ML20140D567
| ML20140D567 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/19/1986 |
| From: | Lorion J CENTER FOR NUCLEAR RESPONSIBILITY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#186-523, RTR-REGGD-01.025, RTR-REGGD-1.025 OLA-2, NUDOCS 8603260358 | |
| Download: ML20140D567 (10) | |
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NUCLEAR REGULATORY COMMISSIOt 7 o '
BEFORE THE ATOMIC SAFETY AND LICENSI G BOARD' N
N In the Matter of
)
Docket Nos.' 50-250-OLA-2
)
50-251-OLA-2 FLORIDA POWER AND LIGHT COMPANY (Spent Fuel Pool Expansion)
(Turkey Point Plant, Units 3 and 4) )
INTEFVENORS' STATEMENT OF MATERIAL PACIS AS TO WHICH THERE IS A GENUINE ISSUE TO BE HEARD WITH RESPECT TO INTERVENORS' CONTENTIONS A.
CONTENTION 3:
- 1. Intervenors main concern in this contention is the fact that the Licensee did not use the 1.65 value recommended in Regulatory Guide 1.25 for analyzing a spent fuel handling accident.
Response
at 1.
- 2. Regulatory Guide 1.25, Section C 1. e.
states that the minimum o
acceptable peaking factor for a PWR such as Turkey Point is 1.65.
Intervenors continue to contend that the use of a 1.0 radial peaking factor is improper and nonconservative; and that radiation releases in an accident could exceed the 10 C.F.R. Part 100 criterion.
Response at 3.
B.
CONTENTION 4:
- 1. Contention 4 contends that the offsite dose limits and onsite dose limits to personnel that would result from a spent fuel boiling event will not meet the 10 C.F.R. Part 100 criterion.
Response at 1.
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( 2 )
Intervenors 'ontend that the use of Reg. Guide 1.25 to 2.
c evaluate offsite doses in a-spent fuel pool boiling event is_not appropriate because this guide is generally used for evaluating dose releases of damaged fuel assemblies with burn-up less than 38,000 mwd /MTU.
Intervenors contend this guide should not be used for. the ' Turkey Point fuel which has a burn-up of 50,000 Mwd /-
MTU. -Response at.2..
3.
The Licensee has not been responsive to the NRC Staff request on whether the onsite personnel exposure limits caused by a spent fuel pool boiling event will meet the 10 C.F.R Part 100 criterion.
Response at 3.
4.
Neither the affidavit of Rebecca Carr, witness for the Licensee, nor that of Robert Wohl address onsite dose to personnel in the event of spent fuel pool boiling.
Response at 4.
- 5. 'The'NRC Staff Response to Licensee's Motions for Summary Disposition states that, " The Licensee has not addressed this issue, nor is the Staff prepared to demonstrate on its motion that summary disposition of this portion (on worker personnel) of contention 4 is appropriate.
Summary disposition should be denied with respect to this aspect of contention 4."
Response at 5.
6.
Intervenors contend the Licensee has not met their burden of proof in two areas.
The first having-to do with the appropriate-ness of using Reg. Guide 1.25 to analyze offsite doses and the second which concerns the lack of data available to prove that onsite doses to workers during the rerack will meet 10 C.F.R.
Part_100 Criterion.
Response at 6.
s
( 3 )
w C.
CONTENTION-5 1.
Contention 5 is concerned with the fact that Westinghouse had informed FPL that loading the outer rows of the new spent fuel racks, which overhang the support pads, could cause rack lift-off in a seismic event.
Response at 1.
2.
The present basis for spent fuel expansion with-these racks is that administrative controls are required to prevent the loading of fuel assemblies into overhanging locations first.
Response
at 2'.
3.
Intervenors do not agree that the Staff should allow FPL to use these new spent fuel racks without a 50.59 review.
Intervenors do not agree with Staff that the design of the rack satisfies the structural aspect of Appendix A requirements of 10 C.F.R. Part 50 (GDC, 2, 4, 61, and 62), because the racks do not meet these criteria if administrative controls are not in place.
Response
at 3.
- 4. Commission regulations require that potential loads from a seismic event will not result in failure to the racks or pool structures.
Intervenors do not believe that the Licensee has sufficient data without a 50.59 review to state with certainty that the operation of the spent fuel pool with the new racks will not increase the probability and consequences of an accident.
Response at 4.
5.
Intervenors contend that the Licensee's motion for summary disposition must fail because the new fuel racks do not meet design requirements and because a seismic load could cause a rack lift-off which could cause a criticality accident by
6
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upsetting the geometrically safe configurations of the pool storage system.
spent fuel Response at 5.
D.
CONTENTION 6_
- l. Contention 6 is concerned with the effect that long term storage of spent fuel will have on the materials integ i r ty of the spent fuel pool and its contents.
Response at 1.
2.
Intervenors point out that the world's oldest Zircaloy clad fuel in storage is approaching 19 years and the olde t s
stainless steel clad fuel about 12 years.
They discuss an article on fuel storage which notes that past experience with f spent uel storage is based on fuel with a burn-up that did not exceed 39,000 mwd /MTU.
Response at 2.
3.
Neither the NRC or Licensee has analyzed the effect that long term storage of spent fuel with increased burn the structural integrity of
-up will have on the spent fuel pool.
At Turkey Point we are dealing with more highly enriched fuel with a much higher burn-up than has been previously experienced in lo ng term storage.
Response at 3.
4.
Intervenors contend that assertions thatthe spent fuel can be safely stored with no materials degradation for the 40 year life of the plant should not only be based on past experience with spent fuel pools, but that studies should be performed to calculate the effect that storing spent fuel with increa sed burn-up and the resultant higher temperatures will have on the spent fuel pool and its contents.
Response at 4.
( 5 )
5.
Intervenors continue to insist that increased heat and radiation caused by the higher density design of the fuel racks, and the storage of spent fuel with higher burn-up will cause a loss of materials integrity to the spent fuel pool and its contents.
Response at 5.
E. CONTENTION 7:
1.
This contention is concerned that the dose received by workers in the r'eracking of the spent fuel pool will not be ALARA.
Intervenors base their contention on the fact that the Licensee's estimated dose of 59 person / rem for the repair is higher than experience at other plants.
Response at 1.
2.
Intervenors are aware that FPL has stated that they have completed the rerack of Unit 3 with 13.2 person / rem cumulative dose.
Intervenors are not prepared to accept this assertion based on the limited data offered to support this contention.
Intervenors will continue to base their response on the 59 person rem estimated value. Response at 4.
3.
Intervenors state that the fact that the leakage detection system and clean-up system will not be operational during rerack, and because they were relied upon in the Licensee's ALARA estimates indicates that the dose received by the workers will not be ALARA.
Response at 5.
4.
Intervenors inform the Board that FPL's performance in the areas of radiological controls and spent fuel pool performance have been declining and point to reports that should be cause for worker concern.
Response 5,6, and 7.
( 6 )
5.
Intervenors contend that because Licensee's dose estimate is based on equipment that will not be operational during rerack and because the estimate of 59 person / rem is greater than that at other plants, Licensee should not be allowed to rerack Unit 4 until they have proven that the dose to workers will be ALARA and meet 10 C.F.R. Part 20 criterion.
Response at 8.
E. CONTENTION 8
- 1. This contention is concerned that the increased spent fuel storage density causes a reduction in the margin of safety from a thermal hydraulic and spent fuel pool cooling system safety concern.
Response at 1.
2.
The Licensee's calculated maximum'. bulk pool temperature of 143* for the increased storage does not meet the requirements of SRP, Section 9.1.3, which states that the spent fuel pool temperature should be limited to 140* F.
Response at 2.
- 3. The increased heat in the spent fuel storage system is amplified by the reduction in time that it takes for the spent fuel to reach boiling in a loss of cooling accident.
The time for boiling has been reduced to 7.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for a normal load and to 1.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for a full core offload.
Response at 5.
4.
The reduction in safety margin for the b' oiling point is especially significant in light of the fact that the spent fuel pool cooling system does not meet the requirements of SRP, Section 9.1.3, Par I.1 and III.
1.
b or General Design Criteria 2 of 10 C.F.R. Part 50, because the cooling system is not designed to provide adequate cooling in a seismic event.
Response at 6.
4
( 7 )
5.
Although FPL has committed to upgrade the spent fuel cooling system, Intervenors do not agree with the Staff's decision to issue the amendments before the upgrade because as it now stands this equipment is'not earthquake proof as it should be.
Response at 7.
Intervenors continue to contend'that neither the Licensee nor Staff have proven that make-up water will be supplied in a timely fashion in a loss of cooling accident.
This creates the possibility that a zirconium water reaction and possible fire or explosion could be caused by a delay in cooling the pool.
Response at 8.
7.
The Licensee has not met its burden of proof on contention 8 because they have not demonstrated that increased storage density and storage of more highly enriched spent fuel with a higher burn-up will not increase both the possibility and consequences of a spent fuel pool loss of cooling accident.
Response at 9.
G.
CONTENTION 10:
- 1. This contention is concerned that the increase in fuel density of the spent fuel pool, combined with storage of fuel with a higher enrichment and burn-up will increase both the possibility and consequences of a criticality accident.
2.
U 235 loading of 52.40 grams per axial centimeter is the maximum loading which can assure a Keff of no greater than 0.95 including uncertainties. Staff Safety Evaluation, Sept.
5,
- 1984, at page 2.
p
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( 8 )
_s 3.
.In order to allow fuel with a maximum uranium 235 enrichment of'4.5 weight percent to be stored.in the spent fuel pool racks, the pool was divided into two separate regions.
4.
The Licensee's consideration of the required calculational uncertainties, conservative assumptions, and worst case design basis accidents resulted.in a predicted keff of 0.9403 for Region I.and a k of 0.9304 for' Region II.
Kopp affidavit at 5.
eff 5.
GDC 62, " Prevention of criticality in fuel storage and handling", states that criticality in fuel storage and handling systems shall be prevented by physical systems or processes.
The NRC acceptance criterion for assuring that GDC 62 is met is found in the Standard Review Plan, SRP, Section 9.1.2, which requires maintaining a storage array' neutron' multiplication factor (keff) less than 0.95 in spent fuel pools during normal and accident conditions.
Kopp affidavit at 2.
- 6. Intervenors contend that the storage of the more highly enriched spent fuel and the increased censity, which increases the keff should not be allowed because it reduces a critical safety margin to within a fraction of the allowable limit.
It is interesting to note that before 1976, the acceptable keff for the 95/95 standard was 0.90.
Because the 95/95 standard is less conservative, prudence would dictate that one leave a significant margin of safety between the calculated kefg-limit and the standard.
7.
It is clear from the Licensee's newly calculated values for k,ff that there adherence to the standard is no longer conservative and that the safety margins for spent fuel storage
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( 9 )
have been significantly reduced. and that the possibility of a criticality accident occurring in the spent fuel pool becomes
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j more likely, i
i 8.
Also, because the use of more highly enriched uranium i
fuel rods with a greater burn-up creates more fission products poisons (Boyd affidavit at 5), it follows that the storage of this i
fuel not only increases the possibility of a criticality accident; i
it would increase the radiological consequences of such an accident.
L CONCLUSION:
Intervenors have proven in their response to
~
j.
Licensee's Motion for Summary Disposition of their contentions that~there remain genuine issues of material fact on each of the seven contentions.
Therefore, because Licensee has not met its burden of proof on these contentions, their motion j
for summary disposition must fail.
l Respectfully submitted,
& i f C W ~
Joette Lorion i
Director, Center for Nuclear Responsibility 7210 Red Rd. #208 I
Miami, F1. 33143 I
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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~
In the Matter of
)
Docket Nos. 50-250-OLA-2
)
50-251-OLA-2 FLORIDA POWER AND LIGHT COMPANY
)
)
(Spent Fuel Pool Expansion)
Turkey Point Plant, Units 3 and 4
)
CERTIFICATE OF SERVICE I hereby certify that copies of "Intervenors' Response to Licensee's Motions for Summary Disposition of Intervenors' Contentions 3,4,5,6,7,8, and 10,"
and "Intervenors's Statement of Material Facts As to Which There is a Genuine Issue to Be Heard With Respect to Intervenors' Contentions 3,4,5,6,7,8,and'10", and Affidavit'of Joette Lorion, have been served on the following parties by deposit in the United States Mail, first class, postage prepaid, on the date shown below:
~
Dr. Robert M. Lazo, Chairman Norman A.
Coll, Esquire Atomic Safety and Licensing Board Steel, Hector & Davis U.S. Nuclear Regulatory Commission 4000 S.E.
Financial Center Washington, D.C.
20555 Miami, F1. 33131-2398 Dr. Emmeth A. Luebke
_ Michael A.
Bauser, Esquire Atomic Safety and Licensing Board Newman & Holtzinger, P.C.
.U.S.
Nuclear Regulatory Commission 1615 L. Street NW
= Washington, D.C.
20555 Washington, D.C.
20036 Dr. Richard F. Cole Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission
[ME
. ' M
Washington, D.C.
20555 Mitzi A.
Young, Esquire Joette Lorion, Director Office of Executive Legal Director Center for Nuclear Responsibilit y U.S. Nuclear Regulatory Commission 7210 Red Road #208 Washington, D.C.
20555 Miami, Fl. 33143 Docketing and Service U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Dated: March ~19, 1986