ML20137L962
| ML20137L962 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/27/1985 |
| From: | Lorion J CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J. |
| To: | FLORIDA POWER & LIGHT CO. |
| Shared Package | |
| ML20137L882 | List: |
| References | |
| OLA-3, NUDOCS 8512030568 | |
| Download: ML20137L962 (6) | |
Text
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.e 0::'; 7,s e, f.'W:c UNITED STATES OF AMERICA
'65 09 9 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'.. '. ;j In the. Matter of
)
Decket Nos. 50-250 OLA-3
)
50-251 OLA-3 FLORIDA POWER AND LIGHT COMPANY )
)
(Increased Fuel enrichment)
Turkey Point Units 3 & 4
)
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INTERVENORS' RESPONSE TO LICENSEE'S INTERROGATORIES TO CENTER FOR NUCLEAR RFSPONSIBLITY AND JOETTE LORION Pursuant to 10 C.F.R. 2.740 (b), Intervenors, the Center for Nuclear Responsibility And Joetto Lorion, hereby respond to
- interrogatories propounded by the Florida Power & Light company.
Intervenors understand that the interrogatories are a continuing obligation and will provide additional information i
1 when it comes to Intervenors' attention.
1.
Witness selection has not presently been determined for contention 3.
As stated, Intervenors will keep the Board and parties posted as is required by Rule y
2.740 (b).
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2.
Not applicable since witness selection has not been determined.
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. 3.
Intervenors intend to use the following documents, books, reports, and papers to present their case on Contention 3:
General Design Criteria (GDC) 62 10 CFR Part 50, Appendix A.
Consumers Power Company (Big Rock Point Plant), Docket no. 50-155, Initial Decision, October 29, 1982.
Policy Issue, SECY-83-337, August 15, 1983, Study on Significant Hazards.
Review and Evaluation of Spent Fuel PWR Expansion Potential llazards Considerations, SAI Report No. SAI-84-221-WA Pev. 1, July 29, 1983, Science Applications Inc.
ANSI NI6 I-75," Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors'.'.
ANSI NI6 9-75," Validation of Calculational Methods for Nuclear Criticality Safety".
ANSI N18 2-1973, " Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants".
ANSI N210-1976 " Design Dbjectives for LWR Spent Fuel Storage at Nuclear Power Stations".
NRC Standard Review Plan, Section 9.12, " Spent Fuel Storage".
"NRC Position for Review and Acceptance of Spent Fuel Storage and Handling Applications" April 14, 1978, revised January 18, 1979.
" Turkey Point Plant Units 3 and 4, Updated Final Safety Analysis Report," Docket Nos. 50-250, 50-251.
" Turkey Point Plant Units 3 and 4, Safety Evaluation Report, Docket Nos. 50-250, 50-251.
" Environmental Assessment and Finding of No Significant Impact-Spent Fuel Pool Expansions, Turkey Point Plant Units 3 and 4," November 14, 1984.
Letter to Eisenhut, NRC, from Williams, FPL, Fuel StorageU-235 Linear Loading Increase, April 14, 1984, with No Significant liazards Consideration attatchment.
Safety Evaluation Related to amendments No. 109 and 103, September 5, 1984.
( 3) 4.
Those documents listed in response to 3 would also be used in cross-examination.
5.
Intervenors contend that the " Criticality Analysis of Spent Fuel Storage Racks, Unit 3 &4" prepared for FPL Company, February 1984, is deficient in the following areas:
2.0 Criteria and methodology for criticality Analysis.
3.0 Criticality Analysis of Spent Fuel Storage Racks.
These areas are deficient because maximum uncertainties could cause the k gg to exceed the 95/95 standard.
e Intervenors also contend that the NRC Staff's " Safety Evaluation Relating to Amendment Nos. 109 and 103," September 5, 1984, is deficient in the following areas:
III. Spent Fuel Storage Rack Analysis.
IV.
New Fuel Storage Rack Analysis.
The NRC Staff has not shown in detail that the storage of mere highly enriched uranium fuel will not cause the 95/95 standard to be exceeded, especially for optimum moderation conditions.
- 6. Intervenor relied upon those documents listed in response 3 when preparing contention 3.
Intervenor also used legal documents loaned to them by Nina Bell of the Nuclear Information and resource service which have since been returned to Ms.
Bell.
- 7. The only person that we have communicated with in regard to Centention 3 is Dr. Gordon Edwards, a mathematician from Montreal, Canada.
(4 )
- 8. Dr Edwards opinion is that the closer that one comes to criticality, which is 1, the greater is the chance that a criticality accident could occur.
He also believes that the less conservative standard decreases the safety margin of the storage pool.
9.
(a) The " limit" to which Intervenore are referring is the 95/95 standard specified in the Standard Review Plan.
(b) By safety margins Intervenors mean k factor. By mar' gin eff of safety, Intervenors mean that the Licensee has raised the kefg to the limit and no degree of conservatism remains, which would allow for uncertainties.
(c) Yes, Intervenors contend that reaching the design base.-
limit of 0.95 for storage of spent fuel leaves no margin of safety against a criticality accident.
The grounds for this statement are that as one reached the upper bounds of a safety standard, one cannot be certain that any uncertainties in the spent fuel storage might not cause the fuel to exceed that standard.
The standard is no longer conservative.
- 10. 10 C.F.R. Part 50, Criterion 62, Appendix A, reouires that criticality in the fuel storage and handling system shall be prevented by use of geometrically safe configurations.
Storage of the more highly enriched uranium fuel with a limit of 0.98, reduces the safety of the fuel storage and reduces the confidence that a criticality accident will not occur.
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V iIbL UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'85 DEC -2 A11 :04 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD brh. 4 w In the Matter of Docket
- s. 50-250 OLA-3 50-251 OLA-3 FLORIDA POWER & LIGHT COMPANY
)
(Increased Fuel Enrichment) l Turkey Point 3& 4 l
CERTIFICATE OF SERVICE I hereby certify that copies of "Intervenors' Response to Licensee's Interrogatories to the Center for Nuclear Responsibility and Joette Lorion", were served on the following parties by deposit in the United States Mail, first class, postage prepaid, on the l
date shown below:
Dr. Robert M. Lazo Harold F. Reis, Esquire l
Atomic Safety and Licensing Board Newman & Hitzinger, P.C.
i U.S. Nuclear Regulatory Commission 1615 L. Street NW Washington, D.C. 20555 Washington, D.C. 20036 l
l Dr. Emmeth A. Leubke Norman A. Coll, Esquire Atomic Safety and Licensing Board Steel, Hector & Davis l
U.S. Nuclear regulatory Commission 4000 SE Financial Center l
Washington, D.C. 20555 Miami, F1. 33131-2398 Dr. Richard F. Cole Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section d
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Joette Lorton Pro Se Litigant for the Mitzi A. Young Center for Nuclear Responsibility Of fice of Executive Legal Director and Joette Lorion U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dated: November 27, 1985 l
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Respectfully submitted, OMA.L e
Joette Lorion Pro se litigant for the Center for Nuclear Responsibility and Joette Lorion State of Florida
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County,of Dade
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I,'Joette Lorion, being first duly sworn, do depose and say that the information contained in this response is true and correct to the best of my knowledge.
CN Joette Lorion Sworn and subscribed before me this [
1985.
day of November,
'0/k 1N otary Public
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State of Florida My Commission Expires:
NCL'C ?.t"; *':': :I ilc,~.'h at Um E C::In '. b;'.:rn sect 25, if 821:J bic.::1fi: Fu:2!:/ 4 i