ML20105B682
| ML20105B682 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/11/1992 |
| From: | Marucci M AFFILIATION NOT ASSIGNED |
| To: | Smith Atomic Safety and Licensing Board Panel |
| References | |
| CON-#392-13215 OLA, NUDOCS 9209210100 | |
| Download: ML20105B682 (23) | |
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gDR ADOCK 05000336
y 00CFETED L'wc UNITED STATES OF AMERICA NUCLEAR REGULATORY CCFMISSICN T
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in the Matter of j
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?l0RTHEAST NUCLEAR ENERGY COMPANY OccKet f(c.(s) 50-336-OLA (Millstone Nuclear Power Station, k
Unit No. 2)
CERTIFICATE OF SERVICE ccm1 Memo 9/11/92 withAugl3LTR CTDHS MEMO 9/8/92 Lieberman.Dodd LTR 9/10/92
~
I hereoy certify that copies of the foregoing
.kU LTR with Attchments 9/10/92' have been served upon the following persons by U.S. mail, first class except as otherwise noted anc in accoraance with the recutrements of 10 CFR Sec. 2.712.
Office of Comission Appellate Administrative Judge Ivan W, Smith. Chairman Adjudication Atomic Safety ano Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 Administrative Judge Administrative Judge Charles N. Kelber Jerry R. Kline Atomic Safety and Licersing Board Atomic Safety and 1,.icensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Wasnington, CC 20555 Washington, DC 20555 Edwin J. Reis. Esq.
Richard M. Kact".h John T. Hull, Esq.
Director, Nuclear Licensing Office of the General Counsel U.S. Nuclear Regulatory Comission Northeast Utilities 4
Washington, DC 20555 P. O. Box 270 Hartford, CT 06101 Nicholas S. Reynolds, Esq.
Patricia R. Nowicki John A. MacEvoy, Esq.
Associate Director Winston i Strawn EARTHVISION, Inc.
1400 L Street. N.W.
42 Highland Drive Washington, DC 10005 South Windsor, CT 06074
2 Docket No. 50-336-OLA Mary Elles Marucci Michael J. Pray, AIA 104 Brcwnell Street 87 Blinman Street New Haven, CT 06511 New London, CT 06320 Rosemary Griffiths Joseph M. Sullivan 39 South Street 17 Laurel Street Niantic, CT 06357 Waterford, CT 06385 Office of the Secretary Attn: Docketing and Service U.S. Nuclear Regulatory Comission Washington, D. C, 20555
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N Dated at /lw k$ t- (7 this (Address)
//_ day of S v ita 1992
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13 AUGUST, '992 ATOMIC SAFETY AND LISENSING 80AcD PANEL UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C.
RE: DOCKET NO. 50-53C-OLA,,ASLEP 92-665-02-OLA MILLSTONE POWER STATIC" UNIT II, SPENT FUEL POOL REDEEIGN AMCNDMENT TO INTERVENTION AND HEARING REQUEST:
ON AUGUST 3RD WE RECEIVED YOUR PANEL'S SCHEOULE FOR FILING OUR ADDITIONAL REQUESTS FOR HEARING AND INTERVENTION WHICH WE INTEND TO COMPLETE BY THE AUGUST 14TH C::ADLINE.
WE FEEL THAT WE HAVE SUFFICIENT CAUSE TO ASK FOR A HEAHING BASED ON THE REDESIGN NOT
.ONLY NOT MEETING THE SPENT FUEL POOL NRC OESIGN SPECIFICATIONS (SAFETY STANDARDS), BUT ON IT ALSO MAKING THE POOL MORE DANGEROUS RATHER THAN LESS DANGEROUS FROM THE CONDITION sOTED IN THE LER#92-003-00.
HONEVER, BECAUSE OF VACATIC.I WE ARE UNABLE TO REACH EITHER OF OUR TWO EXPERTS WHO WILL BE FILING CONTENTIONS.
ONE IS EXPECTED BACK ON AUGUST 13TH AND THE OTHER ON AUGUST 16TH.
ADDITIONALLY, WHILE WE HAVE BEEN ABLE TO GET SOME INFORMATION FROM NORTHEAST UTILITIES THAT OUR EXPERTS WILL NEED TO LOOK AT BEFORE SUDMITTING THEIR QUESTIONS AND AFFIDAVITS, WE ARE UNABLE TO GET FROM NORTHEAST UTILITIES THE CONFIRMING CALCULATIONS BECAUSE THEY ARE CLAIMING THAT THE CALCULATIONS THEY DID WERE NOT USED IN THE REDESIGN CF THE POOL AND REFUSE TO GIVE THEM TO US.
WE NOW NEED TO GET THESE CALCULATIONS FROM THE OUALITY ASSURANCE COMPANY THAT CHECKED HOLTEC'S CALCULATIONS THA.T WERE USED TO REDESIGN THE' POOL BUT NU DID NOT TELL US THE NAME OF THE QUALITY ASSURANCE COMPANY, NU CONTINUES TO USE THIS POOL AT MAXIMUM CAPACITY IN REGION A AND IN SEPTEMBER PLANS TO USE THE POOL FOR A NEW FUEL MOVEMENT INTO THE REACTOR.
BECAUSE OF THIS, WE AGREE WITH YOU THAT DELAYS ARE NOT APPROPRIATE.
HOWEVER, WE ARE UNFORTUNATELY CAUGHT IN CIRCUMSTANCES BEYOND OUR CONTROL.
BUT WE DO EXPECT THAT-OUR EXPERTS WILL BE FILING THEIR CONTENTIONS WITHIN TEN CONTENTIONS OF CCMN, INC. TO NRC.
PAGE l OF 7.
(10) DAYS, AI 5 ATE: AEOVE, nE FEEL THAT WE
' AVE EUF: ICIENT EASON
'O EELIEVE ~~ ~ E REDES!3N NOT ONLi DCEE ':~ ERING THE F:!L UD ~~ '. E SA;ETY STANDARDS, BUT IN CACT REDUCEI IAFE7Y IN THAT DOOL.
%E CEEL TaA? YOU ARE ASKING US TO :: E/ E
.sR CONCEONS AGA!NST ~H!I FEDESIGN WITnOUT BENEFIT 0 HE2;ING ; ; ;'; E ~ E A F I N G D I S C O t/ E : V WE HAVE T-EREFORE TAKEi IT UPON : cc5E_iES TO FIND CJ~ A5 N' U C ~
5 WE CAN 50 THAT WE WILL EE IN COMED EECAUSE WE TAKE THIS MA*TER MOST SEPIIUSLi, WE NOPE HOLTEC NO NU WILL COCPERATE BY PROVIDING LS WIT, THE INFORMATION WE NEED AND THAT YOU WILL GRANT A HEARING SOON.
NU -AS AGREED TO PROVIDE US WITH I N F C:iM A 110 N ABOUT THE WOVNT CF RADIOACTIVITY (IN CURIES PER ISOTOPE) IN A TYPICAL ASSEvetv T-AT HAS UNDE CONE 85" SURNUP WILL HELP THE PUBLIC TO UNDERSTANO TWE POTENTIAL RISKS IN THE EVENT OF AN ACC DENT.
THE NRC HAS TRADITIONALLY RULED THAT ANY REQUESTS FOR DESIGN CHANGES TO THE SPENT FUEL POOLS DOES NO T CONSTITUTE A SIGNIFICANT HAZARDS RISK.
THEREFORE Cui, RECUESTS FOR HEAFING AND INTERVENOR STATUS, WHETHER GRANTED CR DENIED, WouLD N NO WAY AFFECT THE COMPANY FROM PROCEEDING AS IF NO SIGNIFICANT HAZARD EXISTED.
THE DEADLINE FOR ASKING FOR A HEARING WAS MAY 28,1992 SO WE MOVED OUICKLY AND REQUESTED NOT ONLY A HEARING AND INTERVENOR STATUS, EUT THAT AN EXTENSION BE ALLOWED SO THAT THE USE OF TnE SPENT FUEL POOL WOULD NOT BE ALLOWED UNTIL WE HAD TIME TO SUEM:T EXPERT WITi.ESS AND OUR CONCERNS.
WE ASKED FOR A 10 DAY EXTENSION.
JOHN STOLTZ OF NRC DENIED OUR REQUEST AND WE WERE INFORMED THAT THE NRC WOULD DELIVER THE AMENDMENT TO THE EPENT FUEL POOL ON MAY 297H AT NOON.
LATER THAT DAY WE SPOKE AGAIN WITH MR. STOLTZ HE SAID THAT A FINAL RULING WOULD BE MADE TO ADDRESS SOME OF THE CONCERNS WE AND SEVERAL OTHER PEOPLE MADE AND THAT DECISION WOULD SE MADE MONDAY OR TUESDAY (JUNE 1 OR 2).
WE FEEL, BECAUSE OF THE ENORMITY OF THE DAMAGE TO LIFE AND PROPERTY A SPENT FUEL POOL RELEASE ACCIDENT CAN CAUSE, THAT CUR REQUEST FOR AN EXTENSION OF 10 DAYS IS NOT UNREASONABLE.
IHE ERRORS FOUND IN THL DESIGN AND OPERATION OF THE SPENT FUEL POOL IN FEBRUARY 1992 TERRIFY US.
A CRITICALITY COULD HAVE OCCURRED IF OTHER PROBLEMS HAD OCCURRED AT THE SAME TIME, ALLLiING A CHAT.N PEACTION TO BEGIN IN THE WASTE AND COULD HAVE RESULTED IN RELEASE OF THE RAOIOACTIVITY OF THAT FOOL WHICH IS AT LEAST FOUR TIMES THE RADIOACTIVITY OF AN OPERATING NUCLEAR PLANT CAUSING DESTRUCTION MUCH GREATER THAN CHERNOSYL.
THE FACT THAT THE PROPOSED CORRECTIVE ACTIONS WERE NOT SEING TESTED, AND THE MATHEMATICAL CORRECTIONS PROPOSED BY THE COMFANY AND THE ORIGINAL DESIGNER (ABB-COM8USTION ENGINEERING) WERE NOT BEING INDEPCNDENTLY ANALYZED, DOES NOT SEEM APPROPRIATE.
CONTENTIONS OF CCMN, INC. TO NRC.
PAGE 2 OF 7.
I IHAT'THE 'OOL CAPACITY HAD ALREADY EEEN INCREASED I4 1996 ANC IN 198? EY FACKING THE FUEL CLOSER TOGETnEn AND 09 a EXPERIMENTA_
PROG: AM 07 RECONCENTRATING THE IFENT.LE EE OAE E:ACCING. MA E THAT :00 AN ONGOING EXPER!M%T.
WE WEFE :.RTHER SHOCMEO UY ?HE COMPANY'S REGUEST, GPANTED EY
~~E NEC ON MAf 20, 1992, THAT ALL CRITICAu!TY MONI CRS BE REFOVED CROM THA-FARTICULAR POOL.
IN OCTcEEa cF 1991 TwE NFC GRANTED NU' REhEST THAT ALL CS TICALITt MONIT';PI EE REMOVED FFOM ALL OF THE!: IFENT FUEL POOL:.
IN AC7YAL: TY THEi r;E 'EVER THE:5.
a THIS SPEC::IC REOVEST-FOR REMOVAL OF T"E CRITICAL:TY MON!TCRI WAS GRANTED ON.MAY 20, 1992 AFTER TwE M:LL: TONE II POOL WAS FOUND TO-HAVE AND ERROR-OF 5% IN ITI /EFF. CALCULATIONS ERINGING IT CLOSE TO INVOKING A CR TICALITY PRO 9LEM POSSIBLY RESULTING IN A CHAIN REACTION.
= CRITICALITY MONITORS ARE, IF WE UNDERSTAND CORRECTLY, NEUTRON F L U)r ME AS'.; RING EQUIPMENT _ AND THEY NEVE: WERE USED IN THAT FOOL OR ANY_OTHER POOL OF NU OWNERSHIP IN CONNECTICUT.
IHIS MEANS THAT THE UNIT 11 FOOL IS PART OF AN EXPERIMENT.
NU'S ATTORNEY,-NICHOLAS REYNOLDS, TOLD US ON JULY 15 THAT THE COST OF USING-THE POOL FOR_ SPENT FUEL STOPAGE CIO NOT INCREASE THEIR COITS SIGNIFICANTLY, BUT PLACING MONITORS IN THE POOL WOULD.BE.A COST HE FELT WOULD NOT EE JUST!FIED BECAUSE THE-COS*
PROBAELY COULD NOT BE PASSED ON TO THE RATEPAYERS.
lN ADDIT!ON TO THE RISK OF CRITICALITY IN THAT OOL,-THERE IS
.ALSO AERISK OF COOLANT WATER LOSS AND A CHEMICAL REACTION
' OCCURRING, RELEASING VAST AMOUNTS'OF CESIUM 137 AND STRONTIUM 1902 THIS-RISK OCCURS EVERY TIME THE-FUEL IS MOVED INTO OR OUT OF THE REACTOR CORE.- BETWEEN JUNE 26 AND JULY'4,-1992, NU MOVED ALL OF~THE FUEL OUT~OF THE REACTOR SO THEY COULD EEGIN REPLACEMENTRDF THE STEAM GENERATORS, ON REFUELING THEY WILL MOVE BACM 2/3 OF-THE OLD FUEL'AND 1/3.WILL BE NEW FUEL OF A MUCH
-HIGHER ENRICHMENT THAN HAS EVER BEEN USED IN THAT. PLANT WHEN WE EPOKE TO JOHN STOLTZ,.WE TOLD HIM THAT THE RISK. EVEN I:
VERY SMALL,-WAS> UNJUSTIFIED BECAUSE THE DAMAGE WOULD BE EXTREMELY L ARGE AND THERE WERE OTHER f1ETHODS OF FUEL STORAGE THAT WOULD: NOT ENTAIL THESE RISKS.
HE INFORMED US THAT NO PLANT
'WOULD BE~ CONSIDERED FOR ORY CASK STORAGE UNTIL IT RAN'OUT OF SPACE IN: ITS POOLc-WE FEEL THAT FOR THE SAFETY OF CONNECTICUT AND SURROUNDING' STATES THAT THIS MATTER NEEDS TO BE IMMEDIATELY INVESTIGATED.AND THESE. RISK 1 BEARING, DOWNLOADING, LOADING AND USE 0F THIS' POOL BE INVESTIGATED BEFORE THIS PLANT IS ALLOW TO L
CONTINUE' BUSINESS AS USUAL.
L K
INSTEAD.CF; ALLOWING PUBLIC INPUT INTO TnE PROCESS, AN NRC OFFICIAL: TOLD US THAT THEY WERE "NOT GOING T0 00 ANYTHING THAT WOULD.$TCP THE PROCESS" AT MILLSTONE.
THEIR DELAY HAS NOT RESULTED IN ANY CHANGES BEING MADE.
WE-WERE TOLD ~ HAT THEY~WE:E GOING lTO CONSIDER THE CONCERNS THAT A CEW OF US HAD EXPRESSED 70 l
l; h
. CONTENTIONS OF CCMN,~.INC. TO lRC.
PAGE-3 OF 7.
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r THEM. BU~ NO: HARING WOULD BE HELD PRIOP TO THEIR RULING.
STCLT, WHO II THE FROJECT: DIRECTOR CR THE NRC, 'OLD A MEMBEF
- TbCLEAR INFORMATION :EIOURCE IE V:IE (NIRT THAT I~ aA; 700
. ATE TO F~LE A REQUEST ~: 0 HEARINC CR TO SUSMIT C:MVEN~S.
IP.E R E r
MA( BE-OTHERS WHO TRIE
~} INTEFVENE AND WERE NOT ACCF'TED
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.o CN MAY 29N AFT 7R FECE 11:.G TwE R. A VESSAGE WAI LE;- COP M'CHAEL FFAY, ONE OF OL: MEMEE a Wm0.!VEI NEaR ~wE FLANT, 10 CONTACT.OUR COCPD!NAT/.:.
[A MA( 27TH ME RETURNE: THE CALL Ah!
WAS G:VEN.IHE INFORMAi;ON L!STED IN T-E FR SO THAT nE COULD REOVEST A HEAR!NG AND INTERVENE.
ON mar 237H HE CALLED-AGAIN TO TELL OUR COORDINATOH THAT THE NUMBER GIVEN HIM WAS NOT
_ OPERATIONAL.
H:fWAS GIVEN PR. STOLT!*! NUMBER WHICH HAD BEEN CBTAINED EARLIER THAT DAY: WHILE FILING FCP AN EXTENSION AND-HAD COUND THE NUMBER GIVEN IN THE FR WAS INVALID..
HE SAID LATER THAT HE HAD CALLED-
- MR. $TOLTI1AND. EXPLAINED TQ.HIM THAT HE WOULD EE SENDING HIS LETTER THE NEXT DAY BUT DIO NOT-HAVE 7
- ME TO HAVE IT NOTARIZED fAND-THAT HE WOULD SEND nIS NOTARIZED COPY ON JUNE 3RD.
MR.
STOLTZ.DID NOT TELL HIM iuAT IT WOULD-NOT EE ACCEPTED.
MR. PRAY FEELS HIS REOUEST WAS TIMELY,'BUT IT MAY.NOT HAVE BEEN CLEAR FRCM HIS LETTER THAT HE DID NOT HAVE ANY INFORMATION ABOUT THIS UNTIL MAY.27TH.
THERE.IS NO WAY HE COULD HAVE COMPLIED WITH THE DEADLINE AND STILL PRESENT AN ACCURATE ASSESSMENT CF HIS CONCERNS.
OUR LIBRARY 7USUALLY:IS 3-TO 6 WEEKS SEHIND IN GETTING THE' FEDERAL REGISTER.
THE-FR ONLY-SERVES THOSE WITH MORE SOPHISTICATED SKILLS THAT KNOW ABOUT AND HOW TO USE THIS PUBLICATION.
IT SEEMS THAT NEITHER THE UTILITIES NOR THE LOCAL
' PAPER OF RECORO ARE REQUIRED TO INFCRM THE LOCAL PUBLIC, THE RATEPAYERS OR THE SHAREHOLDERS OF THESE LICENSE CHANGES, OR DESIGN-ERRORS.
WE AS'ANJORGANIZATION,'BEING TOTALLY VOLUNTEER AND LESS THAN ONE YEAR 10LD NEED TO DEPEND UPON OUR MEMEERSHIP AND GENERAL PUBLIC TO!LET US'KNOW WHEN THEY ARE CONCERNED ABOUT CONDITIONS OR PLANNED SITUATIONS AFFECT!NG THEIR HEALTH, SECURITY AND WELL BEING.
WE NEED-TO BE SURE THAT THEY WILL KNOW ABOUT MATTERS THATrMUST COMEJBEFORE YOUR COMMISSION THAT AFFECT THEM.
'ALSO,.IFiTHE;NRCLSTAFF DECIDES THAT'NO SIGNIFICANT HAZARDS RISK-EXISTS,JTHEY ARE THELONLYEONES A CITIZEN CAN GO TO TO ASK FOR A
-HEARINGF THIS WILL THEN-PUT THE STAFF IN'A POSITION OF. RULING-LON!THEMSELVES.THAT A RISK DSES EXIST,. AND THEY NEED'TO MAKE THAT DECISION BEFORE A HEARING-CAN BE-HELD.
IFLTHEY' RULE FINALLY THAT NO-SIGNIFICANT HA;ARD EXISTS, THEN A HEARING WILL NOT BE HELD BEFORE THE LICENSE-IS ISSUED.
IT SEEMS U
INAPPROFRIATE-THAT.SIGNI~ICANT_ RISKS ARE BEING TAKEN BY STAFF
-WITHOUT RECOURSE AVAILABLE-TO THE PbELIC CONCERNING THEIR SAFETY CONTENTIONS OF CCMN, INC-TO NRC. -FAGE h OF 7.
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'9Y' INDEPENDENT JUDICIAL PEVIEW, IMIS II TRULY A CAIE 00 7"E IX
_ EEING IN CHARGE OF THE HENHOUSE.
InE PANEL THAT THIS VATTE: II NOW EE;C E !! C:-OIES INTEFN.LLt I: THEI:-DECISION IS NC7 ELT Ei THE OUELIC 70 A L L O'.s ACEII.~: a
- HEARI 3,
THE-ONLY REVIEW THAT I: EXTE9NAL AND 4 /IC AL AICI ~NLf WnETHER'THE NPC :CLLOWED THEIR FR :;C E"'; A ES CORRECTLY, AND NOT F
THE.NRC FROTECTED THE SA:ETY AND PUELIS INFOR.vATISN RIGHTI C:
TnE CITIZENS.
THE flRC: ANEL AND.STA.F FULINGS CAN SE REVIEWED EY TnE
- COMMISS:ON.- BUT IF THE COMMISSION RULES AGAINST THE SA:ETY C:
THE PEOPLE,"THE NEXT STEP IS ONLY PROCEDURAL AND W!LL NOT GIVE.
THE PUBLIC A FORUM FOR ADDRESSING THE 9 SPECIFIC S*FETY CONCEFNS OR EVEN THE SATISFACTION THAT SUCH CONCERNS WERE FROFERLY ADDRESSED.
.IN THIS MATTER'BE ORE THE PANEL, WE WERE TOLD SY GUr VIISING,-
NRC THAT NO SIGNIFICANT1 INCREASE-!N RISK WAS CREATED BY THE
' PROPOSED DESIGN CHANGE'SUT HE WOULD NOT TELL HOW MUCH THE RICK
- WOULD BE INCREASED OR WHAT-THE ACTUAL RISK WAS I: THE PLANT MET DESIGN SPECIFICATIONS, OR WHAT THE RIEK WAS AT THE TIME THE F
COMPANY DISCOVERED DESIGN ERROPS.
WE WERE BEING. ASKED TO TRUST THAT THE NRC MNEW WHAT SIGNI:ICAN~
- WAS,--AND. TOLD WE DID NOT HAVE THE RIGHT TO REQUEST THE INFORMATION.
SUBSEQUENTLY, WE WERE NOT PROVIDED WITH THE REOUESTED-INFORMATION.
-MR. VIS$1NG AND STOLTI SPENT.2 DAYS AND A. WEEKEND FINALI!!NG THEIR REV!EW OF.OUR CONCERNS, WHICH BASICALLY WERE IF THE POOL WAS.0UT: OF COMPLIANCE, HOW COULD THE NEW DESIGN'PUT IT INTO-COMPLIANCE BY. FORCING ALL THE FUEL.THAT WAS IN THE REACTOR TO SE STOREDiIN 2/3RDS OF THELSPACELTHAT'WAS ALLOWED WHEN IT WAS OUT uCF COMPLIANCE OUR MEMBERS AND OTHERG HAVE-ADVISED TO PERSONALLY FILE THEIR COMMENTS, REOUESTS FOR HEARINGS--AND INTERVENOR STATUS, AND PETITION FOR HEARING PRIOR TO ANY FURTHER USE OF THE MILLSTONE-II1 POOL EVEN THOUGHLTHEY.MAY CONTINUE TO BE TOLD THAT THEY WILL
-NOT BE ACCEPTED.
AS PREVIOUSLY STATED, WE HAVE REASON-TO BELIEVE THAT-THE.PUBLIC WAS NOT LEGALLY NOTICED.
.IT SEEMS THATLEVERY POSSIBLE-EFFORT HAS BEEN MADE-TO KEEP THE PUBLICEIN=THE DARK.
THE COPY OF.THE FEDERAL REGISTER OF APRIL 28 SENT-TO-A1 MEMBER OF. DON'T WASTE CONNECTICUT DID-NOT CONTAIN THE: NOTICE PAGES WHERE THE NOTICE OF OPPORTUNITY.FOR HEARING SHOULDLHAVE BEEN-LOCATED.
- THE NUMEER-LISTED-IN THE' FEDERAL REGISTER FOR THOSE TO CALL I:
LTHEY WERE1Fi_-ING IN THE-LAST-TEN DAYS OF THE NOTICE PERIOD WA3 INVALID.
.THE CONNECTICUT DEPARTMENT OF' ENVIRONMENTAL PROTECTION, DIVISION
.0F RADIATION CONTROL COULD.NOT TELL US WHEN THEY-RECEIVED NOTICE CONTENTIONS lCF.CCMN,.INC..TO:NRC.
PAGE 5.0F 7.-
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OF-THE.PPCPOSED LICENSE CHANGE REQUEST OR WHEN !T APPEARED IN THE'FEDE;.AL REGISTER,
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HOWA3D TO GET THE Ur:L..-
v MAIL.GI A CCPY 0: ~~E!A RECUEST CR L:CEN;E AMENOMENT THEv.IENT US 1 COPY OF NE AMENDMENT.
BUT WIT-0.T
-E NRC NOT:CE.
WE CECEIVED THE NU APPL: CAT ;N AEOUT Mv 10.
THE C~F AND WE:E TOLD T-AT THE't O R:-
EE:: RECC Di OF NRC CAL _I UNLEIE T-EY HAVE.A NEE: TO-ACi CN IT.
7-E #ERSON WE I OKE TO SA:D THE DEPARTMENT DIO NOT FEEL ANY.NEED TO ACT.
WE CALLED THE.NRC TO GE THE DATE.THA* THEY WOULD-GIVE NOTICE FOR THE -EARING.. FINALLY, ON MA3 21 WE WAs TOLD 6Y THE OFFICE OF A MR. NELVIN THAT'IT HAD SEEN NOT!OED IN THE APRIL 28 FR.
HIS SECRETARY DICJNOT WANT TO SEND US A COPY, WE HAD TO EXCLA:N THAT OUR LIERARY WAS LATE IN RECE: VIN 3 THE FP AND WE-MIG-T GE~
IT-3~0NER IF 3HE MAILED IT.
IT WAI'PE EIVED THE MAY.26-MAIL.
WE <NEW WHAT WE WERE LCQKING ~0R, AND rNEW THE TIME FRAME IN
-WHICH IT MIGHT HAVE BEEN NOTICED.
IN.MID-MAY WE KNEW IT-WOULD BE NOTICED AFTER 16 APRIL, WE AL5O ALERTED " DON'T WASTE U3" THAT T WOULD APPEAA IN THE FR
-APR!L 1 CR LATER, AND TO LOOK FOR IT.
THEY DID A SEARCH IN
- M!D-MAY-AT TWO LOCATIONS IN THE GREATE: D.C. AREA AND D!DN'T
-FIND IT.
nN IT-SEEMS THE RULE-OF LAW-AT THE-FEDERA LEVEL IS OFTEN CIRCUMVENTED BY ADMINISTRATIVE SETTLEMENTS BEH!ND CLOSED DOORE AND THE PUBLIC CONSTANTLY SHUT OUT,NC~ ONLY FROM THE PROCESS, BUT ALSO-FROM NECESSARY INFORMATION RELEVANT TO MAINTAINI.NG A DECENT STANDARD OF LIFE, IT FURTHER SEEMS THAT IF THE PUBLIC :S NOTIFIED OR ALLOWED A HEARING, IT IS A:TER THE DEED IS DONE AND SIGNED.
' APPEARANCES GIVE RISE TO CONCERNS THAT THIS INDUSTRv !NTENDS TO CONT!NUE TO_MAKE THE WASTE,-BUT NOT AE3UME LIABILITY.
THE RISK ASSUMPTIONS MADE-BY THE-COMPANY AND THE NRC ARE EASED
-MORE ON. COST IN' DOLLARS AND POLITICAL COWER THAN ON DANGER OR DEST UCTION-OF HEALTH AND ENVIRONMENT.,
WHAT NU AND TS REGULATOR $1SEEM TO BE DOING 15 WAITING THE. RESOURCES, INGENUIT',
.AND-HEALTH OF THE PEOPLE SY DIVERTING IHE.FU9LIC FROM ITS RIGHT TO-BOTH'INFORMATION AND CONSENT.
NOW-THAT NU HAS: A LIENSE TO CONTINUE TO USE THEIR POOLi, THE ONLY THING WE CAN ash YOU FOR IS !MMEDIATE ATTENT!ON TO REMDVE THIS ABILITY BY TAKING' ACTION THRCUGH AN APPEAL TO THE NRC LICENSE SOARD OR 'THE NRC NUCLEAR REAC~CR REGULAT!CNS DIRECTOR, OR *THROUGH1AN INJUNCTION EY A FEDERAL OUPT.
EACH-POOL CAN ~ CONTAIN: THE R ADIO-ACT!V:TY OF UP TO TEN REACTCRS L
AND EACH REACTORLHAS A P O O L '._
JUST ONE UEL POOL ACCIDENT RELEASINGLITS-RADIOACTIVITY WOULD EXCEED IN DAMAGE TO LIFE AND CONTENTIONS OF CCMN,.INC. TO NRC, PAGE 6 OF 7.
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,,,,,,3,7*,3$ll'm September 10, 1992 Mr. James M. Taylor Executive Director of operationw Nuclear Regulatory Cominission Washington,: D.C.
20555 Dear Mr. Taylor We are writing to you concerning inferination we have received-from one of our constituents, Mary Ellen Marucci, regarding the issuance of a design change in the spent fuel pool for Millstone Unit Number 2.
We are aware from previous correspondence that the NRC staff made a determination that the proposed license amendment did not involve a Significant-Hazards Consideration and issued the desip change in early June.
While we are also aware that Ms. Marucci s-request for a hearing on this matter is before the Atomic Safety and Licensing Board Panel,.we wanted'to bring to your attention tho' attached material, in particular the memorandum from a sts!!
member of the Connecticut _ Department of Health Services.
Ms. Marucci is most immediately concerned with the need for immediate installation of criticality monitors in the Millstone spent fuel pool.
We would appreciate if you would review the concerns raised on'this issue as expeditiously as possible and report to us in-detail, in accordance with the requirements of the Administrative-Procedure Act assuming such review does not conflict with on-going administrative actions.
. Sincerely,
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ff STATE OF CONNECTICUT DEPARTMENT OF HEALTH SERVICES To: David R. Brown From: Carolyn Jean Dupuy Date: September 8, 1992-
Subject:
Certespondence from Ms. Marucci, re: SPUlT REACTOR POOL SAFETY I have reviewed.the packet of information from Mary Ellen Marucci which Commissioner Addiss forwarded to us and requested that we determine whether to forward in whole'or part to DEP.
The packet contained (1-) materials from the Cooperative Citizen's_ Monitoring Network (CCMtO,
. dated August 24, 1992, to the Administrative Judges of the Nuclear Regulatory Commission;_these materials also_ contained affidavits from-two nuclear physics experts, Dr. Gordon Thompson and' Dr. Michio yaku; l
(2) a request for a 10-day extension,_from August 14 to August 24 (which was granted), with letters-from_Ms. Marrucci to Northeast Utilities (NU) and the NU reply;=
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-(3) attachments which represent the fission product load at t=0 and t=21
= days for the reactor fuel; excerpts from the Final Safety Analysis Report of NU for Millstone 'II; and Benchmark Calculations by lloitec.
I recommend that we send the entire packet to DEP, as requested.by Ms.
e Marucci.
There are_important safety concerns related to the design and inading of the~ spent tuel assemblies in'the spent fuel pool which some members of the scientific community do not feel are adequately addressed.
Since the number of curies in a fully-loaded pool could approach the level in an operating reactor and since accidents-to date-have involved multiple _ factors, it is important that the. potential of criticality be seriously addressed, especially in light of a July 6, 1992 situation at the spent-fuel pool. and the large number of assumptions upon which NU's analysis is based.. The Conclusions and Recommendations section of Dr. Kaku's affidavit are attached,'which highlight the concerns of the group and which detail certain requests to NU as well as
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the NRC.
"Th e-CCM!Puowvinenga gedriturt he7h e a r i'n g*p r o c ede rwi thYtihMR C'sTi%eic s s '
only take4cognizancg of the materials sent to us.
The sDaswuoenTnot9fave re gula t ory-responsibi.1.Lt,yurov* c*t ha ?nu c l ea r-u tili tytind usTrf.
ThTd" bet 6ngsg o the.NR6,7 wit h s om e'no ttftcacit amRe fs 1~g herandw r e s pon s egre e t i v i t i e s9 by t h e 7 e p a r t m eiit o f"E n'vi'ro nardtrtrPfo te ctTo n' tn a c c i d e n t scenarlos.
It is to be' hoped -that-the-NRC wi11' examine the. materials provided by CCMN_ and that-NU 'will: provide information regarded as necessary for thorough
' safety assessment.
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- 29. In conclusion, I ur not Ao optignistic that the rearranted spent {uel pool, when fully k.wled in the future, will moet the criteria thu ka <.95. Although the utility states that reducing fresh fuelin the spent fuel site can c,aly reduce the neutr n levels, I un not convinced. The assumptions behmd the computer calculations are not aufEciently re!!able, especially in the presence of the highly absorbing Doreflex boxes. In (s.ct, many of the usumptions behind neutron transport theory begin to break down precisely because of the presence cf highly abubing thin walls. One's conclusions ue only u vdid u one's usumptiora. Or, a they say in the industry,
- gubage in, guba6e out." This discussion is not purely acaderruc, because the fis-eina product Inventory of the pool wdl eventually reach one billion curies, whic.h is compuable to what is found in s. nuclear power plant.
- 30. The previous reactivity study by CE done ca the spent fuel pool wu in error by 5%, mainly because cf the difBenity in modeling the Ucrofler hores by the neutron difiunion equation. I am not convinced that the newer neutron reactivity study is sensitiw enough to truly calculate the effect of neutron abnorption by the Boroflex boxes, especially because of the degradation and unexpected crosion of the boxes (whose full extent hu never been determined by the utility). The neutron
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l teactivity calculations using Monte techniques studies have inherent uncertainties in them (given the miimptions inherent within the model) that may be too lar6e to mske re!1able estima.tes of Q for the fully loaded pool.
- 31. Given the fact that more spent fuel will be stored at the site, near populated ueu, with about one billion curies cf fission products, I think that NU should model a, more realistic accident scenuio. It should abandon the simplistic single awde failure model (which has never happen d in a raajor nucleu accident) and adopt a more flexible and realistic multimode (titure/ human failure model, which agrees more with the history of put nucleu melting incidents and flulon product release accidents.
- 32. Specifically, a credible scenario exista in which the water. level dropa danger-
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outly in the pool. For exunple, a fire or chemical explosion may cause an evacuation of the tite leuilnB to a power (,Jlure. Without anyone monit.cring the pool, one can imagine the water level dropplag due to leaks, boil o:T, and evaporation u the temperature rises. It only takes about 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to cause boillDE within the stent fuel pool. When the fuel usemblies are uncovered, the ternperaturc may be su$cient to cause hydrogen gu generation and then an explosion, dispersion large unounts of fission products into the envisuanent.
- 33. In light of these difficulties, I would like to make teveral recommendations:
First, that the utility cury out a. full scale evaluation of the Boroflex boxes to check fcr new gaps u well u measure the rate of crosion. Until this is done, all computer progruns are lugely use'ess. The utility abould also perform rigorous benchmuk studles using Boreilax boxes with the the actual geometry found in the spent ful pool, not junt lderliulinna of the. geometry.
- 34. Second, the utility should ca.rry out the reuonable demands of citizens gr such as releuing a copy of its neutron reactivity c.alculation, and placing neutron detectors arocad and inside the pool. This is reasonable. since detectors have a prown worth. For example, the prv.ence of such a detector (which could meuure the level of water at TM1) could have prevented an accident which he already ecas GPU
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11.5 billion. Neutmn countas could give a rough indication of whether the pool had T
higher than expected neutron reactivity before an accident goes out of control.
- 35. Third, the NU abould be required 'o do a realistic analysis of a maximum cndible accht, i.e. the relene of 75% of the fission product inventory into the environment.
Like existing studies of nuclear reactors, one should usume that all safety systems ue somehow volded, and that luge amounts of fission products esca into the environmant la the form of a plume. Since the distribution of fission products is diferent from a co vn entional nuclear reactor, one should obtain different resuh t for 9 a a> pent fuel accident. The fact that,50 yars into the nuclear age, such u buie study g
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+.3 the fe.ct that nuclear n4te hu alnys beci r.iven low priority. Howevn, now that nudt.sr power plants are gradually fdling up spent fuel e!tes and are beginnits to consoitdate ad repackage spent f,;el, it is vital that such a study be done.
3S. UntG these recommendaticas are curied out, I cenot truthfully state the.t a fully loaded spent fuel pool in the new retrrangement is saic. On the contury, it inay even prove '.o be a hes.lth bruard.
I dedr.re, subject to the pain and penalty of perinry, the forquing is true ud ccrrect, to the best of tny knowledge.
1 Signed
$lbb t Michio Kaku, Ph.D k
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J September 10, 1992 NL-92-618 Hs. Mary Ellen Ma ucci 104 Brownell Street New Haven, Connecticut 06511
Dear Ms. Marucci:
Further to our convernation on September 4,
- 1992, I am enclosing the following documents pertaining to the use of Boraflex in the spent fuel racks.
1.
E. J. Mroczka letter to the U.S. Nuclear Regulatory Commission
" Millstone Unit No. 2 Spent Fuel Racks Poison Surveillance Coupon Boraflex Degradation" dated August 7, 1990.
2.
E. J. Mroczka letter to the U.S. Nuclear Regulatory Commission
" Millstone Unit No. 2 Spent Fuel Rac.ks Boraflex Degradation" dated October 1, 1990.
3.
E. J. Mroczka letter to the U.S. Nuclear Regulatory Commission
" Millstone Nuclear Power Station, Unit No. 2 Request for Additional Information - Boraflex Degradation in Spent Fuel Pool Storage Racks (TAC No. 77726)" dated January 4, 1991.
Consistent with eur conversation, it is my understanding that any future information needs you may have of Northeast Utilities or our contractors on this matter will be directed to my attention.
Very trul
- yours, Richard M. Kacich Director-Nuclear Licensing r;ax/'<p Enclosures cc:
Mr. Guy S. Vissing, U.S.
Nuclear Regulatory Commission NL Mens File Ntteltr s
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on onnecticut osm.ono August 7, 1990 Docket No. 50 336 B13605 Re:
Boraflex Degradation U.S. Nuclear Regulatory Comission Attention: Document Control Desk Washington, DC 20555 Gend emen:
Millstone Unit No. 2 Spent Fuel Racks Poison Surveillance Coupon Boraflex Dearadation On July 27, 1990, while preparing Millstone Unit No. 2 poison surveillance coupon f 5 for routine examination, Northeast Nuclear Energy Company (NNECO) observed that the boraflex material in the area of the vent hole was missing.
A visual examination of the remaining surveillance coupons revealed a similar situation existed in all the coupon samples. This was identified to the NRC Resident Inspector on July 30, 1990.
NNECO's initial assessment was that the deterioration mechanisms were probably due to a combination of radiation exposure and erosion induced by flow and gas generation exiting at the vent hole.
Additionally, the erosion was probably limited to only the 'sent location.
was delivered to Combustion Engineering on July 30, The subject coupon (#5)d examination, specifically the removal of the stain-1990 for a more detaile less steel shell encasements, so as to permit inspection of the entire boraflex sample.
This issue. was the subject of a conference call with the NRC Staff on August 1, 1990 in which NNECO explained the circumstances and provided a preliminary assessment of the deterioration mechanisms.
NNECO also provided a short-term action plan that conservatively addressed these observations (i.e.,
maintaining the spent fuel pool boron concentration greater than 1720 ppm and restriction of the loading pattern to a checker board configuration).
These actions were at the time deemed prudent prior to receiving engineering-information from Combustion Engineering.
On August 1,1990, Combustion Engineering rep 9rted that the boraflex material was missing only in the imediate proximity of Se vent hole and the remaining coupon appeared to be relatively intact and undamaged.
Further testing and examinations are ongoing.
Combustion Engineering's assessment based upon visual inspection of the material in the area under question was that the damage to the boraflex is due to flow induced erosion.
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U.S. Nuclear Regulatory Comission B13605/Page 2 August 7, 1990 On August 3,1990, photographs of the subject boraflex coupons were presented to an independent consultant who has extensive experience in inspections and ovaluation of boraflex material.
NNECO was informed that several utilities have experienced erosion of the boraflex coupons in areas that are exposed to flow currents in the rack region of the spent fuel pool.
In the consultant's 1
opinion, based upon the photographs, the damage to the coupon was due to flow-induced erosion.
NNECO's determination, based upon the visual inspection of the surveillance coupon and. utility experiences, is that the deterioration of the boraficx at the vent hole location is due to the accelerated radiation of the exposed boraflex in the coupon coupled with erosion induced by flow currents in the rack region of the spent fuel pool.
Accelerated radiation surveillance has the sample coupons exposed to the most reactive discharged spent fuel on a cycle basis as opposed to long-term surveillance that accounts for fuel age and decay.
NNECO's conclusion is that this deterioration experienced in tht surveillance of the spent fuel racks and does coupon does not affect the calculated K f7 not violate the Technical Specificati8n requirement of K 1
95.
The conclusion is based upon the fact that the vent hole in the' kent fuel racks 4 above the active fuel region and, if the erosion exists at the vent hole location in the racks, it does not affect the current qualification to store spent fuel.
Therefore, no restrictions need to be instituted with respect to storage of fuel in the spent fuel racks such as alternate checker board storage patterns or maintaining high soluble boron concentrations.
NNECO intends to continue to monitor the situation and collect additional intelligence on the deterioration mechanisms being experienced to further support our conclusion.
Our effort: include continuation of the coupon surveillance program an.!
visual inspection of the vent holes in a
representative sample of tht spent fuel racks.
NNECO trusts that the infnrmation in this submittal, most of which was provided to the NRC Staff in a conference call on August 6,1990, is useful.
Should you require any additional information, please contact us.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY E. J. Mroczka
/
Senior Vice President cc:
T. T. Martin, Region 1 Adminhtrator G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 P. Habighorst, Resident Inspector, Millstone Unit No. 2 W. J. Raymond, Senior Resident inspector, Hillstone Unit Hos.1, 2, and 3
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t October 1, 1990 Docket No. 50 336 B13647 Re:
Boraflex Degradation U.S. Nuclear Regulatory Comission Attention:
Document Control Desk Washington, DC 20555 Gentlemen:
Millstone Unit No. ?
Soent Fuel Racks Boraflex Deoradation In a letter dated August 7, 1990,III Northeast Nuclear Energy Company (NNECO) detailed that on July 27, 1990, while preparing Millstone Unit No. 2 Poison Surveillance Cou)on No. 5 for routine examination, it was observed that the boraflex mate..
in the area of the vent hole was missing. A visual examina-tion of the remaining surveillance coupons revealed that a similar situation existed in all the coupon samples.
This was identified to the NRC Resident Inspector on July 30, 1990.
NNiiD's initial assessment was that the deterioration mechanisms were probably due to a combination of radiation exposure and erosion induced by flow and gas generation exiting at the vent hole.
Additionally, the erosion was probably limited to the vent location.
On August 24, 1990, at 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br /> with the plant in Mode 1 at 100 percent power, during performance of neutron blackness testing, gaps were discovered in the boraflex neutron poison material in the Region I spent fuel storage
-racks.
-The - neutron blackness testing-was being performed as part of an investigation for an erosion problem of the boraflex surveillance coupons.
Preliminary results from the blackness testing vendor indicate that of the 420 boraflex panels that were tested, 45 panels have a gap in the poison material and 3 panels have two gaps.
The largest single measured gap is estimated to be 1.8 inches and the largest addition of two gaps in 1 panel was 1.9 inches.
A prompt report of this event was made on August 24, 1990, pursu-ant to the requirements of 10CFR50.72(b)(1)(ii)(B), 'Any event-or condition that resulted in the condition of the nuclear power plant, including its principle safety barriers, being seriously degraded, or that resulted in the nuclear power plant being:
(b) in a condition that was outside the design basis of the plant."
In evaluating the safety consequences of this event, the Combustion Engineering criticality analysis assumed that the boraflex neutron poison material was completely intact.
Since gaps were discovered in the (1)
E. J. Mroczka letter to U.S. Nuclear Regulatory Comission, ' Millstone Unit No. 2, Spent Fuel Racks Poison Surveillance Coupon, Boraflex Degradation," dated August 7, 1990.
0 53422 Rfy a43
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U.S. Nuclear Regulatory Commission l
B13647/Page2 October 1,1990 boraflex material, the Region I spent fuel storage racks were considered, at that time, to be in a condition that was potentially outside of their design basis.
The boron concentration of the spent fuel pool at the time of the event was anproxirtately 2023 ppm, and the fuel assemblies stored in the Region I spent 1 storage racks were arranged in a two-out-of four storage pattern (check.
.,o ard). There were no safety consequences as a result of this event since
.. e K of the spent fuel 9001 was maintained less than 0.95 as required by the p@t Technical Specific.tions.
The spent fuel storage re. were manufactured by Combustion Engineering. The Region I storage racks contt in 384 storage cells designed for fuel assemblies with a maximum enrichment of up to and including 4.5 weight percent U 235.
Each storage cell in Region I contains a poison insert box.
Each poison it, sert box consists of four boraflex panels which are enclosed between two stainless steel sheet panels.
Tiie specific cause of the gaps is unknown, but is believed to be caused by a restraint of the boraflex material coupled with irradiation-induced shrinkage.
Combustion Engineering has completed an analysis which confirms that the K@
is less than 0.95 for 2.7 inch gaps located at the same axial elevat throughout all of the Region I spent fuel storage racks for fuel assemblies with a maximum enrichment of 4.5 weight percent U 235.
There were no safety consequences as a result of this event since the K of the spent fuel pool was maintained less than 0.95 as required by the hnt Technical Specifica-tions.
An increased surveillance program is currently under review and additional investigations are being performed to determine the root cause of the gaps and the potential for the gap size to increase.
On September 21, 1990, a follow up notification call was made to the NRC Operations Center that retracted NNECO's prompt report because of the conclu-sions reached above. This letter is beitig sent to the NRC Staff for informa-tion purposes and requests no specific action to be taken by the Staff.
If you have any questions regarding this information, please contact my Staff directly.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR:
E. J. Hroczka Senior Vice President BY:
C. F. Sears i
Vice President l
l cc:
T. T. Hartin, Region I Administrator G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 W. J. Raymond, Senior Resident inspector, Millstone Unit Nos.1, 2, and 3
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January 4, 1991 Docket No. 50-336 A09150 Re:
Boraflex Degradation U.S. Nuclear Regulatory Comission Attention:
Document Control Desk Washington, DC 20555 Gentlemen:
Millstone Nucleat N wer Station, Unit No. 2 Request for Additional Information B_gnaflex Deoradation in SotA Fuel Pool Storace Racks J
.No. 77726)
In a letter dated October 1, 1990,II) Northeast Nuclear cergy Company (NNECO) submitted information to the NRC Staff regarding hillstone Unit No. 2's Boraflex degradation in the spent fuel pool storage racks.
In reviewing this information, the Syf requested additional information in a letter dated November 15, 1990.
The following are responses to the questions raised by the Staff.
NRC Ouestion #1 Preliminary results from the blacknest tests indicate that 45 panels had a gap in the Boraflex material with the largest single measured gap approximately 1.8 inches wide.
What was the total accumulated gamma radiation to these panels at the time of the blackness tests?
What additional gama dose will be acctmulated by the Boraflex panels before the next blackness testing and what additional shrinkage (gap size) could this cause?
(1)
E. J. Mroczka letter to U.S. Nuclear Regulatory Comission, " Millstone Unit No. 2, Spent Fuel Racks Boraflex Degradation," dated October 1, 1990.
(2)
G.
S.
Vissing letter to E.
J.
- Mroczka,
" Request for Additional Information concerning Boraflex Degradation in Millstone 2 Spent Fuel Pool Storage Racks (TAC No. 77726)," dated November 15, 1990.
-- 05347t AEV 4-88
l U.S. Nuclear Regulatory Comission A09150/Page 2 January 4, 1991 NNECO Resoonse The total accumulated gama radiation to the panels containing gaps was between 5.9 x 10' and 2.3 x 10H rads gama, depending on the service of the rack cell with the gaps.
The spent fuel racks have recently experienced the discharge associated with end of Cycle 10 spent fuel.
A conservative method of estimating the additional exposure is the averagt value at 1.1 x 107 rads / day for 1 year storage.
NNECO is still evaluating the frequency criterion associated with the follow up blackness testing program.
NNECO contends that little or no further increase in gap sizes to the tested cell locations are expected.
This is due to the ftet that Boraflex shrinkage significantly reduces and/or ceases to occur at gamma saturation levels beyond 5 x 10' rads gama.
All of the cells tested, wherein gaps were observed, have seen this exposure level and beyond; therefore, they are at or approaching the saturation level.
NRC Qp etion #2 It is reported that the results of the CE criticality analysis confirms that the K-eff of the spent fuel pool is less than. 0.95 for 2.7-inch gaps located at the same axial elevation throughout Region 1 for the fuel assen4blies enriched to 4.5 weight percent U fuel assemblies stored in Region 1 are arranged N.
Since the present a two-out-of-four storage pattern checkerboard), was this the configuration assumed in the CE criticali(ty anroysis? How much margin existed between the calculated K-eff and 0.957 As a result of previous Question 1 above, could gaps larger than the 2.7 inches assumed in the criticality analysis occur with further irradiation?
MECO Response The CE criticality analysis assumed 4.5 w/o U fuel arranged in a 4-out-of-4 storage configuration as originally rev@ed and licensed by the NRC.
The only difference in the analysis was the incorporation of the axial gaps.
The 2.7-inch gap criteria resulted in a K-eff =.95.
It is possible that larger than 2.7-inch gaps could occur in the untested locations with further irradiation.
However, of the 420 panels inspected, only 45 panels contained gaps; 37 of which had gaps less than 1 inch, 7 had gaps between 1 inch - 1% inches, and 1 panel contained a 1.8-inch gap.
All of the gaps encountered were randomly distributed axially throughout the panels.
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U.S. Nuclear' Regulatory Comission A09150/Page 3
-January 4 1991 Additionally. -the average gap-size experienced by other nuc1 utilities utilizing Bornflex has been less than 1 inch, consistent with our results.-
The follow up future blackness testing program will provide the confirmation of gap formation and sizt in the untested cells.
- However, should additional reanalysis be
- required, a
redevelopment of the criticaif ty model to account for the different gap sizes, axial locations and panels containing the gaps wo':ld eliminate the very conservative nature of-the current analysis and thereby permit incorporation of gaps larger than 2.7 inches should they occur.
Please contact us if you have any additienal questions.
Very truly yours, NORTHEAST NUCl. EAR ENERGY COMPANY 4
A/
E.J.ly6czka
'f Senior Vice President ec:
T. T. Martin Region I Administrator G. S. Vissing,- NRC Project. Managtr, Millstone Unit No. 2 P. Habighorst, Resident Inspector, Millstone Unit No. 2 W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos.1, 2, and 3
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