ML20140D753

Statement of Matl Facts as to Which There Is Genuine Issue to Be Heard Re Contention 3.Operation of Spent Fuel Pool W/Higher Keff Could Cause Criticality Accident.W/Certificate of Svc

ML20140D753
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-#186-524 OLA-3, NUDOCS 8603260477
Download: ML20140D753 (3)

Text

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4 March 19, 1986 00LMETED

'JSMC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENS[Nk Mhkk$ N200 0FFtk J-00CKlint.. a , ,

In the Matter of ) Docket-~Nos.A Sd-250-OLA-3 I 50-251-OLA-3

)

FLORIDA POWER AND LIGHT COMPANY

) (Increased Fuel Enrichment)

(Turkey Point Plant, Units 3'and 4) )

INTERVENORS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE-IS A GENUINE ISSUE TO BE HEARD WITH RESPECT TO INTERVENORS' CONTENTION 3

1. This contention is concerned with the possibility that the operation of the spent fuel pool with a higher k gg g caused by the storage of more highlin enriched fuel with a higher

. burn-up will cause a criticality accident in the spent fuel pool.

2. The spent fuel pool mu'st meet the Criterion outlined in the Standard Review Plan, which is the 95/95 standard.

3. A U235 loading of 52.40 grams per axial centimeter is the maximum which can assure aek gg of less than 0.95. Thus, FPL has reached the limit.

3. The calculated kegg of 0.9403 for Region I and 0.9304 for Region II are'not conserve tive and erode the safety margin for the k egg.

4. Intervenors contend that the higher keff increases the probability that a criticality accident will occur.

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Respectfully submitted, 2 k C ~h gN Joette Lorion Director, Center for Nuclear Responsibility

f- .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION COLyr-[;

. 99-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket hoNdE dd-fidEWLA-3

) 50-251-OLA-3' FLORIDA POWER & LIGHT COMPANY ) 0 Fell: .-

) (IncrhE5b]j{NW uel Enrichment)

Turkey Point Plants, Units 3 and 4 )

CERTIFICATE OF SERVICE I hereby certify that copies of "Intervenors' Response to Licensee's Motion for Summary Disposition of Intervenors' Contention 3",'and "Intervenors' Statement of Material Facts As To Which There is a Genuine Issue To Be Heard With Respect to Intervenors' Contention 3", 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 SE Financial Center Washington, D.C. 20555 Miami, Fl. 33131-2398 Dr. Emmeth A. Luebke Michael A. Bauser, Esquire Atomic Safety and Licensing Board Newman and Holtzinger, PC U.S. Nuclear Regulatory Commission 1615 L. Street NW Washington, D.C. 20555 Washington, D.C. 20036 Dr. Richard F. Cole q '*

Atomic Safety and Licensing Board N CDJdl U.S. Nuclear Regulatory Commission Joette Lorion, Director Washington, D.C. 20555 Center for Nuclear Responsibility Mitzi A. Young, Esquire 7210 Red Rd. #208 Office of Executive Legal Director Miami, Fl. 33143 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dated: March 19, 1986

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