ML19225A184

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Supplemental Response to Util Motion for Summary Disposition Re ASLB 790618 Order.Suports Motion Re Contentions 2 & 3 & Svc Water Cooling Sys.Affidavits of Wermeil,Chan,Ferrell & Campe & Certificate of Svc Encl
ML19225A184
Person / Time
Site: North Anna  
Issue date: 06/25/1979
From: Goldberg S
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
References
NUDOCS 7907180528
Download: ML19225A184 (30)


Text

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UNITED STATES OF AMERICA 6/25/79 7,

4-NUCLEAR REGULATORY COMMISSION

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bk@ [Gi[JO BEFORE THE ATOMIC SAFETY AND LICENSING BOARD j

M%.-c s In the Matter of

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Docket Nos. 50-338 SP VIRGINIA ELECTRIC AND POWER COMPANY

)

50-339 SP

)

(Proposed Amendment to Facilit, (North Anna Nuclear Power Station,

)

Operating License NPF-4 to Permit Units 1 and 2)

)

Storage Pool Modification)

NRC STAFF SUPPLEMENTAL RESPONSE TO VEPC0

SUMMARY

DISPOSITION MOTION In its " Order Partially Granting VEPCO's Motion for Summary Disposition" of June 18,1979, the Board requested the NRC 5th to supplement its initial response to VEPCO's summary disposition motion respecting those contentions not previously addressed. The Staff's supplemental response follows. On 1/

the basis of the attached Staff affidavits,~ and cited documentation, the Staff supports the Licensee's summary disp isition motion on Contentions 2 (accidents), 3, and the recently admitted contention on the service water cooling s'ystem.

The Staff recognizes the existence of certain disputed factsrbetween the parties. The Staff does not believe that any of these facts rise to the 1/ Messrs. Campe and Wermiel are unavailable to sign their affidaviLs at this writing. While not anticipated, minor changes may prove necessary to their affidavits.hich will be formally executed at the earliast possible date.

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level of matcriality necessary to defeat the outstanding summary disposition motion given the present status of the record in this proceeding.~2/

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Contention 2: Radioactive Emission Paragraphs 87 through 114 of "VEPC0's Statement of Material Facts as to Which There is no Genuine Issue to be Heard" (Statement of Material Facts),

attached to its May 11, 1979 summary disposition motion, as relevant to Contention 2, accurately summarize the salient facts not open to dispr.te.

Staff Affidavits of Jared S. Wermiel, Sai P. Chan, and Charles M. Ferrell.

In the evaluation summary which accompanied the proposed modification, the Licensee a alyzed the fellowing accidents:,the loss of spent fuel pool cooling capability (s9.1), spent fuel pool leakage (59.2), earthquakes and tornadoes (89.3), and fuel handling accidents (59.4).

Based on its indepen-dent evaluation, the NRC Staff concluded that none of these accidents would have unacceptabla consequences. Wermiel Affidavit,. Safety. Evaluation (SE),

h2.5,EnvironmentalImpactAppraisal(EIA), 593.3, 3.4, 4.2, 4.4.2, 4.4.4, (Summary, ss9.1 and 9.2); than Affidavit, SE, 52.2,(59.3); Ferrell Affidavit SE, s2.4 (39.4).

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2] With respect to the contentions which remain in issue, the intervenors have done little more than simply assert that VEPCO's Stateme 't of Material Facts are in error without supporting affidavits or otherwise.

In opposing a summary dhposition motion, a. party may not rest upon mere allegations or denials.

10 CFR s2.749(b). At the same time, in an affidavit accompanying its respcase to the motion, the Potcmac Alliance alleged that it needed additional time to present by affidavit facts to justify its opposition.

The regulations provide the Board discretion, under such circumstances, to " refuse the application for summary decision or... order a continuarce to permit affidavits to be obtained or make such other order as is appro-priate and a determination to that effect shall be made as a matter of record.

10 CFR 12.749(c}.

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- Accordingly, no genuine issues of m.aterial fact remain to be resolved with respect to whether the accidents c.

!ered in sections 9.1 through 9.4 of the Licensee's evaluation summary could occasion unacceptable radiological consequences as a result of the proposed modification. Therefore, the Board should grant summary disposition and dismissal of the contention with respect to accident considerations.

Contention 3: Missile Accidents Paragraphs 116-17,121-23, and 126 of VEPCO's Statement of Material Facts, as relevant to Contention 3, accurately summarize the salient facts not open to dispute.

Staff Affidavit of Charles M. F,errell and Kazimieras M. Campe on Contention 3; See also SE, 52.4.

The design criterion for' tornado missle protection for the spent fuel pool was favorably evaulated in 553.5 and 9.1.2 of the Safety Evaluation Report issued in connection with the North Anna, Units 1 and 2, operating license application.

It has been calculated that there was, and with the modifica-tion will remain, a low probability that a tornado-generated missile could damage sufficient fuel assemblies to cause or Tsite doses in excess of 10 CFR Part 100 levels. The design provisions for tortodo missile protection are un-affected by the proposed modification and are acceptable. H.

The probability of occurrence of a turbine missile entering the spent fuel pool and strikin9 the spent fuel assemblies is so low as not to present a significant risk and is unaffected by the proposed modification. Campe/

Ferrell Affidavit.

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_4-Accordingly, no genuine issues of material fact remain to be resolved with respect to the effect of the proposed modification upon the tornado and tur-bine missile protection criteria for the North Anna Power Station, Units 1 and 2.

Therefore, the Board should grant summary disposition and dismissal of Contention 3.

New Contention: Service Water Cooling System The Licenser recently submitted the results of a performance test on the North Anna service water reservoir which indicated that the design maximum temperature for the service water system must be increased based on even-tually supporting four unit op'erati.on.

Since the service water system cools the component cooling water system, which, in turn, cools the spent fuel pool cooling system, this change will result in a corresponding increase in the spent fuel pool cooling water system design maximum temperature for both 0

the normal (140 F) and the abnormal (170 F) cooling load requirements.

In order to maintain the spent fuel pool temperature within the limits defined for the normal and abnormal cases in the Staff Safety Evaluation of the proposed modification, assuming the maximum service water system temperature, one fuel pool cooling pump and two heat exchangers are required to operate.

Staff Affidavit of Jared S. Wermiel on New Contention Concerning Service Water Cooling System.

However, this mode of cperation is needed for only a short period of tire just after refueling when the spent fuel decay heat load is at its great?

level.

Should only one cooler be available during this peak heat load U

perird, the resulting pool water temperatures of 148 F for the normal case 34/

296

" and 177 F for the abnormal case are only slightly abcve the previously established limits and will not result in unacceptable operating conditions nor adversely affect the health and safety of the public.

Id.

Accordingly, no genuine issues of material fact remain to be resolved with respect to the ability of the spent fuel pool system to maintain the spent fuel pool temperature within designated and acceptable limits. Therefore, the Board should grant summary disposition and dismissal of this contention.

Conclusion On the basis of the above, the_ Staff supports the Licensee's summary disposi-tion motion regarding Contentions 2 ~(a'ccidents), 3, and the recently admitted contention on the service water cooling system.

Respectfully submitted, Steven C. Goldberg Counsel for NRC Staff Dated at Bethesda, Maryland this 25th day of June,1979 9

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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)

Docket Nos. 50-338 SP "IRGINIA ELECTRIC AND POWER COMPANY

)

50-339 SP

)

(Proposed Amendment to Facility (North Anna Nuclear Power Station,

)

Operating License NPF-4 to Permit Units 1 and 2)

)

Storage Pool Modification)

AFFIDAVIT OF JARED S. WERMIEL ON CONTENTION 2(a): RADIOACTIVE EMISSION (ACCIDENTS)

I, Jared S. Wermiel, being dul_y sworn, state:

Contention 2 (Radioactive Emission) states, in part:

In CEF's opinion, applicants' analysis of radiation released, and of possible releases, in the event of those accidents considered in [ Sections 9.1 and 9.2]

of the aprlication, are superficial and insubstan-tial in the Summary of the Proposed Modifications.

I have reviewed paragraphs 87 through 90 of "VEPC0's Statement of Material Facts as to Which There is no Genuine Issue to be Heard" (hereinafter re-ferred to in separate Staff affidavits as "VEPCO's Statement of Material Facts") attached to its May 11, 1979 summary disposition motion, as rele-vant to Contention 2, and concur in the statements ccntained therein.

Loss of Spent Fuel Fool Cooling Capability and Fuel Pool Leakage (Summary, 559.1 and 9.2)

The proposed increase in the spent fuel storage capacity does not affect the potential for these accidents as cooling of the pool and the maintenance 34[

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. of an adequate water level in the pool is presently a technical specification requirement for the North Anna operating license and will remain so under the proposed modification.

See also 52.4 of the NRC Staff Safety Evaluation.

prepared in connection with the proposed codification.

The spent fuel pool cooling syston is a seismic Category I system. There-fare, the complete failure cr the spent fuel pool cooling system is considered to be a very unlikely event. However, adequate pool makeup capability is provided from redundant sources to maintain pool cooling as discussed in the

" Affidavit of Paul H. Leech, Francis C. Kornegay and Jared S. Wermiel on Contention 1: Thermal Effects" which ar ompanied the "NRC Staff Response to VEPC0 Summary Disposition Motion," dated June 5,1979. This affidavit also describes the protection available in the event of pool leakage.

Jared 5. Wermiel Subscribed and sworn to before me t: it day of June,1979 Notary Puolic My Commission expires:

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

Docket Nos. 50-338 SP VIRGINIA ELECTRIC AND POWER COMPANY

)

50-339 SP

)

(Proposed Amendment to Facility (North Anna Nuclear Power Station,

)

Operating License NPF-4 to Permit Units 1 and 2)

)

Storage Pool Modi #Mcion)

AFFIDAVIT OF SAI P. CHAN ON CONTENTION 2(a):

RADI0 ACTIVE EMISSION (ACCIDENTS)

I, Sai P. Chan, being duly sworn, state:

Contention 2 (Radioactive Emission) states, in part:

In CEF's opinion, applicant's analysis of radiation celeased, and of possible releases, in the event of those accidents considered in [Section 9.3] of the application, are super-

  1. icial and insubstantial in the Summary of the Proposed Modifications.

I have reviewed parag-aphs 91 through 98 of VEPCO's Statement of Material Facts, as relevant to Contention 2, and concur in the statements contained therein.

Earthauabs and Tornadoes (Sumary, 59.3)

.",s stated in 52.2 of the NRC Staff Safety Evaluation issuec' in connection with the proposed mcdification, the ability of ue pool structure to with-stand the effects of an earthquake or tornado will not be affected by the proposed modification since no structural changes will be required.

The new spent fuel storage racks and pool structure have been analyzed to ensure that the racks can be accommodated by the structure during an earthquake.

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- The proposed modification does not change the physical configuration of the spent fuel pool.

However, two additional floor pads to accommodate seismic loads from the proposed fuel storage racks are presently installed in the fuel pool. This installation was performed prior to issuance of the operating license for Unit 1.

The additional embedments or pads, which are anchored to the concrete via use of anchor bolts, have been seismically designed and analyzed, and would not impair the structural integrity of the pool structure nor cause any leakage problem.

In conclusion, the proposed modification does not involve any significant change in design methods and criteria of the sp. ant fuel storage racks and the fuel pool structure to withstand the effects cf an earthquake or tornado, nor cause any potential problem in structural integrity that would lead to radiological releases.

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Sai P. Chan Subscribed and sworn to before me this 25th day of June,1979 3

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_NotaG/ Public in and for tne State of Maryland, Montgomery County My Commissicn expires:

July 1, 1982 347 Ud\\

SAI P. CHAN PROFESSIONAL QUALIFICATIONS

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STRUCTURAL Ei!GINEERING BRANCH DIVISION OF SYSTEMS SAFETY l

l I am a structural engineer in the Structural Engineering Branch l

of the Division of Svstems Safety.

I am responsible for the evaluation i

of seismic analysis and design of structures, systems and components '

j of nuclear facilities assigned to the Branch.

I I received a B.S. Degree in civil engineering with honor from Lingnan University, China, in 1943.

I received the degree of Master of Science from the University of Illinois, Urbana, Illinois in 1950 and the degree of Ph.D (Structural Engineering) from the.same institution in 1953.

I taught undergraduate students at the National Chiao-tung University,

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Shanghai, China from September 1943 to August 1947.

From October 1947 I

to August 1949 I studied at the University of Paris, France under a scholarship sponsored by the Nationalist Chinese Government and worked as an architectur'al engineer in the Atelier Le Corbusier, Paris, France.

i During the years 1951 and 1952, I worked as.Research Assistant at the, University of Illinois where I developed; numerical methods for dynamic analysis of structures.

Since 1953 I have served in the structural engineering area including research, development, design and analysis for the construction, aerospace and power indtstries. My experience in structural methodology and stress analysis includes development of computer programs and numerical methods for dynamic analysis of' framed and shell structures; analysis of composite, laminated and anisotropic structures; structural optimization and nonlinearities; postbuckling and dynamic behavior of stiffened and monocoque shells.

I also taught at the University of Denver part-time for two years in Theory of Elasticity and Theory of Plates and Shells.

l My experience in seismic design and ground shock problems involves earthcuake design of a fossil-fuel power plant in San Diego, California; mining structures and facilities in Peru; launch towers and silos for the Titan missiles; ground shock studies for the Spring missiles; seismic design and analysis of containment structures and auxiliary buildings of nuclear pcwer plants.

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As a member of the Structural Engineering Branch, Division of Systems Safety, I have participated in developing criteria for seismic design and instrumentation for nuclear power plants, performed evaluations of technical reports concerning structural dynamics and reviewed numerous nuclear power

- I plants in the area of seismic and structural design.

l I am a member of the American Society of Civil Engineers and of the i

American Institute of Aeronautics and Astronautics.

I am registered as l

Professional Engineer in the states of Colorado and Georgia.

I have published tehcnical papers in the Journal of Royal Aeronautical Society and Aircraft Ergineering, and several research reports for the Lockheed-Georgia Research Laboratory.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

Docket Nos. 50-338 SP VIRGINIA ELECTRIC AND POWER COMPANY

)

50-339 SP

)

(Proposed Amendment to Facility (North Anna Nuclear Power Station,

)

Operating License NPF-4 to Permit Units 1 and 2)

),

Storage Pool Modification)

AFFIDAVIT OF CHARLES M. FERRELL ON CONTENTION 2(a): RADI0 ACTIVE EMISSION (ACCIDENTS)

I, Charles M. Ferrell, being duly sworn, state:

Contention 2(a) states in part:

Applicant's analysis of radiation released, and of possible releases, in the event of those accidents considered in

[Section 9.4] of the application, are superficial and in-substantial in the Summary of the Proposed Modifications.

I have reviewed paragraphs 99 through 102,104-105, and 110 through 114 of VEFCO's Statement of Material Facts and concur in the representations con-tained therein.

I also concur in paragraphs 103,106, and 107 excluding the "subcriticality" reference.

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The staff evaluated the consequences of a postulated fuel handling accident as part of the review of the original spent fuel pool design. Our evaluation is contained in the Safety Evaulation Report for North Anna, Units 1 and 2 (NUREG-0053), the consequences were found to be acceptable. We conclude that, since the proposed modification to the spent fuel pool will not increase these consequences, the proposed spent fuel pool modification is acceptable with resoect to the consecuences of a fuel handling accident.

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The staff evalueted the original North Anna Units 1 and 2 spent fuel pool design and a postulated fuel handling accident as shown in the Safety Evaluation Report for North Anna 1/2 (NUREG-0053) using the method and assumptions described in the Standard Review Plan,Section 15.7.4," Radiological Consequences of Fuel Handling Accidents" (NUREG-75/087) and Regulatory Guide No.1.25," Assumptions Used for Evaluating the Potential Radiological Consequences of a Fuel Handling kcident in the Fuel Handling and Storage Facility for Boiling and. Pressurized Witer Reactors."

In our analysis, we assumed that a spent fuel assembly having the ruinimum decay time permitted (100 hrs), which is being moved under water in the spent fuel storage pool, drops from its maximum height in the pool impacting the floor of the pool. This impact is assumed to rupture the cladding on all of the fuhl rods in the fuel assembly causing a release of approximately 10 cubic feet of fis-sion product gases which are contained in the space between the fuel pellets and the 3 /i /

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. zircaloy tubes which serve as cladding. The gas u;bbles are released to.the fuel pool water where they rise to the surface of the pool. The water will scrub out about 99% of the iodine but is not cffective in reducing the quanity of noble gases released to the fual building atmosphere. Once the radioactive gases reach the

' at fuel building atmosphare, tiey are exhausted to the en-vircnment through a safety grade charcoal filter systen.

'ch further reduces the quanity of airborne radioactive io'ines. This filter is not effective in removing noble gases such as kryptons

.1d ztnans, which contribute only to the whole body dose.

The exclusion area boundary and the low population zone doses from the postulated fuel handling accident are shown in Table 15.2 of the Safety Evaulation Report for North Anna Units 1 and 2.

Both the thyroid dose and the whole body dose are about 10% of the 10 CFR Part 100 values of 300 rem thyroid and 25 rem whole body.

The proposed mdification of reducing the grid size of the spent fuel storage racks will not change our analysis or conclusions, since the fuel assembly with the minimum ' decay time has already been~ postulated to be damaged, and the modification does not increase the number of fuel assemblias that can be damaged.

A spent fuel assembly when being moved in the spent fuel pool is moved under-water at a height of about 16 f t. above the pool floor.

Since the spent fuel racks extend up to about 14 ft. above the floor of tne pool, a spent fuel assembly may, if dropped, fall either 16 ft. onto the floor, or about 2 ft.

onto tha spent fuel racks. The fall of two feet will not result in sufficient damage to cause the release of any gap activity to the pool water.

Since the proposed modification will increase the number of stored fuel assem-blies by decreasing the spacing between the assemblies, it is clear 347

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that the proposed modification does not change the height, and therefore, the kinetic energy, that can be imparted to a dropped assembly.

In addition, the North Anna technical specifications limit the maximum size of the load which can be moved over the fuel storage area of the pool to that of a single fuel assembly, the control rod cluster and the spent fuel handling tool or, about 2500 lbs. This requirement prevents the trovement of heavy loads such as a spent fuel shipping cask over stored spent fuel assemblies.

1 Charlas M.' Ferrell Subscribed and sworn to before-me this 25th day of June,1979

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M Notarff' land,MontgomeryCounty ublic in and for thv State of Mary My Comission expires: July 1, 1979 347 307

CHARLES M. FERRELL PROFESSIONAL QUALIFICATIONS ACCIDENT ANALYSIS BRANCH DIVISION OF SITE SAFETY AND ENVIRONMENTAL ANALYSIS i

I am a site analyst in the Accident Analysis Branch, Division of Site Safety and Environmental Analysis, U.S. Nuclear Regulatory Commission. My present duties in this position include the evaluation of site related environmental safety aspects of nuclear power generating facilities and cesign basis acci-dent analysis.

I graduated from Salem College in West Virginia in 1950 with a BS degree in physics and a teaching field also in chemistry, biology, and mathematics. Upon graduation, I was drafted, and after completion of armored inf antry training at Fort Knox, Kcntucky, was assigned as a military physicist to the Radiological Division of the U.S. Army Chemical Corp. at Edgewood, Maryland.

I spent approximately two years in research involving nuclear weapon thermal radiation, riuclear radiation shielding studies and fallout analysis.

I was released from active duty ar.d worked for two years as a civilian physi-cist in Aerosol Physics (Aerobiology) Research at the U.S. Army Chemical Corps Biological Warf are Laboratory at Fort Detrick, Frederick Maryland.

In 1954 I appliad for and was granted an AEC Fellowship in Radiological Physics at Vanderbilt University and the Oak Ridge National Laboratory in Tennessee. An additional year of graduate work in physics was taken at West Virginia Univer-j sity. Night school classes in Nuclear Engineering from the University of Maryland plus short sumer course.s from MIT in Air Pollution, Heat Transfer, and Nuclear Power Reactor Safety constitute the remainder of my formal educa-tion.

In April,1974, I completed a two week course in Pressurized Water Reactor Systems at the Westinghouse Training Center in Monroeville, Pennsyl-vania.

I am a charter member of the Health Physics Society.

I have been a member of the AEC!s (now NRC's) Regulatory staff since 1956.

Of these twenty-three years, five years were sp nt in duties involving the safe industrial and medical use of radioisotcpes, in t:1e evaluation of spent reactor fuel shipping casks and the promulgatici, of reactor fuel shipping regulations. Eight years were served as the Technical Assistant to the Office of Hearing Examiners, U.S. Atomic Energy Cormiission in which I assisted in approximately 40 hearings on nuclear power reactors, fuel reprocessing plants and in addition contract npeals hearings on nuclear e

submarine corrponents and nuclear equ iprmnt.

In January.1969, I transferred to my present position. Since that time I have served as the site analyst on forty one nuclear power plants, two U.S. Navy nuqlear submarine reactors and a proposed nuclear pcwered crude oil tanker.

I se ved as one of the technical reviewers of Chapter 7, 3 /} [

300 1

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" Assessment of Reactor Safeguards" in Applied Radiation Protection and Control by J. J. Fitzgerald, published under the auspices of tne Division of Technical Information United States Atomic Energy Commission.

I have testified in licensing hearings on six nuclear facilities. These include San Onofre 2/3, Beaver Valley Unit 1. Hutchinson Island (now St. Lucie 1), Yellow Creek 1 and 2, Duane Arnold Unit I and Trojan Unit 1.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

Docket Nos. 50-338 SP VIRGINIA ELECTRIC AND PCWER COMPANY

)

50-339 SP

)

(Propcsed Amendment to Facility (North Anna Nuclear Pcwer Station,

)

Operating 1.icense NPF-4 to Permit Units 1 and 2)

)

Storage Pool Modification)

AFFIDAVIT OF KAZIMIERAS M. CA!1PE AND CHARLES M..FERRELL ON CONTENTION 3: MISSILE ACCIDENTS We, Kazimieras M. Campe and Charles M. Ferrell, being duly sworn sworn, state as follows:

We are employed by the Nuclear Regulatory Commission in the Accident Analysis

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Branch of the Office of Nuclear Reactor Regulation.

Statements of our pro-fessional qualifications are attached.

Contention 3 (Missile Accidents) states:

Intervenor contends that the proposed modification of the spent fuel pool will increase the consequences of an acci-dent involving missiles, and that the applicant has not demonstrated that the pool, as modified, will withstand such accidents within the limits set forth in NRC Regula-tions.

This affidavit is written in re:,ponse to the above contention.

We conclude that the proposed spent fuel pool modification meets the applicable NRC staff criteria regarding tornado missiles with respect to North Anna Units i and E.

The discussion and bases for this cor.clusion is presented bel ow.

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I, Kazimieras M. Campe, have reviewed paragraphs 116-17,121-123, and 126 of VEPC0's Statement of Material Facts, as relevant to Contention 3 and con-cur in the representations contained therein.

A.

M nado Missiles The applicable ' tornado missiles for evaluating North Anna Units 1 and 2 are the 1 inch steel rod and the utility pole.

) The utility pole is limited to elevations less than 30 feet above grade while the steel rod is presumed capable of striking at any elevation.

Since the spent fuel pool walls tre of reinforced concrete with a minimum thickr.ess of six feet, neither of the above missiles has the potential for penetrating the walls and thus entering the pool.

The walls extend up to a minimum height of 20 feet and 10 inches, or about 21 feet, above grade. Above this height the spent fuel pool building walls are not designed to withstand design basis tornado missiles such as the steel rod or the atility pole.

Thus, between elevations of 21 feet and 30 feet above grade there is a possibility that a utility pole may enter the spent fuel pool building. The steel rod, not having any restriction on height, could enter the same area from any elevation.up to, and including, the building roof.

With respect to the utility pole, the probability that it will descend along a trajectory which intersects any of the spent fuel assemblies is small.

Assuming conservatively that every utility pole impacting the building walls will penetrate them and enter the building, it is possible that the pole will strike the interior surface of the spent fuel pool wall on the

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- opposite side of the pool. As shown by the Edison Power Research Institute fu

.cale tornado missile tests,(3) the utility pole shatters upon impacting concrete slabs 12 inches or more in thickness.

Thus it is not expected that the pole would continue presenting a missile hazard after impacting the wall.

The probability that the utility pole enters the spent fuel pool and strikes the fuel assemblies varies with the initial azimuth of its trajectory prior to impacting the building.

Trajectory azimuths normal to the north - south walls of the : cent fuel pool building lead to fuel strike probabilities of about 0.05 per missile enterins the building.

Missiles with azimuths of 45 relative to the north - south walls have a fuel strike probability of about 0.2 per missile.

Utility pole missiles having azii..uths smaller than 45 cannot impact any spent fuel.

Since the containment building would intercept such missiles. On the average, considering all azi uths being equally likely, the fuel strike prcbability is estimated to be about 0.1 per missile entering the building.

T'1e above estimates are conservative, since it is assumed that every utility poie impact on the building results in the pole entering the spent fuel pool in an "end-on" orientation. A utility pole entering the pool " sideways" would lose most of its kinetic energy within the 23 feet of pool water and would not be capable of reac.

g the fuel racks with sufficierit sreed to cause significant damage to the fuel arsemblies.

The probability of an "end-on" orientation is esu aated conservatively as 2 bout 0.3.

This is obtained by considering that any missile orientatic. within 45 of the line of trajectory is an "end-on" orientation.

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. In addition to the strike probability considerations, the potential for spent fuel damage is determined by the probability for the occurrence of the tornado event itself. The design basis tornado missiles in Standard Review Plan 3.5.1.4 are based on the most severe tornado wind category, which for the florth Anna site is represented by maximum wind speeds of 360 miles per hour. The frequency of occurrence for this type of tornado is estimated to per year.( } On the Fujita scale (which is a tornado

-7 be less than 10 severity classification system) this type of tornado would be classified as F5, and it represents about 0.12% of tornadoes of all intensities. A ccaservative estimate of the occurrence frequency for tornadoes capc.ble of lofting utility poles is obtained by considering F4 and F3 tornadoes in addition to tornadoes of F5 intensity.

The cumulative probability for these three categories is 9.42%. Tornadoes of lesser intensity are not expected to have sufficient windspeeds for lifting utility poles. This view is supported by the observations made with respect to the recent tornado that occurred at the Grand Gul f site.(5)

Since the tornado occurrence frequency (for all intensities) for the fiorth Anna site is 5 x 10-4 per year, then a conservative estimate of the probability for a utility pole entering the spent fuel pool anc reaching the fuel assemblies is (5x10-4)(0.0942)(0.1)(0.3) 1.4.x10-6 per year.

If we conside-further the fact that the or spent fuel pool will contain freshly discharged fuel only for some fraction of the year, the probability for damaging fuel ar.d causing radiological consequences in excess of 10 CFR Part 100 dose guidelines is even less.

347 313

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-5 Specifically, North Anna Units 1 and 2 nonnally will not be refuelling more often than once a year. Assuming conservatively that refuelling for Units 1 and 2 do not overlap in time, the dose consequer:ce, D, due to fuel damage by the utility pole can be estimated from D= Dj N e-AT Where Dj = Dose consequence due to damage of a single fuel assembly N = Number of assemblics assumed to be damaged by the missile A = Bulk decay constant for the fuel gap activity constituents T = Maximum decay time beyond which damage of N assemblies does not resul: in exceeding 25". of 10 CFR Part 100 dose guidelines.

The dose, D), for a single caraged fuel assembly is estimated to be 5.3 rem to the thyroid at the site boundary.

This estimate includes the following:

a.

A post tornadic meteorology characterized by a windspeed of 3 meters per second and stability class Pasquill D.

b.

A power peaking factor of 1.2 for the damaged assembly.

c.

No iodine removal by the fuel pool ventilation system.

d.

A fuel decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to storage in the pool.

Assuming conservatively that the utility pole is Gpable of penetrating into the building traversing the 23 feet of pool water, and then penetrating through and damaging every spent fue_1 assembly of a freshly discharged 1/3 of a reactor core (representing 52 assemblies), the maximum decay time T for which the above damage would lead to rele:ses in excess of 25% of 10 CFR Part 100 dose guidelines (2) is 0.693 T

(300)(0.25)=(5.3)(52) e' 8

or T is a' cut 15 days.

Since the pool is shared between the two units, 347 314

- E the value of T is doubled, i.e. T 30 days.

Thus, the fraction of a year when the above conservatively postulated damage could exceed 25% of the 10 CFR Part 100 dose guidelines is 30/J55, or 3.08.

Therefore, the probability that a tornado at the North Anna site will loft missiles such as the utility pole, cause damage to the stored fuel, and thus cause doses greater than 25% of 10 CFR Part 100 doses at the site boundary is (1.4.x10-6)(0.08) 1.15x10-7 per year.

In view of the above, the utility pole. as a or potential tornado missile, does not pose a significant hazard with respect to the spent fuel pcol in either the present configuration or the proposed modified configuration.

With respect to the steel rod, if the SFP contained 100% freshly discharged spent fuel assemblies,14 assemblies would have to be damaged before exceeding 25% of 10 CFR Part 100 dose guidelines. A steel rod entering through the upper portions of the SFP building (30 feet above grade or higher) would not be likely to damage that many assemblies due to the steep trajectory upon entry into the SFP. Steel reds impacting the SFP building at lower elevations are subject to geometric considerations similcr to the utility pole, as described earlier in this testimony.

Thus, with respect to the steel rod, the probability of a tornado lof ting it, causing fuel damage, and resulting in dose consequences greater than 25% of 10 CFR Part 100 are (5x10-4)(0.36)(0.1)(0.3)(0.08)

-7 or 4.32x10 per year.

347 315

- 7,-

B.

Turbine Missiles With respect to turbine missiles, the probability of a high trajectory turbine missile entering the spent fuel pool and striking the spent

-0 fuel assemblies is about 7.5x10 per turbine year.

This is based on an estimated high trajectory turbine missile strike probability of

~7 10 per square foot of target area, sr: assumed annual turbine failure

~2 rate of 10 per turoine year, three turbines operating o' the site, and the overall horizontal area occi.ied by the spent fuel assemblies within the pool. However, in view of the requirements imposed on the licensee with respect to the turbine disc integrity and turbine valve testing and inspection, the turbine failure rate is expected to

-4 be significantly lower th'an 10 per turbine year.

Since the proposed fuel storage modification does not affect the turbine failure rate, the staff finds that the potential for a turbine missile entering the spent fuel pool does not pose a significant hazard, for either storage configuration.

Kazimieras M. Campe mh Charles M'. Ferrell /

Subscribed and sworn to before me this day of June,1979.

Notary Public My Conmission expiret

} fj j

- 8.-

References 1.

Standard Review Plan (SRP), 53.5,1.4, Revision 1.

2.

Regulatory Guide 1.117, Revision 1 3.

" Full Scale Tornado-Missile Impace Tests," EPRI NP-440, Research Project 399, (Sandia Report SAND 77-1166), July 1977.

4.

Technical Basis for Interim Regional Tornado Criteria, WASH-1300, May 1974.

5.

Grand Gulf Report, NUREG/CR-0383.

6.

North Anna SER-OL.

7.

SRP, 53.5.1.6.

8.

North Anna FSAR-OL.

e 9

4 XAZIt4IE?AS M. CA14PE_

PROFESL ONAL QUALIFICATIONS _

ACCIDENT n'lALYSIS BRANCH DIVISION OF SITE SAFETY AND E?nIRONMENTAL ANALYSIS I ani a member of the Accident Analysis Branch of the Office of Nuclear e

Reactor Regulation of the United States Nuclear Regulctory Ccranission.

My duties include the identificaticn and evaluation of hazards to th" safe operation of nuclear power plants due to accidents external and internal to those plants. Part of these duties involve the evaluation f

of turbine missile risks.

I have reviewed turbine misgile generation, strike, and damage prcbebilities for nuclear plant license applications since 1973.

i have personally examined and performed photographic f

documentation of the Shippingport and. Gallatin piant turbine failures.

I have prepared most of the technical input for the Regulatory Guide 1.115 which addresses protectica requirements against low trajectory turbine missiles.

In 1975 I co-authored a paper with J. Read of the Accident Analysis Branch on the subject of high trajectory turbine missile strike probabilities. Currently I, am one of the contributing authors to the Staff's forthccming turbine missile evaluation report.

I graduated from the University of Connecticut where I received B.S. and M.F. degrees in Mechanical Engineering 1958 and 1960, respectively. Cetween 1960 and 1962 I completed some advanced mathematics courses at the Rensselaer Polytechnical Institute branch in East Hartford, Connecticut.. During, this period I wa; employed by Pratt and Whitney at the CANEL Analytical Physics Group as ar, analytical engineer. Frca 1962 to 1966 I attended Purcae University, Ihere I received a Ph.D. in Nucle. - Engineering.

Frca 1966 to 1972 I was employed by Hittman Associates, Inc. whem worked in the Radioisotoce Department. During.this period my responsibilities included.

radiation shielding analyses, radioisotopic generator design, and computer code development for.eactor core physics calculations.

Since 1972 I have been employed by the Nuclear Regulatory Comission in the Accident Analysis Branch.

347 318

+-

UNITED STATES OF A ERICA NUCLEAR REGULATORY COMMISSI0ft BEFORE THE ATOMIC SAFETY AND LICErlSING COARD In the Matter of

)

)

Docket Nos. 50-338 SP VIRGINIA ELFCTRIC A*1D POWER COMPANY

)

50-339 SP

)

(Proposed Amendment to Facil1+.y (North Anna Nuclear Power Station,

)

Operating License NPF-4 to Pe mit Units 1 and 2)

)

Storage Pool Modification)

AFFIDAVIT OF JARED S. WEM1IEL ON NEW CONTENTION CONCER: LING SERVICE WATER COOLING SYSTEM I, Jared S. Wermiel, being duly sworn, state; By Order, dated June 6,1979, the licensing board admitted the following new conter. tion raised in the May 9 Motion of Intervenor Potomac Alliance:

The intervenor contends that the service water cooling system for the facility will be inadequate to support the component cooling system for the spent fuel pool if the proposed modification of the pool it permitted.

The licensae recently submitted the results of a performance test on the North Anna service water reservoir. The results of this test iridicated that the design maximum temperature for the service water system must be increased from 95 F to 110 F based on eventually supporting four unit opera-ticn.

Since the service water system cools the component cooling water system, this change will cause an increase in the desian maximum ccmponent coeling water system temperature from 105 F to 113.2 F.

This change also will result in a corresponding increase in the spent fuel pool cooling water system design maximum temperature for both the nornal and abnormal cooling 34[

'l l 0 V

/

- 2'-

load requirements as this system is cooled by component coolina water.

In order to maintain the spent fuel pool temperature within the limits of 140 F for the normal case and 170 F for the abnormal case as defined in the Staff Safety Evaluation of January 29, 1979 for the proposed increased spent fuel storage capability assuming the maximum service water system temperature, one fuel pool cooling pump and two heat exchangers are required to operate.

However, this mode of operation is needed for only a short period of time just after refueling when the spent fuel decay heat load is at its greatest level.

Should only me cooler be available during this peak heat load U

period, the resulting pool water temperature,s of 148 F for the normal case and 177 F for the abnormal case are only slightly above the previously established limits and will not result in unacceptable operating conditions nor will it adversely affect the health and safety of the public.

Jared S. Wermiel Subscribed and sworn to before me this day of June,1979.

Notary Public My Ccmmission expires:

347 po

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

Docket Nos. 50-338 SP

)

50-339 SP VIRGINIA ELECTRIC AND POWER COMPANY )

(Proposed Amendment to Facility

)

Operating License NPF-4 to Permit (North Anna Nuclear Power Station,

)

Storage Pool Modification)

Units 1 and 2)

)

CERTIF.ICATE OF SERVICE, I hereby certify that copies of "NRC STAFF SUPPLFMENTAL RESPONSE TO VEPC0

SUMMARY

DISPOSITION MOTION" in the above-captioneu proceeding have been served on the follcwing by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 25th day of June,1979.

Valentine B. Deale, Esq., Chairman Mr. Irwin 8 Kroot Atomic Safety and Licensing Board Citizens' Eaergy Forum 1001 Connecticut Avenue, N. W.

P. O. Box 138 Washington, D. C. 20036 McLean, Virginia 22101 Mr. Ernest Hill James B. Dougherty, Esq.

Lawrence Livermore Laboratory Potomac Alliance University of California 307 lith Street, N.E -

P. O. Box 800, L-123 Y/ashington, D. C. 20002 Livermore, California 94550 Anthony J. Gambardella, Esq.

Dr. Quentin J. Stober Office of the Attorney General Fisheries Research In-+itute 11 South 12th Street, Suite 308 University of Washington Richmond, Virginia 23219 Seattle, Washington 98195 Atomic Safety and Licensing Michael W. Maupin, Esq.

Board Pane.' '

Hunton & Williams U.S. Nuclear Regulatory Commission P. O. Box 1538 Washington, D. C.

20555 Richmond, Virginia 23212 b0Y

i i

/.tomic Safety and Licensing Appeal Panel (5)*

U.S. Nuclear Regul.atory Commission Washington, D. C.

20555

.t' Docketing and Service Section Office of the Secretary i

U.S. Nuclear Regualtory Commission Washington, D. C. 20555 5

I 7

,bku-4LL$

StevenC.Goldberg Counsel for NRC Staff I

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1

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