ML20136D948

Informs That Util 850201 Request for NRC Approval of Spent Fuel Storage Rack Analysis Withdrawn Per . Intervenors Referenced Request as Basis for Contention 5 in Spent Fuel Expansion Proceeding.Related Correspondence

ML20136D948
Person / Time
Site:	Turkey Point
Issue date:	11/18/1985
From:	Frantz S FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER
To:	Cole R, Lazo R, Luebke E Atomic Safety and Licensing Board Panel
References
CON-#485-229 OLA-2, NUDOCS 8511210395
Download: ML20136D948 (8)

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Dr. Robert M. Lazo, Chairman Dr. Emmeth A. Luebke Dr. Richard F. Cole Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Re: Florida Power & Light Co. (Turkey Point Plant, Units

'3 and 4), Docket Nos. 50-250-OLA-2 and 50-251-OLA-2 (Spent Fuel Pool Expansion)

Dear Licensing Board Members:

The purpose of this letter is to inform the Licensing Board and the parties of a matter which pertains to a contention at issue in the Turkey Point Spent Fuel Pool Expansion Proceeding.

K In a letter dated February 1, 1985, from J.W. Williams, Jr. of Florida Power & Light Company (FPL) to Steven A. Varga of the Nuclear Regulatory Commission (NRC), FPL presented the <

results of a analysis of the potential for lift-off of the spent fuel storage racks during a seismic occurence in the event that the outer rows of the racks which overhang the support pads are fully loaded while the rest of the rack remains empty. FPL reques-ted that the NRC review these results and concur that the analysis is acceptable. Joette Lorion and the Center for Nuclear respon-sibility (Intervenors) referenced this letter as part of their basis for Contention 5 in the Turkey Point Spent Fuel Expan-sion Proceeding.

In a letter dated February 26, 1985, from Daniel G. Mcdonald of the NRC to J.W. Williams, Jr. of FPL, the NRC stated that FPL's request for review of the analysis represented a change in a basis supporting NRC issuance of the amendments authorizing the Turkey Point spent fuel pool expansions. The NRC further stated that FPL could make such changes without prior NRC approval 9511210395 85 g50 l m ;Da

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s provided that a review performed in accordance with the provisions of 10 CFR $50.59 determined that neither a technical specifi-cation change nor an unreviewed safety question is involved. The NRC also stated that it would not take any further action on FPL's request until it received clarification with respect to whether FPL had performed an analysis pursuant to 10 CFR 550.59.

FPL has now responded to the NRC's letter of February 26, 1985.

That response is contained in a letter dated November 13, 1985 from J.W. Williams, Jr. to Steven A. Varga. This letter and the February 1, 1985 and February 26, 1985 letters are attached for the information of the Board and the parties. In sum, the letter withdraws FPL's February 1, 1985 request and states that ,

FPL will review any change in the basis supporting issuance of i the amendments in accordance with the provisions of 10 CFR 550.59.

Sincerely ,,

/ (W Steven P. Frantz

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cc w/ encl.: Mitzi A. Young Joette Lorin Norman A. Coll l Atomic Safety and Licensing Board Panel l Atomic Safety and' Licensing Appeal Board Panel l Office of Secretary - U.S. Nuclear Regulatory Commission i

FLORIDA POWER & LlGHT COMPANY no i mes L-85-30 Office of Nuclear Reactor Regulation Attention: Mr. Steven A. Vorgo, Chief Operating Reactors Branch # l Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20055

Dear Mr.Vorgo:

1 Re: Turkey Point Units 3 & 4 Docket Nos. 50-250 & 50-251 Spent Fuel Storoce Focility Expansion In support of the FPL request to amend the facility operating licenses to permit expansion of the spent fuel storoge facilities at Turkey Point Units 3 and 4, the rock vendor (Westinghouse) onalyzed the spent fuel storoge rocks for overturning and sliding displocements due to earthquake looding for the cases of full, portially filled and empty fuel rocks. The analysis results met and exceeded the atobility criteria of the NRC "OT Position for Review and Acceptance of Spent Fuel Storage and Handling Applications." The results showed that the rocks did not lift off the spent fuel pit embedment plates under seismic event conditions. This information was provided to you in FPL letter L-84-263, dated September 28, 1984.

Thereafter, in a letter dated October 19, 1984, Westinghouse informed FPL that odministrative controls on fuel looding would be needed for those spent fuel rocks whose outer rows overhang the support pods. Westinghouse stated that lifting of a rock could occur during a seismic event if the outer rows are fully loaded while the rest of the rock remains empty. Six (6) Region il rocks with a one row overhang, one (1) Region I rock with a one row overhang and one (1) Region I rock with a two row overhang are offected.

Although not Indicated in their October 19th letter, these controls were required to be consistent with an assumption mode by Westinghouse in its analysis (i.e.,

that the overhanging rows would not be loaded while the rest of the rock was empty). Neither the preliminary seismic / structural analysis report nor the basis provided by Westinghouse for FPL's September 28th letter specified this assumption or identified the need for administrative controls. Consequently, at on October 24, 1984 meeting, FPL requested that Westinghouse provide clarificotton regarding the basis for its recommendations for controls. Westinghouse responded in a letter dated November 16,1984 and received by FPL on November 27,1984.

PEOPLE. . SERVING PE APLE

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i Page 2 Office Of Nuclear Reactor Regulation Mr. Steven A. Vorgo .

After review of the November 16th letter, and additional discussions with Westinghouse, FPL directed Westinghouse to reonolyze the affected rock rnodules with the assumption that overhanging rows are loaded while the remaining rows of the rocks remain empty. Preliminary results of the reanalysis, which showed liftoff could w: cur dsring a seismic event, were discussed with Mr. D. G.

. Mcdonald on December 19, 1984. By letter dated January 10,1985, Westinghouse provided FPL with the final verified results of the reanalysis.

The reonalysis shows that the applicable requirements of the OT position paper are met without any controls. The worst case loadings are 3 outboard rows (2 overhang rows plus the row above support pods) for a Region I module and 2 outboard rows (I overhang row plus the row sove support pods) for a Region 11 module while the rest of the module remains empty. For these loadings a more than adequate factor of safety against overturn is maintained. The following summarizes the results of the analysis:

- The factor of safety against overturn is 8 for Region I and 220 for Region 11, with support pod liftoff of 0.18 inch and 0.01 inch, respectively, during a F seismic event.

- The rock support pods will not slip off the embedment plate under any condition.

- The rocks will not at any point contact other rocks or the pool wall. A revised tabulation of displacements is shown in Table 1.

- Resulting pool floor loods and structurc' stresses are enveloped by the condition of a fully loaded rock.

It is requested that the NRC review the above information and concur that the reanalysis is acceptable. Until NRC concurrence is obtained, FPL will provide I administrative controls on fuel placement in order to preclude the possibility of any liftoff, maintaining the validity of the analysis and results submitted in our September 28th letter. If you have any questions, please contact us.

Very truly yours, J "'

J. W. Williams, Jr.

Group Vice President Nuclear Energy JWW/TCG/ cab

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f?GDfP@ DfP T Mr. J. W. Willians, Jr., Vice President 3 MAR - 1885 Nuclear Energy Department Florida Power and Light Company -

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Post Office Box 14000 Neman & Holtzinger l Juno Beach, Florida 33408

Reference:

TAC Nos. 56805 and 56808

SUBJECT:

SPENT FUEL STORAGE FACILITY EXPANSION  :

By letter dated November 21, 1984, the Comission issued Amendment No.111 to Facility Operating License No. DPR-31 and Amendment No.105 to Facility -

Operating License No. DPR-41 for the Turkey Point Plant Units 3 and 4, respectively, which allowed expansion of the spent fuel storage facilities. Copies of the supporting Safety Evaluation and Notice of

(-- Issuance and Final Detemination of No Significant Hazards Consideration were also enclosed. The Safety Evaluation (SE) and the appended Technical Evaluation Report (TER) provided the basis for our issuance of the requested amendments. Sections 2.3.4 and 2.3.5 of the SE and the appended TER indicated that postulated loeds from a seismic event will not result in failures to the racks or pool structures, thus their integrity will be i maintained. As indicated in Section 3.3.4 of the TER, there would be no lift-off of the rack modules from the pool liner during a seismic event.

This conclusion was based on your September 28, 1984, letter which provided

,the results of the Westinghouse analysis.

By letter dated February 1,1985, you indicate that Westinghouse infomed you, subsequent to your September 28, 1984 letter, that administrative

controls on fuel loading are required for racks whose outer rows l

overhang the support pads in order to be consistent with an assumption by

' Westinghouse during its analysis. That is, the outer (overhanging) rows would not be fully loaded while the remaining portion of the rack module is i

empty.

The NRC staff's SE and the supporting TER conclusions have remained valid

• Ale to the administrative controls initiated when you became aware of the potential need for the controls. These controls, which were prior to any fuel loading in the affected racks, preclude the possibility of any lift-off.

Your February 1,1985, letter requested that we review the inforsation

provided as the result of a reanalysis of fuel racks with only overhanging rows loaded with fuel which indicates the worse case lift-off friess than 0.2 inches during a seismic event and this minimal lift-off will not result in failures to the racks or pool structures and their integrity will be -

maintained regardless of the loading pattern.

, Mr. Williams February 26, 1985 This request for our review of the reanalysis represents a change in a basis supporting the above referenced amendments as d,ocumented in the-supporting Safety Evaluation. 10 CFR 50iS9, " Changes tests and experiments," indicates that licensee's may make changes, conduct tests or experiments not described in the Safety Analysis Report without prior Comission approval unless the proposed change, test or experiment involves a change in the technical specifications incorporated in the license or an unreviewed safety question.

It it not clear from your submittal whether you have perfomed a 50.59 review and documented the results in accordance with the provisions of 50.59(a) and (b) or; that you have detemined that the reanalysis requires a change 'in the technical specifications incorporated in the licenses or that the change represents an unreviewed safety question.

If you have performed a 50.59 review in accordance with the provisions of 50.59(a) and (b) and detemined that neither an explicit technical specification change nor an unreviewed safety question is involved, you do not need our prior approval and your request may be withdrawn. However, if you have detemined a change in the technical specifications incorporated in the license or an unreviewed safety question exists, we request that your -

submittal be modified in accordance with 50.59(c) including a proposed Notice for public coment using the standards in 10 CFR 50.92 concerning the issue of no significant hazards consideration.

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We will take no further action on this request until we receive clarification.

The reporting and/or recordkeeping requirements of this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely,

~

Q A ~sg Daniel G. Mcdonald, Project Manager Operating Reactors ~ Branch #1 Division of Licensing l -

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J. W. Williams, Jr. Turkey Point Plane Florida Power and Light Company Units 3 and 4 cc: Harold F. fleis, Equire -

, Administrator ,

Newman and Holtzinger, P.C. Department of Environmental 1615 L Street, N.W. Regulation Washington, DC 20036 Power Plant Siting Section State of Florida Mr. Jack Shreve 2600 Blair Stone Road Office of the Public Counsel Tallahassee, Florida 32301 Room 4 Holland Building Tallahassee, Florida 32304 James P. O'Reilly Regional Administrator, Region II Nonnan A. Coll, Esquire U.S Nuclear Regulatory Comission Steel, Hector and Davis Suite 2900 4000 Southeast Financial 101 Marietta Street Center Atlanta, GA 30303 Miami, F1orida 33131-2398 Martin H. Hodder, Esquire 1131 N.E. 86th Street Mr. Ken N. Harris, Vice President Miami, Florida 33138 Turkey Point Nuclear Plant Florida Power and Light Company Joette Lorion P.O. Box 029100 7269 SW 54 Avenue Miami, F1orida 33102 Miami, F1orida 33143 Mr. M. R. Stierheim Mr. Chris J. Baker, Plant Manager County Manager of Metropolitan Turkey Point Nuclear Plant Dade County Florida Power and Light Company Miami, Florida 33130 P.O. Box 029100 Miami, Florida 33102 Resident Inspector .

Turkey Point Nuclear Generating Station Attorney General U.S. Nuclear Regulatory Comission Department of Legal Affairs Post Office Box 57-1185 The Capitol Miami, Florida 33257-1185 Tallahassee, Florida 32304 Regional Radiation Representative Mr. Allan Schubert, Manager EPA Region IV Public Health Physicist 345 Courtland Street, N.W. Department of Health and Atlanta, GA 30308 Rehabilitative Services 1323 Winewood Blvd.

Intergovernmental Coordination Tallahassee, Florida 32301 and Review Office of Planning & Budget Executive Office of the Governor The Capitol Building Tallahassee, Florida 32301 l

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P O BOk 14CC. Jut 0 BC ACH. r L 0340E FLORIDA POWER & LIGHT COMPANY uw t a em L-85-409 Office of Nuclear Reactor Regulation Attention: Mr. Steven A. Vorgo, Chief Operating Reactors Branch il Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555 if. k. _ ' ~

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, i Dear Mr. Vorgo.

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,jl Re: Turkey Point Units 3 and 4 ^"*'&' ~ GiS~..!  ; -

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Docket Nos. 50-250 and 50-251 Spent Fuel Storage Focility NRC TAC Nos. 56805 and 56808 By letter dated February 1,1985, FPL requested tEC review of a reonalysis of the spent fuel G. Mcdonald's letter rock modules of February 26,1985with statedonly overhanging that the FPL request forrows review loaded wit of the reonalysis represented a change in a basis supporting Amendments 111 and 105 to the operating licenses for Turkey Point Units 3 and 4 respectively, and that FPL could make such changes without prior NRC opproval provided that a review performed in accordance with the provisions of 10 CFR 50.59 determined that neither on explicit technical specification change nor on unreviewed safety question is involved.

On the basis of Mr. Mcdonald's letter, FPL withdraws its February 1,1985 request. As stated in our February I letter, fuel placement in the new spent fuel rocks will be controlled in occordance with the basis supporting Amendments 11I and 105. Any change to that basis will be reviewed in occordance with the provisions of 10 CFR 50.59. Should o 10 CFR 50.59 review indicate that a technical specification change is required or on unreviewed safety question exists, FPL will request NRC opproval in accordance with 10 CFR 50.59(c).

Very truly yours,

. d. W.

i s,Jr.

e President

@ Nuclear Grou nergy @E JWW/TCG/ cob cc: Harold F. Reis, Esquire Dr. J. Nelson Groce, NRC Region 11 TCG3/006/l PEo?LE . . SERVING PEOPLE