ML19263B005

Motion for Summary Disposition of Suffolk County Contention 7a(vii).Contention Raises No Matl Issue of Fact Re Compliance W/Criteria for New Fuel Storage Sys.Contention Is Ripe for Summary Judgment in Favor of Applicant

ML19263B005
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	12/18/1978
From:	Whittemore F HUNTON & WILLIAMS
To:
Shared Package
ML19263A941	List: ML19263A958 ML19263A964 ML19263A985 ML19263B002 ML19263B005 ML19263B022 ML19267A293 ML19267A306 ML19267A308
References
NUDOCS 7901040035
Download: ML19263B005 (5)

Text

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NUCLEAR REGULATORY COMMISSION 2 ## -:-

% O4 3i Before the Atomic Safety and Licensing Board g

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322

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(Shoreham Nuclear Power Station, )

Unit 1) )

Motion for Summary Discosition of SC Contention 7a(vii)

1. Suffolk County (SC or County) contention 7a(vii) was ruled by the Board to be adequately particularized, Tr. 63, and is as follows:

7a. Intervenors contend that the Applicant and Regulatory Staff have not adequately demonstrated that the Shoreham nuclear system meets the requirements of 10 CFR, Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, with regard to the design adequacy of the following system and response characteristics and/or criteria:

vii. Criterion 62 requires criticality of fuel in the storage and handling system be prevented by physical systems or processes.

Possibility of criticality in the new fuel storage system as a result of reactivity addi-tion by fire protection fogging systems has not been demonstrated to be in compliance with this requirement.

SC's Amended Petition to Intervene at 10-11 (Sept. 16, 1977).

7901040037

2. This contention raises no material issue of fact for the following reasons:

a. The criticality of fuel in Shoreham's new fuel storage system has been analyzed and found to meet the require-ments of Criterion 62.1/ See Affidavit of William J. Tunney at *3 FSAR S 9.1.1.

b. Although FSAR S 9.1.1 does not explicitly address the possibility of partial flooding of the new fuel storage area by the fire protection fogging system, this possibility is covered by the analysis of optimum moderation in that area, See id.

3. For the above reasons, SC contention 7a(vii) raises no material issue of fact regarding compliance of Shoreham's new fuel storage system with Criterion 62. Accordingly, under 10 CFR S 2.749, this contention is ripe for summary judgment in favor of the Applicant. We request that disposition.

Respectfully submitted, LONG ISLAND L GHTING COMPANY

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F. Case Whittemore W. Taylor Reveley, III Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 DATED: December 18, 1978

-1/ SC alleged that the Applicant's demonstration of com-pliance with Criterion 62 was deficient because FSAR S 15 did not contain the underlying assumptions. See SC's Re-sponse to Applicant's Second Set of Interrogatories at 21-22 (Jan. 31, 1978), SC's Particularized Contentions at 7-10 (Nov. 30, 1978). However, the underlying assump-tions appear along with the analysis in FSAR S 9.1.1.

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SC 7a(vii)'

UNITED STATES OF AYERICA NUCLEAR REGULATORY COMMISSION Ecfore the Atomic Safety and Licensing Board In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322

)

(Shoreham Nuclear Power Station, )

Unit 1) )

AFFIDAVIT OF WILLIAM J. TUNNEY William J. Tunney, being duly sworn, states as follows:

1. I am Manager of the Nuclear Fuel Division in the Nuclear Engineering Department of Long Island Lighting Com-pany. Astatementbfmyprofessiona'_qualificationsis attached.

2. Shoreham's new fuel storage systen and the criti-cality analysis for that system are described in FSAR 5 9.1.1.

The new fuel storage system consists of a series of aluminum racks that maintain the spacing between fuel assemblies.

Neutron absorbing curtains are installed between the racks.

3. The Staff has implemented 10 CFR Part 50, Appendix A, Criterion 62 by publishing in Standard Review Plan 9.1.1 guidelines for determining when the design of a new fuel storage system will ensure that the new fuel remains sub--

critical with an ample safety margin. The Plan states that the effective multiplication factor (keff) should not exceed:

a. 0.95 for dry storage conditions (water density of 0.0 gr/ce) or total flooding (water density of 1.0 gr/cc); and

b. 0.98 under optimum moderation conditions.

The criticality analysis under optimum moderation conditions covers a range of conditions with water densities between 0.0 and 1.0 gr/cc which would include both fire protection fogging and partial flooding. Shoreham's new fuel storage system meets the guidelines in Standard Review Plan 9.1.1. See FSAR S 9.1.1.

William J. Tunney Subscribed and sworn to before me this ,rr day of December 1978.

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t:ct:r; Pub!!:, State cf New York No. ',04GC3327 QualC:c in Nass u County Comm:: sten ex;: ires Mar. 30,19..'

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QUALIFICATIONS OF WILLIAM J. TUNNEY My name is William J. Tunney. My business address is Long Island Lighting Company, 175 East Old Country Road, Hicks-ville, New York. Since February 1978. I have been Manager of the Nuclear Fuel Division and report to the Manager of the Nuclear Engineering Department. I am responsible for nuclear fuel design and performance, long-range planning and scheduling, as well as technical and economic direction for the various com-ponents of the nuclear fuel cycle.

I graduated in 1962 from Worcester Polytechnic Institute with a Bachelor of Science degree in physics. I have completed training courses in BWR and PWR technology.

From 1962 to 1970 I was employed by Brookhaven National Laboratory in the position of Physics Associate. During this period I conducted independent research in the area of experi-mental reactor physics. I have been employed by LILCO since 1970. In the period 1970-1973 my responsibilities were to provide technical support for the licensing afforts on the Shoreham Station. From 1973 to the present I have been responsi-ble for nuclear fuel management, including long-range planning, fuel contract evaluation, fuel economics, and development of the fuel management capabilities necessary to support the safe and economic operation of LILCO's nuclear plants.

I am a member of the American Nuclear Society.