ML20151A579

NRC Staff Reply to Appeal Board Order of 880627.* Imposition of License Conditions Not Necessary in Matter.Certificate of Svc Encl

ML20151A579
Person / Time
Site:	Turkey Point
Issue date:	07/14/1988
From:	Vogler B NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#388-6740 OLA-2, NUDOCS 8807200050
Download: ML20151A579 (28)

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5 00CKETED y U5HFC July 14, 1988 UNITED STATES OF AMERICA '88 JL 18 P3 :30 NUCLEAR REGULATORY COMMISSION CFFICE i,! 3EcM MM 00CKEIWi A SU VH1 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD BDHM r

In the Matter of )

Docket Nos. 50-250 OLA-2 FLORIDA POWER AND LIGHT COMPANY l 50-251 OLA-2

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(Turkey Point Plant, Units 3 & 4) ) (SFP Expansion)

STAFF REPLY TO APPEAL BOARD ORDER OF JUNE 27, 1988 In an order dated June 27, 1988, the Appeal Board requested the views of the parties on whether the Licensing Board, under the circumstances of this case, should have imposed license conditions embracing the Licensee's written commitment:; to undertake surveillance testing programs regarding the use of Boraflex in the spent fuel pools and the Licensee's agreement not to store any fuel with an enrichment of U-235 greater than 4.1-percent prior to completion of the next surveillance testing, now scheduled for December 1989. The Staff concludes that the imposition of such license conditions is not necessary.

Addressing the question whether administrative controls should be imposed by means of either a license condition or a technical specifica-tion requirement the Staff advised the Licensing Board, (See, Staff's Proposed Findings of Fact at 4-5, December 24,1987) that the guidance of the Appeal Board in Portland General Electric Co. (Trojan Nuclear Plant),

ALAB-531, 9 NRC 263, 272 (1979) should be followed. There, the Appeal -

Board stated:

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There is neither a statutory nor regulatory require-ment that every operational detail set forth in an applicant's safety analysis report (or the equivalent) be subject to a technical specification, to be includ-ed in the license as an absolute condition of opera-tion which is legally binding upon the licensee when and until changed with specific Connission approval.

Rather, ... the contemplation of both the Act and the regulations is that technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor opera-tion is deemed necessary to obviate the possibility of an abnormal situation or event givina rise to an imme-diate threat to the public health and safeg .

9NRCat273(footnoteomitted,emphasisadded).1/

The Appeal Board pointed out in Trojan that "[t]his is net co say...

that no significance attaches to commitaents in a licenser's safety analy-sis report which have been found not to possess safety implications of sufficient gravity and immediacy to warrant their translation into techni-cal specifications. To the contrary, 10 CFR 50.59(b) specifically charges holders of operating licenses with the duty..." to maintain records of changes in the facility or in procedures described in the FSAR and to report such changes at intervals not to exceed once a year along with a summary of the safety evaluation of such changes. Id.

In the Zion case, the Appeal Board agreed with the Licensing Board that "the effects of corrosion and the objects of the testing and surveil-lance programs in question are not of the gravity and immediacy alluded to i in Trojan that calls for translation from commitments to technical speci-

-1/ See 10 C.F.R. S 50.36; Sacramento Municipal Utility District (Rancho Teco Nuclear Generating Station), ALAB-746,18 NRC 749, 754 n.4 (1983); Commonwealth Edison Co. (Zion Station, Units 1 and 2),

ALAB-616,12 NRC 419, 422 (1980); Virginia Electric Power Co. (North Anna Nuclear Power Station, Units 1 and 2), ALAB-578, 11 NRC 189, 217 (1980).

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fications." Id. at 423. Nonetheless, the Appeal Board incorporated the licensee's comitments relating to testing and surveillance into the Ap-peal Board's order in the proceeding. I_d. at 424. The Appeal Board, however, noted We do not imply that we have cause to believe that the Applicant would not abide by its commitments... We are confident that without further guidance from us, the staff will be able to record the commitments thus embodied so'its inspectors can in-sure compliance." Id_. at 424, fn.9.

Hearings were held in the captioned proceeding on'the Boraflex con-tention (Contention 6) and one other contention on September 15 and 16, 1987. At the hearing, the Staff and Licensee presented testimony on Con-tention 6 by way of a series of witness panels which were in general agreement as to the lack of merit to Contention 6. The intervenors did not sponsor any direct testimony and based their case on the cross-exami-nation of the Licensee's and Staff's panels.

On the basis of the evidence received at the hearing the Licensing

& rd found:

87. The Board finds that, based on the evidence pre-sented by the Licensee and Staff, no safety signifi-cant degradation in the Turkey Point Boraflex panels at Turkey Point is expected to occur. The Licensee's surveillance programs include blackness testing on Boraflex specimens and panels at specified schedules which are adequate to detect physical degradations, including gaps, and will provice reasonable assurance that gap formation will be detected in sufficient time to enable Licensee to take corrective actions such

! that the NRC acc'ptance criterion of k less than or equal to 0.95 is met. LicenseeandSt!ffhaveade-quately analyzed the materials integrity of Boraflex, and the material continues to be acceptable for use in safe storage of the spent fuel at the Turkey Point Nuclear Generating Plant.

27 NRC 387 at 414.

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i The Licensee in a series of letters to the NRC Staff committed to the I surveillance. testing arrangements described in the initial decision. In letters designated L-82-279, 313, 348 and 363 and attached hereto, the Licensee agreed to blackness testing of full length Boraflex panels and surveillance testing of Boraflex specimens. The letters describe the schedule for the testing and the measurements to be taken. The measure-ments include the utiif:c ity of boron distribution, neutron attenuation and spatial boron distribution anomalies and gaps. These tests are now scheduled for December 1989 and are typical of the many surveillance tests that ar. routinely performed by Licensees in the normal operation of their plante. In addition, the regional inspection staff is aware of the com-mitments. As a general rule the Staff does not require special license conditions for such testing.

In letter L-87-363 the Licensee agreed not to store fuel with an enrichment greater than 4.1 percent prior to the completion of the black-ness testing of the Boraflex panels and the surveillance of the Beraflex specimens. As noted earlier, this testing is now scheduled for December 1989. Because of the long lead time and high visibility associated with procuring new higher enriched fuel the Staff is confident that the Boraflex in the spent fuel pool will be adequately tested and examined prior to any enrichment increases in the fuel. In short, the matters

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involved in the licensee's commitments in this case are ndt of the gravity and immediacy referred to in Trojan or Zion 2/

.In view of the foregoing, including the findings of the Licensing Board, the Staff does not believe that the imposition of license j conditions is necessary in this matter. l l

f Respectfully submitted '

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amin H. Vogler Senior Supervisory Trial )

Attorney Dated at Rockville, Maryland this 14th day of July,1988 s

-2/ In Zion, the Appeal Board referred to a then pending Advanced Notice of RuTimahing relating to requirements for technical specifications and concluded that the rulenaking proposal did not suggest treatment dif/erent from the Trojan standard. Id. at 423. The current interim Policy Statement on technical specificitions, 52 FR 3788, contains further guidance in the form of three criteria for determining which matters (existing LCOs) should be included in upgraded technical specifications. In general, these criteria do not appear to be at odds with the Appeal Board's Trojan stardard. More directly related to the Turkey Point proceeding, the commitments at issue would not qualify to be included in technical specifications under the three criteria of the interim Policy Statement.

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• - P. o Box 1d0o0. JUNO BE ACd F. 2NOS-N2' JULY 1 0 1987 L-87-279 U. S. Nuclear Regulatory Commission . 1 Attn Document Control Desk -

Washing.%n, D. C. 20555 Gentlemen:

Re: Turkey Point Units 3 and 4 Docket No. 50-250 and 50-251 Request for Additional Information Boroflex Usage of Turkey Point Attached is Florida Power & Ligh' Company's response to your June 9, J987 request for additional information concerning the continued use of Boroflex of Turkey Point.

Should there be further questions, please contact us.

Very truly yours,

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C. O. Wo d Group Vice President Nuclear Energy COW /RC/gp Attachment ec: Dr. J. N . son Grace, Regional Administrator, Region ll, USNRC Senior hesident inspector, USNRC, Turkey Point Plant e707200004 870710 0 DR ADOCK 0500

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..,. .- - Request for Additional Infonnation -

Boraflex Usage at Turkey Point ,

,. Question 1 Based on the recent experience pertaining to degradation of Boraflex in spent fuel pools at Quad Cities I

and Point Beach Nuclear Power Plants, provide justification to demonstrate the continued acceptability of Boraflex for application in the. Turkey Point spent fuel pool.

Response Boraflex is the, neutron e.bsorbing poison used

's in the Turkey Point spent fuel racks. This material assures a shutdown margin of 5% with no boron in the spent fuel pool water.

As discussed in Section 4.7.2 of the Turkey Point Units 3 and 4 Spcnt Fuel Storage Modification, Safety Analysis Report, dated March 14, 1984, Boraflex has undergone extensive qualification testing to study the effects of gamma and neutron irradiation in various environments and to verify its structural integrity and stability as a neutron absorbing material. These tests indicated that Boraflex maintains its neutron attentuation capabilities when subjected to an environment of borated water 11

• and 1.03 x 10 rads gamma radiation. Additionally, further tests have recently been conducted and preliminary results indicate that some shrinkage (a maximum of about 2%) can occur in Boraflex,

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and that this shrinkage is complete at approximately 10 1 x 10 rads gamma.

Three plants have reported the results of their first Boraflex surveillance. Of these three, the Boraflex material used at Point Beach Nuclear Pover Plant has received the highest accumulated dose. This Boraflex material has been la use for a total of five years, and some of the Boraflex panels have received a 20 year-equivalent radiation dose due to tie spent fuel management techniques used at Point Beach. The examination of the 2" x 2" sample coupons at Point Beach (which had a maximum exposure of 1.6 x 10 10 rads gamma) showed that the coupons had experienced changes in physical gi' characteristics such as color, size, hardness, and brittleness. However, the nuclear characteristics of the samples had not experienced ani' unexpected changes, and the boron absorbing properties of the samples met the acceptance criteria for maintaining the 5% f k/k shutdown margin. Point Beach also examined two ful'. size (150" long x 8" wide) Boraflex ,

panels, which had a maximum exposure of about 1 x 10' rads gamma. These panels had a. far lesser amount of physical changes than the 2" x 2" sample coupons. Thus, the examination of tre Point Beach

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coupons and Boraflex panels indicates that, while

. i some physical changes in Boraflex may occur with accelerated radiation exposure, the Soraflex will retain its neutron absorbing characteristics..

Prairie Island has also examined two large (8" x 12") Boraflex coupons. One of the coupons (which had a 6 .nonth ex'p osure) had an appearance si,mi-lar^

to the as-manufactured Boraflex. The other coupon (which had a 12 month exposure) had some slight physical changes similar to that experienced by the Borafleu panels at Point Beach.

The Boraflex panels in the Quad Cities racks (which had an exposure of about 10 9 rads gamma) were m

1pa examined by a neutron surveillance technique.

Gaps were noted in the Boraflex panels, and review of the size and number of gaps was performed.

This review indicated that the gaps were attributed to a rack design and fabricatien process which did not allow the Boraflex to shrink without cracking.

The Quad Cities racks were designed to hold smaller BWR fuel and did not utilize a protective wrapper for installing the Boraflex. The fabrication process required the Boraflex material to be glued l and firmly clamped in placs to the stainless steel

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,_. fuel rack walls. This process did not allow for the predicted shrinkage of Boraflex and as such gaps developed. Additionally, the Boraflex panels at Quad Cities were not constructed from a singlo ,

sheet of Boraflex, resulting in pre-existing breaks in the Boraficx panels. Less than half of the Boraflex panels at Quad Cities had gaps. Furthermore, the gaps in the Boraflex panels at Quad Cities. 'N varied in length up to a maximum of 4" and were located at various places along the heighth of the panels. A k-effective analysis of the Quad Cities spent fuel pool demonstrated that these ,

gaps did not cause Quad Cities to exceed its 0.95 limit on k-effective.

Eb gliplI' Turkey Point racks are designed to hold the large PWR fuel assemblies. Boraflex panels were constructed from a single sheet of Boraflex and are held in the stainless steel cell wall by enclosing it with a wrapper plate. During fabrication, a cut-to-length sheet of Boraflex was attached to the wrapper plate with adhesive applied in short lengths (up to 2 1/2" long) at a maximum of 16 places (8 per side) along the length of the Boraflex. The purpose of the adhesive was to provide temporary support during the spot welding process and not for long-term

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, binding. The wrapper provides an enclosure which protects the Boraflex from the flow of water, very much like that used in the original Boraflex qualification testing. Additionally, the wrapper enables the Boraflex panel to remain in place without the necessity of tightly clamping the panel in place.

9g In conclusion, the experience at Point Beach indic5tes that some physical changes may occur in Boraflex, but that the Boraflex will retain its neutron attentua+1cn properties. Additionally, both testing of S;t,3 flex and the experience at Quad Cities indicates that some shrinkage in Boraflex map occur, but that this shrinkage is limited to a maximum of 2 to 3% of the length of the Boraflex.

The Quad Cities Boraflex panels had so3ne gaps because the racks did not permi.t the Boraflex to shrink without cracking. Since there are differences in the manufacturing process of the Boraflex used at Quad Cities and Turkey Point, the experience

! at Quad Cities may not be applicable to Turkey Point. In any case, due to the small size and -

the random orientation of the gaps at Quad Citites, I the gaps did not cause the k-effective of Quad l

Cities spent fuel pool to exceed the 0.95 limit.

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. r 1 Theref ore, FPL considers that the Boraflex is acceptable for continued use at Turkey Point.

Question 2 Based en the recent information, provide any changes to the in-service surveillance program for Boraflex neutron absorbing material and describe the frequency of examination and acceptance criteria for continued use. Provide th,e procedures for testing the BorP(lex material and interpretation of test data.

Response To confirm that the Boraflex at Turkey Point is acceptable for continued use, FPL W131 conduct two types of examinations of the Boraflex. First, as described in the Turkey Point Units 3 and'4 Spent Fuel Storage Facility Modification, Safety Analysis Report, dated !! arch 14, 1984. Section 4.8, Testing and In-service Surveillance, FPL will conduct an in-service surveillance program.

This program will evaluate both Region I and Region II Boraflex samples for the following:

I. Physical Characteristics ,

A. Examine the stainless steel jacket and note whether the material is smooth or exhibits any visible damage.

B. Examine the Boraflex poison sample and note whether tite material is smooth

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.. or exhibits any visible changes (color, pitting or cracking, etc.).

C. Measure specimen (s) weight and volume, and calculate its density.

D. Measure the hardness of the specimen (s).

II. Nuclear Characteristics A. Taxe a neutron radiograph of the specimen (s) to determit,- the uniformity of boron 'L distribution.

B. Perform attenuation measurement of the specimen (s), and determine the B yg loading.

The minimum area density of boron should be equal to or greater than 0.02 gm/cm 2 for Region I and 0.012 gm/cm 2 for Region II.

AS (qU-1 Second, FPL will conduct a surveillance program to detect any spatial distribution anomalies in the Boraflex panels. This program, called "Blackness Testing", will involve the use of a fast neutron source and thermal neutron detectors. The tnermal neutron detectors will be connected to fou chart recorders which will record the presence of thermal neutrons. The number of thermal neutrons will be low if the boron carbide is present in the Boraflex material. If gaps or voids are present, the number of thermal neutrons will increase and I

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be recorded by the chart recorders. This arrangement of instruments would detect gaps or anomalies in the Boraflex panels. The Blackness Testing technique was utilized successfully by Quad cities to determine the existence of gaps in their spent fuel racks. FPL will perform the baseline testing in late July or early August for several storage cells in both Region I and Region II that have ,

received the highest cumulated exposure to date.

FPL will then retest these cells on a regular interval to be determined at a later date. This interval will be based on FPL's results and EPRI and industry data.

TPL's surveillance programs will be sufficient to detect any changes in the neutron attentuation properties of the Boraflex and any changes in the physical distribution of the Boraflex. As I a result, these programs will assure that the Boraflex in the Turkey Point spent fuel racks will be acceptable for continued use.

l Question 3 Describe the corrective actions to be taken if degraded Boraflex specimens or absorber is found in the spent fuel pool.

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Response FPL will follow the industry efforts concerning the performance of Boraflex. EPRI, Bisco (the manufacturers of.Boraflex) and several utilities are analyzing data as it becomes available and will notify the industry of the results. FPL will evaluate tnese results and determine whether any additional actions are warranted for the Turkey 73 Point spent fuel racks. .

A sensitivity study has been performed to determine whether the Boraflex material at Turkey Point would be acceptable if it develops gaps. As discussed above, tests and the Quad Cities surveillances i'..dicate that 2% shrinkage could occur. If it B is conservatively assumed that this shrinkage

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would cause gaps in the Turkey Point Boraflex, the shrinkage could result in a two or three inch gap. If it is postulated that such gaps would occur in every Boraflex panel at exactly the same location (which is an extremely conservative and unrealistic assumption based on the Quad Cities data), the attached curves show that the Turkey Toint spent fuel pool would still maintain the required shutdown margin. This shutdown margin does not account for the 1950 ppm boron in solution which adds an additional 3016 k/k shutdown margin.

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A study has been escrgisted to determine the effest of gaps ta*&QILSF12K Poisen plates en rpent fust rash K,gg. The basis for this study was tha Turkey Point Unit 3 Raglen 1 spent fuel storage raaks. .

Aatal gaps in h naA0F1.tX ranging free O ta 10' wre medaled. 1 explis1tly using EDO. mae gapa nra medelod La ene half af and in all of the pisen plates in the raak.

i l . The results free the KD0 ealestations were applied as adders to the originally salestated rash R,gg and unsertainties. N details of the

, esteutstitm of the original K,gg Wth mortaintiu an attached.

The KZNO estenlattens and the origitial stittsality analysis assume a maximus U.235 entishment of 4.5 w/e. m results are presented in 1

, Figures 1 and 2.

L-It was else requested that the same type of data be previded with a

. maximus U.335 emishment of 4.1 w/o asevned, m eristaal criticality analysta included a study which shewed the senaltivity of rass X,gg ts fuel entithet for the Region 1 spent fuel reaks. Thir study was used to determine that W deersue in U.335 eartshment from 4.5 w/o to 4.1 w/o results la a 0.01I AK destasse ta rash K,gg. N o small shange in feel entishasat does met signiftsantly effut the routivity wrth of the Says in the petsee platas, m data for the study ustag the .

4.1 w/o fuel was proeused by subtrasting the 0.018 AK free the results '

af Sha 4.J m/s Juel M. Iha samulsa af sh4a aasand saudy ass l presented in Figures 1 and 3.

The dets presented la this report are the results of a detallad ter.sttivity study and are representativa af the retults that vvald some free a semplete reanalysis of the Turkey Faint Unit 3 Reglen 1 spent fuel storage Tasha.

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resed en the omtysis d.sertbe ae.e ao feue,4n, e,tien a med to

<mte, as it=1 x,,, for as ukey foi.t Ka, ten 1.,e.t fut etera.e reeksi.

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aethod = coeparisons nethod Mas=determined 0.0 AX fros knehaark eritieel Sp ,,, = bias to account for peisen particle self. shielding

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aech - bias to account for satorial thtchness and senstruction tolerance = 0.00740 AK ks 95/95 uncertainty in the nasinal ease 1 50 C. . .

g3,1= K,gg = 0. M 1 a kamathed = 95/95 uncertainty in the mothed bias = 0.013 AK ka = 95/95 uneartainty assectated with material thickness and

" sach constructies tolerances = 0.00721 AK

• Substituting celeviated values in the order listed abeve, the result to:

K,gg = 0.9150 + 0.0 + 0.M25 + 0.00M + ((0.Mi)I + (0.0M

+ (0.00721)2 3 1/2 = 0.9403 i .

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' JULY '? 1987 L-87-313 U. S. Nuclear Regulatory Commission Atin: Document Control Desk Washington. D. C. 20555 Gentlemen: g Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 o^d 50-251 Request for Addificool informotion Boroflex Us:ge in Spent Fuel Pools Your letter doted June 9,1987 requested information concerning the use of Boroflex poison material in the spent fuel storoge rocks at Turkey Point Units 3 and 4. Florido Power & Light provided a response to those questiens by our letter L-87-279 dated July 10, 1987. As this response explains, FPL considers the Boroflex to be occeptable for continued use. FPL will be performing a surveillonee test, known as Blockness Testing, on these rocks and will provid' e the

- 1, results of this surveillonce to the staff. The purpose of this letter is to provide

/ odditional information in response to NRC Stoff question regarding the existence of possible options if degrodotion of the Boroflex were to occur.

FPL hos completed a review of possible options if degraded Boroflex poison is discovered by our surveillance program.

l} The degraded Boroflex could be evoluoted to determine whether the degrodotion and any expected future degrodotion would odversely offect

, FPL's ability to satisfy the .95 K,gg limit for the Turkey Point spent fuel pools, if the pools could still satisfy this limit, no further action would be necessary.

2) Administrative controls could be imposed on the plocement of new fuel assemblies around storage cell locations that have degraded Boroflex. The sensitivity analysis performed for Turkey Point Units 3 and 4 assumes only new fuel with 4.5 w/o fuel is stored in the spei.1 fuel pool. By limiting the amount and location of the storege of new fuel assemblies and by inserting spent fuel between the new fuel, FPL could reduce the K,gg to less than or equal to .95.

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3) A poison material simllor to o control rod or burnable poison could be odded to any new fuel assembly to be placed in a storage cell with degraded Boroflex. This would reduce the K,(( to less than or equal to the .95 limit.

4) Poison plates could be odded into the space between the fuel assembly and the cell wall to assure o K,gg of less than or equal to .95.

5) FPL has taken no credit for the 1950 ppm boron concentration in the spent fuel pool water. This boron concentration alone assures a K,gg of les; than #

.90. In orde: e f;ke credit for this boron, FPL could establish various administrative s cols to provide a high level of confidence that the spent fuel pool water will remain borated. These controls could include isolating pure water sources and routine sampling of the boron concentration.

6) The storage cells with the degraded Boroflev aould be blocked off to prevent looding of any fuel ossembly into the cell.

7) The storoge rocks with the degroded Boroflex could be coated with boron with o sufficient density to assure a K,gg of less than or equal to.95.

8) The storage rocks which contain degraded Boroflex could be replaced.

It should be emphostzed the FPL believes that the Boroflex of Turkey Point is acceptoble for continued use and that no changes will be necessary in the manner in which FPL plans to store fuel of Turkey Point. The purpose of this letter is only to indicate that there ore several possible actions which could be taken to assure the continued safe storage of fuel at Turkey Point if the Boroflex in the spent fuel rocks were to experience degradation.

Should the.e be any further questions, please contact us.

Very truly yours,

. . G .

p C. O. Woody Group Vice President Nuclear Energy COW /RG/gp cc Dr. J. Nelson Groce, Regional Administrator, Region ll, USNRC Senior Resident inspector, USNRC, Turkey Point Plant RG3/0500/2 1

P. o. Box 14000. Juno BE AcH. FL 33408 04:3

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. ,4 _J __ N AUGUST 2 0 1997 L-87-348 U. S. Nuclear Regulatory Commission i

Attn: Document Control Desk Washirgton, D.C. 20555 Gentlemen:

t Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 cnd 50-251 -

Eurveillance Results from Unit 3 Spent ruel Dool Your letter dated June 9.1987 requested information conceming the use of Boroflex neutron obsorbing mater:cl in Turkey Point Units 3 and 4 sp at fuel rocks. Our letters, L-87-279 (dated July 10,1987) and L-87-313 (dated July 27, 1987) responded to your letter, in those letters Florido Power & Light (FPL) committed to provide the staff with the results of our baseline blockness testing prog ram. FPL odded this testing to the existing surveillance program in response to industry experience concerning Boroflex usoge.

Blockness testing was performed during the first week of August 1987 on the installed spent fuel rocks in Turkey Point Unit 3 Spent Fuel Pool. FPL tested eight Region I storoge locations (containing a total of 32 full length Boroflex panels) and ten Region 11 storage locations (containing a total of 22 full length Boroflex panels). FPL selected these storage locations because they are representative of those storage locations which have received the highest occumulated dose for Region I and Region 11. Calculations indicate that the occumulated gamma dose would be 7.8 x 109 rods assuming en infinite array of storage cells each containing a spent fuel ossembly with an overoge bumup of 36,000 MWD /MTU stored for one year. No indication of gops, voids or other spatial distribution onomalies were observed in any of the 54 panels.

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, In addition to indicating the existing condition of the Bcroflex panels, this testing ,

will provide baseline data for comparison against the results of future surveillance

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tests. FPL expects to perform the next test within three years (in conjunction with the five year surveillmce interval for the Boroflex sample coupons), or sooner, if industry experience indicates a shorter surveillance period is worronted. Calculations indicate that the occumulated gamma dose would be 1.2 x 10 10 rods assuming m infinite array of storage cells each containing a spent fuel ossembly with on overage bumup of 36,000 MWD /MTU stored for one year.

Should there be further questions, please contact us.

Very truly yours,

( C. O. Wood Group Vic P sident Nuclear Energy COW /RG/gp cc: Dr. J. Nelson Grace, Regional Administrator, Region 11, USNRC Senior Resident Inspector, USNRC. Turkey Point Plant 0

t RGI/038/2 l

)

vam v.T-m-rnamuso eaAcH. 7L ssee.ono

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%%k AUGUSI 2 7 1997 L 87-363 U. S. Nuclear Regulatory Commission Atin: Document Control Desk washington, D. C. 20555 Gentlemen:

Re: Turkey Point Units 3 ond 4 Docket Nos. 50 250 and 50-251 Request for Additienclinformation l Boreflex Our letter L-87-279, dat d Jsly 10, 1937, provided the results of a sensitivity analysis performed for Tuuey Point Units 3 and 4 spent fuel rocks. lits enolysis was performed to show the of feet of postuloted ga?: on maintaining the 0.95 K gg shutdewn criterio. The analysis shows that Florida Power & Light (FPL) will$e able to maintoln the 0.95 K,gg s,utdowr criterlo for future fuel cycles, essaming that ecch Borofisx plate has geps of 3.! Irches and ecch storage cell in the fuel rocks has on assembly with m enrichment of 4.1%. There cre no Indicottons of gaps as a result of the blackness testing or Turkey Point, and the enrichment of the new fuel currently used at Turkey Point ronges from 3.4% to 3.6%. Under FPL's fuel monogement progrc.m cnd the current lirnits on reactor operations, FPL will only be able to Increas.e the troximum Turkey Point fuel enrichment in small

. Increments (approximately 0.2 %) each cycle. Therefore, of the time of the next bloc' mess testing end surve!!!:nce Of th: Bereflex !n cpproximeta!y thras years, the maximum fuel enrichment at Turkey Point will be less then 4.1%. Prior to completion of that surveillance, FPL will not store fuel with m enrichment l greater than 4.1%.

1

$hould there be cny questio,s, ploose contact us.

l Very truly yours, l

C. O. Wood

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l Group Vice President Nuclear Energy l , n["f l: "' jilthl' gdirem= jj!!

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Attachment cci Dr. J. Nelsm Grace, Regional Administrotor, Region 11, USNRC Senior Resident inspe.:for, USNRC, Turkey Peint Plant l an FPL Group company

) RG3/054/l

1 l

l CXKETE0 LWC i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 88 JL 18 P3 :31 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARQFrfct P b i ni.ui .

00CXi TiNu 4 SEavtcf.

BRAhpi In the Matter of )

) Cocket Nos. 50-250_0LA-2 FLORIDA POWER AND LIGHT COMPANY ) 50-251 OLA-2

)

(Turkey Point Plant, Units 3 & 4) ) (SFP Expansion)

CERTIFICATE OF SERVICE I hereby certify that copies of "STAFF REPLY TO APPEAL BOARD ORDER OF JUNE 27, 1988" in the above-caption?d proceeding have been served on the following by deposit in the United States mail, first class, or as indi-ated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 14th day of July,1988:

Dr. Robert M. Lazo, Chairman

• Richard J. Goddard, Esq.

Administrative Judge Regional Counsel Atomic Safety and Licensing Board USNRC, Region II U.S. Nuclear Regulatory Commission 101 Marietta St., N.W., Suite 2900 Washington, DC 20555 Atlante, GA 30303 ,

Dr. Emmeth A. Luebke Atomic Safety and Licensing Board

• administrative Judge U.S. Nuc! car Regulat:ry Cc=icsicr.

5500 Friendship Boulevard, Apt. 1923N Washington, DC 20555 Chevy Chase, MD 20815 Dr. Richard F. Cole

• Atomic Safety and Licensing Administrative Judge Appeal Board

• Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Michael A. Bauser, Erg. Docketing and Service Section*

Newman & Holtzinger, P.C. Office of the Secretary 1615 L Street, NW U.S Nuclear Regulatory Commission Washington, DC 20036 Washington, DC 20555

s Norman A.~ Coll, Esq. Joette Lorion Coll, Davidson, Carter Smith 7269 SW 54th Avenue Salter & Barkett, P.A. Miami, FL 33143 Co-Counsel for FPL 3200 Miami Center Adjudicatory File

• 100 Chopin Plaza Atomic Safety and Licensing Board Miami, FL 33131 Panel Docket l U.S. Nuclear Regulatory Commission Washington, DC 20555

1. /^ .

BenjaminH.Vohr Senior Supervisory Trial Attorney 5

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