ML20140C831

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Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Intervenors Contentions
ML20140C831
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 01/23/1986
From: Frantz S
FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20140C819 List:
References
OLA-2, NUDOCS 8601290007
Download: ML20140C831 (32)
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UNITED STATES OF AMERICA .

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NUCLEAR REGULATORY COMMISSION 4 BEFORE THE ATOMIC SAFETY AND LICENSING BOAR 2),

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In the Matter of )

} Docket Nos. 50-250 OLA-2 FLORIDA POWER & LIGHT COMPANY ) 50-251 OLA-2

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(Turkey Point Nuclear Generating ) (Spent Fuel Pool Expansion)

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 INTERVENORS' CONTENTIONS Licensee contends there is no genuine issue to be heard with respect to the following material facts:

Contention 3

1. The production of fission products in a fuel assembly is proportional to the power produced by the assembly throughout its operation in the core. The amount of power produced by an assembly (and thus the amount of its fission products) varies from assembly to assembly depending upon the location of the assembly in the reactor core. (Affidavit of Rebecca K. Carr on Contention No. 3 (January 22, 1986), 1 4).
2. Radial peaking factor can be expressed as the ratio of the maximum assembly power to the average assembly power. The radial peaking factor applies only to the assemblies in the core 0601290007 e60123 PDR ADOCK 05000250 G PDR

which produce the maximum power. The other assemblies in the core have a lower ratio of power to average power than the assemblies with the radial peaking factor. (14., TV 5-6).

3. It is inappropriate to use a radial peaking factor when calculating the amount of fission products in all of the assemblies in the core, since the amount of fission products in the core as a whole is dependent upon the overall power of the core and not the power of any individual assembly. (14., V 6).
4. The Nuclear Regulatory Commission (NRC) Staff has issued guidance in Standard Review Plan (SRP) Section 15.7.5 and Regulatory Guide 1.25 for performing analyses of cask drop accidents. This guidance does not specify the number of fuel assemblies which should be assumed to be damaged as a result of a postulated cask drop, but instead states that a conservative approach is to assume that the assembly with the peak fission product inventory is the one damaged. This guidance also states that a minimum radial peaking of 1.65 for pressurized water reactors (PWRs) is acceptable for calculating the fission product inventory. (14., 1 7).
5. The guideline doses in 10 C.F.R. Part 100 are commonly used in the nuclear industry for evaluating the accepta-bility of accident conditions. SRP 15.7.5 states that the doses calculated for cask drop accidents are acceptable if they are well within the Part 100 guidelines. SRP Section 15.7.5 defines well within as 25%. (14., 1 11).
6. The Licensee's analysis of postulated cask drop accidents in the Turkey Point spent fuel pool consisted of two cases using different assumptions regarding the number of freshly discharged assemblies damaged and the radial peaking factor of those assemblies. (14., 1 8).

Case 1 of the Licensee's analysis assumed that all 7.

1 assemblies in the spent fuel pool (including 80 freshly dis-charged assemblies) would be damaged and that the 80 freshly discharged assemblies had a radial peaking factor of 1.65.

Application of a radial peaking factor of 1.65 to all 80 fuel i

assemblies was conservative, because this implies that over half the assemblies in the core produced the peak power -- a condition which is not realistic. (Id., 11 10, 14).

8. Case 2 of the Licensee's analysis assumed that all assemblies in the spent fual pool (including a full core off-load No of 157 freshly discharged assemblies) would be damaged.

radial peaking factor was applied to these assemblies (which is mathematically equivalent to a radial peaking factor of 1.0).

Application of a radial peaking factor to a full core off-load is not necessary or appropriate, since the full core inventory accounts for all of the fission products in the core. (14., 11 12, 15).

9. Both Case 1 and Case 2 of the Licensee's analysis did not apply a radial peaking factor to the fuel assemblies assumed to be discharged during previous refuelings. Application of a radial peaking factor to these assemblies was not necessary

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or appropriate, since the number of these assemblies was assumed to be large and therefore the stored assemblies would be repre-(Id., 11 10, 12, sentative of the assemblies in an entire core.

16).

10. The results of the Licensee's analysis of postulated cask drop accidents at Turkey Point were well within the guideline doses in 10 C.F.R. Part 100 for Case 1 and Case 2.

(14., 11 11, 13).

11. The results of the Case 2 analysis would have been well within the 10 C.P.R. Part 100 guidelines even if a radial peaking factor of 1.65 had been applied to the full core off-load of 157 freshly discharged assemblies. (14., 1 17).
12. Application of a radial peaking factor of 1.65 in Case 1 and Case 2 to the assemblies assumed to be discharged during previous refuelings would not significantly affect the results of the dose analyses, because these assemblies contribute relatively little to the off-site doses due to radioactive decay of their fission products. (Id., V 16).

Contention 4

1. The NRC Staff has not issued specific guidance for the performance of analyses of the radiological effects of spent fuel pool boiling. (Affidavit of Rebecca K. Carr of Contention No. 4 (January 22, 1986, 5 3).
2. The NRC Staff accepted the methodology and assumptions used in an analysis of the radiological effects of spent fuel pool boiling for the Limerick plant. (1d.)
3. The Licensee performed an analysis of the radiological effects of spent fuel pool boiling at Turkey Point which was consistent with the methodology and assumptions used in the Limerick analysis. (14.)
4. The assumptions used in the Turkey Point spent fuel pool boiling analysis were either specific to Turkey Point or generically applicable to PWRs. The assumptions used in the Turkey Point analysis were not the same in every case as those in the Limerick analysis, and the Limerick analysis was not extra-polated to Turkey Point. (Id.)
5. The assumptions regarding saturation noble gas and iodine inventories used in the Turkey Point spent fuel pool 4

b;iling J;plysis were based upon Turkey Point design bases for power, fuel enrichment, and fuel burnup. These assumptions were not the same as those used in the Limerick analysis. (Id., 1 4).

6. The Turkey Point spent fuel pool boiling analysis assumed a failed fuel value of 1 percent based upon measurements at PWRs with Zircaloy-clad fuel. This assumption is conservative because it is a factor of 10 higher than what has been measured for PWRs and far higher than what has been experienced at Turkey Point. The Limerick analysis also used a failed fuel assumption of 1 percent (Id., 1 5).

9

7. The assumptions in the Turkey Point spent fuel pool boiling analysis regarding iodine and noble gas activities were the same as those recommended in NRC Regulatory Guide 1.25.

These assumptions are widely accepted within the nuclear industry as conservative. The Limerick analysis used the same assumptions regarding the gap activities of iodine. (14., 1 6).

8. The results of the Turkey Point spent fuel pool boiling analysis were a small fraction of the guideline doses in 10 C.F.R. Part 100, where "small fraction" is defined as less than 10% of the Part 100 guidelines. (1d., 1 7).

Contention 5

1. The new Turkey Point spent fuel pool storage racks are free-standing and are not anchored to the floor or braced to the pool walls. (Affidavit of Harry E. Flanders, Jr. on Conten-tion Number 5 (January 23, 1986) (Flanders Affidavit), 11 4-5).
2. Some of the new racks contain storage locations which overhang or extend beyond the support pads for the racks.

J (14., VV 4-5).

3. The current licensing basis for the new Turkey Point spent fuel pool storage racks is predicated upon the existence of administrative controls which preclude the loading of fuel assemblies in the overhanging rows before assemblies are loaded into other storage locations. (14., t 23; letter.. dated February 26, 1985, from Daniel G. Mcdonald (NRC) to J.W.

Williams, Jr. (FPL)).

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4. Tr.e NRC Staff has identified criteria which it l will accept for the performance of seismic analysis of spent fuel storage racks. SRP Section 9.1.2 states that spent fuel storage The racks should be designed to seismic Category I requirements.

"OT Position for Review and Acceptance of Spent Fuel Storage and Handling Applications" (NRC Position Paper) identifies criteria for performing criticality analyses for spent fuel pools, and states that the presence of soluble boron in the spent fuel pool includ-may be considered during postulated accident conditions, ing earthquakes. The NRC Position Paper state that either the ASME (American Society of Mechanical Engineers) Code or the AISC (American Institute of Steel Construction) Code are acceptable for deriving allowable stresses in the spent fuel racks, that the ,

amplitudes of sliding motion of the racks should be minimal and impact between adjacent racks or between a rack and the pool wall should be prevented, and that the factors against tilting should be within certain values. These criteria are widely used in the nuclear industry and are conservative. (Flanders Affidavit, TV 6-10).

5. The new Turkey Point spent fuel storage racks were designed in accordance with seismic Category I requirements.

(14., 11).

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6. The presence of soluble boron in the Turkey Point spent fuel pool water will maintain the stored spent fuel assemblies subcritical in the event of an earthquake. (14., f 12; Affidavit of William A. Boyd on Contention 10 (January 20, 1986) (Boyd Affidavit), 11 33-40).
7. The Licensee performed a mechanical and structural analysis of the new Turkey Point spent fuel storage racks in accordance with the NRC Position Paper. The structural analysis of the storage racks was based on the allowable stresses in the ASME Code. (Flanders Affidavit, 1 13).

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8. The Licensee's structural and mechanical analysis of the new Turkey Point spent fuel storage racks assumed that the maximum seismic acceleration was the design basis Safe Shutdown Earthquake (SSE) acceleration in the Updated Final Safety Analysis Report (FSAR) for the Turkey Point plant; that the structural danping value of the racks was consistent with the value in the Updated FSAR and conservative compared to the value recommended in Regulatory Guide 1.61 for welded steel framed structures; that the storage racks were hydrodynamically coupled, that thereby producing maximum deflections, loads, and stresses; i

sloshing above the level of the racks would not impose a load on the racks; and that the coefficient of friction employed was varied to produce the maximum rack horizontal displacement and the maximum rack overturning force. These assumptions are 1

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appropriate for use in analyzing the response of the Turkey Point (Id., 11 spent fuel pool racks and provide conservative results.

14-18).

9. The Licensee's structural and mechanical analysis of the new Turkey Point spent fuel storage racks was performed in two phases. The first phase employed a two-dimensional nonlinear model of an individual storage rack cell. The results of the first phase provided input to the second phase of the analysis.

The second phase employed a three-dimensional linear model for the purpose of calculating loads and stresses in the storage racks. (14., 15 19, 21-22).

10. The nonlinear model used in the first phase of Licensee's analysis accounted for nonlinearities in the response of the storage racks. The loads and stresses calculated by the linear model used in the second phase of Licensee's analysis were corrected to agree with the maximum loads and stresses predicted by the nonlinear model used in the first phase, thereby conserva-tively accounting for the nonlinearities in the loads and stresses. (Id., TV 21-22)
11. The model used in the second phase of Licensee's analysis provided three-dimensional response data for loads and stresses. Use of a two-dimensional model in the first phase of Licensee's analysis was appropriate because the fuel assembly and storage cell are structurally symmetric (identical) about either the x or y horizontal axis. (Id., it 19,21,22).

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12. The models used in both phases of the Licensee's analysis employed tue finite element method, which is widely used in the nuclear power and other industries and is accepted by the NRC for seismic analyses. (16., 1 20).
13. The Licensee's structural and mechanical analysis of the new Turkey Point spent fuel storage racks was performed for two cases. The first case provides the licensing basis for the storage racks and as';umes that administrative controls are in place to prevent loading of the overhanging rows while the remainder of the rack is empty. The second case assumes that no administrative controls are in place and that the overhanging 3 rows are loaded while the remainder of the rack is empty. (Id.,

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, 1 23).

14. The results of Licensee's analysis for Case 1 showed that the rack liftoff would not occur and that the factor of safety against overturning was much greater than the criterion referenced in the NRC Position Paper; that no impact would occur between adjacent racks or the racks and the pool walls; and that the rack stressess would be within ASME Code allowable limits.

(14., 1 24).

15. The results of Licensee's analysis for Case 2 showed that the. maximum rack liftoff would be 0.18 inches but that the rack would be stable and would have a minimum factor of safety'against overturn which is substantially greater than the criterion referenced in the NRC Position Paper; that no impact 5

would occur between adjacent racks or the racks and the pool walls; and that the rack stresses would be within ASME Code l allowable limits. (14., 1 25).

16. The Turkey Point fuel assemblies are designed to withstand steady state and transient operating conditions (including earthquakes) which are far more severe than those postulated in the Turkey Point spent fuel pool under seismic conditions. (Affidavit of Leonard T. Gesinski on Contention No.

5 (January 21, 1986), 1 5).

17. The maximum acceleration imposed on the fuel assemblies in the new Turkey Point spent fuel storage racks as a result of an SSE would be 1.6g. The fuel assemblies can withstand an acceleration of 36g without localized cladding failure. (Id., 1 6-8; Flanders Affidavit, 1 26).

Contention 6

1. The Turkey Point spent fuel pools consist of a reinforced concrete pool structure with a Type 304 stainless steel pool liner. The new Turkey Point spent fuel storage racks are also constructed of Type 304 stainless steel and utilize Boraflex as a neutron absorber. The fuel assemblies to be stored in the new Turkey Point spent fuel storage racks are comprised of Type 304 stainless steel, Inconel, and Zircaloy. (Affidavit of Dr. Gerald R. Kilp on Contention No. 6 (January 20, 1986) (Kilp Affidavit), 1 4; Affidavit of Eugene W. Thomas on Contention No.

I 6 (January 22, 1986) (Thomas Affidavit), 11 4-5; Affidavit of Rebecca K. Carr on Contention No. 6 (January 22, 1986) (Carr Affidavit on Contention 6), 11 4, 6).

2. Temperatures of the water in the Turkey Point

! . spent fuel pools could reach boiling during a postulated loss of cooling accident. Under normal conditions, the temperatures are not expected to exceed 143 F and will usually be less. (Affi-davit of Daniel C. Patton on Contention Nos, 6 and 8 (January 22, 1986) (Patton Affidavit), 11 9-11, 13-15).

3. For materials stored for ferty years in the new Turkey Point spent fuel storage racks, the cumulative gamma dose 10 was conservatively calculated by the Licensee to be 1.9 x 10 Rads and the cumulative neutron fluence was conservatively 13 2 calculated to be 4.8 x 10 n/cm . (Kilp Affidavit, 1 6).
4. Alpha and beta radiation do not have an ability to penetrate materials deeply enough to affect appreciably the structural integrity of the materials in the Turkey Point spent fuel pools. Gamma radiation has a negligible effect on the mechanical properties of'non-organic materials such as stainless steel, concrete, and the other materials in the Turkey Point spent fuel pool. (Carr Affidavit on Contention 6, 11 5, 6; Kilp Affidavit, 1 8).
5. The fuel assemblies and cladding are designed to withstand the radiation levels, temperatures, and heat loads present in a reactor, which are far more severe than those in the

-Turkey Point spent fuel pools. (Kilp Affidavit, 11 7, 9).

6. The neutron fluences expected in the Turkey Point i

spent fuel pools fur a forty year exposure are orders of magni-tude below those for fuel assemblies while in a reactor. Thus, 1

the neutron radiation in the Turkey Point spent fuel pool will have an insignificant ~effect upon the material integrity of the

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fuel assemblies and cla.dding. (Id., 1 7).

7. The corrosion rate of Zircaloy is approximately 1/100,000 inch per year at 500 F and is substantially lower at the much lower temperatures expected in Turkey Point spent fuel pools. The corrosion rate of Type 304 stainless steel has been shown not to exceed 6/10,000 inch per 100 years in an oxygenated borated water enrichment similar to that in the Turkey Point spent fuel pools, and the corrosion rates for Inconel are at least as low as those for stainless steel. Consequently, corrosion will not have any appreciable impact on the structural integrity of the fuel assemblies and cladding. Furthermore, since hydriding is a direct function of corrosion, hydriding of the fuel assemblies will also be virtually nil. (Id., 11 10-12).
8. Zirconium used in Zircaloy cladding of the fuel assemblies is immune to stress-corrosion cracking in water environments like the spent fuel pool. Stainless steel, Inconel, and Zircaloy all form protective oxide filas, and no significant galvanic attack will occur among these materials. (Id., 11 9, 12).
9. Industry experience demonstrates that spent fuel assemblies have been safely stored for more than three decades.

Hot cell examinations on fuel assemblies s'tored for more than ten years show no measurable changes due to corrosion or hydriding and no loss of fuel integrity. (14., 1 13).

10. The fuel assemblies will maintain their material integrity during storage in the new Turkey Point spent fuel storage racks. (Id., 1 14, 20).
11. The stainless steel used in the new spent fuel storage racks for Turkey Point is virtually immune to corrosion at spent fuel pool temperatures, and the neutron radiation levels in the spent fuel pool are orders of magnitude below those sufficient to produce any appreciable impact upon the integrity of stainless steel. Therefore, the racks will maintain their material integrity while in the Turkey Point spent fuel pool.

(Id., TV 15, 20).

12. Boraflex is a silicone-based polymer containing boron carbide. Extensive testing indicates that Boraflex retains its neutron attentuation' capabilities after being exposed to an environment of borated water and gamma and neutron radiation levels substantially exceeding those anticipated for 40 years of tuel storage at Turkey Point. (ld., 11 17-18).
13. Stainless steel was chosen for the liner plate because of its demonstrated ability to perform in various nuclear power plant applications, including those more severe than encountered in the Turkey Point spent fuel pool. (Carr Affidavit on Contention 6, 1 4; Thomas Affidavit, 1 12).
14. The stainless steel used in the liner plate for the Turkey Point spent fuel pools can withstand, without loss of integrity, neutron fluences which are orders of magnitude higher than those predicted for the spent fuel pool. Additionally, the stainless steel maintains its integrity and long-term stability at temperatures in excess of 1000 F, and no appreciable reduc-tions in strength of the stainless steel occur at the tempera-tures expected in the Turkey Point spent fuel pools. (Carr Affidavit on Contention 6, 1 5; Thomas Affidavit; 1 12).
15. No appreciable deterioration or loss of integrity of the Turkey Point spent fuel pool liner will occur as a result of the heat and radiation loads caused by spent fuel pool expansion. (Carr Affidavit on Contention 6, TV 5, 7; Thomas Affidavit, % 16).
16. A concrete structure can withstand neutron fluences orders of magnitude higher than those in the Turkey Point spent fuel pools without loss of material integrity.

Temperatures below 300 F have an insignificant effect on the properties of reinforced concrete. (Carr Affidavit on Contention 6, 1 6; Thomas Affidavit, 11 13-15).

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17. No appreciable deterioration or loss of integrity of the Turkey Point spent fuel pool concrete structure will occur as a result of the heat and radiation loads caused by spent fuel pool expansion. (Carr Affidavit on Contention 6, 11 6-7; Thomas Affidavit, 11 13-16).
18. The increased capacity of the Turkey Point spent fuel pools results in only minor variations in the original design heat loading conditions. (Thomas Affidavit, 1 6).
19. The most severe loads on the Turkey Point spent fuel pool structure due to heat are caused by temperature gradients through the structure. (Id., 1 6).
20. The Licensee analyzed the thermal stresses in the concrete pool structure resulting from temperature differentials, assuming a steady state outside ambient temperature of 30 F and assuming that the pool water was at boiling temperature. The 30 F temperature is extremely conservative given the south Florida site of the Turkey Point plant and the time necessary to develop a steady-state temperature gradient in the 3-foot thick walls of the spent fuel pool. (Id., 11 6-7).
21. Stresses in the walls and floor of the concrete .

pool structure resulting from a temperature differential of 182 F would be within the licensing conditions for the original design.

(Id., 1 8).

22. Thermal, hydrostatic, and hydrodynamic loads on the liner plate system will not result in a loss of function of the liner. (Id., 1 9).

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Contention 7

1. The expansion of the capacity of the Turkey Point Unit 3 spent fuel pool was completed in March 1985, resulting in a collective occupational exposure of 13.17 person-rem. This exposure agrees with industry experience of about 25 person-rem for reracking two units. (Affidavit of Joseph L. Danek on Contention 7 (January 21, 1986) (Danek Affidavit), 11 2, 32; Affidavit of Rebecca K. Carr on Contention No. 7 (January 22, 1986) (Carr Affidavit on Contention 7), 1 24.
2. The storage capacity of the Turkey Point spent fuel pools will be expanded by a process called reracking. The reracking operation consists of several phases, including removal of the old spent fuel storage racks, installation of new racks

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with a higher density array, transfer of spent fuel assemblies from the old racks to the new racks, and support services.

(Danek Affidavit, 1 2; Carr Affidavit on Contention 7, 1 6).

3. Due to space limitations, it is not possible to install all of the new Turkey Point spent fuel storage racks at one time. Consequently, the reracking operation is cyclical in nature, involving installation of several new racks, shuffling of fuel from several old racks to the new racks, removal of the old racks, and installation of new racks in the space vacated by the removal of the old racks. (Carr Affidavit on Contention 7, 1 6).
4. To promote the safe and efficient handling of the spent fuel racks, the water level in the spent fuel pools will be

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lowered approximately 8 feet during the rack handling operations

but will be restored to normal levels during fuel handling operations. Once the water level has been lowered, a work platform will be installed in spent fuel pool as a base for rack handling activities. Underwater work will be performed using long-handled tools, and therefore it is not anticipated that the use of divers will be necessary during reracking operations.

(14., 1 7).

5. During those periods when the water level is lowered, the system for cleanup of radioactive contaminants in However, at other the spent fuel pool water will not be in use.

times prior to and during the reracking operation, the system will be dedicated to cleanup of the spent fuel pool water and will operate for sufficient time to ensure that any further reduction in the radioactivity in the pool water would be minimal. (Id., 1 8; Danek Affidavit, 1 14).

6. Two analyses were performed by the Licensee to estimate the total occupational exposure required for the I reracking. As a result of the first analysis, the Licensee j

estimated that the collective exposure would be about 109 person-rem per unit. In response to a question from the NRC f

Staff, the Licensee performed a second analysis and lowered its estimate to 59 person-rem per unit. (Carr Affidavit on Conten-tion 7, 1 4 and Table 2).

7. In the Licensee's original estimate, the major l

1 contributors to occupational exposure were expected to be the radioactivity in spent fuel pool water and the radioactivity on i

the exposed walls of the spent fuel pool. In the original estimate, no credit was taken for operation of the spent fuel pool cleanup system, and conservative estimates were made of the dose rates expected from crud deposition on the exposed walls of the spent fuel pool. (14., 11 9-11).

8. The Licensee's original time estimate contained conservative time estimates to complete tasks. (Id., 1 13).
9. In the Licensee's revised estimate, the dose rates in and around the spent fuel pool were conservatively reduced to account for operation of the spent fuel pool cleanup system; the time estimates for certain tasks were reduced after the proce-dures for the reracking were finalized and greater details regarding the tasks known; and the dose rates for some activities were lowered following a determination that the activities would be performed in a different area with lower dose rates than originally assumed. (Id., 11 15-20).
10. The Licensee's original and revised estimates were conservative and overpredicted the actual exposure incurred during the reracking of T'urkey Point Unit 3. The primary reasons for overpredicting the actual exposure were underpredicting the ability of the cleanup system; overpredicting the difficulty associated with removing and installing the racks; under-estimating the degree to which the spent fuel pool walls could be decontaminated; and overpredicting the amount of crud that would be on the old racks. (Id., 1 22-24).
11. The Licensee implemented standard health physics techniques to maintain personnel exposures as low as is reason-ably achievable (ALARA) during the reracking of Unit 3. Similar techniques will be utilized during the reracking of Unit 4.

(Danek Affidavit, 11 4-5).

12. The Licensee maintained occupational exposures ALARA during the reracking of Turkey Point Unit 3 by preplanning activities and training workers. This consisted of several measures, including meetings of all groups involved in the reracking to discuss radiological protection, minimizing the number of workers and activities needed for reracking, training of workers in FPL's radiation protection program, control of work through use of radiation work permits, establishing written procedures to control the reracking activities, and providing on-the-job coverage by health physics technicians. (14., 11 6-12).
13. The Licensee maintained occupational exposures ALARA during the reracking of Turkey Point Unit 3 by reducing levels of radioactivity in work areas. This was accomplished by operation of the spent fuel pool cleanup system, cleaning radioactive crud off the exposed walls of the spent fuel pool, removal of radioactive crud from the old storage racks prior to transfer from the spent fuel pool, and use of measures to prevent the spread of radioactive contamination. (Id., 1 13-17).
14. The Licensee maintained occupational exposures ALARA during the reracking of Unit 3 by reducing the amount of time spent by workers in radiation areas. This was accomplished by the use of procedures, training of workers, and practicing with remote tooling prior to the rerack. (14., 11 18-20).
15. The Licensee maintained exposures ALARA during the reracking of Turkey Point Unit 3 by increasing the distance between workers and sources of radiation. This was accomplished by use of remote tools, assembling work equipment in low radia-tion areas when practical, and controlling access to radiation areas. (Id., 11 21-24).
16. The Licensee maintained exposures ALARA during the reracking of Turkey Point Unit 3 by using shielding and protec-tive clothing. This consisted of maintaining approximately fifteen feet of water in the spent fuel pool to shield workers from the spent fuel, use of protective clothing, and use of respirators when the potential for airborne radioactivity existed. (Id., 11 25-27).
17. The Licensee maintained exposures ALARA during the

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This reracking of Turkey Point Unit 3 by radiation monitoring.

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consisted of use of personnel monitoring equipment, permanent area radiation monitoring, permanent airborne radioactivity detectors, and periodic airborne and area radiation monitoring.

! (Id., 11 28-30).

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18. The radiation protection measures used during the Turkey Point reracking are similar to those implemented during the reracking of other plants (except for use of divers) and the previous reracking of Turkey Point, and there are no additional measures which are reasonable and which could have reduced the occupational exposures appreciably during the reracking of Turkey Point Unit 3. (Id., 1 7).
19. During the reracking of Unit 3, the pump back portion of the leakage detection and collection system for the Turkey Point spent fuel pools was not available. Any leakage would have remained in the monitoring trench behind the pool liner and would have contributed a negligible dose to workers involved in the reracking due to the distance between the trench and the workers and the shielding provided by intervening structures and objects. (14., 1 31).

Contention 8

1. The decay of fission products in spent fuel assemblies produces heat., The amount of decay heat generated by spent fuel is a function of burnup and time after shutdown.

Decay heat decreases with time following shutdown. (Patton Affidavit, 1 3).

2. The spent fuel pool serves as a storage location for spent fuel and provides radiation shielding and decay heat removal for the spent fuel. These functions are assured by maintaining an adequate water level in the pool and through operation of the spent fuel pool cooling system. (Id., Y 4).
3. The Turkey Point spent fuel pool cooling system consists of a pump, heat exchanger, filter, demineralizer, piping and associated valves and instrumentation. The system also contains an 100 percent capacity spare pump, and alternate connections are provided for connecting a temporary pump to the spent fuel pool loop. The heat removal rate through the heat exchanger is a function of the temperature of the component cooling water and the spent fuel pool water. (Id., t1 5-6).
4. Makeup water for the Turkey Point spent fuel pool is provided by a makeup system. Makeup water is supplied from the demineralized water system or the refueling water storage tank at a flow rate of up to 100 gpm. Alternate means of makeup include temporary connections from the fire water system or the primary water storage tank. (Id., V 7).
5. The NRC Staff has issaed guidance for spent fuel pool cooling in SRP Section 9.1.3, which states that the tempera-ture of the pool should not exceed 140 F and the liquid level in the pool should be maintained under conditions associated with the maximum normal heat load with normal cooling systems in operation, and that the temperature of the pool should not exceed boiling and the liquid level in the pool should be maintained for l

the abnormal maximum heat load from a full core off-load with normal systems in operation. Additionally, SRP Section 9.1.3 states, among other things, that the spent fuel pool cooling system should be seismic Category I or, in the alternative, the makeup system, the fuel pool building, and the ventilation and filteration system should be seismic Category I. (Id., TV 11-13).

6. The Licensee analyzed two cases to determine whether the Turkey Point spent fuel pool cooling and makeup systems have sufficient capacity to cool the spent fuel and maintain the water level in the pool. The first case postulated the addition of a number of assemblies in excess of a normal core off-load to the number of assemblies stored in the pool from previous refuelings, and the second case postulated the addition of a full core off-load. (14., 11 10, 12).
7. In both cases, the Licensee assumed that the total number of assemblies in the spent fuel pool would slightly exceed the actual capacity of the new storage racks. Additionally, both cases used other conservative assumptions regarding the amount of heat generated and the amount of cooling provided. (Id., 11 9-12).
8. In the first case, the Licensee determined that the temperature of the spent fuel pool would rise to 143 F and that the evaporation rate would be 1.5 gpm, which is well within 0

j the capacity of the makeup system. The 143 F calculated in the first casa exceeds the 140 F guideline in SRP Section 9.1.3.

However, the difference between the Licensee's calculated temperature and the guidance provided in the SRP is slight (only 30 F), the Licensee's temperature was calculated using conservative assumptions, and the temperature of the water was calculated to decrease to 140 F within a relatively short period of time (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />). (Id., 1 11). The NRC Staff found the maximum temperature of 143 F to be acceptable. (Safety Evaluation Related to Amendment No. 111 to Facility Operating Licensee No. DPR-31 and Amendment No. 105 to Facility Operating Licensee No. DPR-41, Turkey Point Unit Nos. 3 and 4 (November 21, 1984) (SE), S 2.7.2). The spent fuel will remain adequately cooled and covered with watir at all times under the conditions postulated in the first case. (Patton Affidavit, 1 11).

9. In the second case, the Licensee determined that the temperature of the spent fuel pool would rise to 183 F, which is below boiling as recommended by SRP Section 9.1.3., and that the evaporation rate vould be 5.5 gpm, which is well within the 100 gpm capacity of the makeup system. Thus, the spent fuel will remain adequately cooled and covered with water at all times under the conditions postulated in the second case. (Id., 1 12).
10. The existing cooling system piping and makeup lines for the Turkey Point spent fuel p&ols are not seismic Category I and have not been designed to remain functional after a safe shutdown earthquake. In response to the NRC Staff's review of FPL's application for the spent fuel pool expansion,

FPL has committed to upgrade the spent fuel cooling loop such that it will remain functional after a safe shutdown earthquake.

(14., 11 8, 15).

11. The seismic upgrade of the Turkey Point spent fuel cooling system will be completed by the end of the'second refueling outage after issuance of the Turkey Point spent fuel pool expansion amendments. Until the seismic upgrade is com-pleted, the amount of fuel that is scheduled to be stored in the pools will be less than the capacity of the pre-existing storage racks, and the spent fuel pool expansion amendments will not result in an increase in the amount of cooling and makeup necessary for these assemblies. (Id.).
12. Zirconium-water interaction does not occur at temperatures below 10000 F. The temperatures in the Turkey Point spent fuel pools are far below those necessary for a zirconium-water reaction to occur. (Id., 1 16).

Contention 10 1 1. The Turkey, Point spent fuel pool expansion amendments authorize the replacement of the pre-existing spent fuel storage racks with new storage racks. The new storage racks l

can store spent fuel assemblies in a higher density array and are designed to accommodate the more highly enriched fuel which is now authorized for use at Turkey Point. (Boyd Affidavit, 1 10).

l l

2. As a result of the Turkey Point spent fuel pool expansion amendments, the spent fuel pools ars divided into two regions. Each region consists of new storage racks which have a different high density fuel storage configuration and a different amount of neutron absorber than the racks in the other region.

(Id., t 11).

3. The Region 1 fuel racks have been designed to permit storage of unirradiated fuel assemblies with an enrichment of 4.5% of Uranium-235. The Region 2 fuel racks have been designed to permit storage of irradiated fuel assemblies with a reactivity equivalent to a fuel assembly with a zero burnup enrichment of 1.5%. During the interim period of installation of the new racks, the Region 2 fuel racks have also been designed to permit storage of fuel assemblies in a checkerboard arrangement with a zero burnup enrichment of 4.5%. (Id., 11 12-13).
4. Guidance for preventing criticality in spent fuel pools has been provided by the NRC Staff in SRP Section 9.1.1 and the NRC Position Paper. This guidance states that the effective neutron multiplication factor in spent fuel pools should be maintained at a value less than or equal to 0.95, including all uncertainties, under both normal and accident conditions. (Id.,

1 16).

l i

5. The design basis k-effective limit for the Turkey Point spent fuel pools is 0.95 at a 95%/95%

probability / confidence level. This limit conforms with the guidance provided by the NRC Staff in SRP Section 9.1.2 and the NRC Position Paper. (14., 1 17).

6. Prior to issuance of the Turkey Point spent fuel pool expansion amendments, the design basis k-effective limit for the Turkey Point spent fuel pools was 0.95 at a 95%/95%

probability / confidence level. The amendments did not modify or increase this limit. Therefore, the amendments will not increase the probability of a criticality accident. (14., 1 17).

i

7. In general, the design of the Turkey Point spent fuel racks assures that the design basis k-effective limit will not be exceeded. The new racks permit storage of more highly enriched fuel assemblies in a higher density array than the pre-existing racks. To counterbalance the reactivity effects of these changes, the new storage racks include a neutron absorber called Boraflex. (14., 11 14 and 18).
8. The Licensee performed criticality calculations for the new Turkey Point spent fuel storage racks with a computer program called KENO-IV. KENO-IV is widely used in the nuclear industry for the purpose of calculating the criticality of fuel I racks, and it has been verified by comparison with criticality experiment data for fuel assemblies similar to those for which the Turkey Point spent fuel storage racks were designed. (Id.,

11 19-20; SE, $$ 2.1.1 and 2.1.4).

29 -

9. The Licensee calculated the isotopic compositions of the fuel assemblies to be stored in the Turkey Point spent fuel pools with a computer code called PHOENIX. The accuracy of the PHOENIX code has been demonstrated by comparison with l

measurements made for fuel samples taken from the core of the

< Yankee reactor. (Boyd Affidavit, 11 19, 21; SE, SS 2.1.1, 2.1.2 and 2.1.4).

10. The Licensee calculated the decay of fission products and their neutron capture effects during storage of fuel assemblies in the Turkey Point spent fuel pool with a computer code called CINDER. CINDER has been widely used in the nuclear industry for over 20 years, has been well benchmarked by many sources, and is accepted by the NRC. (Boyd Affidavit, 11 19, 22).
11. The Licensee's criticality calculations for the new Turkey Point spent fuel storage racks used conservative assumptions. These assumptions included assuming that the array of fuel assemblies is infinite in lateral and axial extent; assuming lower concentrations of certain neutron absorbing fission products than actually present in the spent fuel; neglecting neutron capture by the fuel assembly spacer grids and sleeves; neglecting neutron capture by the boron in the spent fuel pool water; and assuming a spent fuel pool water density and temperature which maximizes the amount of moderation provided by the water. The criticality calculations for the Region 1 racks and the Region 2 racks with 4.5% enriched fuel assemblies in a

I checkerboard arrangement contained additional conservative assumptions, including assuming all fuel rods contain 4.5% ,

enriched Uranium, neglecting burnable poison in the fuel rods, neglecting neutron absorbing Uranium-234 and Uranium-236, and neglecting fission-product poisons. (Id., TV 22-23, 25, 27).

12. The Licensee's criticality calculations for the new Turkey Point spent fuel storage racks accounted for biases and uncertainties either by assuming worst case conditions (e.a.,

assuming fuel assemblies are centered and assuming minimum width 1

and thickness of poison materials) or by increasing the nominally calculated value of k-effective by the amount of the reactivity effects of the biases and uncertainties (including biases and uncertainties in the analytical methods and the material and mechanical construction tolerances of the sheet metal cell walls, i

cell center-to-center spacing cell bowing, and Boraflex neutron absorbing properties). The criticality calculations for the Region 2 racks with irradiated fuel assemblies having an equivalent zero burnup enrichment of 1.5% also accounted for the biases and uncertainties' associated with plutonium reactivity and (Id.,

other reactivities that are a function of irradiation.

11 20-21, 25, 29).

13. The results of the Licensee's criticality calcula-f tions for the new Turkey Point spent fuel storage racks were a k-effective of 0.9403 (including all uncertainties) for the Region 1 racks; 0.9304 (including all uncertainties) for the i

P.agion 2 racks with fuel assemblies with an equivalent zero

O burnup enrichment of 1.5%; and 0.8842 for Region 2 racks with 4.5% enriched fuel assemblies in a checkerboard arrangement (this latter value did not include biases and uncertainties, since assuming conservative values for these terms would still result in a k-effective well-below 0.95 at a 95%/95% probability /

confidence level). These values conform with the design basis k-effective limit.

14. The NRC Staff has adopted the double contingency principle of ANSI (American National Standards Institute) N16.1-1975 which, in effect, states that it is not necessary to consider two unlikely, independent, and concurrent changes in conditions in performing criticality analyses. The Licensee's criticality calculations for the new Turkey Point spent fuel storage racks were performed in accordance with the double contingency principle. (Id., 1 33).
15. The Licensee's criticality calculations were performed assuming the absence of boron in the Turkey Point spent fuel pool water, which is an accident condition. The presence of borated water is equivalent to a negative reactivity chan~ge of about 0.30 in k-effective. (ld., 1 34).
16. Under the double contingency principle, it is unnecessary to postulate an accident involving both the absence of borated water and another independent change in conditions in the spent fuel potl. The negative reactivity of the borated water in the Turkey Point spent fuel pools would more than offset an increase in reactivity resulting from other accidents,

1 l

0 including the absence of Boraflex poison plates in the storage racks and changes in the mechanical or geometric configuration of the storage racks or fuel assemblies caused by an inadvertent drop of an assembly, a cask drop accident, an earthquake, and other types of credible accidents. Consequently, these accidents would not cause the calculated k-effective to exceed the design basis limits. (Id., TV 35-40).

Respectfully submitted,

) /) /*

/h & kV 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 (305) 577-2800 (202) 955-6600 January 23, 1986

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