ML17341A085
| ML17341A085 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/25/1981 |
| From: | Utley E CAROLINA POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17341A086 | List: |
| References | |
| NO-81-342, NUDOCS 8103190169 | |
| Download: ML17341A085 (10) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of FLORIDA POilER 5 LIGHT COMPANY (Turkey Point Nuclear 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 6a, b, c, AND e I Richard Codell, being duly sworn, depose and state as follows:
l.
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.
I am the Hydraulic Engineer assigned to the Turkey Point Plant steam generator repair program.
3.
Contention 6 in part states:
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:
t a
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 4
structure in which they are stored or upon another object or objects; and e.
leakage through the floor beneath tho stored steam generators.
I have reviewed the above stated contention based on several sources of information which include but are not limited to The steam Generator Repair Report (SGRR) 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) idated March 15, 1972 The Updated Safety Evaluation Report on the Steam Generator Repair dated December 17, 1980 (NUREG-0756)
The proposed design for the on-site storage facility has changed cons'.deraoly since the Board Order of August 3, 1979.
These design changes would strongly affect the Hearing Board's initial appraisal of Contention 6.
Based on my 5
review of the above-stated references, I have reached the following conclusions:
l.
In response to Contention 6a, 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.l.l, from the
- SGRR, attached).
The original storage structure would have been at a
water level of only 5.0 feet MLW. 'uring the safety review cf the'plant, the Design Basis Flood event was the Probable Maximum Flood (PMF), identified I
I as a hurricane surge which would reach
- a. stillwater level of 18.3 feet MLW (SER, 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.
Jn 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, p. 10).
During an assumed occurrence of the Probable Maximum Flood, the storage I
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 l.
USNRC, Regulatory Guile 1.59, "Design Basis Floods for Nuclear Power Plants"
4 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 (Figure D.l.l).
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 wave which could be sustained on the plain without breaking would be about 80 percent of the water depth, or in this case about 0.6 ft., crest to trough.
This wave 2/
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, the staff concludes that there will not be a significant immersion of the steam generators caused by a hurricane.
2.
In response to Contention 6b and c, the staff has demonstrated in response to Content":on 6a above that there will be no significant immersion of the 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.
Therefore, the steam generators would not float even if immersed.
3.
In response to Contention 6e, the staff has considered the possible waterborne pathways to the environment or man of the leakage of radioactivity 2.
U.S. Army'orps of Engineers, "Shore Protection Manual,"
Coastal Engineering Research Center, Third Edi.ion, 1977, Section 3.
Fy) from the steam generators, although no credible mechanism for such a
leakage is likely.
Liquid radioactive coniamination, if released from the ste'am generator, would be inhibited from releases to the environment by the integrity of the storage building, including a 6-inch thick reinforced concrete floor.~
Even if the spilled radioactivity could enter the ground, no potable ground water could be affected.
The two major ground water units underlying the site, the Biscayne aquifer and the Floridian aquifer, are both highly saline, and in addition, the direction of the ground water gradient is away from land.
Any reversal of the ground water gradient, for instance from overpumping, would be highly unlikely, and because of salt water intrusion, would make the water unfit for public consumption.
Any contaminated water entering the ground would have to percolate through approximately 18 feet of engineered fill and soil before:reaching the water table.
This contaminated water would then migrate.laterally with the slow ground"i>ater 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 would he 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 leakage would be discovered well before radioactive ground water could escape to the environment, even for this improbable scenerio.
- the original plan called for a dirt floor in the storage'uilding.
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