ML20247A608

Sworn Written Rebuttal Testimony of DA Reid,Jt Herron, Jk Thayer,Ch Hansen & PA Bergeron Submitted by Vermont Yankee Nuclear Power Corp Per 10CFR2.1113(a).* Board Should Approve License Amend.Certificate of Svc Encl

ML20247A608
Person / Time
Site:	Vermont Yankee
Issue date:	03/20/1989
From:	Paul Bergeron, Hansen C, Herron J, Reid D, Thayer J VERMONT YANKEE NUCLEAR POWER CORP.
To:
Shared Package
ML20247A487	List: ML20247A480 ML20247A549 ML20247A608
References
OLA, NUDOCS 8903290154
Download: ML20247A608 (14)

Text

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1-MAR 20 '89 12:46 P.h -l UNITED STATES OF AMERICA NUCLEAR REOULATORY COMMISSION )

befort the ATOMIC SAFETY AND LICENSING BOARD I

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In the Matterof

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VERMONTYANKEENUCLEAR )DocketNo.50 271 OLA POWERCORPORATION '

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- (Vermont Yankee Nuclear ) Naa' uelPoo!

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Power Stadon) .

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Sworn Wrluen RebonalTestimony of i Donald A. Reid, John T. Harron, Jay K. Hayer, C. er H. Hansen, and Paul A. Bar ,

Subadttedby ermontYankeeNuclearPower tion l Pursuant to 10 C.F.R. 4 2.1113(a) '

1. We

• Affidavit of Dale O. Bridenbaugh and Stenn C. Sholly"(hereinafterIntervenor Affidavit) at paragraph 9 at:ees: "If the decay beat ansval funedoc fails, the inte fuel cladding cannot be maWaM." nis staternent is not exactly cormet as wrinen, and 4V 1 Yankee offers the following clartfleation.

The scenario described implies that as soon as the decay heat removal funcdon fails integrity of the spent fuel cladding cannot be maintained red a .radiological u talease will) an im?Wdm is misleading. In accordance with VYNPd cmMdeae :

+h Je ni 1987 leuer to the NRC (FVY 87 65), the teroperamre rise in the fuel pool, assundng ' lo cooling, was conservatively calculated to be 3.2'F/hr (42 days after shutdown of nuclearrea forlast offload). Without the very conservadvs namnmptions of the NRC Standard Review l i

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NUREO 0800 (5RP), heatup is calculated to be less than 2'F/hr (after 42 days rise and an inidal fuel pool temperature of 150'F it would take approximately 2 '

pool even started to boil. Assumfog no makeup water m the pocl the =Wm boiloff w 16.6 OPM per 12:ter VYNPC to USNRC on March 2,1988 (PVY 88-17). Actually, less, sinos that calculation was based on 21 days aftershutdown. ]

Themfore, considering that there is approximately 235,000 galions of waterin of which approximately 165,000 gallons are above the top of the spent fuel assem

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take neveral days (about 6.9 days) for the water to boiloff to the point of first y fuel assemblies and longer to cause fuel cladding damage. Dere would be many be taken to midgate the event during this scenano.

2. The Intervenor5 Affidavit at paragraph 11 statesi "The SPPCS is a . . . non Class system." Tids is not exactly true and Wrmont Yankee offers the following clantication:

The Spent Puel Pool Cooling System (SPPCS) at VY receives electrical pow busses capable of being powered by the etnergency diesel generators in the event offdte power. This system is classified and maintained as " safety class elecideal", a t!

a used at Vermont Yankee to desedbe electrical systems and componems that am I key safety systems.

Class IE is a similar designation for electrical systems designed in accordance with t provisions of IEEE Standard 308. This standard was developed after Vermont Yankee w designed and lleensed; however, " safety class electrical" as used at YY and " C IEEE 308 are synonomous terms.

3. The Interveners Affidavit at paragraph 11 states, "The two trains of the SFPCS ar headored together on the suedon side of die pumps and at the discharge of the Vermont Yankee offers the following cladficarica of that statement. De d!acharge of th pumps are also cross connected, thereby allowing olther pump to supply either or both heat j

exchangers. (FSAR Figum 10.5-1)(A11 FSAR citadons are to the most recendy updated dated NcnA 30,1988.)

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4. In the same paragraph, Interveners Affidavit states : " Heat bom the RBCCW the n1timate heat sink via the residual heat removal service water system." This is from the Reactor Building Closed Cooling Water System (RBCCW) at VY !s take Water System (SW), which is a different system from the Residual Heat Removal S j

System (RHRSW), as is clearly shown in FSAR Figum 10.6,1A.

5. The Interveners Affidavit at paragraph II, footnote 10 states:" . . . the 'i NRC Staff b es* nates that the normal heat generadou rate is 10.1 MBtu/hr and the sharwmal (for a full core offload) is 21.46 MBtu/hr." Vermont Yankee offers the following cla this statement.

%ces figums are based upon 6 days of decay following reactor shutdown a stated in the SRP. Using similar assumpdons except for detartmning the decay h days of decay, Vermont Yankee calculated 9.1 MBtu/Hr for normal heat gr .h and 18.I MBtu/Hr for the abnormal beat genersdon rates. (VYNPC wntten testimony at p 1

calculations are. in fact. the same, as set forth in Figure 2 of our letter to the Staff 1988 (FVY 88 17), a copy of which is attached.

6. He Intervenor's Affidavit at Paragraph 13 states: "Use of the RHR system to '

roudne backup to an inadequate spent fuel coolleg system is not, hwever, in accord intent of the design process which allows cooling i onofbythe the spent fuel . . .".

RHR system l

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Verant Yankee concurs that the RHR system was not intended to be used for the SFPCS. The system has never been operated in that inode and the appli i

spent fuel storage to 2870 assemblies does not propose to operate in that manner. with the enhanced spent fuel pool cooling system. However, it would be imprudent i

capability of the RHR to be used in that manner should some entitely unandcipated affected the espability of the SFPCS.

7. noIntervenor's Affidavit at Paragraph 16 states: "Acconting to an NRC Scaff evaluat! i the Vermont Yankee SFPCS does not have sufficient capacity to cool the norma heat load and maintain the pool water temperature below 140*F In the event of sing 3 i

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I failure," While this statement was tn:e at one time, it is misleading because the Staff co referred to was based on the use of a one pump - one heat exchanger mode, and s NRC Staff agreed wls Vermont Yankee that the proper single failure analysis

- two heat exchanger mode, and on this basis the Staff concurred that t g, VY SPPCS had 5

cooling capacity.

The exact history that NECNP omits is this: When the original application was submitte (VYN?C letter to USNRC April 25,1986) and the answers to the USNRC were de (VYNPC Letter to USNRC November 24,1986), Vettnant Yankee calculated the dec requiretact.ts and corresponding capacity of the spear fuel pool cooling system based on the following assumpnens:

1507rnaximum fuelpool temperamre One spent fuel pool cooling train consisted of 1 pump and thest exchanger 83% capacity factor for 18 months This led to a calculadon of 42 days from shutdown to ability to restart, en de assump pump.I heat exchanger was the appropiate single acdve failce mode.

The NRC's calculadon of decay heat load requirements and conesponding capa fuel pool cooling system (NRC Staff response to NECNP's First Set of Interrogatori Docketed Request to the NRC Staff August 5,1987) were based on de following as 1407 Maximum (celpool temperature One spent feel rool cooling trato consisted of 1 pump and I heat exchanger 100% capacity factorfor 18 monds This led to the Staff's calculation of 69 days required from shutdown to restart, on the s

"*"medM about the appropriate single failure mode. This result led to a reassessment of what was in fact the correct single failure mode (and resulting maximum system heat rem aftera sinyle active fallms).

As a result of discussions with the NRC, Vermont Yankee reevaluated the decay h 4

l MAR 20 '99 12 49 e.6 requirements and reevaluated the coneaponding capacity of the Spent Fuel P based on the following assumptions (VYNPCletter to USNRC Merch 2,1988):

150*F maximum fuelpool temperanne One spent fuel pool cooling trab consisted of 1 pump and 2 heat exchangers 100% capacity factorforla months.

He iauhs (VYNPC le::er to USNRC March 2,1988) of the reevaluadon clearly indi the exisdng spent fuel pool cooling system as well as the enhanced spent fuel are sufficient to remove all normal heat loada even considering single failure cases. T agreed, upon reanalysis, that the appropriate one pmnp two heat exchanger mode w (see NRC's Response to NECNP's first interro5atories, 12/27/88, response to question 5 ) The SFPCS can maintain the temperature of the apent fuel pool below 150*F using heat exchangers. The 150'F limit is in accordance with the Technical Specification Yankee. For the case of a fullcore off load the RHR system is used to cool th and it has the capability to also keep the spent ft:el pool temperature below 150*F.

8. The Intervenous Affidavit at paragraph 17 states: "the licensee has idendfed the benign single failure possible." Thla assertion is wrong. %e single active failure that h greatest effect on the capabllhy of the SFPCS to cool the spent &ci poolis the loss of one SFPCS pumps.1 (See also pa:agraph 9 below). With the loss of one pump the sys have one puts and two heat exchangers, which has been shown egabic cf ma fuel pool temperature below the required limh of 150*F after 10 days of decay. (Le 1

When considering the single failure criterion, the loss of one ef the two SFPC was determined to have the steatest effect on the capability of the SFPCS to cool pool. The most limidng scenano that would casse this event would be a loss of nor coincident with the loss of one of the two in the availability of two SW pumps, one RB y diesel generators. This scocario would result pump, and one SFPCS pump (arnong others).

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USNRC dared March 2,1988). %is capability was proven using an SRP bai

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and methods that yielded resulta comparable to the heat loads calculated by NR documented in "NRC Staff response to NECNP's First set of Interrogatories an Request to NRC Staff " dated August 5,1987. Thus the mm limMa* single activI beenidentifled and evaluated.

9. The Intervenor's Affidavit at paragraph 18 states: "There are several postu

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failures for Vermont Yankee which would result in is availability of only one tra i Safety Features (ESP) equipment (l.c.,1 train of RHR.1 train of Service W j

and 1 SFPCS heat exchanger) being available." This testimonyis not correct. De System is designed such that any of the four service water pumps can supply a system. Further, even under design basis accident condidons, any two pumps are$

supplying the required cooling capacity (FSAR Section 10.6.5). Two service w l.

Powered electrically from each of the two Emergency Diesel Generators, thus makin 1%det from the " postulated single fail: ass" noted by the Interveners. This is cl VY FSAR Section 10.6 and Figure 10.61A. The Reactor Building Closed Coo -1 (RBCCW), which is the cooling loop between service water and the Spent Fu System (SFPCS), is also not a train.a' ligned system, that is to say, either pum cooling flow to either or both heat exchangers, u is clearly shown in VY FSAR Sec j

Figure 10.91. As we described earlier, the SFPCS is also not a train aligned syste FSAR Secdon 10.5 and Figure 10.51. Derefo:e, even with the " postulated single in the Intervenor's Affidavit two SFPCS heat exchangers and at least one SFP always available, and receive sufEclent f'ow,for heat removal from the Spen Fue!Po

10. The Intervenor's Affldavit at Paragraph 19 states:"Under these failure con train of service water will be available. Thus the fact that the SFPCS heat exchan connected is largely ir:elevent since one of the two SFPCS heat exchangers will not have flowing pass the secondary side of the heat exchanger. . . ."

As we demonstrated in the prior paragraph, this asserdon is simply erroneous.

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11. The Intervenor's Affidavit at paragrsph 21, foomote 20 states: "The St'! l the service water system is therefore not an acceptable Seismic ter' Category I m for the 'sput fuel pool. . . . The cooling tower deep basin altamate cooling c classification is not adressed in the updated FSAR. In addition piping cell to the service water system pumps would also have to be Seismic C isoladon valves wcold have to be provided. The NRC Staff has concluded cooling cellis not an acceptable Seismic CategoryImakeup source forthe spen assertion is not true. What is true is that, as of the dme of &c NRC Staff statemen

j Staff had not reached any anal conclusions. In fact, the service wanor s leismic makeup system (PSAR Sections 10.6 and 12), and we believe the Staff .

In particular, the cooling tower deep basin is a Sesmic Category I strucmte. (F

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10.8.3) The piping from the deep basin to the RHR service water pumps (PSAR Appendix A). He fire water system is not a seismically quallflod system

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from the service water system by a normally closed manual valve (FSAR P!g fire water piping and valve making the connection to the Service Water Sy qualified Category 1(FSAR Appendix A). (Also VYNPCletier to USNRC dated Mal FVY 8817),

12. The Intervenor's Affidavit at paragraph 21 footnote 21 states: "The Staff ha demonstrated, however, that the condidone requWd to reader this makeup pa Category 1, . . have been met for the existing SFPCS or for the evM enhan:ed syrtem."

Vermo.it Yankee offers the following clarification to these statements. The en Pool Cooling System has been designed to provido a Seismic Category I m fuel pool.The system description for the enhanced system ( YYNPC letter to hitl '

1988), included a Figure A 1 that clearly shows a valved connecdon to the S service water system. This path, when installed, provides a fully Seismic Catego makeup path independent of the existing seismic makeup path described in our clariAc footnote 20 above.  ;

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13. For the reasons set forth in the two prior paragraphs, the bases for the in Intervenor's AffidavitParagraph 21 and 22 areinvalid. ,

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14. The Intsrvenor's Affidavit at paragraph 23 states: ". . . given the tuost crit sing 16 failure, the configuration of the Vermont Yankee SFPCS is . . . one exchanger...." (

As demonstrated above, this conclusion is wrong as a matter of readily demonst single active failure that has the greatest effect on the capability of the SFPC ,

poolis the loss of one of the two SFPCS pumps. Because of the cross connec service water system and the RBCCW system, cooling water will always be ava SPPCS heat exchangers.

15. The Intervenous Affidavit at Paragraph 26 states In footnote 4 ofits Novem tiling, the licensee states that prior to restart of the reactor there is no requireme RHR trains on the reactor. His is quite likely incorrect." Vermont Yankee o clarification of this atatement.

Footnote 4 from the November 10, 1988 Memorandum of VYNPS in response Memorandum and Odw of 10/24/88 and Motion for Per Tech Leave to Pile the Spec Secdon 3.5.A.1 " both . . . the 1.PCI subystems (Mode of RHR System) 3 be operable prior to Reactor starmp mode from the coki shutdown conditio shutdown / refueling operadons, Tech Spec Sections 3.5.H.3 and 4 govem ope of the Core and Containment Cooling Subsysterr.:(!ncluding RHR). These provisio require ava!! ability of both RHR trains before the plant can proceed fmm cold shutd refueling.

16. We Intervenous Affidavit at paragraph 28 states :

'"Ihis (referring to the drawings subalued to the Staff on the FA-,4y Standby Subsystem] providea no informadon on e design for the ett.anced syttem's pamps, leaving critical design quesdens unans there any alngle-failure points among the AC and DC power supplies for valves i While the information referred to was not ce the drawings, it was contained in the bal 8

1 MAR 20 '99 12151 -P,1C materials submitted to the Staff, in particular, the pumps for the Emergenc wul be powered by separate AC and DC busses. Then are no " single AC and DC power supplies for valves that would be more . In limidng than a p addition, the new system will be designed and installed as Seismic Catego portions of the exisdag SFPCS (suction 8" FPC 13, discharge 6" PPC 22) qualified as Seismic Category I. The new system will be physically located in Banding, a Seismic Cuegory I strucmre, designed to withstand wind forc (FSAR Section 5.3.3.3).

The new system design will also protect each train from common effects caused by fire, Cooding, and missiles (VYNPC le:ter to USh1C date

17. Based upon the above clarificadons and corrections to the informa Interveners, it is clear that the requested ll:ense amendment sadsfies all ap requirements and therefore the Board should approve the license smaaA an additional 870 fuel assemblies in the spent fuel pool at Vermont Yankee, 9

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de foregoing statoments are true, IMst[ df( of March I98 a is N '

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StateofVennxt:

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..I}?.1W Then personally appcated John T. Herp, 'who being first dWy sworn

$e ferepdagr.atementsarsnue,tMsdelof Maren 1989,beforem 9

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Commonwealth hau type of Massachusetts 3,,

the foregoms statements are true, this.AQ.of March.19h LWL BTofaryPubil(

My Commission expires /d &#A Commonwealth h "* of Massachusetts: -

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cash that the foregomg statements are true, this .3 L ,

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nAa ze >es ws2 3.0 HEAT LOAD COMPARISON 3

NRC VY

_ DAYS HEAT LOAD DAYS __

HEATLOA.R 6.25 10.17NBTU/HR 6 10.35MBTU/HR 6.92 9.91 7 9.93 7.92 9.58 8 9.59 8.92 9.31 9 9.32 9.92 9.09 10 0.1 l 4

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FIGURE #2'

.-4' VYN-123 ASLB - Special' l 1

CERTIFICATE OF SERVICE 'f 1

l 1 I,~R-. K. Gad III, hereby certify that on March 20, 1989, l I made service of the within " Vermont: Yankee Nuclear Power  ;

Corporation's Motion,to Strike the State of Vermont's So-  !

Called ' Rebuttal' Testimony;" " Vermont Yankee Nuclear Power Corporation's Requested Findings of Fact and' Rulings of Law;" .l and " Sworn Written Rebuttal 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. S 2.1? l3 ( A) in the indicated manner to:'

Charles Bechhcefer,. 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 i U.S. Nuclear Regulatory Montpelier, VT 05602 l Commission FAX: 802-828-2342 )

East. West Tot,ers Building l 4350 East' West Highway I Bethesda, MD 20814 l

Gustave A. Linenberger, Jr.* Andrea Ferster, Esquire ***

Administrative Judge. Anne Spielberg, Esquire Atomic Safety and' Licensing Harmon, Curran & Tousley Board Panel Suite 430 U.S. Nuclear Regulatory 2001 S Street, N.W.

Commission Washington, DC 20009 East West Towers Building FAX: 202-328-6918 4350 East West Highway

' Bethecda, MD 20814 Mr. James H. Carpenter

• George B. Dean, Esquire

• I Administrative Judge Assistant Attorney General Atomic Safety and Licensing Department of the Attorney Board Panel General U.S. Nuclear Regulatory One Ashburton Place Commission Boston, MA 02108' l Omni Parker House 60 School Street Boston, MA 02108 l

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u_________.__.________________. _ _ - . _ _ _ _ _ .)

4-Adjudicatory File ** Ann P. Hodgdon, Esquire

• Atomic Safetyfand 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 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Atomic Safety'and Licensing ** Geoffrey M. Huntington, Esq.**

Appeal Board Panel Office of the Attorney General U.S. Nuclear Regulatory Environmental Protection Bureau Commission State House Annex Washington, DC 20555 25 Capitol Street Co NH 03301-6397 l i

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u e R. K. Gad III / l

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