ML17340A887
| ML17340A887 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/11/1981 |
| From: | Codell R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17340A884 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8103240519 | |
| Download: ML17340A887 (12) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
FLORIDA POWER 8
LIGHT COMPANY
)
)
(Turkey Point f/uclear Generating
)
Units 3 and 4)
)
Docket Nos.
50-250-SP 50-251-SP (Proposed Amendments to Facility Operating License to Permit Steam Generator Repairs)
AFFIDAVIT OF RICHARD B.
CODELL ON CONTENTION 6 a, b,
- c AND e
I, Richard Codell, being duly sworn, depose and state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a
Senior Hydraulic Engineer in the Division of Engineering, Office of Nuclear Reactor Regulation.
2 ~
Contention 6 states, in part:
There are likely to occur radioactive releases from one or more stored assemblies to unrestricted areas which violate 10 CFR Part 20 or are not as low as is reasonably achievable within the meaning of 10 CFR Part 50, as a
result of:
a.
substantial immersion of the steam generators in sea water during a hurricane; b.
movement of steam generators while so immersed; C.
impact of such moving steam generators upon the walls of the structure in which they are stored or upon another obiect or ob,iects; and e.
leakage through the floor beneath the stored steam generators.
810 38405(%
4'
3.
I have reviewed the above stated contention based on several sources of info~nation which include, but are not limited to:
The Steam Generator Repair Report (SGGR), dated March 28,
- 1980, (with all available amendments through February 26, 1981);
The Final Safety Analysis Report (FSAR);
The Draft Environmental Statement related to steam generator repair at Turkey Point Plant Units 3 and 4
(DES, NUREG-'0743);
The Safety Evaluation Report (SER-OL) dated March 15, 1972; and The Updated Safety Evaluation Report on the steam generator repair dated
- December, 1980 (NUREG-0756).
The proposed design for the on-site steam generator storage facility has changed considerably since the initial license amendment request.
Based on my review of the above-stated documents, I have reached the following conclusions:
(i)
In response to contention 6(a), the storage structure will now be located at an elevation of 17.5 feet Mean Low Water (MLW) with an additional elevation of 0.5 feet for the floor height (see Figure D.F 1, from the SGRR, attached).
The storage structure would have originally been at a water level of only 5.0 feet MLW.
During the safety review of the plant, the Design Basis Flood event was the Probable Maximum Flood (PMF), identified as a hurricane surge which would reach a stillwater level of 18.3 feet MLW (SER-OL, p. 10).
The Probable Maximum Flood is defined as the most severe flood due to the most adverse natural phenomena which could reasonably occur at that particular site.
In 1/
USNRC, Regulatory Guide 1.59, "Design Basis Floods for Nuclear Power Plants."
4i
addition to the still water level of 18.3 MLW, it was determined that wind generated waves could run up on the vertical walls of the intake structure to 22.5 ft MLW (SER-OL, p. 10).
During an assumed occurrence of the Probable Maximum Flood, the storage building would be exposed to the still water level of 18.3 feet, but not to the high runup associated with the plant intake structure.
The storage building is located on a filled plain about 65 feet from a
graded 3 on 1 slope which runs down to a level of 5 feet MLW.
(See attached figure.)
The still water level on the 17.5 feet MLW plain would be only 0.8 ft.
Incoming large waves would break on the 3 on 1 slope, well short of the storage building.
The maximum wind generated waves which can b
su. tained on the plain without breaking is about 80 percent of the water depth, or in this case about 0.6 ft., crest to trough.2/
This wave would be expected to cause only minor runup on the storage building, probably less than 1 foot, to an elevation of less than 19.3 feet MLW.
Since the floor of the storage building will be at 18.0 feet MLW, there will not be a significant immersion of the steam generators caused by a hurricane.
(ii)
In response to contention 6(b) and (c), as demonstrated in response to contention 6(a), there will be no significant immersion of th steam generators caused by the Design Basis Flood.
Furthermore, the Staff has calculated an approximate specific gravity for the steam generator of greater than 1.7.
(1.7 times the weight of water).
There-fore, the steam generators would not float even if immersed.
2/
U.S.
Army Corps of Engineers, "Shore Protection Manual," Coastal Engineering Research
- Center, Third edition
( 1977), section 3.
~ t
(iii)
In response to Contention 6(e), the Staff has considered the possible waterborne pathways to the environment or man of the leakage of radioactivity from the steam generators, although no credible mechanism for such a leakage is likely.
Liquid radioactive contamination, if released from the steam generator, would be inhibited from being released to the environment by the integrity of tne storage building, including a
-inch thick reinforced concrete floor.*
Even if the spilled radio-activity could enter the ground, no potable ground wate'r could h.
a,fected.
The two ma.ior ground water units underlying the site, the Biscayne aquifer and the Floridian aquifer, are both highly saline
- and, in addition, flow in the direction of the ground water gradient which is generally away from land.
Any reversal of the ground water gradient, for ins tance from overpumping or drought, will cause salt water intrusion in the Biscayne aquifer.
This intrusion would make the water unfit for human consumption irrespective of any possible contamination from the Turkey
~oint site.
Any contaminati'on entering the ground would.have to percolate through, approximately 18 feet of engineered fill and soil before reaching the water. table.
The contamination would then migrate 1'aterally with the slow ground water flow toward the canal system which completely surrounds the plant site.
The Staff estimates that the minimum ground water travel time from the storage building to the canal system wouldbe several years.
In addition, most of the radionuclides would move more slowly than this through the ground water because of the process of sorption.
Since the steam generators will be inspected quarterly, any radioactive The building was originally to have an earthen floor.
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leakage wou'<d be discovered well before radioacti've ground water could escape to the environment, even for this improbable scenerio.
Richard 8.
Codel l Subscribed and'worn to before me this,'J day-of/j~'.. -"/~-1981.
g lo ivory Publ.~r.
t'1y Commission expires:
4~
Richard B. Codell PROFESSIONAL QUALIFICATIONS
.,Office of 'Nuclear Reactor Re ulation I a~
a Senior Hydraulic Engineer, Hydrologic Engineering Section, Hydrologic and Geotechnical Engineering Branch, Division of Engineering,, Office of Nuclear Reactor Regulation.
I s.ucied:chemical engineering at the Pennsylvania State University where I was a':arded the degrees of Bachelor of Science in 1965 and Master of Science in 1967.
I took courses at the University of Rochester and Lehigh University, and was awarded the degree of Doctor of Philosophy in Chemical Engineering from Lehigh University in 1973.
My doctoral dissertation was "Digital Computer Sim;lation of Thermal Effluent Dispersion in Rivers, Lakes and Estuaries ".
Courses which I have taken pertinent to my present discipline are in the areas of transport phenomena, fluid dynamics, physical oceanography, water resources, estuary and river pollution modeling, river hydraulics and surface water hydrol oo~, ground water hydrology, advanced mathematics, computer applications, econo,.ics, statistics and nuclear chemical engineering.
I have published in the American Institute of Chemical En ineers Journal, Con:rol En ineerin
, the Journal of Surface and Colloids Research, the American Societ of Civil Enqi neers
- Journal, and presented papers at several technical sympos ia.
I was employed by the U.S.
Army Missile Command, Redstone
- Arsenal, Alabama, fro;., March 1972 to August 1973.
My responsibilities included simulating the per=ormance of several air-defense missile systems.
My e..ployment with the NRC (formerly the AEC) dated from August 1973, when I was hired as a "Chemical and Thermal Dispersion Analyst" in the Environmental Specialists Branch.
My responsibilities included the evaluation and development, of techniques for the analysis of the fate of chemical and thermal effluents from nuclear facilities, the effects of intake structures on rivers, and the environmental review of nuclear facilities in the licensing process.
In May 1974, I transferred to the Site Analysis Branch (presently Hydrologic and Geotechnical:Engineering Branch) for my present assignment as Senior Hydraulic Engineer.
My responsibilities in the licensing review of nuclear facilities includes the evaluation of Safety Analysis Reports and Environmental Reports in the areas of flood vulnerability and protection, environmental and safety-reliated accep=ability of effluents in both surface and ground water, adequacy of water supply, especially emergency supplies, the environmental impact of construction activities and plant operation, as well as an assortment of other activities related to hydrosphere.
In addition, I have been involved in the development of computer models and procedures in these and related areas.
I am an Associate Member of the Am rican Society. of Civil Engineers.
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