ML20195D811
| ML20195D811 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 06/07/1999 |
| From: | Cooper J AFFILIATION NOT ASSIGNED, STONE & WEBSTER, INC. |
| To: | |
| Shared Package | |
| ML20195D715 | List: |
| References | |
| ISFSI, NUDOCS 9906100047 | |
| Download: ML20195D811 (13) | |
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- e. a UNITED STATES OF AMERICA NUCLEARREGULATORY COMMISSION Before the Atomic Safety and Liceneine Board In the Matter of
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PRIVATE FUEL STORAGE L.L.C.
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Docket No. 72-22
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(Private Fuel Storage Facility)
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AFFIDAVIT OF JERRY COOPER CITY OF ENGLEWOOD
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) SS:
STATE OF COLORADO
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I, Jerry Cooper, being duly sworn, state as follows:
1.
I am the Project Engineer with Stone & Webster Engineering Corporation (Stone & Webster) for the Private Fuel Storage Facility (PFSF). Stone & Webster is the architect-engineer for the PFSF. As Project Engineer for the PFSF,I am responsible for diiccting the multidiscipline engineermg and design activities of the PFSF project. I am providing this affidavit in support of a motion for partial summary disposition of Conten-I tion Utah K in the above captioned proceeding to describe the ability of the PFSF to withstand heat and temperatures under conditions that might result from a wildfire adja-cent to the facility.
2.
I have participated in and am knowledgeable of the design and layout of the PFSF. My professional and educational experience is summarized in the curriculum vitae attached as Exhibit I to this affidavit. I have 28 years of experience in the engi-neering, design, construction, operation, and maintenance of naval nuclear power plants, i
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y commercial nuclear plants, spent fuel storage facilities, and environmental remediation projects.
3.
All spent fuel at the PFSF will be located inside the Restricted Area. The Restricted Area is a 99 acte, roughly rectangular area surrounded by two fences, which will contain the concrete storage pads on which the spent fuel storage casks will be to-
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cated (8 casks per pad). The Restricted Area will also contain the canister transfer -
building, constructed of reinforced concrete, where the spent fuel canisters will be trans-ferred from transportation casks to storage casks. The transportation casks containing the canisters will be brought into the canister transfer building imm outside the ISFSI cither on rail cars (via the PFSF rail line) or heavy-haul tractor trailers (via the PFSF access -
i road).' Finally, in a corner of the Restricted Area, removed from the canister transfer building and spent fuel storage casks, will be the security and health physics building, constructed of reinforced concrete masonry, which will contain the offices and equipment for security and health physics personnel and an emergency diesel generator.
4.
The layout of the PFSF Restricted Area is shown in Figure 1.2-1 of the
~ PFSF Safety Analysis Report (SAR), which is attached as Exhibit 2 to this affidavit. As can be seen on this Figure, the concrete storage pads 'and the spent fuel storage casks will be separated from the inner fence surrounding the Restricted Area by a minimum dis-tance of 150 ft. That portion of the Restricted Area not covered by the concrete pads will
. have a crushed rock surface 12 inches deep. The inner fence is separated from the outer fence by a distance of 20 ft. The area Mrw the fences (referred to as the isolation l
' zone on Figure 1.2-1), will have a crushed rock surface 12 inches deep. Surroundmg the
' outer fence, at a distance of 10 ft. from the fence, will be a 20-foot wide perimeter road with a crunhad rock surface 12 inches deep. (While SAR Figure 1.2-1 refers to the Re-stricted Area and perimeter road surfaces as " crushed rock" and the isolation zone surface as " compacted gravel," those surfaces will all be composed of the same aggregate road base.) The 10 ft. space between the outer fence and Se perimeter road will also have a 12-inch deep crushed rock surface. PFS will implement a maintenance program to con-a 2
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trol any significant growth of vegetation through the crushed rock surface of the Re-stricted Area, the isolation zone, the 10 ft space between the isolation zone and the pe-
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rimeter road, and the perimeter road. Thus, the surface of the Restricted Area from the concrete pads to the outside of the perimeter road will be non-combustible.
5.
I have read the affidavit of Carlton Britton. In addition to the surface of the Restricted Area being non-combustible, the spent fuel, the equipment, and the PFSF personnel inside the Restricted Area will be pmtected from wildfires by a barrier of crested wheat grass that PFSF will plant around the Restricted Area. The barrier will be 300 ft. wide and will run outward from the outer edge of the perimeter road around the Restricted Area. A barrier of crested wheat grass would remain in place with little main-tenance after it was planted. Britton Aff. at j 8. Crested wheat grass is fire resistant and thus would eliminate or greatly reduce the effect of any wildfire approaching the PFSF.
11 6.
The closest possible point of approach of a wildfire outside the Restricted Area, assuming that it penetrated the barrier of crested wheat grass around the Restricted Area, would be the closest total distance from the outer edge of the perimeter road sur-rounding the Restricted Area to a spent fuel storage cask or a structure used to handle spent fuel storage casks.' nus, the closest possible point of appmach to any spent fuel storage casks inside the Restricted Area would be 162 ft., to any casks in the canister transfer building. The spent fuel storage casks on the concrete storage pads would be at least 200 ft. from the outer edge of the road and thus at least 200 ft. from the fire.. San SAR Fig.1.2-1, Exhibit 2.
. 7. ~
The canister transfer building will have concrete walls two feet thick, with a concrete roof one foot thick and a concrete foundation five feet thick. Response to NRC Roquest for Additional Information 3-5, at 1, dated Mar. 24,1999. Th'us it will be 1
non-combustible and because of the low thermal conductivity and high specific heat of concrete, no fire outside the Restricted Area would pose a hazard to the building or to any 3
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- r. 3 spent fuel, fuel casks, fuel canisters, or personnel located inside the canister transfer l
building.
8 I have also read the affidavits of Krishna Singh, and Ram Srinivasan. The.
' distance from the closest possible point of approach of a wildfire, combined with the.
temperatures generated by a fire, Britton Aff. at B 6-7,9-10, and the resistance to fire of the spent fuel casks systems, Singh Aff, at 17; Srinivasan Aff. at M 5-6, and the canister transfer building, would prevent a wildfire from posing a hazard to the spent fuel, the fuel canisten, or the fuel casks.
9.
The only significant sources of combustible material that would be present inside the Restricted Area would be: 1) the diesel fuel in the tanks of any heavy haul trucks bringing spent fuel transportation casks to the ISFSI, SAR f g.2.5.1.; 2) the dicscl fuel in the tanks of any train locomotive bringing transportation casks to the ISFSI, SAR
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5 8.2.5.1; 3) the diesel fuel in the cask transporter vehicle that would move casks from
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the canister transfer building to the storage pads, SAR Q 8.2.5.1.; 4) the diesel generator fuel tank inside the security and health physics building; and 5) the diesel fuel storage,
- tank, which would be located at least 50 R. inside the inner fence surrounding the Re-stricted Area, approximately 200 ft. northeast of the canister transfer building and 700 ft.
cast of the nearest fuel casks. Commitment Resolution Information, NRC RAI g-2 (sec--
ond round), dated Mar. 24,1999.
10.
A wildfire would not cause any of the fuel sources inside the Restricted Area to ignite or explode. The diesel tanks will be designed in accordance with the re-quirements of NFPA 30. The diesel storage tank will be located at least 50 ft. inside the 1
inner fence around the Restricted Area, which would provide a 100 ft. firebreak between the outer edge of the perimeter road and the tank. The crested wheat grass barrier around the Restricted Area would provide another 300 ft. of separation between the fire and the tank. At that distance a fire would have no chance whatsoever ofigniting or exploding i
the diesel fuel in the tank. Britton Aff. st i 10. The diesel emergency generator tank will be a double-walled tank located inside the security and health physics building. The 4
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<.n building will be protected by the crested wheat grass barrier. Furthermore, even if the fire were to penetrate the crested wheat grass barrier, because the area between the outer i
edge of the Restricted Area and the outer edge of the perimeter road are covered with crushed rock, a wildfire could not come closer than 50 ft. from the building. In addition, the tank will be protected from fire by the building, by virtue ofits of reinforced concrete
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masonry construction, by a sprinkler system within the building designed to NFPA 13 standards, and by the tank's own double walled construction. Therefore, a wildfire would not ignite or explode the diesel generator tank. All other diesel fuel sources would be farther than 100 ft. from any wildfire (assuming that it penetrated the crested wheat grass barrier around the Restricted Area) and would not be threatened by virtue of their distance from the fire.
11.
Futther, PFS has analyzed the potential consequences of diesel fuel fires and has found that they would pose no hazard to the spent fuel o'r the integrity of the spent fuel storage casks or the fuel canisters contained therein, even if the diesel fuel were somehow ignited. Section 8.2.5 of the PFSF SAR shows that fires involving diesel fuel from a heavy haul truck, the cask transporter vehicle, or the locomotive would not threaten the integrity of the spent fuel storage casks (or the fuel canisters inside). Diesel fires (and wildfires) would not threaten the integrity of any spent fuel transportation casks (or canisters contained therein), in that under 10 C.F.R. $ 71.73(c)(4), certified transpor-tation casks are required to be designed to withstand a design basis fire. The explosion of vehicle fuel tanks is not a credible event because of the distance that would separate them j
from any wildfire. Britton Aff. at110.
12.
A fire involving the diesel fuel from the storage tank northeast of the can-ister transfer building would not threaten any spent fuel storage casks or canisters con-tained therein, in that the tank will be 700 ft. from the nearest concrete storage pad and 200 ft. from the canister transfer building. The explosion of the diesel storage tank is not i
credible because of the distance that would separate it from any wildfire. A fhe or explo-sion involving the diesel fuel from the diesel generator tank inside the security and health 5
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I physics building would not threaten any spent fuel storage casks (or canisters inside), in that the security and health physics building is over 900 ft. fmm the nearest concrete stor-age pad and over 350 ft. from the canister transfer building. Commitment Resolution In-formation, NRC RAI 8-2 (second mund), dated Mar. 24,1999.
j 13, Any hazard that a wildfire might pose to any other structure or piece of equipment around or inside the Restricted Area is irrelevant, in that section 3.4 and Table 3.4-1 of the PFS SAR show that the fuel casks, the fuel canisters, the storage pads, and the canister transfer building (including components inside the building) are the only
" structures, systems, and components important to safety" (defined by 10 C.F.R. { 72.3) at the PFSF. The NRC defines as such those systems that 1) maintain the conditions re-quired to store spent fuel safely,2) prevent damage to the spent fuel container during
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handling and storage, and 3) provide reasonable assurance that the spent fuel can be han-died without undue risk to the public. Specifically, the security and health physics building and the security and perimeter lighting systems are not "important to safety."
Nor are any aspects of the PFSF electrical power supply or instrumentation systems.
Those systems provide for the safety of the PFSF only indirectly. The PFSF is designed so that no harm to the public health and safety would result from the failure of those sys-tems. If those systems were damaged by a fire, PFS would simply repair or replace them afterwards. NRC regulations do not require a higher level of protection for those sys-te'ms.
14.
Finally, a wildfire at the PFSF would not cause the evacuation of PFSF se-curity personnel. By virtue of the 300-ft. crested wheat grass barder surrounding the PFSF Restdcted Area and the distance between the outer edge of the perimeter road around the Restricted Area and the location of the spent fuel storage casks and the canis-ter transfer building, the heat from the fire would not pose a threat to any personnel inside
- the Restricted Area. Britton Aff. at j 10. Furthermore, PFSF security perEws.cl will have appropriate emergency breathing apparatus available to them such that the smoke 6
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from a fire at the PFSF would not force them to evacuate. The spent fuel casks inside the 1
PFSF Restricted Area will be protected by PFSF security personnel at all times.
ydet>per I
I Swom to before me this '/
day of June 1999.
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JOANNEG MOON 1
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_ STATE OFCOLORADO ll or-l My Commission expires 4/-c7 /- doe 3 My %'g
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- Jerry L. Cooper Lead Senior Engineer Experience Summary Mr. Cooper has 28 years experience in the Engineering, Design, Construction, Operation and Maintenance of Nuclear Power Plants. He is a Lead Senior Engineer in the Mechanical Division and has been with Stone & Webster Engineering Corporation for 23 years. He has over 19 years experience with the Duquesne Light Company's Beaver Valley Unit Nos. I and 2 Nuclear Plants.
Mr. Cooper is currently assigned as Project Engineer for the Private Fuel Storage Facility project (PFSF).
His responsibilities include directing the engineering and design activities in suppon of the project license application.
Mr. Cooper returned to Stone and Webster in April 1997 after spending 15 months working for Lockheed Manin Advanced Environmental Systems on the Pit 9 Remediation Project. The Pit 9 project was an environmental remediation project using state of the art technology to retrieve and process buried transuranic waste from the Subsurface Disposal Area at the Idaho National Engineering and Environmental Laboratory. Mr. Cooper served as the Offsites/ Treatment Manager responsible for engineering and design of the Treatment Facility Building and the Offsites Support Area.
Prior to this Mr. Cooper was the Assistant Project Engineer for the Continuing Services activities for the Beaver Valley Power Station Unit Nos. I and 2. He was responsible for the organization, administration and direction of all Engineering Disciplines to ensure proper technical interface with the Duquesne Light Nuclear Engineering Department. Specific responsibilities included the preparation of Design Change Packages for plant modifications, engineering calculations, equipment procurement specifications and..
resolution of detailed engineering problems. Additionally, he has served as the Mechanical Engineer on the Evaluation Team for the Safety System Functional Evaluation of the Recirculation spray System and the Residual Heat Removal System.
He was assigned to the Beaver Valley Unit No. 2 Site Engineering Office in 1981 as an Engineer in the Nuclear / Mechanical Group. His responsibilities included engineering suppon of such major construction activities as turbine erection, turbine lube oil flush, main condenser erection, fuel handling crane erection and operation, and ASME XI In-Service Inspection for piping welds. He also served as the piping engineer responsible for all major piping installation. In 1984, he was assigned to the Integrated Construction Suppon Group. This group was established to work directly with construction and contractor personnel to provide technically acceptable and construction conscious solutions to field problems. In 1987, Mr. Cooper became the Principal Engineer, supervising all Mechanical Division activities of this group. During start-up testing and initial operations, he served as Principal Engineer responsible for all Mechanical Division activities of the Site Engineering Group and later as Assistant Superintendent of Engineering responsible for Mechanical, Structural and Engineering Mechanics disciplines as well as administration and direction of the Site Engineering Group's policy and procedures.
Prior to his site assignment, Mr. Cooper spent six years in Stone & Webster's Boston Office assigned to the Beaver Valley Power Station Unit No. 2 Nuclear Project in both the Piping Engineering Group and the Nuclear Group. His duties included: responsible engineer for all NSSS systems and equipment; preparation of specifications for canridge type liquid filters, valves, strainers and steam traps; coordination of purchase orders with vendors; review and approval of vendors' equipment drawings; and resolution of N&Ds from the Vendor Surveillance Group or the Site Quality Control Group.
Prior to joining Stone & Webster, Mr. Cooper spent five and one-half years in the U.S. Naval Nuclear A
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l Resume ofJerry L. Cooper Power Program where he served as a Mechanical Operator on an SSW Poseidon submarine. His duties included maintenance, operation, training, and testing of nuclear fluid, ships propulsion, and various support systems.
Education B.S., Engineering - Geneva College U.S. Navy Nuclear Power Program l
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Figure 1.2-1 PFSF GENERAL ARRANGEMENT PRIVATE FUEL STORAGE FACILITY SAFETY ANALYSIS REPORT Revision 3
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