ML20140C623

Affidavit of SE Turner Re Contention 3 Concerning Increased Fuel Enrichment.Certificate of Svc Encl

ML20140C623
Person / Time
Site:	Turkey Point
Issue date:	01/17/1986
From:	Sarah Turner BLACK & VEATCH, FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML20140C595	List: ML20140C591 ML20140C602 ML20140C618 ML20140C623
References
OLA-3, NUDOCS 8601280375
Download: ML20140C623 (23)

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UNITED STATES OF AMERICA bhjZ  ;

NUCLEAR REGULATORY COMMISSION t,% cycd,,[g d }~ ]. }

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD M. s K f '[\\ # T

)

In the Matter of )

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

)

(Turkey Point Nuclear Generating ) (Increased Fuel Enrichment) 4 Units 3 & 4) )

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)

AFFIDAVIT OF DR. STANLEY E. TURNER ON CONTENTION NO. 3

1. I, Stanley E. Turner, Ph.D., am an employee of Black & Veatch, Engineers-Architects, working as a Consultant and Project Manager in the Southern Science Office of Black & Veatch 4

located in Dunedin, Florida. In that capacity, I performed or directed the performance of criticality safety analyses for the new and spent fuel storage areas,at the Turkey Point Nuclear Generating Station. I am a Registered Nuclear Engineer (Florida,

1. 22862) with over 30 years experience in the nuclear analyses of a wide variety of reactor types and configurations. More 4

specifically, I am a member of the American Nuclear Society Standards Committee 8.17 (Criteria for Nuclear Criticality Safety of Reactor Fuel Elements) and have recently been actively engaged in the criticality safety evaluation of new and spent fuel storage egg 12;gg7cg atO8jjgo G

o facilities for twelve nuclear power stations. A summary of my professional qualifications and experience is attached as Exhibit A and is incorporated herein by reference.

2. The purpose of my affidavit is to address Contention 3. Contention 3 and the bases for the Contention are as follows:

Contention 3 That the uranium enrichment amendments increase the chances of a criticality accident occurring in the fresh fuel pool and establishes a clear reduction in the safety margin of the fresh and spent fuel pool.

Bases for Contention a) The U-235 loading of 52.40 grams per axial centimeter (SER pg 2), is the maximum loading which can assure a k,gg of no greater than 0.95, includ-ing uncertainties. Thus, the safety margins for the enrichment of the fueY have been pushed to the limit and leave no margin of safety.

b) The increase of criticality from 0.95 to 0.98 for the fresh pool pushed the criticality of the pool closer to criticality, which is 1.0. This increases reactivity and increases the possibility of a criticality accident and/or loss of fuel cooling system flow. Thus, the requirements of 10 C.F.R. Part 50, Appendix A, criterion 62 will not be met.

On page 7 of-its Memorandum and Order of September 24, 1985, the Licensing Board stated that Coatention 3 "should be read as

] challenging the adequacy of this acceptance criteria by alleging that k,gg of 0.98 is not adequately safe for fresh fuel exposed to l

o abnormal, optimum moderation conditions and 0.95 is not adequate for fresh or spent fuel exposed to the abnormal condition of full flooding with unborated water."

3. The remainder of this affidavit is divided into four principal parts. The first part discusses a few of the more

,, pertinent principles of reactor physics. The second part describes the fresh fuel storage vaults and the spent fuel storage pools for Turkey Point. The third part discusses the acceptance criteria for preventing criticality in fresh fuel storage areas and spent fuel pools, and the final part explains why these acceptance criteria are adequate to prevent criticality.

I. General Princioles of Reactor Physics

4. The primary fissile material in new fuel assemblies for a nuclear power reactor is an isotope of uranium called uranium-235. In general, when a neutron is absorbed by uranium-235, there is a high probability that the uranium-235 will undergo fission, resulting in the release of more neutrons. In turn, these neutrons either can be absorbed by other uranium-235 (producing additional fission), can be absorbed by non-fissile material called " poisons" (resulting in no additional fission), or can escape without being absorbed (also resulting in no additional fission).

5. In general, neutrons released as a result of fission have a high kinetic energy and are called " fast" neutrons. Fast neutrons have a relatively low potential for being absorbed by and i

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i o-producing fission of uranium-235. Consequently, in nuclear power reactors, a " moderator" (typically water) is used which tends to reduce the energy of the neutrons to thermal equilibrium with the reactor core material (this process is called " moderation"). In contrast to fast neutrons, " thermal" neutrons have a relatively high potential for producing fission of uranium-235. Thus, in the absence of a moderator for producing thermal neutrons, any fast neutrons released by fission will likely escape or be unproductively absorbed, resulting in no additional fission.

h 6. As is apparent from the preceding paragraphs, not all neutrons released as a result of fission will cause additional fission. If fewer neutrons are being produced as a result of fission than are escaping or being unproductively absorbed, the fission reaction will not sustain itself, and the condition is classified as being "subcritical." In contrast, if an equal or 1

greater number of neutrons are being produced as a result of fission than are escaping or being unproductively absorbed, then the fission reaction will sustain itself; this condition is referred to as " critical."

7. The term " effective multiplication factor,"

designated by the symbol k,gg and commonly called k-effective, has been devised as a measure of the ability of a fission reaction to sustain itself. K-effective is defined as the ratio of the number

, of neutrons per unit of time resulting from fissions to the total

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number of neutrons lost per unit of time by absorption and leakage. Criticality occurs whenever the effective multiplication

5-factor (k,gg) reaches or exceeds a value of 1.0. For a k,gg less than 1.0,.the neutron chain-reaction cannot be sustained and the neutron flux level will be negligibly small. The margin below a k,gg of 1.0 is the safety margin to criticality, and this margin (Ak,gg) is the difference between 1.0 and the k,gg of a given system. For example, a system with a k,gg of 0.95 is subcritical by a safety margin of 0.054ik,gg.

II. Description of the Fresh Fuel Storage Vaults and the Soent Fuel Pools for Turkey Point

8. The new fuel storage vault (or room) and the spent e

fuel storage pool at Turkey Point are unrelated facilities and are 1

l physically located in separate areas of the plant. These two independent facilities are designed for different purposes, have different design criteria, respond differently to abnormal or accident conditions, and are therefore discussed separately in succeeding portions of this affidavit.

9. The new fuel storage vault (or room) is intended for the receipt and temporary storage of fuel assemblies being shipped

into the plant prior to their being loaded into the reactor core.

Since these new fuel assemblies are unirradiated, they do not yet contain any radioactive fission products and therefore do not require shielding or cooling. Consequently, fresh fuel assemblies are stored in a dry condition in the Turkey Point new fuel storage vault, and a cooling system is neither present nor is required for dry storage of unirradiated fuel assemblies in the new fuel storage vault. Since no moderation is provided for fresh

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assemblies stpred in a dry condition, the normal k,gg for such fuel assemblies is an extremely low value with a very large safety margin to criticality.

10. Spent fuel storage pools are designed and intended

- for the purpose of receiving and safely storing fuel discharged from the reactor core. Spent fuel storage pools are flooded with water to provide shielding and cooling. In pressurized water reactor plants, including Turkey Point, water in the spent fuel pools is normally maintained with a sufficient concentration of soluble boron which acts as a neutron poison and thereby assures a very low value for k,ff with a large safety margin to criticality.

III. Development of Acceptance Criteria for Preventing Criticality in Fresh Fuel Storage Areas and Spent Fuel Pools

11. Criticality analyses for fresh fuel storage areas and spent fuel pools are governed by General Design Criterion (GDC) 62 of Appendix A to 10 CFR Part 50 of the Nuclear Regulatory Commission's (NRC) regulations, which states that " Criticality in the fuel storage and handling system shall be prevented by physical systems or processes, preferably by use of geometrically safe configurations."

12. Prior to 1973, general practice in the nuclear Industry was to design fresh or spent fuel storage facilities for a maximum k,gg of about 0.90 (approximately the k,gg of a single Calculations of k,gg were i

isolated fuel assembly in water).

performed assuming fully flooded unborated conditions using 1

methods then extant, without considering uncertainties in the calculated k,gg. At that time, it was believed that the safety margin in k,gg of 0.10 was more than sufficient to account for any uncertainties while still preventing criticality.

13. In August 1973, the American National Standards Institute (ANSI) issued an industry standard designated as ANSI N18.2-1973, which recommended a design basis k,gg of 0.95 for storage of fresh or spent fuel assuming fully flooded unborated conditions, and a k,gg of 0.98 for a normally-dry fresh fuel storage facility assuming abnormal conditions of optimum moderation. The NRC essentially adopted the ANSI N18.2 recommendations when it issued Sections 9.1.1 and 9.1.2 of the Standard Review Plan (SRP) (NUREG-75/087) in 1975. The SRP was reissued in 1980 as NUREG-0800, with little substantive change in the criteria in Sections 9.1.1 and 9.1.2. 1/

1/ Currently, SRP Section 9.1.1, entitled "New Fuel Storage,"

states that the NRC Staff will accept storage racks for new fuel assemblies if the spacing between fuel assemblies in the storage racks is sufficient to maintain the array, when fully loaded and flooded with potential moderators such as nonborated water fire extinguishant aerosols, in a suberitical condition, i.e., K,gg of less than about i

0.95. Furthermore, the design of the new fuel storage racks will be such that the K,gg will not exceed 0.98 with fuel of the highest anticipated reactivity in place assuming optimum moderation. '

Credit may be taken for neutron  !

absorbing materials.

SRP Section 9.1.2, entitled " Spent Fuel Storage," currently i i

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14. Part of the NRC (and industry) rationale for moving from the pre-1973 k,gg practice of 0.90 to the higher limits in SRP Sections 9.1.1 and 9.1.2 is the following:

o Significant improvements have been made in calculational methods. Additionally, calculational methods are verified against experimental data that represents, as nearly as possible, the system being evaluated. 2/

o In calculating k,gg in accordance with SRP Sections 9.1.1 and 9.1.2, a total uncertainty factor is determined and added to the calculated k,gg to define the maximum possible k,gg. 3/

states that the NRC Staff will accept storage racks for spent fuel assemblies if the center-to-center spacing between fuel assemblies and any strong fixed neutron absorbers in the storage racks is sufficient to .saintain the array, when fully loaded and flooded with nonborated water, in a subcritical condition. A K,gg not greater than 0.95 for this condition is acceptable.

2/ See U.S. Nuclear Regulatory Guide 3.41, " Validation of Calculational Methods for Nuclear Criticality Safety," Rev. 1 (May 1977).

3/ Further definition and clarification of the NRC position were provided in an April 14, 1978 letter from Brian Grimes, transmitting the NRC "OT Position for Review and Acceptance of-Spent Fuel Storage and Handling Applications," setting forth in greater detail the NRC acceptance criteria for spent fuel storage pools.Section III.l.5 of this guidance emphasizes that the " neutron multiplication factor in spent fuel pools shall be less than or equal to 0.95, includina all uncertainties, under all conditions" (emphasis in original).

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15. At the present time, so far as I know, analyses for all U.S. reactor plants (including Turkey Point) 4/ and most foreign plants utilize the NRC criteria for criticality safety, providing a safety margin of 0.05fik,ff for spent fuel storage pools in the absence of soluble boron, and a 0.026k,ff margin for

-the dry storage vaults under hypothetical conditions of optimum moderation.

IV. Adequacy of the NRC Acceptance Criteria for k,gg for Storaae of Fresh and Spent Fuel ~

A. Adeauacy of the Criteria in General

16. The criteria in SRP Sections 9.1.1 and 9.1.2 which form the design basis for the Turkey Point fresh fuel storage vaults'and spent fuel pools are adequate to prevent criticality in accordance with GDC 62 of the Commission's regulations. The adequacy of these limits is demonstrated in general by the following considerations:

o The criteria specify limits on k,gg which are less than 1.0. Consequently, these limits require fresh fuel and spent fuel to be stored in subcritical

! conditions, and provide for a margin of safety to criticality.

4/ See letter dated April 4, 1984, from J.W. Williams, Jr.

(Florida Power and Light Company) to Darrell G. Eisenhut (NRC), attaching " Criticality Analyses of the Turkey Point Plant Units 3 and 4 Storage Racks With Increased Enrichment" (February 1984), p. 3.

s o The k,gg of a given system is calculated by methods that have in turn been calibrated and checked against critical configurations whose k,gg has been experimentally determined. Thus, the values of k,gg calculated by such methods are highly reliable and constitute an appropriate basis for determining whether or not a system will be critical.

o The NRC's acceptance criteria for criticality analyses require consideration and inclusion of all known uncertainties in the calculation of k,gg.

These uncertainties encompass uncertainties in the calculational mebhods as well as uncertainties due to mechanical tolerances in storage rack manufacture and fuel assembly fabrication. Given these uncertainties, the actual k,gg may be higher or lower than the nominally calculated k,gg.

However, for conservatism, it is assumed that the actual k,gg is greater than the nominally calculated k,gg as a result of these uncertainties.

Since all uncertainties are therefore already included in the calculated maximum k,gg values, the safety margins specified in the NRC acceptance criteria are conservative.

o It is important to recognize that the safety margins for subcriticality specified in the NRC acceptance criteria relate to very unusual and

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1 highly improbable accident conditions (i.e., fully flooded unborated conditions and conditions of optimum moderation). Normally, in pressurized i

water reactor plants, and the Turkey Point nuclear I

plant in particular, the new fuel vault (or room) is maintained in a strongly subcritical condition by the absence of water or other moderator.

Similarly, under normal conditions, the spent fuel pool is assured of being strongly subcritical by the presence of soluble boron in the pool water.

o Given the highly subcritical effects of the absence

{ of a moderator in the fresh fuel storage vaults and the presence of borated water in the spent fuel pools, there is no possibility of a criticality 1

accident in the fr4sh fuel storage vaultr. or the spent fuel pools unless (1) water is admitted into the new fuel vault or soluble boron is removed from

the spent fuel pool water, and (2) some other 4

independent and highly unlikely accident condition, which significantly increases k,gg, is postulated to occur simultaneously. The possibility of such l concurrent, independent, multiple failures is not credible. As a result, the NRC's "OT Position for Review and Acceptance of Spent Fuel Storage and I Handling Applications" accepts the double

contingency principle of ANSI N16.1-1975, which ,

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provides that designs for operations with fissionable materials outside reactors are acceptable if at least two unlikely, independent and concurrent accidents are necessary before a criticality incident would be possible.

B. Adeauacy of the Criteria for Fresh Fuel Storace Vaults

17. As discussed above, two separate criticality safety criteria are specified in the NRC's acceptance criteria for new fuel storage vaults. For racks fully loaded with fuel of the highest anticipated enrichment, the two criteria are as follows:

o At a hypothetical low-density optimum moderation condition, the maximum k,gg, including uncertainties, shall not exceed 0.98; and o If flooded with clean, unborated water, the maximum k,gg, including uncertainties, shall not exceed 0.95.

Both criteria relate to highly improbable accident conditions, since criticality is not possible in the normally-dry storage vault in the absence of water or other moderator. Each of these

- two criteria and its associated criticality safety margins is discussed separately below.

a) Low-Density Moderation

18. Criticality analyses, using sophisticated analytical techniques, indicate the possibility of a sharply defined peak in k,gg for postulated low-density water moderation

J' at 5% to 10% of full water density. The water density corresponding to the maximum in k,gg is termed " optimum" moderation, and any increase or decrease in density (and thus moderation) results in large reductions in k,gg. The existence of a stable fog or foam of precisely the optimum density uniformly and everywhere throughout the storage vault is not in itself a credible occurrence. Actual fogs and foams generally have an effective density much lower than the optimum density, and larger water droplets (i.e., raindrop size) would not remain stably suspended in air. However, the theoretical condition of optimum moderation establishes a conservative upper bound on the possible k,gg with assurance that any realistically possible condition will have a substantially lower k,gg with a corresponding larger safety margin. Thus, the NRC k,gg criterion for optimum moderation in new fuel storage vaults is sufficient to prevent criticality and inherently provides a large criticality safety margin, although the magnitude of the safety margin cannot be quantified.

19. It should be noted that, in the case of the Turkey Point new fuel storage vaults, there was no requirement for evaluation of the low-density moderator accident at the time the

. vaults were originally licensed in 1972-73. The NRC criterion of a k,gg less than 0.98 for such an upper-bound limiting condition was established in 1975 and is, therefore, a new and additional requirement imposed by the increased fuel enrichment amendments rather than an increase in a previous criticality safety limit.

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b) Flooded Condition

20. The second of the NRC criticality safety criteria j relates to the accident condition in which the new fuel storage i vault is postulated to be fully flooded with clean unborated water. Unlike the low-density, optimum moderation case (which is i-j not credible and which exists only in theory), postulated

flooding, in general at least, corresponds to a condition which might possibly exist in nature (although it has an extremely low likelihood of occurrence in a fresh fuel storage vault). Thus, the NRC criticality safety criterion specifies a k,gg limit of

! less than 0.95 for the fully flooded condition, which is more i

j rigorous than for the purely hypothetical low-density moderation i accident.

] 21. At the NRC limit (k,gg of 0.95, including uncertainties), the criticality safety margin is 0.056 k,gg. For

{ most new storage vaults under the flooded accident condition, the total uncertainty is usually about 0.016k,gg. Thus, the NRC i criterion provides a criticality safety margin that is approximately a factor five times the uncertainty which is included in the calculated k,gg. This safety factor is more than l i , sufficient to assure that criticality will not occur under l postulated flooding conditions.

22. It should be noted that the increased fuel j enrichment amendments for Turkey Point did not modify the pre-l existing k,gg limit of 0.95 for the fresh fuel storage vaults i

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, o under fully flooded conditions. Thus, the amendments did not ,

change or otherwise reduce the minimum criticality safety margin of 0.056 k,gg for this condition.

C. Adequacy of the Criteria for Spent Fuel Storace Pools

23. As discussed above, the NRC criticality safety criterion for spent fuel poo,ls states that k,gg should be no greater than 0.95, including all known uncertainties, under conditions where the soluble boron, for whatever reason, may be absent from the water in the pool. Therefore, even in the highly unlikely event in which soluble boron may be absent, the criticality safety margin would still be at least 0.056k,gg.

There is no k,gg criterion applicable to " optimum moderation" accidents in spent fuel pools, since the presence of stainless steel plates between the assemblies in the spent fuel storage racks absorbs thermalised neutrons and therefore removes the conditions necessary for optimum moderation.

24. A criticality safety margin of 0.056k,gg is more than adequate to assure that a criticality accident will not occur in the spent fuel storage pool, even for the very unlikely condition where all of the soluble boron normally in the storage pool water may be lost. The total uncertainty in criticality safety analyses of spent fuel storage pools is included in the k,gg value and usually amounts to 0.01 to 0.0256k,gg. Thus, the NRC k,gg criterion of 0.95 for spent fuel storage pools provides a safety factor of 2 or more above the normal uncertainty.

Therefore, given the precision of current validated calculational

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methods and inclusion of all known uncertainties in the maximum k,gg, the criticality safety margin of 0.050k,gg is more than adequate to compensate for the unlikely existence of any unrecognized or unknown factors and to provide assurance that a criticality accident will not occur in the spent fuel. Additional confidence is provided by the soluble poison normally present in the spent fuel pool water.

25. Finally, it should be noted that the increased fuel enrichment amendments for Turkey Point did not modify the pre-existing k,gg limit of 0.95 for the spent fuel pools. Thus, the amendments did not change or otherwise reduce the minimum criticality safety margin of 0.056 k,gg for the spent fuel pool.

V. Conclusions

26. The fresh fuel storage vaults and spent fuel pools for Turkey Point are unrelated facilities located in separate areas of the plant. Under normal conditions, the assemblies in the fresh fuel storage vaults are stored in a dry condition, and the assemblies in the spent fuel pool are stored in borated water.

The NRC acceptance criteria, adopted for use at Turkey Point, 4

mpate that the k,gg of the spent fuel pools should be equal to or less than 0.95 (including all uncertaintles), assuming the absence of boron in the pool water, and the k,gg of the fresh fuel storage vaults (including all uncertainties) should be equal to or less i

than 0.95 for fully flooded conditions and 0.98 for hypothetical optimum moderation conditions. Since these limits are less than I

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1.0, including all uncertainties, and are applied to highly unlikely postulated accident conditions, they are sufficient to prevent criticality and to provide for adequate margins of safety.

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1 FURTHER AFFIANT SAYETH NOT The foregoing is true and correct to the best of my knowledge,'information and belief.

AX, &w Stanley E. T rner STATE OF FLORIDA )

COUNTY OF PINELLAS)

Subscribed and sworn to before me this / 9 day of 76nuor(-7 , 1986. My commission expires: 3 / 7- 1 (- .

I>, et w i' ll Ja/cliX

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NOTARY PUBLIC

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l EXHIBIT A I STATEMENT OF PROFESSIONAL QUALIFICATIONS OF DR. STANLEY E. TURNER Education: University of South Carolina, B.S. Chemistry, 1945 University of Texas, Ph.D., Nuclear Chemistry, 1951 Professional Experience: Southern Science Office of Black & Veatch, Engineers-Architects Proiact Manmaar/ Consultant fl977-Present)

Dr. Turner is responsible for a wide range of scientific projects, including radiological monitoring systems, assessment of alternate nuclear fuel cycles, combustible gas generation and control, reactor physics analyses, and safety evaluations.

Over the past few years, Dr. Turner has been involved in the design, evaluation and licensing of high density spent fuel storage racks, including both criticality analyses and assessment of radiological consequences. Additionally, he has evaluated the core physics performance and isotope production rates of research, test, training, production, and power reactors. As Project Manager for several U.S. Arms Control and Disarmament Agency programs, Dr. Turner has investigated possible modifications to reactors for improved fuel utilisation and has evaluated advanced PWR reactor concepts, involving extended fuel burnup, increased core regionalization and alternate methods of reactivity control.

MUS Cornoration - Benior Consultant fl973-1977)

Dr. Turner was Project Manager on numerous assignments. Among them were the assessment of post-LOCA hydrogen generation, and methods of control and development of specialized radiological monitoring systems; a survey of European nuclear fuel cycle plans and capabilities; generic review of public issues in the nation's nuclear power program; investigation of Halon-1301 for fire control and inhibition of hydrogen burning; a study of radiolytic decomposition of Halon; and a survey of U.S. nuclear plant practice for foreign clients.

His other work dealt wath such activities as

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analytical physics support, evaluation of catalyst performance, and fission gas release and inventory calculations.

Southern Nuclear Enaineerina, Inc. - Vice President, Physics (1964-73)

During his association with this company,

, Dr. Turner managed and participated in a number of projects which involved assessing tritium production and control methods; performing i calculations of heavy isotope production; reviewing licensing documents; preparing operating procedures; performing safety assessment of large, special purpose reactors; evaluating consequences of industrial sabotage in nuclear power plants; ,

assessing reactors for maritime application; and evaluating fuel cycle economics.

General Nuclear Enaineerina - Senior Reactor Physicist (1957-19641 Dr. Turner performed or directed most of the fuel cycle cost evaluations, heavy isotope analysis, and fuel management work performed by this company. He planned and coordinated various experiments and testing programs, and managed research and development activities related to advanced nuclear i fuel elements. th addition, he participated in  ;

plant licensing actions and safety reviews, and served as a member of the Safety Committee for an operating nuclear power plant.

Socony-Mobil Research Laboratory - Physicist

(1952-1957) a Dr. Turner performed research in radiological i

methods for oil exploration, including radiation measurements and field tests.

! U.S. Navy Radioloalcal Defense Laboratory -

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' Physicist (1951-1952) l Dr. Turner performed research in the consequences and methods of defending against nuclear bomb <

detonations, including field tests and radiological  !

measurements.

BeneraII Societies: Sigma Pi Sigma, Phi Lambda Epsilon, Blue Key, Sigma Xi j Dr. Turner is a member of the ANS Standards Committee 8.17 on Nuclear Criticality Safety, and Chairman of ANS 5.3 and 5.4 Working Groups on

. . o Fission Product Release. He was formerly a member of the ANS 5 Committee on Decay Heat and contributed to the formulation of the standard on fission product decay heat.

Registered Professional Nuclear Engineer: Florida, No. 22862.

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'. UNITED STATES OF AMERICA L3'y NUCLEAR REGULATORY COMMISSION -j s/4lj ,c, , , _ {

BEFORE THE ATOMIC SAFETY AND LICENSING BOhRD' y;, .> -lg g; y'l'y

)

In the Matter of )

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

)

(Turkey Point Nuclear Generating ) (Increased Fuel Enrichment)

Units 3 & 4) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of

1. Letter from Steven P. Frantz to Licensing Board Members (Jenuary 23, 1986).

2. Licensee's Motion For Summary Disposition Of Contention 3 (January 23, 1986).

3. Licensee's Statement Of Material Facts As To Which There Is No Genuino Issue To Be Heard With Respect To Contention 3 (January 23, 1986).

4. Affidavit of Dr. Ctanley E. Turner On Contention No. 3 (January 17, 1986).

in the abovo captioned proceeding were served on the following by deposit in the United States mail, first class, properly stamped and addressed, on the date shown below.

Dr. Robert M. Lazo, Chairman Atomic Safety and Licensing Board Panol U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Emmoth A. Luobke Atomic Safety and Licensing Board Panol U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Richard F. Cole Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

. . . +

i v,  !

Atomic Safety and Licensing Board Panel

! U.S. Nuclear Regulatory Commission i Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of Secretary U.S. Nuclear Regulatory Commission

Washington, D.C. 20555 l

Attention: Chief, Docketing and Service Section ,

(Original plus two copies)

Joette Lorion  !

! 7269 SW 54 Avenue t l

Miami, FL 33143 l

Mitzi A. Young Office of Executive Legal Director l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Norman A. Coll

• Steel, Hector & Davis

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4000 Southeast Financial Center Miami, FL 33131-2398 1

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Steven P. Frantz F Newman & Holtzinger, P.C.

1615 L Street, N.W.

Washington, D.C. 20036 Dated: January 23, 1986 i

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