ML20196G113
| ML20196G113 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 06/28/1999 |
| From: | Johns J AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20196F952 | List: |
| References | |
| ISFSI, NUDOCS 9907010054 | |
| Download: ML20196G113 (9) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing 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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I DECLARATION OF JEFFREY JOHNS Jeffrey Johns states as follows under penalties of perjury:
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I am a Licensing Engineer for Stone & Webster Engineering Corp. I am providing this declaration in support of a motion for partial summary disposition of Con-tention Utah R in the above captioned proceeding to show that a fire - even assuming !Lo fire fighting by site personnel or fire suppression by any of the installed automatic fire suppression systems - would not cause a release of radioactivity at the Private Fuel Stor-age Facility (PFSF).
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My professional and educational experience is summarized in the cur-t riculum vitae attached as Exhibit I to this declaration. I have 21 years of experience in the nuclear power industry and nine years of experience with the licensing ofindependent l
spent fuel storage installations (ISFSIs). I have experience in performing accident analy-ses for nuclear power plants and ISFSIs and in preparing ISFSI emergency plans. For the PFS project I am responsible for the preparation of the PFSF Safety Analysis Report, in-l cluding accident analysis and radiation protection for the spent fuel cask systems to be used at the PFSF. As part of my responsibilities, I have performed assessments of the effects of possible fires at the PFSF.
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9907010054 990628 PDR ADOCK 07200022 C
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I am knowledgeable of the design and operation of the PFSF and the spent fuel casks that will be used there. I am knowledgeable of the means of estimating the du-ration of and maximum temperatures produced by diesel fuel fires. I am familiar with the j
affidavit of Jerry Cooper regarding the resistance of the PFSF to wildfires. I am also fa-miliar with the affidavit of Krishna Singh and the declaration of Ram Srinivasan regard-ing the resistance to fires of the spent fuel cask systems that will be used at the PFSF.
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The State of Utah has alleged in Contention Utah R that PFS has not pro-vided reasonable assurance that the public health and safety will be adequately protected in the event of an emergency at the PFSF, in that PFS does not have adequate support ca-pability to fight fires onsite. The State's claim is immaterial, however, in that the PFSF is designed to withstand the effects of credible fires without any firefighting by personnel or the operation of any automatic fire detection / suppression system such as a water sprin-kler.
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The only significant sources of combustible material near the spent fuel casks at the PFSF will be the diesel fuel tanks of the PFSF cask transponer vehicle (which will move storage casks from the Canister Transfer Building to the concrete stor-age pads) and the locomotive and the heavy haul truck tractors (which will bring spent fuel transportation casks from ofTsite to the Canister Transfer Building). PFS will have two diesel fuel storage tanks at the PFSF, but they will be too far away to pose a hazard to either the spent fuel storage casks on the storage pads or inside the Canister Transfer
- Building. Cooper Aff. at 119,12. There will be no other significant sources of combus-tible material in the Restricted Area in which the spent fuel casks and the Canister Trans-fer Building are located at the PFSF. Safety Analysis Report (SAR) at 8.2-24 to -25. As described in the affidavit of Jerry Cooper the surface of the Restricted Area is covered with crushed rock 12 inches deep and the Canister Transfer and Security and Health Physics Buildings are of concrete construction. Cooper Aff. at 13-4,7.
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PFS analyzed the potential impact of fire on the PFSF and the spent fuel storage casks that would be located there in Section 8.2.5 of the PFS Safety Analysis Re-2
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'6 port (SAR). SAR Section 8.2.5.2 considers fires involving 50 gallons of diesel fuel from a postulated rupture of the fuel tanks of the cask transporter vehicle (which contain a total of 50 gallons), and 300 gallons from a postulated rupture of the saddle tanks of a heavy i
haul vehicle tractor (which contain a total of 300 gallons). PFS evaluated the effects of cask transporter (i.e.,50-gallon) fires both outside the Canister Transfer Building and in-side a canister transfer cell inside the Canister Transfer Building. SAR at 8.2-25 to -28.
It evaluated the effects of a heavy haul truck (i.e.,300-gallon) fire inside the cask load / unload bay in the Canister Transfer Building. SAR at 8.2-25 to -27.
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A 50-gallon diesel fuel spill (from the cask transporter) would not cause a radioactive release from a spent fuel storage cask. PFS assumes that the 50 gallons encir-cles a spent fuel storage cask, ignites, and burns until all of the fuel is expended, with no j
credit taken for fire fighting of any kind. As stated in the PFSF SAR:
i This scenario is analyzed in Section 11.2.4 of the HI-STORM SAR. From IAEA requirements (Reference 18),
the " pool" of fuel is assumed to completely encircle a stor-age cask and extend I meter beyond the cask surface.
Based on the minimum outer cask diameter of 132.5 inches (HI-STORM), this spill would result in a ring of fuel with a pool surface of about 21,260 sq in around the storage cask.
SAR at 8.2-25. Fifty gallons spread across this area would pool to a depth of 0.54 iM PFSF SAR Section 8.2.5.2 states that:
A fuel consumption rate of 0.15 in/ min was assumed (Ref-erence 19) based on gasoline / tractor kerosene experimental burning rates.
SAR at 8.2-25. As stated in the PFSF SAR, the 50 gallons of fuel would sustain a fire for about 3.6 minutes. Id. The maximum temperature produced by the fire would be less than 1475 'F. The temperature and duration of the fire are such that it would not cause a radioactive release from a spent fuel storage cask either outside the Canister Transfer Building or inside a canister transfer cell inside the building. SAR at 8.2-26, -28; Singh 1
Aff, at 13; Srinivasan Aff. at 15.
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On the other hand, the SAR's evaluation of a fire resulting from a postu-lated spill and ignition of 300 gallons of diesel fuel from the saddle tanks of a heavy haul vehicle tractor in the Canister Transfer Building cask load / unload bay did not estimate the burn time of this volume of diesel fuel. Rather, the evaluation relied on operation of the automatic fire detection and suppression systems to extinguish the postulated fire in less than 15 minutes. SAR 8.2.5.2. Nevertheless, if no credit is taken for the automatic fire detection / suppression systems in the cask load / unload bay, the fire duration can be l
estimated by applying the same method that was used for the 50-gallon fire analysis (i.e.,
by assuming that the fuel pools on the floor of the cask load / unload bay and burns until it is consumed), and the resulting temperature can be evaluated based on information in the i
Fire Protection Handbook (Reference 1). Such an analysis of the 300-gallon fire shows that it would burn out in less than 10 minutes and would not threaten any systems, struc-tures, or components (SSCs) important to safety even without the operation of automatic fire detection and suppression systems.
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The cask load / unload bay is approximately 198 ft. long and 48 ft. wide.
SAR Fig. 4.1-1. Diesel fuel spilled into this bay would tend to spread forming a rela-tively thin layer. In calculating a fuel burn time, it is conservative to assume that the die-sel fuel forms a relatively deep pool, in that a deep pool bums longer than a shallow pool, and a 1 inch depth is considered to be a very conservative assumption. A 300-gallon vol-ume ofliquid at a depth of 1 inch would occupy an area of 481 sq. ft., represented by a circle with a 12.4 ft. radius. This surface area is only 5% of the total area of the cask load / unload bay, a the walls of the bay would not confine the spilled fuel within a smaller and deeper pool. Any drain smnps in the cask load / unload bay that could poten-tially collect diesel fuel from postulated rupture of the heavy haul tractor fuel tanks will be located so as to assure that burning of diesel fuel in these sumps will not threaten SSCs important to safety.
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Assuming that this pool of 300 gallons of diesel fuel is ignited and burns, the duration of combustion can be calculated using the 0.15 inch / minute fuel consump-4 l
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i tion rate specified in Section 8.2.5.2 of the PFSF SAR (Reference 2). A 1 inch deep pool ofdiesel fuel will be' consumed in 1 in. / 0.15 in/ min. = 6.67 minutes. Figure 7-9B of Reference 1 provides time-temperature curves for different types of fires from slight to moderate to severe. Temperature curve E of this figure is for the " standard exposure fire I
- severe", and includes fires fueled by flammable liquids. This standard fire time-temperature curve, which is also shown in Figure 7 9A of Reference 1, reaches a tem-1 1
perature of 1,000 *F at 5 minutes and a temperature of 1300 *F for a 10 minute burn du-i ration. ~ For the calculated 6.67 minute bum duration, a peak temperature of approxi-mately 1200 'F would be reached., This fire would not threaten any SSCs important to safety at the PFSF in a way that could cause a radioactive release. The overhead crane is located approximately 70 ft above the floor of the Canister Transfer Building, and the semi-gantry crane is located approximately 55 ft above the floor of the Canister Transfer Building. SAR Fig. 4.7-1 (sheet 2). The only credible significant impact a fire might have is that it could cause a loss of electrical power to SSCs inside the Canister Transfer Building. SAR section 8.1.1.3 shows, however, that a loss of power would not cause an accident that would result in a release of radioactivity, even ifit occurred while canister transfer operations were in progress.
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It is not credible that the postulated 300-gallon diesel fuel fire discussed above would affect spent fuel storage casks or transfer casks containing loaded spent fuel canisters, since the spent fuel storage casks at the PFSF will be located either on the con- -
crete storage pads or in a canister transfer cell, but not in the cask load / unload bay, and a j
loaded transfer cask would only be located in a canister transfer cell. The cask load / unload bay is physically separated from the transfer cells by a concrete wall, and will be constructed so that any spilled diesel fuel would remain in the bay and would not i
enter a transfer cell. See SAR at 8.2-26 to -27; id. at 5.1-4 to -6; id. Figs. 1.2-1, 4.7-1 i
(sheet 1).
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Potential fires involving diesel fuel from the locomotive also would not cause a radioactive release at the PFSF. PFSF SAR section 8.2.5.1 states:
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For rail delivery / retrieval of shipping casks, the train loco-motives are required by administrative procedure to stay out of the Canister Transfer Building. The design of the building and its surroundings will assure that any diesel fuel spilled outside the building will not flow into the building, which could create a fire hazard.
Thus, fuel from the locomotive could not cause a fire inside the Canister Transfer Build-ing.
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A locomotive fuel spill and associated fire at the PFSF is extremely un-a likely given the low speeds at which the locomotives will operate at the PFSF and the dif-ficulty ofigniting spilled diesel fuel. Nevertheless, it could be postulated that the fuel tank (s) of a locomotive staged at the PFSF ruptures and diesel fuel spills onto the ground j
and ignites outside the Canister Transfer Building. The PFSF railroad line nearest the spent fuel storage pads is 107 ft from the closest pads, at the south end of the PFSF Re-stricted Area. SAR Fig.1.2-1. Thus, a fire associated with a locomotive would be ap-proximately 100 ft from the nearest spent fuel storage casks. As a result of the distance, the heat flux impinging on the storage casks (Section 21, Chapter 6 of Reference 1) and the effects of such a fire on the storage casks at the PFSF would be much less than those resulting from the postulated fire in which 50 gallons of diesel fuel is assumed to encircle a storage cask and burn, which is described above. Therefore, the storage casks would retain their integrity and there would be no release of radioactivity from storage casks, even in the highly unlikely event of a diesel fuel fire associated with a locomotive.
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In addition to fire not threatening the integrity of the spent fuel casks at the PFSF, no credible fire at the PFSF would threaten any other SSCs important to safety in a way that could cause a radioactive release. The only credible significant impact a fire might have is that it could cause a loss of electrical power to SSCs inside the Canister Transfer Building. As indicated above, however, SAR section 8.1.1.3 shows that a loss of power would not cause an accident that would result in a release of radioactivity, even ifit occurred while canister transfer operations were in progress.
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In addition to a fire inside the PFSF Restricted Area not posing a threat to cause a radioactive release, a wildfire adjacent to the PFSF Restricted Area would also not cause a radioactive release. Because of the distance that would separate a wildfire from the Canister Transfer Building and the spent fuel storage casks at the PFSF, a wild-fire would pose no direct threat to the spent fuel casks or the SSCs important to safety in the Canister Transfer Building, even without firefighting by personnel or the operation of any automatic fire suppression systems. Cooper Aff. at j 8. Furthermore, a wildfire could not cause a fire or explosion on site that would threaten the spent fuel casks or the SSCs important to safety. Id at $$ 10-14.
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In conclusion a fire at the PFSF (or a wildfire adjacent to the PFSF Re-stricted Area) would not cause a radioactive release, even if no credit were taken for fire-fighting by personnel or for automatic fire detection / suppression systems.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on Junen,1999.
k Jeffrey Johns References 1.
Fire Protection Handbook, Sixteenth Edition, National Fire Protection Associa-tion,1986.
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Gregory, J.J., et. al., Thermal Measumnents in a Series of Large Pool Fires, SAND 85 10%, Sandia National Laboratories, August,1987.
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JOHNS
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JEFFREY R. JOHNS Licensing Engineer
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EXPERIENCE
SUMMARY
Mr. Johns has 21 years ;f experience in the nuclear power industry, including 4 years as an officer in the U.S. Naval Nuclear Power Program and 17 years in nuclear licensing-engineering at Public. Service Company of Colorado's (PSCo) Fort St. Vrain (FSV) nuclear power plant and ISFSt..He has been actively involved with ISFSI licensing work since plans were first formulatea to license and construct the FSV ISFSI in 1990. Mr. Johns joined Stone & Webster recently as a l
permanent employee to assist in the licensing effort for the Private Fuel Storage Facility ISFSI.
Mr. Johns was Supervisor of PSCo Nuclear Licensing from 1981 to 1991. He was responsible for the performance of 10 CFR Part 50.59 safety evaluations, for maintaining the FSV plant SAR up-to-date to reflect plant modifications and the current cafety basis, and preparing amendments to the facility technical specifications. He was instrumental in helping PSCo comply with major regulatory changes, such as those stemming from the accident at Three Mile Island and the environmental qualification and fire protection rules. Mr. Johns developed acceptance criteria specific to FSV and interfaced with the NRC to obtain their approval.
' He was responsible for directing the reactor vendor in accident analyses, which were necessary to license major modifications and determine compliance with new regulations. Mr. Johns received a $1,000 award for providing the analytical basis for the FSV plant symptom-oriented emergency operating procedures. He assisted in accident analyses for the ISFSI, was responsible for determining event classification of accidents assessed in the ISFSI SAR, and helped to prepare ISFSI emergency procedures.
Mr. Johns was PSCo's lead in developing the FSV decommissioning accident analyses and preparing major portions of the decommissioning plan (licensing basis for decommissioning). He chaired the Hazards Analysis Review of Decommissioning Committee, consisting of personnel with expertise in the areas of construction, nuclear safety, health physics and industrial safety.
Mr. Johns served on the team appointed to revise station procedures to make the FSV ISFSI a l
" stand-alone" facility, in preparation for termination of the Part 50 license.
RELEVANTPROMCTEXPERIENCE Private Fuel Storage Facility, Private Fuel Storage, LLC - As Licensing Engineer, responsible for the preparation of the Safety Analysis Report (SAR), including accident analysis and radiation protection involving both of the selected storage system vendors Fort St. Vrain ISFSI, Public Service Company of Colorado - The FSV ISFSI is a Foster-Wheeler storage vault system. Mr. Johns assisted in licensing the FSV ISFSI under 10 CFR Part
- 72. He interfaced with the NRC on the ISFSI accident analysis, specifically resolving a Heensing issue related to the source term and consequences of the ISFSI Maximum Credible Accident, postulated breach of a fuel storage container.
He was responsible for ISFSI SAR updates to maintain the ISFSI licensing basis up-to-date. He substantially revised the SAR to incorporate results of new analyses for reduced decay heat removal, following the occurrence of a natural convection cooling flow path blockage event in 1992 that exceeded the design basis.
He was also responsible for the performance of safety evaluations (per 10 CFR Part 72.48) on ISFSI design modifications, and prepared a safety evaluation concoming modifications which make the ISFSI cask load / unload port compatible with new spent fesl shipping casks. Mr. Johns
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y had the lead role in licensing the new spent fuel shipping casks. designed by Transnuclear Inc., to transport loaded fuel storage containers from the ISFSI without the need for transfer of fuel 1
elements into a special cask liner.
He developed two amendment packages to the FSV ISFSI license. The first permitted installation of pipelines in the vicinity of the ISFSI that supply natural gas at high pressures to the combustion turbines used to repower the FSV plant. Mr. Johns directed analyses to determine natural gas plume dispersion under various meteorological conditions, pressures at the ISFSI resulting from postulated detonation of the natural gas cloud, and structural effects on the ISFSI. The second 1
amendment permitted storage of low-level radioactive waste and radioactive sources for instrument calibration at the ISFSt. Mr. Johns prepared the safety analyses for both amendment packages. The safety analyses were reviewed and accepted by the NRC and their contractor without questions, and the NRC issued the license amendments.
Mr. Johns provided assistance to the FSV Emergency Planning Coordinator with ISFSI emergency procedures, event classification, and in creating realistic drill scenarios for the annual examinations of emergency preparedness, observed by the NRC.
l EDUCATION B.S., Biological Science - Stanford University LICENSES AND REGISTRATIONS Professional Engineer-Colorado
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