ML20237A063

Affidavit of TC Feigenbaum Re Length of Fuel Cycles at Seabrook Station & of Future Plans for Fuel Cycle Length. W/Certificate of Svc

ML20237A063
Person / Time
Site:	Seabrook
Issue date:	08/06/1998
From:	Feigenbaum T AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20237A053	List: ML20237A050 ML20237A063
References
LA, NUDOCS 9808130056
Download: ML20237A063 (9)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BfFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) l North Atlantic Energy Service Corporation ) Docket No. 50-443-LA I

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(Seabrook Station) )

AFFIDAVIT OF TED C. FEIGENBAUM 1, Ted C. Feigenbaum, being duly sworn, hereby state as follows:

1. I am employed by the North Atlantic Energy Service Corporation (North Atlantic) as the Executive Vice President and Chief Nuclear Officer. I have been the Chief Nuclear l

Officer at Seabrook Station since 1992 and have been employed at Seabrook Station since 1984. My business address is:

North Atlantic Energy Service Corporation l

Seabrook Station Laft4yette Road I

Seabrook, NH 03874

2. In my position I am responsible for all operatians at Seabrook Station. I have personal knowledge of the length of the fuel cycles at Seabrook Station and of the future plans for fuel cycle length.

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gDR ADOCK 05000443 PDR

3.

When the sixth operating cycle began on 6/26/97, Seabrook Station had planned to begin its next refueling outage on 3/S/99, an operating cycle of just over 20 months.

This would have allowed all necessary surveillance to be performed in accordance with the existing Technical Specifications without a mid-cycle or early shutdown.

4. Seabrook Station experienced an unplanned outage that started on 12/5/97 and lasted just over 42 days. As a result, the planned start of the next refueling outage was l postponed until 4/3/99. This change in date was to allow the full utilization of the fuel.

5. With the .;hange in outage date, and with the schedule in the current Technical Specifications certain surveillance would come due before the outage began. This would require either a mid-cycle or early shutdown. Either of these actions would add to the cost of power being generated by Seabrook Station dJe to either wasted fuel or replacement power costs. The recovery of those costs from the customers of Seabrook Station's owners would likely be sought.

6. North Atlantic filed the request being challenged by the Seacoast Anti-Pollution League as part of a series of filings to extend surveillance schedules to allow the current cycle to safely continue, to its intended completion, thus avoiding unnecessary costs to customers. The extension has been evaluated by North Atlantic and determined to be consistent with NRC generic guidelines and safety criteria related to 24 month operating cycles.

'7. On 6/11/98, another unexpected outage occurred at Seabrook Station and lasted approximately 30 days. This resulted in another change to the planned start of the refue!%g outage. The planned start date is now 5/1/99. This could result in further costs to customers should the requested changes not be granted.

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8. Seabrook Station's initial fuel criticality occurred on 6/13/89. The cycle was completed on 7/26/91. This is considered a nominal 12-month cycle.

9. The second cycle of operation was also a nominal 12-month cycle that began on j 10/9/91 and was completed on 9/7/92. i I

10. The third cycle was the first of a nominal 18-month length. The cycle t>egan on

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11/11/92 and was completed on 4/9/94.

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11. The fourth cycle was also a nominal 18-month length cycle. The cycle began on 7/29/94 and was completed on 11/3/95.

12. In 1995, consistent with a general industry trend, North Atlantic determined that there would be economic benefit in operating Seabrook Station with longer fuel cycles. This benefit would occur due to the elimination of one refueling outage every six years. The decision was made to begin a transition from an 18-month cycle to a 24-month cycle.

13. The fifth operating cycle was the first of two planned " transition" cycles that would ultimately lead to 24-month cycle. The cycle began on 12/9/95 and was completed on 5/9/97.

14. The industry has experienced a small number of issues associated with longcr ~uel cycles and higher energy cores. Some of these were associated with plants using a 24-  !

I month cycle and some occurred at plants with shorter e ;arating cycles but which had the potential for a greater effect in a longer cycle.

15. In addition, the nuclear power industry, including Sea'orook Station, has begun making ,

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' i substantial reductions in the duration of refueling outages. Reducing refueling outage i'

length reduces the economic benefit of going to a 24-month cycle.

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16. As a result of this industry experience and the reduced potential for cost savings, North Atlantic decided to not move to a 24-month cycle but rather return to an 18-month fuel cycle.

17. North Atlantic has no plans to operate Seabrook Station witn a 24-month cycle at the present time. The current operating cycle, Cycle 6, is nominally a 20 month fuel cycle, as discussed above. Seabrook Station's next operating cycle, Cycle 7, will be an 18-month cycle that will start on or about 6/9/99 and be completed on 11/11/2000.

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18. None of the license amendments necessary to allow operation during the sixth operating cycle without a mid-cycle or early shutdown request any change to the fuel enrichment or burnup.

19. The foregoing statements are true and correct to the best of my knowledge and belief.

&& &d M r Ted C. Feige um Subscribed to and sworn before me this @ day ofM 1 8.

o Susan J. Mdssdr, Notary Public My commission expires December 22,1998 i

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ATTACHMENT B i

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4 REACTOR COOLANT SYSTEM

,gg, BASES

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3/4.4.4 RELIEF VALVES (Continued)

(2) No Surveillance Requirement (ACOT or TADOT) exists for verifying automatic operation.

(3) The required ACTION for an inoperable PORV(s) (closing the block valve) conflicts with any presumed requirement for automatic actuation.

3/4.4.5 STEAM GENERATORS l The Surveillance Requirements for inspection of the steam generator tubes ensure that the structural integrity of this portion of the RCS will be main- l tained. The program for inservice inspection of steam generator tubes is based '

on a modification of Regulatory Guide 1.83. Revision 1. Inservice inspection of steam generator tubing is essential in order to maintain surveillance of the conditions of the tubes in the event that there is evidence of mechanical damage or progressive degrad3 tion due to design, manufacturing errors, or in-service conditions that lead to corrosion. Inservice inspection of steam generator tubing also provides a means of characterizing the nature and cause of any tube degradation, so that corrective measures can be taken.

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SEABROOK - UNIT 1 B 3/4 4-2a Amendment No. 16 a

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, REACTOR COOLANT SYSTEM p BASES -

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3/4.4.5 STEAM GENERATORS (Continued)

The plant is expected to be operated in a manner such that the secondary coolant will be maintained within those chemistry limits found to result in negligible corrosion of the steam generator tubes. If the secondary coolant

' chemistry is not maintained within these limits, localized corrcsion may likely result in stress corrosion cracking. The extent of cracking during plant operation would be limited by the limitation of steam generator tube leakage between the Reactor Coolant System and the Secondary Coolant System (reactor-to-secondary leakage = 500 gallons per day per steam generator). Cracks having a reactor-to-secondary leakage less than this limit during operation will have an adequate margin of safety to withstand the loads imposed during normal operation and by postulated accidents. Operating plants have demonstrated that reactor-to-secondary leakage of 500 gallons per day per steam generator can readily be detected by radiation monitors of steam generator blowdown. Leak-age in excess of this limit will require plant shutdown and an unscheduled inspection, during which the leaking tubes will be located and plugged.

Wastage-type defects are unlikely with proper chemistry treatment of the secondary coolant. However, even if a defect should develop in service, it will be found during scheduled inservice steam generator tube examinations.

Plugging will be required for all tubes with imperfections exceeding the plug-ging limit of 40% of the tube nominal wall thickness. Steam generator tube

m. ' inspections of operating plants have demonstrated the capability to reliably detect degradation that has penetrated 20% of the original tube wall thickness.

Whenever the results of any steam generator tubing inservice inspection fall into Category C-3, these results will be promptly reported to the Commis-sion in a Special Report pursuant to Specification 6.8.2 within 30 days and prior to resumption of plant operation. Such cases will be considered by the

' Commission on a case-by-case basis and may result in a requirement for analysis, laborato:y examinations, tests, additional eddy-current inspeci.fon, and revi-sion of the Technical Specifications, if necessary.

3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE 3/4.4.6.1 LEAKAGE DETECTION SYSTEMS The RCS Leakage Detection Systems required by this specification are pro-vided to monitor and detect leakage from the reactor coolant pressure boundary.

These Detection Systems are consistent with the recommendations of Regulatory Guide 1.45, " Reactor Coolant Pressure Boundary Leakage Detection Systems,"

- May 1773.

3f4.4.6.2 OPERATIONAL

• LEAKAGE l PRESSURE BOUNDARY LEAKAGE of any magnitude is unacceptable since it may

( be indicative of an impending gross failure of the pressure boundary. Therefore, t

the presence of any PRESSURE BOUNDARY LEAKAGE requires the unit to be promptly placed in COLD SHUTDOWN.

SEABROOK - UNIT 1 B 3/4 4-3 9

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. 1 DOCKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION

% E 12 All :35 BEFORF THE ATOMIC SAFETY AND LICENSING ROARD OFf!C!.

RUMWOF Ct:cF, ' , ,;

,i R t In the Matter of ADJUD % STAFF

) j

)

North Atlantic Energy Service Cogoration ) Docket No. 50-443-LA

)

(Seabrook Station) )

CERTIFICATE OF SERVICE I hereby certify that copies of " NORTH ATLANTIC ENERGY SERVICE CORPORATION'S RESPONSE TO PROPOSED CONTENTIONS" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 10th day of August,1998. In addition, a courtesy copy has been sent by e-mail this same date to those parties designated by an asterisk (*).

Office of the Secretary B. Paul Cotter, Jr.*

U.S. Nuclear Regulatory Commission Chairman Washington, D.C. 20555 Atomic Safety ar.d Licensing Board Attn: Docketing and Service Station U.S. Nuclear Regulatory Commission (original + two copies) Washington, DC 20555-0001 Steven R. Hom, Esq

• Dr. Charles N. Kelber*

Office of the General Counsel Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Robert A. Backus Linda W. Little* -

Backus, Meyer, Solomon, 5000 Hermitage Drive Rood & Branch Raleigh, NC 27512 116 Lowell Street P.O. Box 516

' Manchester, NH 03105-0516 o _ _ _ - - ..

6 li ' Adjudicatory File Office ofCommission Appellate Adjudication f Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nucles Regulatory Commission Washington, DC 20555 Washington, DC 20555 David A. Repka V N Winston & Strawn Counsel for Nonh Atlantic Energy Service Corporation m..