ML20206R956

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Applicant Motion for Partial Summary Dispostion of Utah H Contention H,Inadequate Thermal Design.* Pfs Requests That Board Grant Applicant Partial Summary Disposition with Respect to Subparts 3,4 & 5 of Contention Utah H
ML20206R956
Person / Time
Site: 07200022
Issue date: 05/19/1999
From: Gaukler P
AFFILIATION NOT ASSIGNED, SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20206R953 List:
References
ISFSI, NUDOCS 9905210018
Download: ML20206R956 (11)
v • d • e


Text

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4 DOCKETED May 19, ik99 UNITED STATES OF AMERICA

'99 MAY 20 P4 :44 NUCLEAR REGULATORY COMMISSION OR:

RU' ADJLC M

Before the Atomic Safety and Licensing Board

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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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APPLICANT'S MOTION FOR PARTIAL

SUMMARY

DISPOSITION OF UTAH CONTENTION H -INADEQUATE THERMAL DESIGN I.

INTRODUCTION Applicant Private Fuel Storage L.L.C. (" Applicant" or "PFS") files this motion for summary disposition of three subparts of Contention " Utah H -Inadequate Thermal Design," (" Utah H") pursuant to 10 C.F.R. 2.749. Summary disposition is warranted I

on the grounds that there exists no genuine issue as to any material fact relevant to the subparts of the contention and therefore, under the applicable Commission regulations, the Applicant is entitled to a decision as a matter oflaw. This motion is supported by a Statement of Material Facts as to which PFS asserts that there is no genuine dispute and affidavits from Indresh Rampall and Donald Wayne Lewis.

i II.

STATEMENT OF THE ISSUE On April 22,1998, the Atomic Safety and Licensing Board (" Licensing Board" or

" Board") admitted Contention Utah H. Private Fuel Storage, L.L.C. (Independent Spent 1

9905210018 990519 PDR ADOCK 07200022 C

PDR

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Fuel Storage Installation), LBP-98-7,47 NRC 142,253 (1998). The pertinent parts of the contention assert that:

The design of the proposed ISFSI is inadequate to protect against overheating of storage casks and of the concrete cylinders in which they are to be stored in that:

3. PFS's projection that average daily temperatures will not exceed 100 F. fails to take into account the heat stored and radiated by the concrete pad and storage cylinders.
4. In projecting ambient temperatures, PFS fails to take into consideration the heat generated by the casks themselves.
5. PFS fails to account for the impact of heating the concrete pad on the effectiveness of convection cooling.8 (Emphasis added).

In the bases for Utah H, relating to subpart 3 above, the State asserted specifically that the concrete pad and the " concrete cylinders" in which the " casks" will be stored

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"will serve as reservoirs that trap and radiate heat" and thus will have "a potentially significant effect on average ambient temperatures." Utah Contentions at 54.2 In relation to subpart 4 of Utah H above, the State asserted that "it [was] likely that additional heat from... adjacent cask [s] would increase the external and internal temperatures of the concrete storage cylinders, and therefore the maximum cladding 8 PFS does not move for summary disposition of the other four subparts of the admitted contention. S,e_e LBP-98-7,47 NRC at 253.

2 " State of Utah's Contentions on the Construction and Operating License Application by Private Fuel Storage, L.L.C. for an Independent Spent Fuel Storage Facility," dated November 23,1997 [hereinatter

" Utah Contentions"]. The " concrete cylinders" to which the State refers are the cylindrical concrete shells comprising the outer portion of the spent fuel storage cask system. The storage cask system also includes the steel spent fuel canister, which is located inside the concrete shell and which contains the spent fuel assemblies. See PFS SAR Figs. 4.2-1 and 4.2-4. The State's reference to the " casks" stored inside the

" concrete cylinders" actually means the canisters lccated inside the concrete shells.

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1 temperature." & at 54-55. Regarding subpart 5 of Utah H above, the State asserted that the concrete pads, because of their heat-retaining nature, would heat the air near the ground and thus impact the effectiveness of the ventilation systems of the casks, which l

rely on the natural convection of air from the bottom of the cask to the top. & at 55.

The State urges, with respect to all parts of Utah H, that "PFS should be required to perform the requisite calculations and re-evaluate the temperature-related design limits of the facility." & at 55.

The Applicant moves for summary disposition of subparts 3,4, and 5 of Utah H on the grounds that there no longer exists a genuine dispute concerning any facts material to the foregoing matters. The Applicant has revised its thermal analysis so as to render the issues in the pertinent subparts of Utah H moot by considering the specific factors urged by the State. In response to the NRC Staff's Requests for Additional Information

]

("RAl") 4-2,3 PFS supplied a revised Holtec thermal calculation for the HI-STORM 100 1

cask system based on an expanded thermal model which takes into account the specific 4

' actors urged by the State in subparts 3,4 and 5. Specifically, regarding subpart 3, the j

f revised Holtec thermal calculation expressly models heat stored and radiated by the concrete pad. Rampall Aff, at j 6.5 Regarding subpart 4, the revised calculation also

'" Safety RAI No. 2 Responses," submitted under letter from John D. Parkyn, Chairman, Private Fuel Storage, to Director, Office of Nuclear Material Safety and Safeguards, USNRC (Feb. 10, 1999)

[ hereinafter"RAI Resp. 4 2,"), Rampall Aff. Exhibit 2.

  • Rampall Aff. Exhibit 3.

8 The revised calculation also models heat stored and radiated by the concrete cylinders as did the original.

Thus both the pad and the concrete cylinders are now analyzed as sought by subpart 3 of Utah H. Rampall Aff. at j 6.

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l incorporates heating produced by adjacent casks. Id. at j 7. Recarding subpart 5, in the revised calculation, the ambient air is heated by the concrete pad before it enters the air inlet at the bottom of the casks. Id. at

8. Thus, no contested issues remain wit'i respect to subparts 3,4, and 5 of Utah H and the Applicant is entitled to a decision on those subparts as a matter oflaw.

III.

LEGAL BASIS FOR

SUMMARY

DISPOSITION OF CONTENTION UTAH H A party is entitled to summary disposition of all or any part of a matter if"there is no genuine issue as to any material fact and... the... party is entitled to 2 decision as a matter oflaw." 10 C.F.R. @ 2.749(a) and (d); see generaljy"Applicent's hiotion for Summary Disposition of Utah Contention C - Failure to Demonstrate Complianc: with NRC Dose Limits," dated April 21,1999, at 4-16.

IV.

THE APPLICANT IS ENTITLED TO PARTIAL

SUMMARY

DISPOSITION OF CONTENTION UTAH H PFS is entitled to partial summary disposition of Utah H because there remains no genuir.: ::; sue as to any material fact relevant to subparts 3,4, and 5 of contention Utah H.

PFS has revised its thermal analysis of the spent fuel storage casks under normal and off-normal transient conditions so as to render those subparts of the contention moot. Where 4

i a contention is rendered moot by events occurring after its admission, summary disposition is warranted.'

Subpart 3 of Utah H is moot because the revised calculation does "take into 1

account the heat stored and radiated by the concrete pad and storage cylinders." The original calculation assumed that the concrete pad was completely insulated, h, no heat transfer took place between the pad and the air or the cask. Rampall aft. at 13 (citing RAI Resp. 4-2 at 2-4). The revised calculation, however, is different in three ways.7 First, the revised calculation assumes that the exposed area of the pad, outside the area covered by the HI-STORM cask, is heated from an insolation heat flux, i.e., solar heating, and the storage cylinders or casks are subject to full insolation on their top surfaces and a view-factor adjusted insolation on their lateral surfaces. Rampall Aff. at 13 (citing RAI Resp. 4-2, at 3).s Second, conductive heat transfer takes place between the pad and the cask and the pad and the soil beneath it. Id. (citing RAI Resp. 4-2, at 3). Third, convective heat transfer takes place between both the pad and the ambient air and the cask and the ambient air and radiative heat exchange takes place between the pad and the

7 The Holtec calculation conservatively bounds the arrangement of casks that will be present at the PFS ISFSI. Rampall Aff. at1110-12.

  • The intensity of the thermal radiation impinging on the pad, and the lateral and top surfaces of the casks is derived from the standards for solar loading set in 10 C.F.R. { 71.71(c) for the analysis of transportation casks. Rampall Aff. at 16 (citing Calc. Pkg. at 5).

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storage casks and pad and ambient air. & (citing RAI Resp. 4-2, at 3).' Thus, this issue i

1 is moot and PFS is entitled to summary disposition.

Subpart 4 of Utah H is now moot because the revised thermal calculation does "take into consideration the heat generated by the casks themselves." Specifically, the revised calculation does so by imposing a reflecting and insulated hypothetical cylindrical boundary around the cask. Rampall Aff. at 17. The boundary reflects all the heat radiated from the cask surface in the lateral direction back on to the cask. & This heat reflection mirrors the heat produced by and radiated from the adjacent fuel storage casks from all sides towards the cask being analyzed. & The insulation feature of the hypothetical cylindrical boundary models the blocking of radiation by the reference cask in the lateral direction by other casks in the array, and therefore, in addition to assuming that the reference cask is heated in the lateral direction by adjacent casks, the model further conservatively assumes no radiative cooling in the lateral direction. & Thus, the insulated, reflecting cylindrical boundary surrounding the reference cask being analyzed enables the modeling of the spent fuel storage cask temperatures to take into account the heat generated by the casks themselves. & Therefore, the issue raised in subpart 4 of -

i Utah H is moot and p"'I is entitled to summary disposition.

i Subpart 5 of Utah H is now moot because the revised calculation does " account for the impact of heating the concrete pad on the effectiveness of convection cooling."

' The revised thermal model for the Hi-STORM 100 is depicted in Figure 4.2.2 of the Proprietary Calculation. Rampall Aff, at j 6.

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The Hi-STORM convective cooling effectiveness is determined by the temperature of ambient air entering the cooling ducts. Rampall Aff. at 18. The impact of concrete heating on the temperature of ambient air is accounted for in the expanded HI-STORM thermal model. Id. The revised model assumes that cooler air descending between the storage casks would be heated by the concrete pad and the concrete cask surface by thermal convection and radiation before entering the air inlet ducts. IA (citing RAI Resp.

4-2 at 3).'" The explicit inclusion of ambient air heating by heat stored in the concrete pad and the concrete cask overpack in the revised calculation therefore moots this issue as well, and PFS is entitled to summary disposition.

Thus, thermal analysis for the HI-Storm 100 storage cask system has been revised to take into account the specific concerns expressed by the State in Subparts 3,4 and 5 of Utah H." The RAI response and the Holtec Calculation package sets forth the pertinent information which shows that the factors urged by the State are now accounted for in the e

This etTect is demonstrated in the results of the analysis which show an elevation of the temperature of the air entering the cask inlet ducts. Rampall Aff at 18 (citing RAI Resp. 4-2 at 4). The heating effect of the pad on the air is depicted in Figures 4.2.3 and 4.2.4 of the Calculation Package.14

" The distances between the casks in PFS's cask array are greater than the minimum distances specified by Holtec (for which the revised analysis was performed) and therefore the revised thermal analysis bounds the PFS cask array. Rampall Aff. at1110-12. Further, due to storage system design and thermal modeling i

differences between the HI-STORM 100 and the TranStor cask systems, the calculated temperature of the spent fuel cladding from a fully loaded HI-STORM 100 cask will be greater than that from a fully loaded TranStor cask (all other conditions being equal), and therefore the Holtec analysis is again bounding.

Lewis AtT. at15.

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1 thermal analysis for the PFSF. The Applicant has expressly met the concerns set forth by the State in Subparts 3,4 and 5 and thus those subparts should be dismissed.i2 V.

CONCLUSION For the forgoing reasons, the Board should grant the Applicant partial summary disposition with respect to subparts 3,4, and 5 of Contention Utah H.

Respectfully submitted, O

Jay E. Silberg Ernest L. Blake, Jr.

Paul A. Gaukler SHAW, PITTMAN, POTTS &

TROWBRIDGE 2300 N Street, N.W.

Washington,DC 20037 (202) 663-8000 Counsel for Private Fuel Storage L.L.C.

Dated: May 19,1999 l

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" Any attempt by the State to find some new alleged flaw or mistake in the technical analysis should be rejected as a late filed contention. The calculation has been available to the intervenors for more than two months, Lewis aft. at 16, and any such new contentions would lack good cause and should be rejected.

See Private Fuel Storage, LBP-99.-3,49 NRC _, _, slip op. at 9-10 (1999)(45 days late was " approaching e

the outer boundary of

  • good cause"'). See also Board Memorandum and Order (" General Schedule for Proceeding and Associate Guidance") dated June 29,1998 at 5 ("any contention based on [the SER or DEIS/FEIS] should be submitted no later than thirty days after these documents are made available to the public").

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board j

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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STATEMENT OF MATERIAL FACTS ON WHICH NO GENUINE DISPUTE EXISTS The Applicant submits, in support ofits motion for partial summary disposition of Utah H, this statement of material facts as to which the Applicant contends that there is no genuine issue to be heard.

1. PFS's initial License Application dated June 20,1997, calculated the thermal response of the spent fuel storage cask systems to be used at the Private Fuel Storage Facility ("PFSF") for normal and transient conditions.
2. On November 23.1997, the State of Utah filed as part ofits contentions, Contention Utah H, challenging the adequacy of PFS's calculation of the thermal response of the storage cask systems.
3. In its Memorandum and Order of April 22,1998, LBP-98-7, the Licensing Board admitted the following pertinent parts of Contention Utah H:

The design of the proposed ISFSI is inadequate to protect against overheating of storage casks and of the concrete cylinders in which they are to be stored in that:

3. PFS's projection that average daily temperatures will not exceed 100 F. fails to take into account the heat stored and radiated by the concrete pad and storage cylinders.

I

4. In projecting ambient temperatures, PFS fails to take into consideration the heat generated by the casks themselves.
5. PFS fails to account for the impact of heating the concrete pad on the effectiveness of convection cooling.
4. In its response to RAI 4-2, dated February 10,1999, PFS filed a revised thermal calculation to supplement the original vendor calculations. The revised calculation was performed by Holtec for the HI STORM 100 cask system. A fully loaded HI STORM 100 cask will experience higher temperatures, all other conditions being equal, than a fully loaded TranStor cask. Therefore, the revised thermal calculation for the HI STORM 100 cask is bounding.

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5. The Holtee revised thermal calculation was based on the minimum cask separation distances allowed under the Topical Safety Analysis Report (" TSAR"),

Revision 5, for the HI STORM 100 cask system. The casks at the PFSF will be separated by distances greater than the minimum distance prescribed in the Holtec TSAR. Thus, Holtec's calculation is valid for the PFSF.

6. Subpart 3 of Contention H asserts that "PFS's projection that average daily temperatures will not exceed 100 F. fails to take into account the heat stored and radiated by the concrete pad and storage cylinders." Bases related to subpart 3 state that the concrete pad and the concrete cylinders in which the casks will be stored "will serve as reservoirs that trap and radiate heat" and (nus will have "a potentially significant efTect on average ambient temperatures."
7. The revised thermal calculation does "take into account the heat stored and radiated by the concrete pad and storage cylinders." It does so in the following respects: (1) The revised calculatica assumes that the concrete structures (i.e. the pad and the storage cylinders) are heated radiatively by the sun. The exposed area of the pad, outside the area covered by the HI-STORM cask, is heated from an insolation heat flux. The storage cylinders or casks are subject to full insolation on their top surfaces and a view-factor adjusted insolation on their lateral surfaces. (2) Conductive heat transfer takes place between the pad and the cask and the pad and the soil beneath it. (3) Convective heat transfer takes place between both the pad and the ambient air and the cask and the ambient air and radiative heat exchange takes place between the pad and the storage casks and pad and ambient air.
8. Subpart 4 of Contention H asserts that "[i]n projecting ambient temperatures, PFS fails to take into consideration the heat generated by the casks themselves." Bases for Subpart 4 asserted that "it [was] likely that additional heat from... adjacent cask [s] would increase the external and internal temperatures of the concrete storage cylinders, and therefore the maximum cladding temperature."

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9. The revised calculation does take into account the heat generated by the adjacent l

casks. Specifically, the revised calculation does so by imposing a reflecting and insulated hypothetical cylindrical boundary around the cask which reflects all the heat radiated from the cask surface in the lateral direction back on to the cask.

i This heat reflection mirrors the heat produced by and radiated from the adjacent fuel storage casks from all sides towards the cask being analyzed.

10. Subpart 5 of Contention H asserts that "PFS fails to account for the impact of heating the concrete pad on the effectiveness of convection cooling." Bases for subpart 5 asserted that the concrete pads, because of their heat-retaining nature, would heat the air near the ground and thus impact the efTectiveness of the ventilation systems of the casks, which rely on the natural convection of air from the bottom of the cask to the top.

I 1. The revised calculation does " account for the impact of heating the concrete pad on the effectiveness of convection cooling." The revised calculation assumes that cooler air descending between the storage casks will be heated by the concrete pad and the concrete cask surface by thermal convection and radiation before entering the air inlet ducts.

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