ML20140C618

Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention 3.New Fuel Storage Vaults & Spent Fuel Storage Pool Unrelated Facilities & Physically Located in Separate Areas of Plant

ML20140C618
Person / Time
Site:	Turkey Point
Issue date:	01/23/1986
From:	Frantz S FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20140C595	List: ML20140C591 ML20140C602 ML20140C618 ML20140C623
References
OLA-3, NUDOCS 8601280373
Download: ML20140C618 (5)

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jiUCLEAR REGULATORY COMMISSION REEQRE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

) Docket Nos. 50-250 OLA-3 FLORIDA POWER & LIGHT COMPANY ) 50-251 OLA-3

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(Turkey Point Nuclear Generating ) (Increased Fuel Enrichment)

Units 3 & 4) )

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LICENSEE'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD WITH RESPECT TO CONTENTION 3 Licensee contends that there is no genuine issue to be heard with respect to the following material facts regarding Contention 3:

1. The new fuel storage vaults and the spent fuel storage pool at Turkey Point are unrelated facilities and are physically located in separate areas of the plant. (Affidavit of Dr. Stanley E. Turner on Contention No. 3 (January 17, 1986)

(Turner Affidavit) 1 8).

2. Under normal conditions, fresh fuel assemblies are stored in a dry condition in the Turkey Point new fuel storage vault. Since no moderation is provided for fresh assemblies

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3 stored in a dry condition, the normal k,gg for such fuel assem- )

blies is an extremely low value with a very large safety margin to criticality. (Turner Affidavit, 1 9). l

3. Under normal conditions, the Turkey Point spent fuel pools are flooded with water with a sufficient concentration of soluble boron to assure a very low value for k,gg with a large safety margin to criticality. (Turner Affidavit, 1 10).

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4. Standard Review Plan (SRP) Section 9.1.1 states that the NRC Staff will accept storage racks for fresh fuel assemblies if the k,gg of the storage array is less than about 0.95 for fully 4

flooded conditions and if the k,gg will not exceed 0.98 assuming optimum moderation. The criticality analyses for Turkey Point utilize the NRC criteria in SRP Section 9.1.1 for criticality safety. (Turner Affidavit, 11 13, 15).

5. SRP Section 9.1.2 states that the NRC Staff will accept storage racks for spent fuel assemblies if the k,gg of the storage array is not greater than 0.95 when fully flooded with unborated water. The criticality analyses for Turkey Point utilize the NRC criteria in SRP Section 9.1.2 for criticality safety. (Turner Affidavit, 11 13, 15).

6. The increased fuel enrichment amendments for Turkey Point did not modify the pre-existing k,gg limit of 0.95 for fresh storage vaults and spent fuel pools under fully flooded conditions with unborated water. Thus, the amendments did not change or otherwise reduce the minimum criticality safety margins for these conditions. (Turner Affidavit, 11 22, 25).

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7. At the time the Turkey Point new fuel storage vaults were originally licensed in 1972-73, the NRC did not have a

! requirement to evaluate storage of new assemblies under conditions of optimum moderation. The increased fuel enrichment amendments establish a k,gg limit of 0.98 for fresh assemblies under condi-tions of optimum moderation, and this limit is a new and addi-tional requirement rather than an increase in a previous criti-cality safety limit. (Turner Affidavit, 1 19).

8. The NRC criteria for criticality safety in SRP Sections 9.1.1 and 9.1.2 are the same as those specified in an industry standard, ANSI N18.2-1973. Reactor plants in the United States and most foreign plants utilize these criteria. (Turner Affidavit, 11 13, 15).

9. The criteria for criticality in SRP Sections 9.1.1 and 9.1.2 and the k,gg limits for the Turkey Point fresh fuel

, storage vaults and spent fuel pools are adequate to prevent criticality. The adequacy of these limits is demonstrated in general by the following considerations:

o The k,gg limits are less than 1.0, which assures that fresh fuel and spent fuel are stored in subcritical conditions with a margin of safety to criticality.

o K,gg of a given system is calculat.ed by i methods which have been calibrated and checked and therefore which provide highly reliable values of k,gg. j 1

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o All known uncertainties are accounted for in the calculation of k,gg.

o The k,gg limits apply to very unusual and highly improbable accident conditions; under normal 4 conditions, the fresh fuel is assured of being strongly subcritical by the absence of a moderator and the spent fuel is assured of being strongly subcritical by the presence of soluble boron.

o A criticality accident is not possible unless two independent and unlikely accident conditions are postulated to occur simultaneously, which is not credible and need not be considered under NRC Staff and industry standards.

(Turner Affidavit, 1 16).

10. The k,gg limit of 0.98 for storage of fresh fuel under conditions of optimum moderation is sufficient to prevent criticality and provides a large criticality safety margin, because a uniform condition of optimum moderation throughout the storage vault is not credible and is only a theoretical and conservative upper bound condition. (Turner Affidavit, 1 18).

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11. The k,gg limit of 0.95 for storage of fresh fuel under flooded conditions provides a criticality safety margin of 0.05 6 k,gg. This margin is approximately a factor of five times the usual uncertainty included in the calculated k,gg and is more than sufficient to assure that criticality will not occu3 under postulated flooding conditions. (Turner Affidavit, 1 21).

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12. There is no k,gg criterion applicable to " optimum moderation" accidents in spent fuel pools, since the presence of L stainless steel plates between the assemblies in the spent fuel storage racks absorbs thermalized neutrons and therefore removes the conditions necessary for optimum moderation. (Turner Affi-davit, 1 23).

13. The k,gg limit of 0.95 for storage of spent fuel under flooded conditions with unborated water provides a criti-cality safety margin of 0.05 6 k,gg. This margin provides a safety factor of 2 or more times the normal uncertainty included in the calculated k,gg and is more than adequate to assure that a criticality accident will not occur. (Turner Affidavit, 1 24).

Respectfully submitted, M

/

CO-COUNSEL Harold F. Reis Norman A. Coll Steven P. Frantz Steel Hector & Davis Newman & Holtzinger, P.C.

4000 Southeast Financial 1615 L Street, N.W.

Center Washington, D.C. 20036 Miami, FL 33131-2398 (202) 955-6600 (305) 577-2800 DATED: January 23, 1986 i

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