ML20247A840
| ML20247A840 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/10/1989 |
| From: | Kudrick J Office of Nuclear Reactor Regulation, NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML20247A784 | List: |
| References | |
| OLA, NUDOCS 8903290206 | |
| Download: ML20247A840 (8) | |
Text
.
t March 10, 1989 CqtgifP UNITED STATES OF AMERICA
.gg gp, y gp gg NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Fi 0L-In the Matter of VERMONT YANKEE NUCLEAR
)
Docket No. 50-271-OLA POWER CORPORATION (Spent Fuel Pool Amandment)
(VermontYankeeNuclearPower
)
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 l
Branch, and I am responsible for review and oversight of reviews involving aspects of spent fuel storage, including spent fuel pool cooling, under 10 C.F.R. Part 50.
NECNP'S Statement of Contention 1:
The spent fuel pool expansion amendment should be denied because, through the necessity to use one train of the reactor's residual heat removal system (RHR) in addition to the spent fuel cooling system in order 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.
l My response to Contention 1:
The Staff has reviewed the thern!al 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,
$0b.Ob0lk
[
G O~--_--__-______-____-------
1 a i maintain the pool temperature below the TS limit while considering a sir.gle active failure.
j Any consideration of the adequacy of spent fuel pool cooling l
capability for the currently authorized storage limit was resolved in the course of our review. The Staff has concluded that the spent fuel pool rooling system is capable of removing the heat load from the maximum l
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 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, l
I particularly Criterion 44 and SRP Section 9 L3, " Spent Fuel Pool Cooling 4
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 9.1.1.
j The design m ts the requirements of General Design Criterion 44 regarding decay %:at 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 j
isole. tion capability of system components and piping, if required, such j
that the ability of the system to remove decay heat will not be compromised.
j l
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 I
pursued this lack of information with the Applicant. Questions took on
l 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 Licensee 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 time 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
E
. many forms including questions concerning. the conditions and proccdores 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 poo1' temperature limit. The Staff evaluation, the operational restrictions, 'and acceptance of this system j
are discussed in our SER dated October 14, 1988.. Because of the applicant's connitment 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 1
ccoling system was assumed to be available.
The review of the capability l
I of the existing spent fuel pool cooling system to acconnodate the heat l
1 load from 2870 fuel assemblies was terminated because it was superseded by the June 9,1988 connitment.
Finally, in Contention 1 there is an identified concern about the !"e of the RHR system 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 1
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 I
_____.______x___.______
_m__m
y-l
- 5.-
during refueling, when the head is removed and the spent fuel pool is l
' joined with the. reactor 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 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
'I
{
filed in this proceeding:
1.
.The' Staff's SER dated October 14, 1988; l
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.
)
I
\\
John A. Kudrick V N v'
l Selc ion Chief, BWR Systems
- Section, Plant Systems Branch Subscribed and sworn to before me this /#4y of March,1989 1 /sb id NO Notary Public My commission expires: 7- /- 9/
b 1
x g.. i,i' ~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'89 MAR 27 A9 47 BEFORETHEATOMICSAFETYANDLICENSINGBOAR};,
l
)
W Locu
- i In tne Matter of VERMONT YANKEE NUCLEAR Docket No. 50-271-OLA h.
POWER CORPORATION (SpertFuelPoolAmendment)
(VermontYankeeNuclearPower
)
Station)
CERTIFICATE OF SERVI _CE I hereby. certify that copies of " AFFIDAVIT OF JOHN KUDRICK ON BEHALF OF THE NRC STAFF REGARDING NECNPS CONTENTION 1" in the above-captioned proceeding
.g 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 Comission's internal mail system, or as indicated by a double' asterisk by use of Facsimile Machine, this 10th 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 Comission 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 Licensi0g Board Environmental Protection Bureau i
U.S. Nuclear Regulatory Comission 25 Capitol Street Washington, D.C.
20555 Concord, NH 03301.-6397 Atomic Safety and Licensing Board Andrea C. Ferster, Esq **
Panel (1)*
Harmon, Curran & Tousley U.S.
Nuclear Regulatory Comission 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 Montpelier, VT 05602 One Ashburton Place, Boston, MA 02108 i
R.K. Gad, III, Esq.**
Ropes and Gray Jay Gutierrez,, Esq.*
225 Franklin Street Regional Counsel i
Boston, MA 02110 USNRC, Region I 475 Allendale Road King of Prussia, PA 19406 l
g.
- c..
g n
- pY, l;-
'.; 5
3:,
l u;
~ -
j y
2.'
i
+
c e
1 s of 1
. Atomic Safety;and Licensing Appeal Docketing and Service Section*
4 Panel ~(5)*.
Office'of the Secretary, L'
U.S.' Nuclear Regulatory Comission
'U.S.' Nuclear Regulatory Comission j
l
.1 Washington, D.C.
20555 Washington, D.C.
20555 l
l l
Adjudicatory. File
- I Atomic' Safety and Licensing Board j
U.S. Nuclear Regulatory. Comission Washington, D.C.
20555
,j l$N a
Patricia A. Jehle.
)
. Counsel for NRC Staff j
.i I
.l 4
.i 1-I
____-_x___--
l
.1 y
John A. Kudrick Professional Qualifications Plant Systems Branch q
Division of Engineering & Systems Technology l
I I am a Section Leader in the Plant Systems Branch in the Division of j
Engineering and Systems Techr. ology, Office of Nuclear Reactor Regulation, j
United States Nuclear Regulatory Commission.
In this position I supervise a j
group of engineers in performing technical' reviews, analyses, and evaluations concerning the construction and operation of nuclear power reactors.-
t 1
I received a Bachelor.of Science Degree in Mechanical Engineering in 1959 a'nd a Master of Science Degree in Mechanical Engineering in 1962,.both from Drexel University. Subsequently I have taken a number of advanced
{
courses in fluid flow and thermodynamfes as well as several system type courses directly related to comercial power plant design.
)
1 My thirty years of ' experience have been almost exclusively in the field of nuclear engineering.
Prior to my joining the Comission, I spent a combined j
six years with Martin Marietta Corporation and McDonnell Douglas Corporation.
J Projects in which I was involved include the nuclear power station at the South i
Pole, terrestrial radioisotope power generators, and nuclear power generators J
for space applications.
During the following-seven years, I was employed by Hittman Associates, engaged in a wide variety of nuclear related assignments.
j They included such topics as the artificial heart, heart pacemaker, space j
power, as well as comercial power.
l" I joined the Containment Systems Branch, Division of System Safety, Office of 1
Nuclear Regulation of the Nuclear Regulatory Comission in September,1972.
l' In'1975 I became a Section Leader and have functioned in this capacity in both containment systems as well as balance of plant related branches since that time. During the past five years, I have been a Section Leader in the Plant Sy 9 ems Branch.
My duties have been both as a technical reviewer and a.
i first libi technical supervisor.
I have had an average of six engineers under j
lay supervision.
I have review and supervisory responsibility for the i
following nuclear power plant systems and areas of concern:
containment performance, containment cooling systems, new and spent fuel storage, spent
{
fuel pool cooling, fuel handling, service water, component cooling water.
l condensate storage, ultimate heat sink, instrument air, main steam isolation valve leakage control, containtnent isolation valves, combustible gas control i
systems, heating ventilating and air conditioning, flood protection, post-fire l
protection, and site analysis.
In general, I have responsibilities in most l
balance of plant activiths, i
With respect to the technical issues related to the Vermont Yankee request to l
increase the number of spent fuel assenblies allowed in the spent fuel pool, I l
have been the technical supervisor for all efforts within the Plant Systems j
. Branch scope of review during the past two and one half years.
In.this
(
capacity, I have also participated in the actual review of the cooling C
performance of the fuel pool systems.
4 l
i i
--