ML19259D285

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Affidavit in Response to ASLB 790907 Memorandum & Order Questions A.1,A.3-A.6,B.3d & E-H.NUREG-0404 Cannot Be Applied to Facility.Present License Does Not Allow Use of Zircaloy Fuel.W/Drawing & Prof Qualifications
ML19259D285
Person / Time
Site: La Crosse File:Dairyland Power Cooperative icon.png
Issue date: 09/13/1979
From: James Shea
Office of Nuclear Reactor Regulation
To:
Shared Package
ML19259D279 List:
References
NUDOCS 7910170565
Download: ML19259D285 (10)


Text

U:11TED SLATES OF iiMERICA fiUCLEAR REGULATORY C0!"iISSIO!!

BEFORE THE ATOMIC SAFETY AND LICE!JSIriG COARD in the Matter of DAIRYLAf1D POWER E00PERATIVI:

)

Docket f;o.59-409

)

(SFP License Amendrient)

(La Crosse Boiling Water Reactor)

)

AFFIDAVIT OF JAMES SHEA ON BOARD QUESTIONS A.1; A.3; A.4; A.5; A 6; B 3d; E; G; AND H I am the fluclear Regulatory Corrmission project manager for the La Crosse Boiling Water Reactor (LACCWR) within the Division of Operatir.g Reactors.

The purpose of

~

my affidavit is to answer certain Board questions indicated above, conc.erning the proposed modification to the LACBWR spent fuel pool.

My professional quali-fications are attached.

Board Question flo. A.1 Assuming storage of zircoloy-clad fuel, what circumstances distinguish the long-tenn offsite storage situation discussed in flVREG-0404, App. H

p. 23 from the present situation to a degree necessary to make fiUREG-0404 inapplicable to the present factual situation?

Response

The reason NUREG-0404 is inapplicable to LACBWR is because no zircaloy fuel may be used there without a license amendment.

(See response A-3).

Board Question fio. A.3 On what Sasis can thn Co wir, ion peni t 7ircolny-clai vent fuel to be stored in the LACBWR spent f uel pool, given the unresolved questions presented by Dr. Weeks' affidavit?

7910110s -d 1162 51-2

, pasppnse Zircaloy-clad spent fuel can not be stored in the LACBWR spent fuel pool because of Tcchnical Specification 2.7.2 Fuel Assemblies 2.7.2.1 The reactor core shall contain 72 fuel assemblies with each fuel assembly containing either 96 or 100 fuel rods clad with stainless steel.

Each fuel assembly shall have a nominal active fuel length of 83 inches and contain a maxinum total weight of 121.1 kilograms uraniua.

Reload fuel shall be similar in physical design to the initial core loading and shall have a maximum enrichment of 4.05 weight percent U-235.

Proposed Revised Technical Specification 2.12.3 Spent Fuel storage shall be provided in the spent fuel storage racks located at the bottom of the stor, age well within the containment vessel. The spent fuel storage racks are designed and shall be maintained with a nominal 7.0 inch center-to-center distance between fuel assemblies in each in-dividual rack assembly and with a boron containing poison slab between each storage location to ensure Keff of!_ 0.95 when flooded with unborated water.

Fuel in the storage well shall have a U-235 loading i 22.6 grams per axial centimeter for stainless steel clad fuel assemblies.

Storage of zircaloy clad fuel in the LACBWR FESW would require a safety evaluation by the -licensee and NRC of the safety aspects of both use of zircaloy fuel elements in the LACBWR reactor and storage of LACBWR fuel elements in the LACBWR FESW.

If all safety requirements for the use and storage of zircaloy clad fuel e'lements were-acceptable to the NRC, it would be-necessary to issue an amendmer.t to LACBWR License No. DPR-45 containing the approved changes.to the LACBWR Technical Specifications.

1162 513

, Board Ques _ tion flo. A.4 Is not further review by the Staff, and a conconitant technical specification or license condition change, appropriate before storage of zircoloy-clad fuel at LACBWR may be found to be in accord with the public health and safety?

Response

Yes.

P,efer to A.3 response.

Board Question flo. A.5 Does any technical specification or license condition currently in effect pre-clude the ctorage of zircoloy-clad fuel in the LACBWR spent fuel pool?

Response

Yes.

Refer to A.3 response.

Board Question flo. A.6 If not, would the Applicant or Staff (or CREC) have any objections to a condition or technical specification requiring Staff review and approval, and license amendment, prior to storage of zircoloy-clad fuel in the LACBWR spent fuel pool?

-Response Refer to A.3 response.

l}b.d 3}4

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Board Questic, No. B.3.d Has either Wisconsin or Minnesota adopted or sanctioned the EPA-recommended PAGs, whether by statute, regulation, or other regulatery rnethod?

Response

I have been informed by state officials that both Minnesota and Wisconsin presently use the EPA-PAGs on an informal basis.

Board Question No. E From the material provided to the Board, we have been unable to determine the surface elevation of water of water on the reactor side of the fuel transfer canal gate under various conditions, e.g., during reactor operation, during fuel transfer, and during shipping cask movements.

Please provide this information.

However, it now appears that water pressure on the fuel transfer canal gate will be higher for the new rack design and under the proposed new technical speci-fications.

Moreover, it appears that the depth of water covering the new racks will be much less than for the existing design in case of a fuel transfer canal gate failure.

If so, the Board questions why a gate or pressure vessel to cavity seal failure accident was not analyzed and discussed in.the SER.

~'

Response

During reactor operation the reactor upper cavity and fuel transfer canal are drained and dry.

During refueling operations when spent fuel assernalies are rea:cved f ro.n the core and transferred to the fuel element storage well (FESW) racks the reactor i16.2 515

, upper cavity and fuel transfer canal are flooded.

The wa h r level in these flooded cavities and the FESW is at the top i.g. 700 foot elevation.

(See diagrri, Attachment A).

During fuel transfer when the reactor is in operation (reactor upper cavity and fuel transfer canal drained) the water level in the FESW must be at about the same level (700 foot elevation) so that fuel assemblies can be moved over the top of the racks with sufficient st:bmergence to prevent excessive radiation levels at the storage well water surface.

During shipping cask movement in the FESW the water level must be at least 16 feet abe"e tie top of the FESW racks to prevent excessive radiation exposures to workers, bu'- not much higher,to allow for water displacement when the cask is submerged.

Following installation of the two-tiered spent fuel racks in the FESW it will be necessary to increase the FESW level about 14 feet above the bottom of the transfer canal from the present level two feet below the canal i_.e.16 feet above the top of the new racks (approximately elevation 694'). As a result the canal gate must be in the closed position after the canal is drained.

Pressure ~against the bottom of the gate will be 6 or 7 psig.

DPC has tested the

- gate for leakage with the water, level at the top of the FESW (or about 22 feet above the top of the fuel racks) without causing measurable leakage through the gate seals.

I162

'16

, The canal opening to the FESW is closed by un aluminum plate one inch thick about 20 inches wide and 21 feet in height.

The gate is sealed and bolted across the 15-3/4 inch opening that allows fuel asserilies to pass from the canal ir to the FESW when flooded. A biological shield plug constructed of concrete and sheathed in 1/4 inch carbon steel lowered into position in the canal behind the gate, provides adequate attenuation to permit fuel assembly transfer while the canal and upper reactor ;ovity are drained. The plug plane view is 15-3/4 inches by 48 inches.

The plug is 21 feet in height and weighs 8-1/2 tons.

In the unlikely event of a failure of the transfer car:al gate or pressure vessel to cavity seal that causes the FESW water level to drop to the floor of the canal, the dept.h of water over the top of the new spent fuel racks would be about two (2) feet compared to about 12 feet for the currently installed racks.

The.

radiation level at the surface of the water would be significantly gr ater than the required twelve feet coverage and without compensating measures, worker radiation exposure would oc greater.

However,- the health and safety of.the general public would not be affected since no release of radioactivity wculd

' occur For'this reason and the very low-probability of such-an accident, the consequences were not evaluated.

I l 6.!

f,17

, Board Question flo. G Does the LACBUP, equipment comply with flUREG-0554 " Single-failure Proof Cranes for Nuclear Power Plants" (August,1979)?

Response

To the best of my knowledge no nuclear plant has such a crane.

The referenced fiUREG is a newly developed guide.

DPC designed and installed, with flRC approval, a crash pad on the floor of the open area of the spent fuel storage pool.

The

' intended function of the crash pad is to mitigate the consequences of a postulated cask drop in the spent fuel storage well so that such an event wili not breach the integrity of this pool. The crash pad was installed in case the containment polar crane equipment fails while lifting the fuel cask over the FESW. The consequences of cask drop ~onto stored fuel have been documented.

Board Question flo. H Should the integrity of the fuel pool liner, walls, drain lines, and valves somehow be lost, it appears that fuel melting could occur which could result in large fission product releases.

If so, what emergency provisions are there to either prevent or limit melting or to mitigate the consequences?

1162 318

. a Pesponse The FESW is a massive reinforced concrete structure with nearly a five foot thick floor and walls averaging three to five feet in thickness constructed inside the containment stru.cture. The probability of a class 9 accident in the spent fuel pool is very low and ti'e consequences of such accidents, because of the very low probability, are not analyzed by the licensee or the flRC.

It cannot be determined, following such a destructive event, what capability in terms of confinement and

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fuel cooling capab'ility would remain to mitigate the consequences of fuel over-heating since the event necessary to cause the destruction of the FESW would likely damage the nearby reactor vessel and the engineered safety features.

flowever, for less catastrophic conditions where the fuel remains covered but normal cooling is lost, fuel integrity can be maintained by providing a few gallons per minute of water available from several sources (such as the onsite fire water; the nearby liississippi River; and onsite water storage tanks) to.

replace that lost in the containment atmosphere due to evaporation (boil off).

I have rea: the foregoing affidavit and ' swear that it is true and accurate to the best of my knowledge and belief.

m (Tcm

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James Shea Subscribed and sworn to before a

me this.

1 day of

' l ', 1979

-N J

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mara Notary Puali ity Commission Expires

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Concret.e Wal1 FIGURE 3.1 FUEL STORAGE POOL ELEVATIO'I - NORTl! A 1D SOUTI! WALLS s3 2 11/)

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PROFESSIO:lAL QUALIFICATI0ls OF JAMES J. SHEA I am the fluclear Regulatory Com1ission Project Manager for the La Crosse Boiling Water Reactor as well as two other nuclear po.cer plants.

I have served the Commission in this capacity for more than 15 years hav r-) at one time or another been Project Manager for 12 of the nuclear power plants now licensed to operate in the United States.

As a Project Manager I manage and participate in the review and evaluation of s<fety and environmental considerations associated with the design ad operation of nuclear power facilities, especially those licensed for operation.

I also currently manage and participate in the Systematic F 'aluation Program which involves a comprehensive review and evaluation of older operating facilities to determine and document the acceptability of their departures from current licensing requirements.

I have contributed to tvio special studies performed by the flRC.

The reports titled " Generic Environmental Statement on Mixed Oxide (GESMO - 1976)

Fuel and fluclear Energy Center Site Survey (flECSS 1975).

Prior to goverrment service, as a manager and engineer in industry, I-was responsible for thermal hydraulics, heat transfer. instrumentation and controls design and testing of nuclear reactor prototypes for the Navy nuclear program.

I have a BS and MS in Chemical Engineering from Worcester Polytechnic Institute of Technology, Worcester, Massachusetts,1944 and 1947, and am a registered professional engineer in the state of flew York.

116.2 521

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