ML20028E147

Testimony of C Hillman & T Postlewait on Sinclair Contention 4.Contention Has Faulty Premise.Administrative Procedures & Design Features of Plant Adequate to Meet B&W Specified Secondary Water Chemistry Limits.Related Correspondence

ML20028E147
Person / Time
Site:	Midland
Issue date:	01/17/1983
From:	Hillman C, Postlewait T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML20028E139	List: ML20028E138 ML20028E147 ML20028E156 ML20028E163
References
NUDOCS 8301210028
Download: ML20028E147 (14)

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DOCKETED TESTIMONY OF CRIS HILLMAN tlS M c AND TERRY POSTLEWAIT

'83 Jrq 19 y9;93 ON SINCLAIR CONTENTION 4 My name is Cris Hillman. I am employed by Consumers Power Company as the Plant Chemical Engineer at the Midland Nuclear Plant. In this job, my responsibilities include management and development of an integrated plant chemistry program. I have a BS in Chemical Engineering from Michigan State University and five years experience in chemical engineering in support of nuclear power plant operations at Palisades and Midland. Further information is contained in my resume in Attachement A. I believe as a result of this training and experience, I am qualified to address Sinclair Contention 4.

My name is Terry Postlewait. I am employed by Consumers Power Company as a Staff Engineer in the Design Production Department, Mechanical / Nuclear Section of the Midland Nuclear Plant Project at the Company headquarters in Jackson. In this job, my responsibilities include such activities as the revi ;f mechanical systems design and support of licensing activities. As required, I interface with Bechtel and Consumers Power Company personnel in the resolution of design and construction problems. I have a BS in Mechanical Engineering from the University of Toledo and ten years experience in the design, installation and operation of mechanical equipment.

Eight of these years have been with Consumers Power Company, associated with I

fossil and nuclear power plants. I have been on the Midland Project specifically since April of 1980. Further information is contained in my 8301210028 830117 PDR ADOCK 05000329 T PDR miO183-3545a141

2 resume in Attachment B. I believe as a result of this training and experience, I am qualified to address Sinclair Contention 4.

Sinclair Contention 4 states:

"The degradation of steam tube integrity due to corrosion induced wastage, cracking, reduction in tube diameter, and vibration induced cracks is a serious unresolved safety problem at the Midland Nuclear Plant. It is admitted that the chemistry of the cooling water is critical to prevention of steam tube failure, (NUREG-0886). However, the fact that these plants depend on cooling water from the cooling pond increases the likelihood of corrosion and poor water chemistry because the DEIS states that the plant dewatering system will first be discharged to the cooling pond. (DEIS at 5-2). That means that many wastes, including radioactive materials from leaks and spills on the reactor site, can enter the cooling pond and disrupt the chemistry of the pond. Therefore, due to this contribution of an undetermined amount and quality of ground dewatering inflows to the cooling pond, the NRC's bland assurance that corrosion is unlikely due to the lack of sodium thiosulfate, is unsatisfactory. (NRC Response to Interrogatory 9.J.) In fact, due to the contribution of groundwater, the NRC is not fully aware of the likely constituents of the cooling pond, and the findings required by 10 CFR SS 50.57(a)(3)(i) and 50.57(a)(6) cannot be made."

I. Introduction Sinclair Contention 4 is based on the faulty premise that the control of cooling (pond) water chemistry is critical to the prevention of steam generator tube failure (inaccurately deduced from misinterpretation of NUREG 0886). The fact is, NUREG 0886 refers to the control of secondary water chemistry, not cooling water (pond) chemistry, as being a key to minimizing steam generator tube degradation. As can be seen from the simplified sketch of the Midland Plant thermal cycle shown in Attachment C, cooling water from the cooling pond does not flow through the secondary system or the steam generators during normal operation. Regardless of what the cooling water chemistry may be, administrative procedures and design features of miO183-3545a141

o 3 the plant are adequate to meet B&W specified secondary water' chemistry limits and thus, steam generator tube corrosion will be minimized.

The water normally used in the secondary system is supplied by

, the Plant Makeup Demineralizer System and does not come, directly or indirectly, from the cooling pond. There are only two circumstances under which cooling water from the cooling pond can be introduced into the secondary system and come into contact with the steam generators.

The first is leakage through the condenser. The second is emergency operation of the auxiliary feedwater system, taking water from the pond.

These are discussed below.

II. Description of How Cooling (Pond) Water Can Enter the Secondary Cycle A. Condenser Leaks Attachment C includes a simplified schematic cross section ,,

of a typical condenser. Esch Midland Unit utilizes such a condenser to condense the turbine exhaust steam for reuse in the secondary cycle. The condenser is basically a sheil and tube type heat exchanger with the turbine exhaust steam being condensed on the shell side and the cooling water being pump <d through the tubes.

The cooling water flowpath is physically separated from that of the steam by means of the tubes and the tubesheets. Each tube-to-tubesheet joint is made watertight by mechanically expanding the tube into the corresponding hole in the tubesheet.

Cooling water can find its way into the secondary cycle via the condenser if the tube-to-tubesheet joint or the tube itself miO183-3545a141

4 1

l should develop a leak. Should this occur, the solution is to reroll the tube-to-tubesheet joint or to insert a mechanical plug in each end of the tube. These techniques are standard in the industry and are quite effective, t

In-leakage of cooling water to the secondary system is normally indicated by on-line instrumentation. The sample point used to detect a suspected condenser leak is located in the condensate pump discharge piping as noted in Attachment C. The condensate pump discharge sample is continuously monitored for cation conductivity, pH, dissolved oxygen, sodium and silica. A cooling water-to-secondary leak will normally be indicated by an increase in sodium and/or cation conductivity level. Grab samples for cation conductivity and sodium are also taken from the same sample point and analyzed in the laboratory once per shif t. This serves as a check of the on-line instrumentation and is used to either confirm or reject the suspected condenser leak.

In addition to the methods and practices described above, each condenser is equipped with a hotwell* sampling system. The system collects condensation and/or leakage from each tubesheet.

Samples are then collected and analyzed in the laboratory on an as-needed basis. This system is useful in identifying which individual tube bundle contains the leak.

• The term "hotwell" is standard in the condenser industry and denotes the bottom section of the condenser in which the condensed steam (condensate)is collected prior to being pumped through the demineralizers to the steam generators.

miOl83-3545a141

5 Procedures are now in place that require management personnel be informed of off-normal chemistry conditions which includes suspected condenser leaks. Additionally, Technical Specification 16.6.8.4, Item C, Subsection vii has been proposed which concerns cooling water-to-secondary leakage. This proposed Technical Specification states: "When condenser in-leakage is confirmed, the leak shall be repaired, plugged or isolated within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />."

Once a leaking portion of the condenser is identified, that ha,1f of the condenser can be isolated by shutting off cne cooling water loop. The specific leaking eierent (eg, tube or tube-to-tubesheet joint)can then be further identified by means of portable leak detection equipment, and the leak corrected by plugging or rerolling the tube-to-tubesheet joint.

B. Auxiliary Feedwater System The second path for potentially introducing cooling pond water into the secondary system is by way of the Auxiliary Feedwater (AFW) System. The AFW System, initiated by an Atxiliary Feedwater Actuation Signal (AFWAS), is used to supply water for shutdown to the secondary side of the steam generators in the event main feedwater is lost. During Plant operation, the AFW pumps are aligned to take suction from the condensate storage tank, in the event AFW is needed. Should an AFWAS occur, condensate from the condensate storage tank would be pumped to the secondary side of the steam generators. In the unlikely event that this supply of water miO183-3545a141

6 9

to the AFW pump suction should be lost for a specified period of time and an AFWAS be present, suction is automatically transfereed to the service water system, which is a source of cooling pond water. In either of these cases, AFW is used only to shut the plant down, not to continue operating. The frequency of occurrence of the coincidental set of circumstances leading to the use of cooling pond water as a source of AFW is extremely low. The plant can be safely shut down in this scenario of using cooling pond water in the steam generator; prior to restarting the unit, necessary actions, inspections, etc would be performed to ensure integrity of the steam generators.

Note that the water in the condensate storage tank, referred to as " condensate," is a mixture of condensate from the secondary system and demineralized makeup water from the Plant Makeup Demineralizer System and is essentially the same quality as secondary system water. The Plant Makeup Demineralizer System takes its normal suction from the City of Midland water system but can use Dow Chemical Company's demineralized water as a backup source. In cither case, the source water is processed through the plant makeup i demineralizers to assure proper quality prior to being pumped to the i

condensate storage tank. The cooling pond is not a source for demineralized or makeup water.

l l III. Description of Secondary Water Chemistry Control The secondary system of the plant is a water system which uses t

ammonia for pH control and hydrazine for oxygen control. The allowable piO183-3545a141 i

l I

7 maximum limits of these and other parameters are specified by B&W. The limits to be met by CP Co are in all cases the same or more stringent than the B&W recommendation.

The secondary systems of both Unit I and Unit 2 are equipped with full-flow deep bed condensate demineralizers. There are six condensate demineralizers in the system, five in service and one in standby. The demineralizers remove cationic and anionic impurities that exist in the condensate. The demineralizers are located downstream of the condensate pumps and have adequate capacity to purify the feedwater prior to its introduction to the steam generators. Thus, impurities which may enter the secondary system via a condenser leak are adequately removed prior to the condensate being sent to the steam generators.

Conclusions Cooling pond water quality itself is not relevant to steam generator tube corrosion. This is because the cooling pond water does not flow through the steam generators under normal opt rating conditions. In the event that condenser in-leakage were to occur, the Midland Plant's design features and procedures are adequate to meet the B&W minimum standards for secondary system water quality and thus, minimize steam generator tube corrosion.

In the unlikely event that cooling pond water were to be introduced into the steam generators by means of emergency actuation of the AFW system, the plant can be safely shut down. Appropriate actions would be taken prior to restarting the unit to ensure the integrity of the steam generators.

miO183-3545a141

8 Thus, there is reasonable assurance that corrosion of the steam generator tubes does not depend on cooling pond water chemistry; therefore, the NRC can make the findings required by 10 CFR 50.57(a)(3)(i) and 50.57(a)(6).

1 l

miO183-3545a141

ATTACEMENT A

?:r.a of Cris Hillman Education and Training 1977 Bachelor of Science in Chemical Engineering: Michigan State Unive:sity 1979 AICHE Today Series; Industrial Water Conditioning - 1.4 CT.U credits Nuclear Steam Sepply Technical Training, Eabcock & Wilcox -

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Mechanalysis Course (Vibration Testing), IRD - 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> 1950 Principles of Supervision, Consumers Power Company - 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> 1951 Radiochemistry for Supervisors, Babcock & Wilcox - 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> Human Aspects of Management, Cor.samers Pc we r Company -

20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> 19S2 Westinghouse PVR Chemistry Course, Westinghouse - 5 wecks ES,=erience 1977-1978 Graduate Engineer, Palisades Nuclear Plant, Consumers Power Ccopany. Werked on varicus projects during refueling outage.

1978 Associate Engineer, Palisades Nuclear Plant. Worked for Plant Chemical Engineer (Palisades). Duties included support of decineralizer cperations and operator training on makeup demineralizer.

l 1978-1950 Associate Engineer, Midland Project Testing. Responsible for

development and implementation of acceptance tcst procedures.

1980 Associate Engir.eer, B C Cobb Stean Plant. Trouble shoot and increase reliability of new denineralizer system.

1 Associate Engincer, Midland Project Testing. Responsible for overall preparation and cocrdination of startup chemistry program including the criting of a startup chemistry manual.

Responsible for startup and operation of plant makeup demineralizer system.

1950-Present Chemical Engineer, Midland Nuclear Plant. Responsible for directing pl.r.t chemist :y staff activities such as startup che:tistry supp;rt, budget p.:cparation, chemistry procedure prepa stion .snd revice, and technical surport for chemistry l related activities.

ti C I S 3- 2.i45b 173

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ATTAC2fEhT B Resume of Terry Postlewait Position Staff' Engineer, Midland Nuclear Plant Project, Design Production repartment, Mechanical / Nuclear bection Education University of Toledo, 1970, BSME

- ~

Eggerience Apr-Present Jcined the Midland Project as a Senior Engineer in the Design 1980 Production Department. Duties include assis snce to Safety &

Licensing Dcpartment, review of design of mechanical systems, resolutien of p ctlees, comzenting en developnent of specifi-cations, procedures and drawings and as-needed assistance to engineering and field personnel. In June of 1981, proccted to Staff Engineer and involved with additional duties such as coordinating Design Production Department assistance to field activities involving completion / turnover of syst os, pr . .ici-pation in program to control design changes and assista.ae to Safety & Licensing Eepartment in developing and aiministering the Spatial Systems Interacticn Program and in efforts to ob- , ,, e tain NPDES Permit and finalize the Midland Plant E-vironmental ,s<

. Statement.

/ .

Aug - Apr Consumers Feuer Company 1977 1980 Sgnior Engineer - Responsible for reviewing design of new, and modification to existing, power plants. Prinarily involved with review of r.echanical design of Midland Units 1 & 2. In December 1977, also assumed the duties of Project Engineer for completica of D E Karn Plant, Units 3 & 4 and modification work on Karn Unit 4 cold rebeat piping to solve excessive noire and vibration problem.

Feb - Aug Alyeska Pipeline Service Company 1575 1977 Rotating Equipocet Engineer - Assigned to the tanker loading teroinal for the Trans-Alaskan pipeline. Duties included reviewing mechanical design, meritoring the contractor to ensure proper installation and alignment of rotating l

i equipment, startup probles assistance and field design -

changes.

1971 - 1975 Coasumers Power Ccmpany Associate & General Engineer - Duties included review cf mechanical design for new nuclear and fossil generating units including specifications, bids and bid evaluatiens, QA requirements, witnessing performance tests and preoperational test reviews. Vas primarily associated with review of

! rechanical design of D E Earn Plant 3 & 4 ciOIS3-3545c173 l

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1965 - 1971 Surface Combustion Division, Midland Ross Corporation Technician r.nd Design Engineer - Worked 1965 - 1970 as sechanical lab technician in davelopnent of steel and glass

.. pelletizing processes, industrial heat treating furnaces ano burners. Upon obtaining cy BES2 degree in 1970, worked as design engineer responsible for desiEn and drafting on heat treating furnaces.

1965 Johns-Manville Laboratory Technician - Worked in R&D section developing fiberglass products and related manufacturing equipmen:.

1964 - 1965 Stauffer Chemical Company Chemical Laboratory Technician Performed qualitative analyses for on-line chemical processes.

1963 - 1964 Toledo-Beaver Tools Eguipment Operator - Operated latbes, drill presses and mills in the production of pipe cutting and threading tools.

Additional Training June 1977 Attended training on nachinery vibration detection, analysis and balancing given to IRD Mechenalysis, Inc , , -

,s.-

- - June - Dec Attended five courses on Prsgrar:matic Qaality Assurance 1978 1982 Training for the Midland Project June 1978 Attended Technical Seminar on machinery vibration given by Mechanical Technology, Inc May 1979 Attended Seminar on piping design given by Teledyne Engineering Jan 1981 Attended one week training course on the B&W simulator i

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I 4J . . . MIDLAND 1&2-FSAR RESUME OF WILLIAM BECKMAN 13A.2.6 ctLATED CormF#m ex.n CHEMISTRY / HEATH A

PHYSICS SUPERINTENDENT 'a Education and Training '

00;KEJE9 1967: Bachelor of Science in Chemistry:

University, Fairfield, Connecticut Fairfield' '

1971: Naval Officer Candidate School, Newport, FN 19 N0 5d hone Island U.S. Navy - 6 months 1972: ~ T. ,

Naval Nuclear Power School, Bainbridge, Marylanjjf"*"

6 months ~

Nuclear Power Training Unit, SlC Prototype, Windsor, Connecticut U.S. Navy - 6 months _-

1973-1975: Various Service Schools 1976: QA Indoctrination Workshop, Consumers Power Company - 3 days 1977: Radiochemistry for Supervisors, Babcock & Wilcox -

10 days Principles of Supervision, Consumers Power Company - 5 days 39 1978: Human Aspects of Management, Consumers Power Company - 5 days 1979: Principles of Data Processing and FORTRAN Programming, Delta College - 4 credits Public Presentation Skills Course, Central Michigan University - 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> Principles of Leadership Effectiveness, Consumers Power Company - 3 days 1980: Techniques of Supervision, Consumers Power Company - 5 days Managerial Economics, Consumers Power Company -

5 days 1981: Annual Short course on Radiation Protection, University of Michigan - 10 days Selected' Topics in Reactor Health Physics, HP Society, 1981 summer school, University of Kentucky - 5 days Effective Management, Consumers Power Company -

4 days )

Revision 39 13A.2-12 11/81

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Expnrience l 1967-1971: Senior Sales Engineer, Stero Polymers, Goodyear Chemical Division, Goodyear Tire and Rubber 1971-1972: Attended various Service Schools, U.S. Navy 1972-1973: Qualified Engineering Officer of the Watch. on SIC reactor plant, Windsor, Connecticut 1973-1975: 39 Engineering Officer of the Watch, responsible for watch supervision and overall safe operation of S5W reactor plant - 32 months 1973-1974: Main Propulsion Assistant and Radiologi' cal Controls Officer, USS John C. Calhoun SSBN 630B. Duties included supervision of nuclear plant mechanical maintenance radiation protection, chemistry, and radiochemistry - 24 months 1974-1975: Electrical Officer and Sonar Officer, USS John C.

Calhoun SSBN 630B. Duties included supervision of nuclear plant electrical maintenance - 8 nonths 1 43 1975-1976: General Engineer, Chemistry Department, Palisades Nuclear Plant (CE PWR), Consumers Power Company.

Duties included design and implementation of plant I modifications and preparation of chemistry procedures - 9 months 1976: General Office, Palisades Nuclear Plant, coordinated and scheduled refueling outage -

6 months 39 1976-1977: General Engineer, Midland Nuclear Plant. Duties included design reviews of plant systems with respect to chemistry, environmental, and radiological considerations 1977-1979: Chemical Engineer, Midland Nuclear Plant.

Responsible for development of the Chemistry / Radiochemistry Department. Duties expanded for 9 months in 1977 to include supervision of the environmental and radiation  !

protection programs 1980-Present: Chemistry / Health Physics Superintendent, Midland 143 Nuclear Plant 139 Revision 43 13A.2-13 4/82 I

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