from inoperability of the full. train of pumps has not been considered by the Applicant.
4 Applicant's Testimony, Table 2, at 9. Also it is noted that the correct flow rate for the 1 pump, 2 heat exchanger case is not 450 gpm. It is likely that flow .
would be somewhat greater depending on the pump curve.
However, of more significance is the fact that use of 450 gpm is indicative that a system flow analysis has not been performed to investigate the true feasibility of a one pump, two heat exchanger option.
5 Although Applicant's Testimony is deficient in that the assumptions for the one pump, two heat exchanger heat removal rate are nowhere presented, it is clear from the magnitude of the heat removal rate (9.1 Mbtu/hr) that the Applicant assumed design cooling flow in both heat exchangers from reactor plant closed cooling water system and service water system.
6 Applicant's Testimony, Table 3, at 15.
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that time, and the technical specifications should be modified to disallow placing the mode switch'in Startup I 7
until sufficient decay has occured .
It is concluded that, until 69 days of decay have occurred, the existing SFPCS does not meet the single failure criterion, and the Applicant's Testimony is 7
A potentially more severe condition exists which is unanalyzed in the record of the proceeding. This condition is the replacing the spent fuel pool gate, and thus separating the RHR and SFPCS, prior to the end of refueling. This action procedes placing the mode switch in Startup, perhaps by a considerable time. The ability to meet the single failure criterion with the spent fuel gate in place is uncertain, depending on the interpretation and application of Technical Specifications 3.5.H.2, 3, and 4:
3.5.H
- 2. Any combination of. inoperable components in the Core and Containment Cooling systems shall not defeat the capability of the remaining operable components to fulfill the core and containment cooling functions. .
- 3. When irradiated fuel is in the reactor vessel and the reactor la in the cold shutdown condition, all Core and Containment Cooling subsystems may be inoperable provided no work is permitted which has the potential for draining the reactor vessel.
- 4. Whe.. irradiated fuel is in the reactor vessel and the reactor is in the refueling condition, both LPCI subsystems, or both Core Spray systems, or one diesel generator may be inoperable provided that a source of water of greater than 300,000 gal is available to the operable core cooling subsystem.
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. refuted. This testimony is consistent with and affirms the testimony of Dale G. Bridenbaugh and Steven C.
1 Sholly, dated March 1, 1989. Also affirmed are Bridenbaugh and Sholly's arguments concerning the failure of the SFPCS during postulated seismic events, together with the lack of a Seismic Category I backup supply, rendering the existing SFPCS, a priori, unable to meet the single failure criterion.
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, IV. Insufficient Information is Developed in the Record to Determine Contention 1 for the Enhanced SFPCS l
Applicant's Testimony claims that Contention 1 is made moot by commitment to the enhanced SFPCS.O However, the commitment and associated conceptual information has not been provided in sufficient detail to determine whether the single failure criterion has been met in at r) least four specific areas (items A through D below).
Each of these four areas could result in a single event which could cause unacceptable resort to the RHR system (item E below). Applicant and the NRC staff have made conclusions based on a construction permit level, or 0
Applicant's Testimony at 17.
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conceptual, presentation inappropriate.to a proceeding
-for amendment to an operating license (item F below).
A. Single. failure design cannot be determined since subsystem boundaries are not clearly shown and failure in c seismic event cannot be predicted.
Failures during seismic events are within the single. J failure definition, " Multiple failures resulting from a single occurence are considered to be a single 9
failure ." ,
Applicant committed to an enhanced SFPCS which is designed as seismic category I in its June 7, 1988 submittal. A P&ID for the entire proposed SFPCS was provided as Figure A-1. However this figure does not identify the boundaries of the enhanced SFPCS'and the existing SFPCS. New equipment and piping takes suction from. existing (and nonseismic) line 8"-FPC-1B and discharges into existing (and nonseismic) line 6"-FPC-22. No commitment is made to upgrade this existing piping to seismic category I requirements, and seismic category I boundaries are not shown.
SRP 9.1.3 indicates:
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l See above, p. 2 and 3 Page 8 ]
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The P& ids are reviewed to verify that they clearly indicate the physical division between each ggrtion and indicate required classification changes This inability to determine seismic design' boundaries means single failure adequacy cannot be determined.
B. Single failure design cannot be determined since the physical location of the enhanced SFPCS components has not been identified, and failure from earthquake, tornadoes, floods, fire and internally generated missiles cannot be determined.
Failures during earthquakes, tornadoes, floods, fires and from internally generated missiles are within the single failure definition, " Multiple failures resulting from a single occurence are considered to be a single failure 11" . Lacking proper location and separation, each of these events, by single occurence, could incapacitate the enhanced SFPCS such that safety function could not be performed. For example, if the enhanced SFPCS were located in a nonseismic building, collapse of the building during an earthquake would be a single event defeating system safety function. Or similarly, if located in the same fire zone, a single fire could defeat
- safety function.
O SRP 9.1.3, III.1.a 11 See above, p. 2 and 3 Page 9
i SRP 9.1.3 indicates:.
Reference to SAR Chapter 2, describing 1 site features and the. general arrangement and layout drawings, will be necessary as well as to the SAR tabulation of seismic gesign classifications-for structures The location and design of the system, structures, and pump rooms (cubicles) are reviewed to determine thatthegegreeofprotectionprovidedis adequate t Applicant has not provided plan or layout drawings.to show the location or arrangement of the proposed 14 system . Consequently, single failure adequacy from earthquake, tornadoes', floods, fires and internally generated missiles cannot be determined.
C. Single failure design cannot be determined since the review of environmental qualification has not been accomplished, and failure from incompatibility with the environment cannot be determined.
Failures due to incompatibility with the environment (10 CFR 50.49) are within the single failure definition, 12 SRP 9.1.3, III.2.a 1 '
SRP 9.1.3, III.2.b 14 In NRC Staff Response to NECNP's Second Set of Interrogatories and Request for Production of Documents ,
to NRC Staff on the NRC Spent Fuel Pool Expansion Safety
' Evaluation, NRC responded to Interrogatory 10(D) that it had reviewed plan drawings submitted as part of the June 7, 1988 submittal. If this is correct, these plan drawings were not provided to all the parties to this ,
proceeding.
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" Multiple failures resulting from a single occurence are considered to be a single failure 15." Should equipment prove incompatible with the environment, the single failure could encompass failure of equipment otherwise considered to be redundant. Applicant has stated that the enhanced SFPCS pumps will be environmentally 16 qualified , and that:
Essential electrical components in this portion of the system are also environmentally qualified to ensureoperggilityunderdesignbasisaccident conditions. '
Applicant has not identified which are " essential
' electrical components" and it is not clear whether more than the enhanced pumps are to be qualified.
Further, SRP 9.1.3 indicates:
The EQB reviews the *** environmental qualification of mechanical and electrical equipment (of the
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15 See above, p. 2 and 3 16 June 7, 1988 submittal, at A-5.
17 June 7, 1988 submittal, at A-10.
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l l SFPCS] as part of its primary 8 review responsibility l
for SRP Section(s] *** 3.11 SRP 3.11 indicates:
At the OL stage, the staff reviews the !
[ environmental qualification) program again as l described by the applicant. *** The review verifies the list of equipment associated with each system and equipment. *** The staff audits the equipment qualifiggtion review.
file and conducts a plant site .
1 Since Applicant has not identified which equipment will l
be environmentally qualified, and since the staff has not performed itu SRP review, it cannot be determined whether ;
the enhanced SFPCS system meets the single failure, criterion in environmentally degraded conditions. As recognized by the NRC staff in SRP 3.11, it is only possible to properly assess environmental qualification after all equipment is identified.
D. Single failure design cannot be determined since the physical separation allowing independence of electrical systems has not been reviewed, and failure due to improper separation cannot be i determined.
Failure of more than one train of electrical power due to lack of proper separation would constitute a single failure. Indeed, Regulatory Guide 1.75, " Physical 18 SRP 9.1.3, I.4.
19 SRP 3.11, III.(2).
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Independence of Electrical Systems," identifies the l
single failure critorion as part of its basis:
General Design Criteria 17, " Electrical Power Systems," requires, in part, that the onsite electrical power supplies *** have sufficient independence to perform th assumingasinglefailure.gfrsafetyfunctions The NRC staff is charged with the responsibility to-review each system to assure adequate electrical redundancy and separation is met. SRP 8.3.1 indicates:
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The ASB examines the physical arrangement of l components and structures for Class lE systems and their supporting auxiliary systems, to determ,ine that single events and accidents will not disable redundant features. *** The ASB determines those system components requiring electric power as a function of time for each mode'of reactor operation and accident condition as part of its pri responsibility for SRP Section(s 9.1.3.].ggry review The descriptive information including electrical single-line diagrams (CP and OL stage), functional P& ids (CP and OL stage), and electrical schematics (OL stage) is reviewed to verify that this redundancy is reflected in the standby power system with regard to both power sources and associated 20 Regulatory Guide 1.75, Section A. We note that GDC 17 refers specifically to single fai' o of electrical power systems. However, it is not correct to consider the enhanced SFPCS ,in vacuo, without its electrical supply or its effect on the electrical system. Thus, the single failure adequacy of the enhanced SFPCS must include any infringement or effect related to its electrical components.
1 SRP 8.3.1, I.8.
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distribution systems. .Also, it'is verified in coordination with other branches that redundant safety loads are distributed between redundant distribution systems, and that the instrumentation and control devices for the. Class lE loads and power
. system are supplied fygm the related redundant.
distribution systems Applicant has committed that:
The two Normal Fuel Pool Cooling Subsystem Isolation Valves V-19-H and I are nonthrottling MOVs, each
. powered by a ggfferent safety-related electrical.
power supply.
However this is the only statement made concerning power supplies; no commitment is made for the pumps or o,ther electrical equipment.24 Further, while Applicant has
'provided a piping and instrumentation diagram (P&ID) with its June 7, 1988 submittal, it has not provided single-line diagrams or electrical schematics. Neither has it shown physical location of the enhanced SFPCS.
'Thus, from the information provided the NRC staff cannot 22 SRP 8.3.1, III.l.
l 23 June 7, 1988 submittal, at A-5.
24 In the Safety Evaluation (October 14, 1988), at 31, NRC concludes, ex nihilo, that "the ESS (emergency I standby subsystem] receives electrical power from l safety-related IE power sources." Applicant's material refers only to two valves, and does not define safety-related to mean Class lE. ;
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have performed its single' failure-review for the SFPCS in the electrical area, and the single failure' adequacy of the SFPCS remains indeterminate.
E. Indeterminate identified above may potentially conclude that unacceptable usage of the RHR system would be considered J- the last resort Lacking sufficient information and proof for single failures by 1) seismic event, 2) improper location,
- 3) inadequate environmental qualification, and
- 4) insufficient electrical separation can lead to a conclusion of reliance on the RHR system as system of-last resort.
- 1. In a design basis seismic event, portions of the existing SFPCS could fail due to nonseismic design.
Since the system boundaries (and seismic design limits) of the enhanced SFPCS are not clear, nonseismic supply and discharge piping could fail. The only system remaining might be the seismic category I RHR system.
- 2. Improper physical location could lead to failures of both existing and enhanced systems. Existing SFPCS pumps are located within the same cubicle. If the enhanced SFPCS pumps are located in the same cubicle, or in the same fire or flood area, both existing and enhanced SFPCS l
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1' 's. e could be incapacitated by the single event. If the enhanced SFPCSlwere located in a nonseimic area, building collapse coupled with seismic failure of the existing SFPCS, could defeat both systems. This could lead to reliance on the RHR system which is located in a different area.
'3. Inadequate environmental qualification could lead, lar single event, to failure of both enhanced SFPCS and existing SFPCS (which apparently is not environmentally qualified). Should this single event occur (a degraded environment), the RER system might be the only remaining system for fuel pool cooling.
- 4. Electrical separation requirements are established to prevent one electrical train causing failure to another.
Improper separation of the enhanced system could by single event, cause electrical failure of both enhanced trains, and one or both trains of the existing SFPCS.
This could result in reliance on the RHR system for spent fuel pool cooling.
The possibilities of single failures leading to use of the RHR system in the last resort, a use which would be unacceptable (Applicant's Testimony at 6), preserve the Page 16
4 It basis of Contention 1,'which alleges lack of single 1
failure design due to reliance.on the RHR system.
J F. The NRC staff has performed a construction permit stage review inappropriate to this proceeding As identified above, NRC staff has not reviewed (1) specific seismic design boundaries, (2) actual system location and layout for earthquake, flood,. fire and
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internally generated missiles, (3) specific environmental l qualification aspects, or (4) location and connection for j electrical. redundancy. All of this review is appropriate to an operating facility. Rather, NRC staff has accepted l the single commitment from Applicant that the enhanced system will meet the single failure criterion. This constitutes a " construction permit stage" type review l l
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inappropriate to this proceeding. Mere commitme;,t or?
promise should not be deemed an acceptable bas- M .,r determining the proceeding.25-William K. Sherman AM %
Sworn and subscribed to before-me at Montpelier, Vermont this 17th day of March, 1989.
M Sandra I. JoyFg f '
Notary Public My commission expires February.10, 1991. ! -
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n.,c Determination by mere commitment constitutes a return to the beginning of the proceeding. Both Vermont Yankee
. (Licensee's Response to the Contentions of the New England Coalition on Nuclear Pollution, dated April 9,
- l. 1987, at 3-4) and the NRC staff _(NRC Staff Response to Contentions of the State of Vermont, Commonwealth of Massachusetts and New. England Coalition of Nuclear Pollut1nn, dated April 13, 1987, at 18-19) initial briefs held that the SFPCS met the single failure criterion.
l' The progress of'the proceeding has proven that the
! existing SFPCS does not meet the single failure L criterion, and thus Vermont Yankee has proposed the enhanced SFPCS. Both parties again claim the single failure criterion is met, without adequate design, ;
development, production of documents and review.
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'- 'mc UNITED. STATES OF~AMERICAi ' gg gtg.20 P 3 :19 NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING APPEAL BO P , . . .
CH: n , v Before Administrative Judges
~
Charles Bechhoefer,. Chairman Gustave A. Linenberger, Jr.
7 James H. Carpenter In the Matter of )
)
' VERMONT YANKEE NUCLEAR ) Docket No. 50-271-OLA POWER CORPORATION ) (Spent Fuel Pool ~
) Amendment)
(Vermont Yankee Nuclear )
Power Station) )
)
4 CERTIFICATE OF SERVICE I, Samuel H. Press, hereby certify that on March 17, 1988, I made service of the within Brief^and Profiled Testimony of William K. Sherman in accordance with the rules of the Commission by mailing a copy thereof, postage prepaid,-
to the following:
Charles Bechhoefer, Esquire, Andrea C. Ferster, Esquire Chairman Harmon Curran & Tousley Administrative Judge Suite 430 Atomic Safety and Licensing 2001 S Street, N.W.
Board Panel Washington, DC 20009 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Gustave A. Linenberger, Jr. George B. Dean,-Esq.
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Environmental Protection l
Board Panel Division U.S. Nuclear Regulatory Department of the Attorney Commission General l
Washington, D.C. 20555 One Ashburton Place Boston, MA 02108 Page 1
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i Mr. James H. Carpenter Ann P. Hodgdon, Esquire ,
Administrative Judge Office of the General Counsel l l
Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, D.C. 20555 Atomic Safety and Licensing R. K. Gad III Board Panel Ropes & Gray U.S. Nuclear Regulatory 225 Franklin St.
Commission Boston, MA 02110 Washington, DC 20555 Geoffrey M. Huntington, Esquire Office of the Attorney General Environmental Protection Bureau i State House Annex I
25 Capitol Street Concord, NH 03301-6397
[ aM M i
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Samuel H! Press Special Counsel ;
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