ML20234E077
| ML20234E077 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/16/1987 |
| From: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| To: | |
| References | |
| CON-#387-4457 OLA-2, NUDOCS 8709220275 | |
| Download: ML20234E077 (116) | |
Text
{{#Wiki_filter:: R 3 NA_ O L TRANSCRIPT OF PROCEEDINGS L UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD APPEAL In the Matter of: _ ) '
)
FLORIDA POWER & LIGHT COMPANY
) Docket No. 50-250-OLA-2
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(TURKEY POINT NUCLEAR GENERATING UNITS 3 & 4) )
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O _ 378
,_ Pages; 262 through 374 Place: Miami, Florida Date: September 16, 1987
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1: 262 j i__ f UNITED STATES NUCLEAR. REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD APPEAL Sac 50T&I i' In the Matter of: )
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'f FLORIDA POWER & LIGHT COMPANY ) Docket No. 50-250-OLA-2 ,
) 50-251-OLA-2 I (TURKEY POINT NUCLEAR GENERATING )
UNITS 3 & 4) ) i' Wednesday, September 16, 1987 i South Courtroom U. S. District Courthouse 300 NE First Avenue Miami, Florida
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( < The above-entitled matter came on for hearing, NZ! pursuant to notice, at 9:00 a.m. BEFORE: JUDGE ROBERT M. LAZO, CHAIRMAN , Atomic Safety and Licensing Board Panel ' U. S. Nuclear Regulatory Commission Washington, D. C. 20555 JUDGE EMMETH LUEBKE, MEMBER Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 JUDGE R; CHARD F. COLE, MEMBER ' Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 l l (Continued on next paDe.) y I WJ5 Acme Reporting Company (202) 628-4888 <
263 - O APPEARANCES: For the Nuclear Re_q_u_1_atory_ Commission: MITZI A. YOUNG, ESO. JANICE E. MOORE, ESO. Office of the General Counsel l U. S. Nuclear Regulatory Commission l Washington, D. C. 20555 For the Florida Power & Liaht Co.: STEVEN P. FRANTZ, ESO. Newman & Holtzinger, P. C. 1615 L Street, N. W. , Suite 1000 Washington, D. C. 20036 NORMAN A. COLL, ESQ. Coll, Davidson, Carter, Smith, ' Salter & Barkett 3200 Miami Center 100 Chopin Plaza Miami, FL 33131 Eor the Intervenor: JOETTE LORION Director Center for Nuclear Responsibility, Inc. 7210 Red Road, #217 Miami, FL 33143 x J Acme Reporting Company - (202) 628-4888
264 I 1 INDEX 4
.-x I J n> 2 WITNESSES: DIRECT CROSS REDIRECT RECROSS EXAM l 3
Gerald Kelp 265 4 William Boyd 265 l 1 5 Russell Gouldy 265 ! Mitzi A. Young 300 375 ! 6 7 James Wing 336 340 l g Conrad E. 336 340 l McCracken 9 Laurence I. Kopp 336 340 10 11 12 s t i 13
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265 1 PROCEED I NGS 2 JUDGE LAZO: Would the hearing come to order, please. 3 Ms. Lorion, are you read to proceed with cross-4 examination? 5 MS. LORION: Yes, I am. 6 JUDGE LAZO: Dr. Kilp, Mr. Boyd, you remain sworn. 7 Whereupon, 8 GERALD KELP g 9 WILLIAM BOYD 10 RUSSELL GOULDY 11 ha'.d.ng been previously duly sworn, were recalled as witnesses 12 herein and were examined and testified further as follows:
' J 13 CROSS-EXAMINATION (Continued) 14 BY MS. LORION:
15 Q Dr. Kilp, before I go on with the testimonies here, 16 we talked yesterday about the blackness tests on Turkey Point 17 and the gamma radiation that the fuel had been exposed to. And 18 I think in a Florida Power & Light letter dated August 20, 19 1987, it says, " Surveillant results from Unit 3 spent fuel pool 20 to the Lt. S. Nuclear Regulatory Commission." It states that, 21 " Calculations indicate that the accumulated gamma dose would be 22 7.8 times 10 to the 9 rads assuming an infinite array of 23 storage cells each containing a spent fuel assembly with an 24 average burnup of 36,000 MPd/MTU stored for one year." 25 And then you had indicated that for two and a half
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</ T 266 1 years that would be hiDher. I noticed in reading the NRC's 2' testimony on this contention that they took the 7.8 times 10 to 3 the 9 as the accumulated gamma exposure at the time of testing. !
l 4 And'so I think it's really important to know exactly what the 5 exposure was at the two and a half year period, and I was 6 wondering if you could tell us that or calculate that for us. ! 7 A (Kilp) Well, I certainly can' t calculate it, and I I 8 don' t think I could make a very good guess, but we could put it 9 between two bounds. It has to be between the number you just 10 mentioned and 1.2 times 10 to the 10th. 11 Q And that was after five years. 7-% -12 A (Kilp) That would be after five years. (/ 13. Q So you can' t even make a rough estimate of what it )
.q 14 would be?
l 15 I just think it's rather important in light of Point j 1 16 Beach and Quad Cities to know what it was at the time of i 17 testing. 18 MR. FRANTZ: I think he has already answered that. 19 He can' t make the calculation. He can put it between two q 20 bounds, and that's the best he can do. I think the question 21 has been asked and answered. 22 BY MS. LORION: l l 23 Q So then the answer is, is that we don' t know in any [ 24 of the papers exactly what gamma dose the fuel had received at 1 25 the two and a half year testing point for the blackness (s l Heritage Reporting Corporation (202) 628-4888
s ( 267 1 testing., 2 A (Kilp) We don' t know exactly the gamma dose, no. 3 Q Okay. Going back to the testimony, and this is the 4 testimony of Dr. Kilp and Russell Gouldy, and I think we ended 5 up on about page 32. 6 This question is to either of you, and the statement i 7 reads, "FP&L surveillance program in blackness testing will be 3 8 sufficient to detect any changes in the neutron attenuation 9 properties of the Boraflex and any changes in the physical 10 distribution of the Boraflex." 11 Isn' t it a true statement that so far Florida Power & l eg 12 Light surveillance program is only sufficient, or only has been
'/ f J 13 sufficient to detect changes that were not -- that were 1. 5 14 inches or greater, in gaps, in measuring gaps in the Boraflex?
f 15 A (Gouldy) Yes, according to Dr. Turner's report, 16 that's what he has a high level of confidence of being able to 17 detect. < 18 0 On page 34, we' re talking about -- again it says 19 both, so it's to either of you. If degradation of the Boraflex 1 20 were to occur unexpectedly at Turkey Point, there would be no 21 impact on the public health and safety as explained in the 22 I itensing Board's memorandum and order of March 25, 1987 at 23 page 58. The boron in the Turkey Point spent fuel pool water 24 would keep the pools within their K-effective limits even if it
/"'N 25 assumed that the spent fuel storage racks do not contain any f
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268 ( l l 1 Boraflex. 2 Isn' t it true that the objective of the 95/95 3 standard is to maintain the racks with -- fully loaded with 4 fuel of the highest anticipated reactivity and flooded with 5 unborated water at a temperature corresponding to the highest 6 reactivity? 7 Isn' t the 95/95 standard -- 8 A (Boyd) I think it's .95 K-effective is the standard 9 that we look at. 10 Q But don' t we look at it -- I mean, as a standard 11 looking at a pool with unborated water? I mean, shouldn' t it 12 met it in a pool is unborated water is the question I' m asking. 13 A (Boyd) That's correct. 14 O So then your statement about it would meet it because 13 you would have the boron in there -- I just don' t understand 16 that statement because you are supposed to be able to meet it l 17 without the boron in there; i sn' t that correct? 18 A (Boyd) The boron is not considered in the normal 19 criticality analysis, but in reality is it in the spent fuel 20 pool. But there is a condition meaning you can consider the 21 presence of boron in the water and that would be under some 22 condition that you consider an accident. 23 So if you consider the Boraflex will totally 24 disappear, 1 believe you could consider that an accident. And 25 we' re saying with the boron in the water, we could still meet Heritage Reporting Corporation l (202) 628-4888 l l
i L/ e69 1 the .95 if the Boraflex totally disappeared. 2 O But I' m asking, aren' t you supposed to be able to 3 meet the .95 without any boron in the water? 4 A (Boyd) We have met the .95 without the boron. 5 Q The next -- 34 and 35, it seems like a lot of it -- 6 Mr. Boyd, is your - paraphrasing your testimony, so I am going 7 to try to go to that too. i 8 You say that the Turkey Point spent fuel pools would 9 remain within their -- and this is on page 34 of the -- not 10 your testimony; the Kilp - Gouldy testimony -- with storage 11 of -- that you would meet -- Turkey Point spent fuel pools g"T' 12 would remain within their .95 K-effective limit under the
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b~O) 13 following postulated conditions. And then you have the storage 14 of 4.2 percent enriched fuel which is the maximum enrichment 15 planned for operations of the Turkey Point reactors prior to 16 the next surveillance and testing of the Boraflex in 17 approximately three years. 18 The stored fuel would remain within in K-effective 19 limits with 3.5-inch Daps in the center of each Boraflex panel. 20 3. 5 inches is equivalent to 2.5 percent of the length of the 21 Boraflex panels. 22 Now isn' t Turkey Point allowed to store fuel enriched 23 to 4.5 percent? 24 A (Boyd) Yes, it i s.
.f 25 Q And I think from the next paragraph on 35 it'-- first l
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270 1 of all, let me'ask you. Would the 4.1 percent enriched fuel 2 meet the .95 K-effective if you had gaps over 3.5 inches? If 1 3 you had a gap of 4 inches, would it meet it? ] 4 A (Boyd) Would you. repeat that? i 5 Q Yes. Would the -- maybe it would be easier if we go 6 to your testimony. I 7 A (Boyd) Okay. l l 8 0 Okay, and you have some charts attached to it. j 9 Figure 2, and I think this is a picture of the 4.5 percent fuel 1 10 enriched, right? l l 11 A (Boyd) Right. i
,7' 12 Q And then Figure 3 is the 4.1 percent enrichment. !
k~ 13 A (Boyd) Correct. 14 0 Okay, where you have gaps in all four plates on 15 Fi Dure 3, the line there, this is at 4.1 percent enrichment. 16 A (Boyd) Okay. 17 Q Is it fair to say that from this chart'that at about I l 18 3. 5 inches you would exceed the .95 K-effective -- 19 A (Boyd) You would -- 20 0 -- if you had gaps in all four plates? 21 A (Boyd) If we had gaps in all four plates, and there 22 is 4.1 weight percent, you can array with no burnup, there was 23 no boron in the spent fuel pool, we have a low water I 24 temperature corresponding to cur full water density, we had no l
/ ) 25 fissure parts with U-234 or 236, and not considering some of u> 8 i
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J 1 l Fl LJ 271 j 1 1 the structure in the racks, it's possible that we could exceed a j 2 . 95. 3 Q In this kind of abnormal condition is what you are 4 saying. Being an abnormal condition, but you could exceed. 95.
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a 5 A (Boyd) With all those conservatism conditions, yes, ( 6 it's possible to exceed . 95. 7 Q And doesn' t the standard require you to meet the .95 8 K-effective even in an abnormal condition with unborated water? 9 A (Boyd) No, it doesn' t . 10 G It doesn' t. ; 11 A (Boyd) It requires me to meet the .95 in a normal jf-) 12 condition with unborated water. Abnormal, I could take'eredit 1 1 E*d ' 13 for all of these. 14 O You can take credit for that. , 15 So say at Quad Cities where they developed 4-inch 16 gaps, okay, and you had 4-inch gaps in all four plates, there 17 is a possibility at Turkey Point that if you had fuel enriched 18 to 4.1 percent, you would not meet the .95 K-effective. 19 A (Boyd) My understanding of Quad Cities, they only 20 had one or two gaps that were 4 inches. In fact, I think most 21 of the gaps were around an inch and a half. So my 22 understanding of the report at Quad Cities and the data that 23 ca;ne out of there if they were imposed on Turkey Point, I don' t l [ 24 believe they would exceed the .95 limit even without f#e) , %A 25 considering boron and all these other conditions. l Heritage Reporting Corporation (202) 628-4888 l
i%-)- l 272 l
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1 Q Okay. But is it fair to - going back to this 2 testimony and also the testimony in the Kilp - Gouldy page 35 3 there. Is it fair to say that -- you are saying that fuel with 4 a 4.1 enrichment will meet the .95 K-effective as long as it is 5 not -- does not have gaps for -- excuse me -- gaps in all four j 1 6 plates greater than 3.5 inches; is that-what you are saying? l 7 A (Boyd) That's part of what I' m saying. It also has 8- to have no burnup on it; has to be fully loaded rack and 9 looking at an infinite array condition.- In addition, no boron, 10 no U-234 or U-236 which are poisonoun to the neutrons and which j 11 would reduce reactivity. g 12 These other conditions, the water temperature or : N.,s < 13 densities vary -- the temperature is very low, density very i 14 high, assuming water density of one which essentially is .l l 15 nonachievable in the spent fuel pool. ) i 16 O Do you happen to know if the NRC safety evaluation or i i 17 your criticality analysis or any of your safety documents , 18 looked at an accident, a criticality accident as an accident q 19 that could cause damage to the spent fuel pool? 20 MR. FRANTZ: I object to that question. It's outside l 21 the scope of the contention. I 22 MS. LORION: I think we are going to have fights over j l 23 criticality today, so maybe we should resolve it right now. j l 1 24 JUDGE LAZO: Ms. Lorion, perhaps you might explain to { 1 l ((~)\ 25 the Licensing Board what it is you are hoping to develop here, t t- . 4 Heritage Reporting Corporation (202) 628-4888 l
ma- ; b 1 1 1 y + LJ 273 1 MS. LORION: WhentheNuclearRegulatorh' Commission 2 stated that reracking of the spent fuel pool was a no 3 significant hazard, they declared that there would be no 4 accidents previously analyzed that they could see in this 5 amendment request. A previously e.nalyzed accident in spent 6 fuel storage is a criticality accident caused by a loss of l 7 poison. Boraflex is a poison. It's exhibitinD gaps in the i i 8 Quad Cities plant. If gaps are exhibited, it affects the j i 9 criticality, and criticality affects that chance of an 10 accident. i 11 And I' m trying to get at the relationship between his
,,/^ . 12 analyses that .95 K-effective and criticality accidents, and if
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13 that was looked at. 14 MR. FRANTZ: Judge Lazo, I might say, first of all, 15 that to the extent she is trying to tie this to the no 16 significant hazards consideration analysis, that has already 17 been ruled on the Board. That is outside the scope of this. 18 type of proceeding. 19 Tc the extent she is trying to look at the impacts of 20 the criticality accident, again that seems to be outs 1de the 21 scope of the contention. I have no problem if she is 22 questioning what the impacts of various sized gaps would be on 23 the K~ effective. I think that is within the scope of the 24 contention. 25 JUDGE LAZO: Yes, surely. Heritage Reporting Corporation (202) 628-4888
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- l. 1 Mrs. Young, do you have anything to add to this i U l 2 discussion?
3 (Pause.) 1 1 4 MS. YOUNG: Generally, the staff concurs with Mr. 5 Frantz's objection and agrees that the analysis of criticality 6 accidents would be outside the scope of this contention as 7 posed. 8 JUDGE LAZO: Well, we are going to sustain the 9 objection, Ms. Lorion. As Mr. Frantz indicated, of course, you 10 are not restricted in' discussing the impact of gap size on 11 K-effective, l e- 12 MS. LORION: I understand. I would like to add some l v 13 thing though. ; 14 In documents I received from the Board that talked 15 about the' degradation of Boraflex, they stated that the staff 16 was going to reassess Contention No. 10 which was about f i 17 criticality. And before this hearing I never received a notice 18 of whether they were going to consider that contention based on 19 the new information at Quad City and Point Beach. 20 JUDGE LAZO: Perhaps you misspoke, Ms. Lorion. I l l 21 don' t think you received that from the Board. It probably was I r 22 a Board -- t 23 MG. LORION: I mean from the staff. 24 JUDGE LAZO: From the staff. i i
/~h 25 MS. LORION: Yes, excuse me. Order from the staff.
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) 1 , JUDGC 4.P.-ZG: Wej 1, Mr. Frantz, do you have -- I h!; F * :)
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; (2 MM. FRANTZ: I w$ sh Ms. Lorion'Noulo be more i
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4 . hE,'VOUNG: I t:Tink I ran'be of assistance, j
! , J e 1 L' y 5 In ths, staff's Soard notification to this Board which 6 distributed the. Quad, Cities and Point Beach repcrts --
J 7 1 ? MR. FRANTZ,: Yes. f
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8 ' MS. YOUNG: -- discovering the carra, the staff had
,9 mentfcned.that tr.ose reportm touched on sorwa aspects of I
,10 Cont nirib ion 20. Anti , you know, it's basic information to the 1 ; .
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11 Board,',and ther.-Sad made a statement in that Board notification ., fS 12 lthat wer w ou f 'd keep the:Boacd apprised of any developments on I J {'/) 13 i issue after that po2nt
} Che B.:>ra fl ex f N / 01R. FRANTZ: I think borth our testimony by Mr. Doyd 15 '[eddresses criticality. The shaft' hes testimony which also ,
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16 siddresses . cr i t i er.,l i ty. I th ir4' we have done everything that we 1 i
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, 10 < JUDGE LAidf Well, now I don' t understand you, Mr.
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19 lFeantz. You are saying the staff ancI the liceresee have both i
- 20. addressej criticality, but -- ;
> l l 21 MR. . $'n ANT Z : I' m sorry --
l i l j 22 JUDGE L.AZC: --- M s . Lorion cannot? l r 1 I 23 MR. FRANTZ: We have addressed not criticality, but l 24 K-e f f ec t: is e. l } I
' I 25 JW GE LAZO: All right.
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.L/ 276 1 MR. FRANTZ: And whether'we' meet the K-effective 2 limits. And that is all we need to do I think in this 3 proceeding. That is all we are required to do to address thin 4 contention. 1 And I don' t think anybody has ever suggested that
) 5 we address the impacts of criticality accidents here. 6 MS. LORION: I believe that the Board stated, and I ! 7 could look it up, that they were reanalyzing Contention 10 in O light of this new information to see if they were going to look 9' at it e t' h e a r i n'g , and I never received any notice what they are 10 looking at it entailed, and what they decided. i 11 MR. FRANTZ: Contention 10 does not deal with
,rw 12 criticality accidents. It deals with meeting the H-effective a
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13 limits, and that's been disposed of by the Board already 14 through a motion for summary disposition. I 15 We in our testimony have addressed the impacts of 16 gaps on K-effective, so has the staf f's testimony. And to the 17 extent you want to characterize that as being a reconsideration 18 of Contention 10, it's really of no importance here. The fact 19 of the matter is both the staff and FPL have analyzed.the 20 impact of gaps and criticality on K-effective, and have shown 21 that we can meet the K-effective limits. 22 JUDGE LAZO: Ms. Lorion, let me again correct you. 23 It was not the Board but the staff that indicated they were l [~ 24 going to -- 1
,I 25 MS. LORION: Oh, sorry.
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(~ r 4 E_j 277 1 JUDGE LAZO: -- analyze regarding Contention 10. 2 MS. LORION: Excuse me. 3 JUDGE LAZO: And we, too, recall receiving that l l 4 notification. 5 MR. FRANTZ: In any case, Ms. Lorion, I might point l l 6 out that what the staff may or may not have said in that Board 7 notification certainly has no bearing upon what we are trying 8 to address here. The staff can do what it wants to do. That 9 does not affect the issues we have to address here in this 10 contention. 11 MS. LORION: Perhaps we should just proceed until we
/~N 12 reach our next impasse.
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13 MS. YOUNG: Well, let me just state one thing for the 14 record. I am reading from the staf f's Board notification dated 15 June 15, 1987. And there is a sentence in there which states, 16 "The staff is examininD new information about Boraflex to 17 ascertain whether it would affect the staf f's February 18, 1986 18 response to licensee's n:ot ion for summary disposition and 19 affidavit concerning Contention 10. This contention was 20 summarily disposed of by Board order dated March 25, 1987 and 21 addresses possible spent fuel pool criticality." 22 That's what the staff stated in its Board 23 notification. As a result of our testimony in this pr oceed ing, 24 we have taken a position that the evidence on Contention 10 is h 25 adequate. It does not need to be reopened, but we have l Heritage Reporting Corporation (202) 628-4888 L___________._
s' * , Y: i . d, , f. 278-1- addressed the analysis of criticality with respect to 2 Contention'6. 3 JUDGE LAZO: .Has that staff position been put in the
;4 record,.or are you putting it in now?
5 MS. YOUl4G: Well,'it was basically kind of.a passive 6- position from the fact that. we didn' t file a motion to reopen. 17 But,we do have the affiant on Contention 10 h'ere and he is 8 available for questioning on whether he has changed his 9 conclusions-in his affidavit on Contention 10. EndT1' 10 JUDGE LAZO: All right, thank you, Mrs. . Young. 11 BY MS. LORION: t 12 Q Mr. Boyd, .can you tell rme what the purpose is of the f' 13 .95 K-effective limit? 14 -JUDGE COLE: I' m sorry, .I didn' t hear the first part 15 of that. question. I' m sorry. 16 BY MS. LORION: 17 Q Mr. Boyd, could you tell me what the purpose is for 18 the .95 K-effective limit?
- 19 A (Boyd) Well, .95 K-effective limit is the 20 K-effective value that assures a substantial margin for 21 criticalities reached.
l 22 O At what point would fuel become critical? 23 A (Boyd) At 1. 24 O At 1. 25 What is criticality? Heritage Reporting Corporation (202) 628-4888
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,[ 279 1 A. '(Boyd) Criticality is the process'in which a number 2 of neutrons produced by fissioning is' equal.to the, number off 3; neutrons lost in leakage or. absorption into the elements.
L4- -Q What could be.the result of this fuel ceaching
-5 criticality?
6 MR. FRANTZ:' I object. We have already had a ruling 7 from the Board that the impacts of criticality-are beyond the 8 scope of this contention. 9 JUDGE LAZO We' ll sustain the objection.
- 10. MS. LORION: . Well, maybe we will go back to the track 11 we were on before we started this.
12' BY MS. LORIDN:
'& 13 Q Did you perform the original criticality analysis for 14 the:reracking?
15 A (Boyd) I did work with.that, yes. 16 'O And is it accurate to state that the K-effective
~ 1 '7 limit as a result of that' element analysis was .94037 18 A (Boyd) For Region 1, it was.
19 Q For Region 1. 20 And the limit again is .95, am I correct? { 21 A (Boyd) Yes. j 1 22 Q Is it fair to say that there is not a large marD n i I 23 there to deal with before you get to .957 ! 1 i l 24 A (Boyd) No, I would say there is a substantial margin l (~' i l - 25 there. I l L Heritage Reporting Corporation ] (202) 628-4888 j i 1 L _ __
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} V- 280 i L 1 Q And why would you say that? p l 2 A (Boyd) Well, I would say that based on my experience L l 3 as a core designer. Typically when we design the core,.we are i j 4 predicting K -- infinity of K-effective for the core within
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5 .2 .3 percent. And if there was a 1 percent error in our L I L 6 core prediction, the core would have to shut down. So now I 7- have a 1 percent margin on top of a 5 percent margin for 8 K-effective of 1, and to me that's substantial margin. , l j 9 Q Going back to the charts again. With the part Figure l l-10 the 4.1 percent enrichment, could you explain that chart, 3, 11 please?
/'S 12 MR. FRANTZ: I believe that question is so vague and 13 general that it's not capable of a reasonable answer. Be more 14 specific, Ms. Lorion.
15 BY MS. LORION: 16 O Could you explain the information -- I mean, not the 17 numbers, but what you mean by gaps in two of four plates, gaps 18 in all four plates? 19 A (Boyd) Okay, if you picture the design of the fuel 20 racks, there is essentially a can around every fuel assembly. 21 On each face of that can there is a Boraflex sheet. So i f you 1 22 imagine just one can, an infinite repeating array of thoue 23 cans, when I say gaps in all four plates I' m saying that i 24 looking at one can, there is a gap in every plate around that
/ ) 25 can at the same elevation. And that is repeated on an infinite LJ Heritage Reporting Corporation (202) 628-4888
l L2 281 1 array basis. 2 O And why did you choose gaps in all four plates? Is 3 that a conservative -- f 4 A (Boyd) Obviously. 1 That's the conservative figure. / 5 Q 6 A (Boyd) And getting worse. a 7 Q Okay. Now if you have fuel enriched with 4.1 percent i 8 uranium, is it fair to say from this chart that if you have j 9 4-inch gaps in all four plates, that you would pass the .95 10 K-effective limit just a little over -- if you had 4-inch gaps 11 in all four plates? ll gG 12 A (Boyd) If we had 4-inch gaps in all four plates, and l } 13 all the other conditions I mentioned earlier, fresh fuel and no 14 burnup, no U-234 or 235, no boron, and so on, it is possible, 15 yes, that we can exceed . 95. 16 Q Can you tell me why Florida Power & Light is stating, f 17 or has stated in their newest letter to the Board of August 18 31st, and I' ll just read you a piece. This letter states that, 19 " Turkey Point will not store fuel with an enrichment of 4.1 4 20 percent prior to the completion of the next surveillance 21 testing of Boraflex in approximately three years." i 22 PaDe 2, "A sensitivity analysis has indicated that 23 the Turkey Point spent fuel pool will remain within their .95 24 K-effective limits assuming each storage cell in the racks ) 25 contains a fuel assembly with an enrichment of 4.1 percent and HeritaDe Reporting Corporation (202) 628-4888
vf'Y, y V. . 282.
;1, each Boraflex plate in the cells has a gap of 3.5 inches."~
^ 2 Do you happen to know why Florida Power & Light is
- 3. limiting themselves to an enrichment of 4.1 percent? {
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'4 . MR. FRANTZ: I' m not sure that you have properly l
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5- characterized it. What we are saying there is that'we will 6 not.- I' m not sure we'have gone beyond that, that there is any 7 limit in our license or any other thing that prohibits us from 8 doing that. We have just stated that we will not from various 9 considerations, including if you read the attachments, the fact ,j 10 that our' current enrichment is only 3.4 to 3.6 percent,. and
.11 that we can only increase -- for practical reasons we can only o
12 increase that enrichment approximately 1 or 2 percent per 13- cycle. 14 BY MS. LORION: ! 15 Q Do you know, Mr. Boyd, is Florida Power & Light has I 1G been licensed to use an enrichment of 4.5 percent in, or stores i I 17 fuel with an enrichment of 4.5 percent? 18 A (Boyd) Yes, they have. 19 Q They have. 1 20 Going back to Figure No. 2, your chart there. If i i l 21 Florida Power &-Light were to store fuel enriched to 4.5 q 22 percent with gaps of 3.5 inches, wouldn' t the be well over the 23 .95 K-effective according to this sensitivity analysis? - 24 A (Boyd) With this sensitivity analysis and with all j 25 the conservatism I applied or eight conservatism, it is I i l l Heritage Reporting Corporation j (202) 628-4888 q i _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ .J
..m by 283 1 possible they could exceed a .95 limit.
2 Q Have there been -- has FPL placed any restrictions on 3 itself not to use 4.5 enriched fuel? 4 A (Boyd) I don' t know. 5 0 You don' t. 6 Getting back to the testimony of Mr. Kilp and -- or 7 Dr. Kilp and Mr. Gouldy on page 39. I think you corrected your 8 testimony, Mr. Gouldy, to read, or it's both of you, I guess, 9 on page 39, answer 36 where you have, "The results of the 10 blackness test at Turkey Point Unit 3 indicate that the { 11 Boraflex panel do not have gaps." ['Sj 12 You corrected it to read, "The blackness testing at i
~ ~ '
13 Turkey Point had the capability to detect Daps of approximately 14 1 to 1 and a half inches or greater"; is that correct? 15 A (Gouldy) That's correct. 16 Q So then that -- the line that -- it indicates the 17 Boraflex panels do not have gaps has to be qualified; am I 18 correct? I mean, can you state -- 1 19 A (Gouldy) I had received a report from Dr. Turner 20 after filing this testimony, and that's -- af ter reading his 21 report, looking at his conclusions, had to make this 22 correction; t hat 's correct. j 1 23 O Thank you. f 24 Also a little farther down it says, "During 25 fabrication a cut-to-length sheet of Boraflex was attached to f ) i Heritage Reporting Corporation (202) 628-4888
if '% ss 284 1 one wrapper panel with adhesive applied in short lenDths at a 2 maximum of 16 places along the Boraflex." And then you have a 3 correction there, paDe 39, line 15. 4 " Initially during manual fabrication no adhesive was 5 used to attach the Boraflex panel to the wrapper. 6 Subsequently, the fabrication process was automated. During 7 automated fabrication, a cut-to-length sheet of Boraflex was 8 attached to one wrapper panel with adhesive applied,*in short 9 lengths at a maximum of 16 places ulong the Boraflex." 10 Are there any potential problems with using an 11 adhesive to attach the Boraflex
,/~'s 12 A (Gouldy) I don't know.
() 13 0 You don' t know? 14 You haven' t read that there might be some potential 15 problems in the Point Beach or Quad Cities report? 16 A (Gouldy) Yes, the Quad Cities report, in their 17 fabrication and design indicated adhesive was used. 18 Q There is a footnote here that FPL -- "FPL has 19 determined that none of the Region 1 racks at Turkey Point 20 utilized adhesive. And that some of the Region 2 racks at l 21 Turkey Point utilized adhesive. l i 22 So some of the racks have adhesive and some don' t, is 23 that what you are saying? l 24 A (Gouldy) That's correct. A review of the records, 25 fabrication records, it's shown that adhesive was used on some l Heritage Reporting Corporation I (202) 628-4888 l l l _ )
kJ 285 1 of the racks, Region 2 racks. - 2 O And it goes on to say that, "FPL was not aware of 3 this at the time of the August 1987 blackness testing. FPL has 4 subsequently determined that none of the racks utilized for 5 blackness testing at Turkey Point utilized adhesive to attach 6 Boraflex to the wrapper." 7 If in the Quad Cities report the presence of 8 adhesive, it was stated that it might have posed a problem with t 9 the Boraflex. The fact that none of the racks you tested { 10 utilized the adhesive, does that have any significance? 11 MR. FRANTZ: I am going to object to that. I don' t
/"T 12 believe that the Quad Cities report says that the use adhesive I l e
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13 is a problem. That's not been established in the record. All 14 Mr. Gouldy has testified to is that the Quad Cities racks did 15 use adhesive. 16 JUDGE LAZO: Well, the fact that the matter's been 17 brought up indicates there is some issue involving the use of 18 adhesives or not. 19 MR. FRANTZ: Yes, I agree, Judge Lazo. But all I am 20 saying is that the report itself does not characterize the use i 21 of adhesive as the problem or the cause of any problem. 22 JUDGE LAZO: Yes, and Ms. Lorion is trying to find 23 out if it can cause a problem. 24 MR. FRANTZ: Okay. Her question implied that it was 25 a problem, and I thought that she was asking him to make some Heritage Reporting Corporation (202) 628-4888
j l I f s- 286 1 judgment based on the existence of a problem using adhesive at 2 Quad Cities. 3 JUDGE LAZO: Yes, you are correct, and perhaps Ms. 4 Lorion can rephrase the question. 5 BY MS. LORION: 6 Q Okay, is there a possibility -- okay, if you had 7 tested the racks that had adhesive, is there a possibility that 8 the test results would have been different? 9 MR. FRANTZ: I object. That calls for speculation. 10 JUDGE LAZO: Well, does the witness know? 11 THE WITNESS: (Gouldy) When I set up the test
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1 12 program, I utilized the section of the racks that had the -- i
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13 represented the highest radiation dose exposure for Region 1, 14 Region 2. Limited amount of fuel we had to move to limit the 15 radiation dose the workers received. In that area, from the : 16 results of the Westinghouse review, did not use adhesive, or i 17 had not used adhesive. 18 JUDGE LAZO: Did you know that at the time? 19 THE WITNESS: (Gouldy) At the time, no. And that's 20 why I had to reissue some testimony here. 21 The areas that did have adhesive used had such old 22 'uel in it or no fuel stored in it if radiation is the cause of 23 shrinkage in there, the gap, I wouldn' t expect any to be in 24 those because of the fuel that is there or no fuels in those 25 racks. Heritage Reporting Corporation (202) 628-4888
1 l l r'i l Lj 287 1 So we picked the area that had the highest radiation 2 dose and examined those. So I had to change the testimony that 3 I expected the area we picked was the highest received dose in 4 that pool at that time. 5 JUDGE LAZO: Thank you, Mr. Gouldy. 6 BY MS. LORION: 7 O Do you know, Mr. Gouldy, what effect the use of 8 adhesive could have on the Boraflex from your reading of the 9 Quad Cities document or any other of the documents? 10 A (Gouldy) They were suggesting binding caused by the 11 adhesive I believe in the Quad Cities report.
,r] 12 Q And what would the binding cause?
( )
J 13 A (Gouldy) Did not allow for shrinkage.
14 Q Ond so then it -- 15 A ( Go u l d y-) In their design. 16 Q Could that potentially cause gaps, or breakage? 17 A (Gouldy) I' m not sure. 18 Q Thank you. 19 On page 41 you' re talking about the -- line 6 and 20 down -- how the -- the Boraflex panels in use at Quad Cities 21 had experienced shrinkage and cracking at 10 to the 9 rads 22 gamma in the Boraflex surveillance capsules, but not the 23 Boraflex plat ers in use at Point Beach have experienced some 24 degradation at 1 times 10 to the 10 rads gamma. However, the 25 Boraflex used at Point Beach and Quads Cities is capable of Heritage Reporting Corporation (2O2) 628-4888
- m. !
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( B y'Y Rf gae 1 performing its' intended-safety function despite the
- 2 degradation.
- 3. I ' don' t know'who wrote that, but.what is the: basis r i
!4 for-that statement? .f L !
5 A. (Gouldy) The -- l 6 O About the degradation; that. it's capable of. { 7 performing its intended safety function despite the 8 degradation., 9' A (Gouldy) The cover. letters attached in the, reports
' 10~ of thel surveillance from Point Cities, or Point Beach and Quad-11 Cities indicated that they still met their .95 K-effective 12 requirement, and as such, the material was still capable of ,f.
13 performing its intended function. , 1 14 Q Do you remember also in that letter that -- or in the 15 report that. Quad Cities -- about Quad Cities where they said 16 that they would have to do more calculations to see if they had 17- larger gaps and more gaps if they would still meet that limit, 18 do you remember reading anything about that?
'1 19 A (Gouldy) Yeah, that was a preliminary report. !
- 20 MS. LORION: I would like to, first of all, have )
)
.21 these reports both entered into the record because I think they ]
i 22 are very important. i 23 MR. FRANTZ: There has been no foundation for ) I 24 admission of those reports into the record. I i 25 MS. LORION: I think in terms of knowing of the l Heritage Reporting Corporation ) (202) 628-4888 i l 1
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y E. 289 1 Turkey Point. plant;is going to meet the .95 K-effective and if 1 2 the'Boraflexlis. going-to degrade to unacceptable levels, that
- 3. these reports'are really_.very important reports in terms of 4 judging what Florida Power & Li D ht is saying as opposed'to what 5 other' reactor operators are saying.
6 MR. .FRANTZ: Judge Lazo,.those reports contain
'7 conclusions, they contain' analysis. The authors'of those 8 reports are not here. We cannot cross-examine them. I don' t t
E9 believe there is sufficient ~ evidentiary basis for admission of-10 those reports into evidence,' -and we object to their admission. 11 . JUDGE LAZO I' m not sure that we have fully 12 identified the reports we are speaking of yet. What are these,
* ~2 .13 part of the reports that were sent to the Board by staff.in the 1
14 Board notification? 15 MR. FRANTZ: I believe those are -- l 16 JUDGE LAZO: Or were they sent by Florida Power & 17 Light? 18 MR. FRANTZ: ' I believe those reports were sent via a 19 Board notification by the NRC staff. 20 MS. YOUNG: Yes, Judge Lazo. The Quad Cities and. 21 Point Beach reports were distributed by Board notification 22 entitled Board Notification Regarding Brookhaven -- oops. 23 I' m sorry. Board Notification Regarding Anomalies in Boraflex 24 Neutron Absorbing Material, BN-87-11, dated June 15th, and the 25 two reports attached. Heritage Reporting Corporation (202) 628-4888
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~1 One was forwarded by cover letter dated February 11, 2 1987 to the Nuclear Regulatory Commission; attention, Mr.
3 George Lear, Director, PWR,. Project Director 4 No. 1. 5 And the second report on'Uuad Cities is distributed i 6 by cover letter dated May 5, 1987, to Abert Davis, Regional 7 Administrator, U. S. Nuclear Regulatory Commission, Region 3. 8 JUDGE LAZO: Well, Ms. Lorion, it's rather late in 9 this proceeding for admitting these reports and eliciting 10 testimony on them. 11 MS. LORION: Well, perhaps I could just ask you to
. /"'N 12 take official notice of the reports, and I could read some 13 pieces of the reports as I' m reading Florida Power & Light's 14 testimony, because I think some things in the reports conflict 15 with what Florida Power & Light is saying.
16 MR. FRANTZ: I object to the extent she wants the ! 17 Board to take official notice of this. Again, there is not any 1 18 grounds for official notice of this type of report. j 19 Second of all, the mere fact that Ms. Lorion reads f d 20 something does not make that evidence, does not make that 21 something that can be relied upon as part of the record. Only 1 22 the witnesses' statements become part of the record, not 1 1 23 statements by counsel. She can read all she wants to. Unless i 24 she gets the witnesses to agree to the truthfulness of those l ( ) 25 statements, there is nothing in evidence. U Heritage Reporting Corporation (202) 628-4888
i 1 j r ' "i LJ 291 ! 1 JUDGE LAZO: That's the problem, Ms. Lorion. Of )1 2 course, we can take official notice of any agency document. 3 But these are Westinghouse documents. 4 MS. YOUNG: Judge Lazo, these aren' t Westinghouse i 5 documents. They are reports prepared by I think consultants ) 6 for Point Beach and Quad Cities. 7 JUDGE LAZO: I see. 8 MS. YOUNG: The staff has no objection to Ms. Lorion 9 asking questions about the reports attached to the Board 10 notification. I think that's a proper scope of inquiry. But I 11 would also concur With Mr. Frantz that they should not be
'"; 12 received in evidence since we don' t have the witnesses to
~5 13 support their admission.
14 JUDGE LAZO: Are these witnesses -- are any of them 15 familiar with the documents, or do they have copies of the 16 documents? 17 THE WITNESS: (Kilp) I' m familiar with them. 18 THE WITNESS: (Gouldy) I' m familiar, but don' t have 19 a copy. 20 JUDGE LAZO: Well, Ms. Lorion, why don' t you proceed 21 if you have a copy that the witnesses could be provided. Let ' s 22 see how far we can go without getting into a barrage of 23 objections. ! EndT2 24 MS. LORION: Thanks. Heritage Reporting Corporation ! (202) 628-4888
g) l ) F -( 292 1 Q Okay, back to page 41, and I think I just asked 2 about starting at line 11, "however, the Boraflex in use at 3 Point Beach and Quad Cities is capable of performing its 4 intended safety function despite the degradation," and asked 5 your basis for that statement. I wonder if you could answer 6 that again, I really lost track. 7 A (Gouldy) Okay. 8 MR. FRANTZ: He's already answered that question. 9 It's on the Record. I' m not sure we need to have that 10 repeated. 11 JUDGE LAZO: Well, I think it's worthwhile for
T 12 clarification to start over in that area.
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13 MR. FRANTZ: Okay. 14 THE WITNESS: (Gouldy) The cover letters stated that 15 they met they met their .85 K effective. Also, the coupons 16 which they analyzed, the neutron attenuation test, showed it 17 had adequate boron to maintain the shutdown criteria, so it was 18 the material itself, even though it had degraded or cracked, 19 still had the boron to maintain the shutdown capability for 20 that intended safety function. 21 Q Okay, on that May 5 letter, when the Quad Cities 22 report was submitted, from Commonwealth Edison, I' d like to 23 read a paragraph and you can tell me if I' m reading it 24 accurately. It's the third paragraph. "During the past 25 several months, efforts have been made to understand the Heritage Reporting Corporation (202) 628-4888
l t i 293 1 anomalies discovered in the fuel storage racks at Quad Cities ) 2 station. Non-destructive testing of the racks have shown gaps j 3 in the Boraflex extending the full width of the cell wall up to i 1 4 four inches in length. There is no criticality concern with ) 5 spent fuel at this time." Am I reading that correctly? - 6 MR. FRANTZ: I object. 7 JUDGE LAZO: Do you have a question, Ms. Lorion? I 8 mean, that's not a question. 9 MS. LORION: Well, I don' t know that I have a ) 1 10 question. What I' m trying to get at is there's two places 11 where there was a statement made that the Boraflex at Point 73 12 Beach and Quad Cities in capable of performing its intended ( )
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13 safety function despite the degradation. And I don' t quite 14 know how to do this, but what I' m trying to Det at is that 15 there are two places in here where they kind of qualify that 16 and make a statement that they can' t project, you know, that it 17 can. So, you know, Florida Power & Light said they based their 18 statement on these documents, but in the documents it states, 19 for instance, on page 811 of the Report it says, " Projections 20 of the overall service life of Boraflex in the spent fuel pool 21 environment are not possible at this time." 22 JUDGE LAZO: Now, the problem is that accepting the 23 reading of a statement from a document where the authors are l 24 not present has no evidentiary value. 25 MS LORION: Okay, I see. Heritage Reporting Corporation 3 (202) 628-4888
jww I ) L_f 294 1 JUDGE LAZO: Now, if you say to these witnesses, "do 2 you agree with that, or is that your understanding, or if you 3 know anything about it?" 4 MS LORION: Thank you, Judge Lazo. 5 BY MS. LORION: 6 Q Do you agree with that statement or do you know 7 anything about it? 8 A (Gouldy) Okay, where -- 9 Q The one in the letter on paragraph 3. 10 A (Gouldy) They are discussing gaps in the material. 11 Not that the material itself was not able to perform its
'~'g 12 function.
s i l'~ 13 Q Okay, are they also stating that there is no concern 14 with criticality at this time? I mean, if it doesn' t perform 15 its function, does that mean that the criticality is at fault? 16 MR. FRANTZ: I'm going to object. She's asking them 17 to interpret something that's been written by another author. 18 I don' t think that's appropriate. They have no understanding 19 of what was the mind state of the author. 20 JUDGE LAZO: Well, she can certainly ask them if they 21 agree and if they say they don' t know c;r can' t answer that or 22 have no understanding of it, than one answer. If they agree, 23 then let them say so. l 24 BY MS. LORION. 25 Q Okay, lets just go to page 11. " Projections of the Heritage Reporting Corporation (202) 628-4888
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-1; overall,'" and this is down at the bottom paragraph where tit's ,j p
2L stated, " service life of Boraflex in a. spent fuel pool 3 environment are not possible at this time." 4 A (Gouldy) 'Sorry, is this page 811? , 5' Q 'Right, of the Quad Cit 10s report, not the letter. Do t I 6- you agree with that-statement, any of you? j 7 A: (Boyd) I don' t understand the statement. 8 A. .(Gouldy) Yes.. I don' t know what they' re basing it .i
}
l 9 on. l 10- Q What would " service-life of Doraflex" mean to you? q 11 A (Boyd) What? .c l F , 12~ -Q " Service life of Borafles." Does that have any !
\
13 meaning? j 14 A '(Boyd) Not to me. I 15 -Q Okay, thank you. 16 Again, on page 41, line 19, they' re talking about the , 17 surveillance programs for the Boraflex. That "the surveillance ) 18 programs are adequate to determine whether the Boraflex at i i 19_ Turkey Point has experienced the types of degradation which ) 20 have developed at Point Beach and Quad Cities." In that are 21 you talking about the blackness testing and the coupons that i 22 you also plan to test in five years? 23 A (Boyd) Yes, ma' am. 24 O And in your opinion it is adequate to wait another h 25 three years before you perform blackness testing again? Heritage Reporting Corporation (202) 628-4888
) r'^ L_/ 296 1 MR. FRANTZ: I object to that. It's been asked and 2 answered several times yesterday. 3 JUDGE LAZO: I think that's true so you don' t have to 4 answer to that question. 5 BY MS. LORION: 6 O Okay, on page 42, line 10. " Based upon industry and 7 Turkey Point specific data, we believe that Turkey Point is 8 capable of performing it's safety funct ion. " Can you tell me 9 what that statement is based on? What industry data and Turkey 10 Point data you' re basing that on? 11 A (Gouldy) One, the results of the blackness testing, T')) 12 which I'll have the preliminary results, having performed the ( 6 13 test at the time, and Point Beach surveillance, which stated ; 14 that their Boraflex used in their design in their racks was 15 capable of meeting its function for the next five years, ten 16 years of use. And the manufacturers of Boraflex, who have 17 qualified tests done at the University of Michigan and are 18 continuing to perform tests at Michigan, show that for the 19 radiation exposures, the material still meets its function of 20 stopping neutrons or absorbing neutrons. 21 Q But are you talking about Turkey Point? The Doraflex 22 at Turkey Point being capable of performing its safety function 23 for 40 years' storage or for an additional, I guess it would be 24 15? 25 A (Gouldy) It's hard for me to tell you for how long g Heritage Reporting Corporation (202) 628-4888 I l l
i p l ,r. . b/ 297 1 its service life will be. &tt its surveillance program is set 2 up to pick that up and to note any changes. And the rest of 3 the industry, which has longer usage, is doing the same.
~4 O And you said you arri also basing this statement on 5 Point Beach stating that their Boraflex will be capable of 6 performing its safety function for five years?
'7 A -(Gouldy) Well, that was part. You mentioned several 8 other factors that were --
9 Q But that was part of your statement?' 10 A (Boyd) Point Beach's surveillance program is five-( , '. 11 year intervals. They did their five-year surveillance, their
,/~g 12 material met their five-year acceptance criteria, and it's
(
)
13 acceptable for use until their next five-year surveillance 14 program. 15 Q Are you able to state with any kind of confidence 16 that throuDh the life of this Amendment around the year 2000 17 A. D. that the Boraflex will be capable of performing its safety 18 function? f 19 A (Boyd) I would expect it with the radiation doses 20 that Dr. Kilp has shown, in comparing that to the test data 1 1 21 done at the University of Michigan, I would expect it to. 22 Q Can any of you tell me the effect that increased 23 radioactivity has on -- if you had gaps in the Boraflex? ) I 24 A (Boyd) I don' t understand the question.
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y' ' ) I L_f 298 1 where Boraflex has gaps in it, have any effect on the spent 2 1 rel pool? If you had Gaps in the Boraflex? j 3 MR. FRANTZ: Excuse me, I' m not sure the question is 4 clearly stated. Are you saying, Ms. Lorion, that the gaps are 5 having an increase in K-effective? Are you saying that, you ' 6 know, again, you push -- this isn' t fair. 7 Q Okay, okay. I' ll try to clean it u p. 8 Higher burn-up fuel has higher reactivity? Th a t ' s 9 not true? 10 A (Gouldy) Higher burn-up fuel has lower reactivity. 11 Q Higher burn-up fuel has lower reactivity?
'~T 12 A (Gouldy) Yes.
I 5l
)
13 Q Okay, then I don' t have a question about that. Okay, 14 maybe the question was, does more highly enriched fuel have 15 higher reactivity? 16 A (Boyd) Yes, at the same burn-up. And could any of you answer what the effect of using 1 17 O l 18 more highly enriched uranium fuel in increased reactivity could 1 19 have on a spent fuel pool where Boraflex was exhibiting gaps l 20 of, say, 2 to 4 inches? 21 MR. FRANTZ: Again, I object. The question does not 22 state what the assumptions regarding the enrichment are; it l 23 requires them to postulate conditions which are not included in l l 24 i this part of your statement. The question is just not l 25 answerable given the basis stated in your question. l HeritaDe Reporting Corporation l (202) 628-4888 l
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1 JUDGE LAZO 'I thought she was rather specific. m 2 1 THE. WITNESS: .( Boyd)- Could you repeat the question? i3' JUDGE LAZO Could we ask the Reporter to read back' 4" the; question?
'5 REPORTER: EPlay back'3.
]
6 THE' WITNESS: (Boyd) The way I understood'the 17 question, the answers are in the graphs.in figures 2 and 3. 8 This is what will happen to the rack K-effective as.you change , 9 the gap size, you change enrichment, assuming all of these .l 10 previous assumptions. 11 BY MS. LORION: 12- 0 Okay, so assuming that,. say you had a 3-inch or a *- 13 inch' gap, if your fuel was more highly enriched at 4.5 percent 14 than at'4.1 percent, you would reach the .95 K-effective limit
' 15 sooner if there were gaps in the Boraflex?
16 A (Boyd) You would have a higher K-effective value if 17' the same conditions exist for 4.1 as for 4.5, you obviously f 18 have a higher K-effective value for 4.5. l l
- 19. Q And I think you stated in your testimony, Mr. Boyd, !
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l 20- "in some cases, with gaps in all four plates, and gap size over i l 21 say 3.5 inches, the 4.5 enrichment would not meet the 4.5 K-l 22 effective? 23 MR. FRANTZ: That's been asked and answered I don' t 24 know how many times today already, at least times, if I can go l l 25 back and count them. 1 l-1 I Heritage Reporting Corporation (202) 628-4888 i
l I.__d' 300 1 JUDGE LAZO: We' l l sustain the objection. That has 2 been asked and answered.
- 3 MS. LORION: I have no more questions. Thank you.
4 JUDGE LAZO: Mrs. Young, does the staff have cross 5 examination of these witnesses? 6 MS. YOUNG: Yes, Judge Lazo, but as a result of some 7 of the questioning by Ms. Lorion, the staff would humbly 8 request a short break before we begin cross. So we could i 9 organize our questions a little better. 10 JUDGE LAZO: That will be fine. We will take a 15 11 minute mid-morning recess now. [Off the Record.3 I l
]/ 12 [Back on the Record.3 Would the hearing come to >~4 13 order please? Mrs. Young, are you prepared to proceed?
i 14 MS. YOUNG: Yes, I am. )
)
15 CROSS EXAMINATION 1 1 16 BY MS. YOUNG: 17 O Gentlemen, if you would turn to page 17 in your 18 testimony, and that would be of Kilp and Gouldy. I believe the f i 19 answer on 818 states that there are two different radiation ) l 20 monitors which would identify increased radiation levels and 21 sper
- fuel pools, is that correct? 1 22 A (Gouldy) That is correct.
23 Q Ue heard testimony from Mr. Sellers yesterday 24 regarding the status of the leak detection system, and the 25 clean-up system and I belleve at that time he stated that he l 1 l 1 l Heritage Reporting Corporation ] (202) 628-4888 ! l { I
I 1 l l s' 301 1 1 did not know whether they were operational. Mr. Gouldy, can l 2 you tell me whether the clean-up system for the spent fuel l l 3 pools at Turkey Point is operational? j 4 A (Gouldy) Yes, I can. If you' re stating the " clean-5 up system is the deminuralizer," yes, that is in service. It 6 needs new resin and will be changed out on regular maintenance, : i 7 which is common following a refueling outage., 8 O But the demineralized will be restored to operability . b 9 after the refueling outage? 10 A (Gouldy) It's operable. 11 Q And what about the leak detection system, ifi that
! f} 12 operable at the plant?
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13 A (Gouldy) Yes, that's now checked and logged daily on 14 the operator's log. 15 Q And isn' t it true you also have requirements for 16 sampling the water in the spent fuel pools at Turkey Doint?
.17 A (Gouldy) Yes, we have a tech-spec requirement to 18 sample it monthly. However, we routinely do it more frequently 19 than monthly.
20 Q On what interval do you sample the water? 21 A (Gouldy) Weekly or bi-weekly. 22 O Okay, if Dr. Kilp and Mr. Gouldy would t urn to page 23 27 of the testimony? If you look at about line 19 of that 24 testimony, it states that "the gaps were 1.35 inches long on 25 the average, and the maximum Daps were 4. 5 inches in length Heritage Reporting Corporation (202) 628-4888 l 4 i _m____ _
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. b_d 302 1 (which occurred in only one panel)." Isn' t it true that-the 2 Quad Cities report found gaps in two panels of three or four
'3 inches?
4 A (Kilp) I think that is correct. 5 Q So, that statement basically could be revised a 6 little bit to be more accurate? 7 A (Kilp) I think the maximum you' d get -- there was 8 only one of four inches. I think there were two like three and 9 a half or four inches. Three or greater. That's my 10 recollection. I could be wrong about this. 11 Q Okay, you have a copy of the Quad Cities report 12 before you, right?
# J 13 A (Kilp) Yes.
14 O Would you turn to table 4-17 Does that show that 15 Quad Cities group their data in terms of gap size of three to 16 four inches? l 17 A (Kilp) You' re asking me to find two -- okay, I see l l 18 there are two entries of four inches on that table, is that i l 19 what you' re asking? 20 Q Yes. 21 A (Kilp) Yes, I see two entries there. l l 22 Q Thank you. Turn to page 36 of the same testimony. 1 23 About line 12, the testimony states, " Testing and surveillance 1 l l 24 of the Boraflex of approximately three years -- " Excuse me, I 25 didn' t start at the beginning of the centence: "Therefore, at Heritage Reporting Corporation (202) 628-4888 1
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303 y' ' ( 1 the time of the next b?ackness teFring .and surveillance for the 2 Boraflex at approximately three years, the maximum' fuel 3 enrichn.e t t' a t Turkey Pot.nt will not be greater - than 4.1
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4 percer.t!. '" { is the icorrect? ! 5 A i (unuldy) Th a t is correct.
'6 0 Does th'!) Licenseni plan to -- let me start agains
)
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7 does the Lipyynsee also state in khe letter dated August 27, 1
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8 1987. that I would not store fuel with an enrichment Dreater 9 than 4.1 weight percent uranium prior to tf.n completion of the 10 next surveillance? I, 4 t
!, 11 A (Gouldy) Yes, we did.
t ' ,. < r ,
/~'j ' 12 O Will the Licensee be following up that Jetter l
13 commitment Hith an update to its FSAR? 14 A (Goldy) No, we will not.
. 15 O If the Licensee makes a decision not to, or to exceed
(
'16 the 4.1 weight enrichment, before the next surveillance, will 17 they be informinD the NRC of that fact?
18 A (Souldy) Yes, we would. 19 Q I' m add:*ensing this generally to the panel. I i ; 20 believe the testing of the Boraflex enamined 54 panels in the 21 spent' fuel p .>o l , isi that correct? The blackness testing? 22 A (Gouldy) Yes. We have complete results for 54 1 23 pangls. ,
, . ,i 24 e
. C< What percentage of the panels in the spent fuel pool 25 decy,that testing represent? That test sample?
Heritage Reporting Corporation
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L_j 304 1 A (Gouldy) I' m not sure, i 2 O Can you give us a rough estimate? 3 A (Gouldy) Of the panels that have fuels stored in it,
]
4 or all the panels in the total pool? I l Of the panels that has fuel stored in it. 5 O 6 A (Gouldy) I don' t have a calculator so can 1 make a 7 guess? 8 0 Yes, it can be a rough estimate. How many storage 9 cells are filled right now. 10 MR. FRANTZ: I would like to admonish the witness not I 11 to guess. If you can estimate based upon your knowledge, )
) ,'~
12 that's fine. But don' t guess.
#' One thousand panels.
13 A (Gouldy) l 14 0 Approximately 1,000 panels. Do you know 15 approximately how many total panels are in the pool? 16 A (Gouldy) About 3,500. ! 17 Q Thank you. 18 Dr. Kilp, would you turn to page 24 of your k 19 testimony? On about line 11, it starts: "durinD irradiation 20 of the Doraflex, small amounts of non-radioactive gasses (N,. 21 0,. CO, CO,' and low-molecular weight hydrocarbons) may be 22 generated, plus a small amount of helium from the neutron-boron 23 reactions." Is that correct? 24 A (Kilp) Yes. 25 Q Where did you derive this information? Heritage Reporting Corporation (202) 628-4888 J
Y l' 1 1
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l i
-(- 305 L 1 A (Kilp) Well, basically I got it from the Quad Cities 1
2 and the Bisco test reports. 3 Q And did the Bisco test data also suggest that a large 4 amount of hydrogen was released during gas formation? 5 A (Kilp) I don' t recall that. That may be correct. 6 Q Let's turn to the revision of the Kilp and Gouldy 7 testimony. In the first revision, I' m talking about page 39, 8 line 4, it states that " blackness testing at Turkey Point had 9 the capability to detect gaps of approximately one to one and a 10 half inch or greater." I believe also the report prepared by 11 Dr. Turner at page 5 makes a similar statement. Do you have j) 12 that before you? 13 A (Kilp) In fact I have not read that report. That 14 was very recently received by Turkey Point. Mr. Gouldy may 15 have that. 16 0 You have page five before you? 17 A (Gouldy) Yes, ma' am. 18 G And on page 5 it makes a similar statement that the 19 "high gamma radiation background is estimated to have reduced 20 detection capability to gaps of 1 to 1.5 inches in width," is I l 21 that correct? l l 22 A (Gouldy) That is correct. l 23 Q And also on page 7, Dr. Turner states in the third l I 24 full paragraph on that page, that "small gaps less than 1. 5
/ / 25 hinches, if present , would be lost in the statistical variation j
(/ II Heritage Reporting Corporation (202) 628-4888 l l l l
i L _/ 306 1 of the counting rates." Do you see that statement? 2 A (Gouldy) Yes, I do. 3 Q Is there an apparent inconsistency in the Licensee's 4 testimony which states that the blackness testing had the 5 apparent capability to detect gaps of one to one and a half i 6 inches, and Dr. Turner's statement that testing does not detect 7 gaps less than 1. 5 inches? Could you just explain the 8 difference between those two statements? 9 A (Gouldy) Well, they are both Dr. Turner's statemento 10 in his report. 11 Q What is your understanding of the difference in the
'~'
12 two statements? 13 A (Gouldy) If I use the strip chart recordings, I have 14 indications that I can look at. However, he did a statistical 15 analysis of all the data, and this appears to be his review of 16 this pure statistics of pure count rates in counting -- appears 17 to be his conclusion on statistical variation. 18 O Now, is his conclusion that he has a higher 19 confidence in detection of gaps of 1. 5 inches? , 20 A (Gouldy) I don' t know. I don' t know which is 21 higher. 22 O Now, is it your testimony to the Board that blackness 23 testing can detect gaps from between 1 to 1.5 five inches? 24 That ' s all I' m trying to understand. 25 A (Gouldy) Oh, yes. That's my testimony reviewing his . Heritage Reporting Corporation (202) 628-4888 l
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i f~'3 ! s. 307 1 report and actually performed a test with him. 2 Q So his statement on page 5 that there is a reduced 3 detection capability to detect gaps of one to 1. 5 inches, does 4 not give you any opinion as to -- l 5 A (Gouldy) Yes, I believe it discusses yesterday that 6 the instrumentation should pick up, we believe, about a half-7 inch gap or larger. However, having finished a refueling, the 8 demineralizers were exhausted. We had a hi Uh er background than 9 we expected. And it limited the sensitivity of the equipment a 10 little bit. I 11 O Okay, I' ll go to another point. If you turn to page
, t 12 33 of the same testimony, and I' m sorry to keep switching you i J 13 back and forth. I believe at about line 13, it states that 14 "the tested cells, (containing a total of 22 full-lenDth 15 Boraflex panels) were in region two of the fuel pool and that i
16 eight of the cells (containing a total of 32 full-length ' 17 Boraflex panels) were in red i on one of the spent fuel pool." la You aDree with that reading of your testimony? j l 19 A (Gouldy) Yes, 1 do. 20 Q Slow, but -- all right. The storage cells in region i l l 21 one are surrounded by four panels of Boraflex, is that correct? 22 A (Gouldy) That is correct. 23 Q So you get 8x 4 = 32. How many panels surround the 24 panels in region two? 25 A (Gouldy) Two. Heritage Reporting Corporation (202) 628-4888
I ) l l l L_.I 308 ; { 1 Q Taking a normal calculation, you' d go 2 x 10 and get 2 20. If you' d just explain how you get 22 panels from -- and I . 1 3 might also suggest you refer to Dr. Turner' s -- figure, the 4 figure he has on page 4 of his report? 5 A (Bouldy) That was what I was going to refer you to. 6 The section we checked, again, was the region that had the -- 7 represented the highest dosed area for the fuel that we had 8 Just put in region one, and limited the amount of fuel. Along 9 there is the border between red ion one and region two fuel 10 racks. Essentially, on every region two cell, there is a 11 Boraflex panel for each cell. All the way around.
,#~'; 12 However, since region one and region two have a
}
13 border there, cells identified as V-11, V-10, V-9 and V-8 and 14 V-7, do not have a Boraflex panel on them, since they are 15 facing the region one. 16 Additionally, I did not count for checking the 17 Boraflex panel between V-10 and U-10, or V-11 ana U-il, V-9 and 18 U-9, V-8 and U-8, V-7 or U-7, since that's the same Boraflex 19 panel being checked from one side or the other side. Adding up 20 the number of Boraflex panels that way gives you 22. 21 Q All right then, so no Doraflex panels in this diagram 22 of basically the eastern side of the storage cells, and this 23 diagram, the grid only indicates storage locations and not 24 Boraflex panels, is that correct? 25 MR. FRANTZ: Excuse me, but just a slight Heritage Reporting Corporation (202) 628-4888
i J 309 1 clarification: I think you said there is none on the eastern 2 side of V-11, V-10, V-9, V-8 and V-7 only, and not all 18 cells 3 -- 4 MS. YOUNG: I think the witness can answer the 5 question. 6 THE WITNESS: (Gouldy) Yes, the eastern side, the V-7 11, V-10, V-9, V-8, V-7, the eastern side, that side facing the 8 reDion one, does not have a Boraflex panel. 9 DY MS. YOUNG: 10 Q All ri Dht, so this, the grid here, only represents 11 storage locations, and not locations of Boraflex panels?
,j 12 A (Gouldy) That is correct.
13 Q Thank you. Turn to page 36 of your testimony. About 14 line 18, a sentence starts: " Storage of spent fuel with the 15 burn-up of 36,000 mwd /MTU, the one year exposure was calculated 16 to be 7.8 x 10' rads gamma." Do you see that statement there? 17 A (Gouldy) Yes, I do. 18 Q Okay, do you have a copy of a letter dated August 20, 19 1987 to the MRC staff? 20 A (Gouldy) No, I don' t . 21 Q Do you have a copy? 22 MS. YOUNG: Would the Board like to see a copy? 23 JUDGE LAZO: Now, the letter was from whom? 24 MS. YOUNG: Florida Power & Light to the Nuclear 25 ReDulatory Commission. And it's their letter numbering Heritage Reporting Corporation (202) 628-4888 w _____
p . L_/ 310 , 1 designation is L-87-348. 2 JUDGE LAZO: I believe we do have that. 3 MR. FRANTZ: That was provided to the Board by 4 monitor date August 21, 1987, 5 MS. YOUNG: I can proceed? 6 JUDGE LAZO: We have received a copy of it. 7 MS. YOUNG: Do you have a copy before you so you can 8 follow this line of questioning? 9 BY MS. YOUNG: 10 Q Just to refresh your memory, your testimony on page 11 36 says that "7.8 x 10' rads is the gamma exposure for one
~'
; 12 year," is that correct?
I /
~D 13 A (Gouldy) That is correct.
14 O Now, look at the second paragraph of the August 20 15 letter. It says that FP&L selected these storage locations 16 because they wer e representative of those storage locations 17 which have received the highest accumulated dose for region one 18 and regi.on two. Calculations indicate that the accumulated 19 gamma dose would be 7.8 x 10' rads, assuming an infinite array 20 of storage cells, each containing a spent fuel assembly with an 21 average burn-up of 36,000 mwd /MTU stored for one year. Do you 22 see that statement there? 23 A (Gouldy) Yes, I do. 24 O All right, is the 7.8 x 10' rad the highest k 25 accumulated dose to date at the time the testing was performed 1 Heritage Reporting Corporation (202) 628-4888
,I 35 , l :.< - ) o H1 .s , 4 a' 3 04 .ZT a. ;- , 14 7 k- - 1 m > .f~Y Ldi , O [y/M( ,[ 311' j i if for;those-storage locations?: c p .. , 2 A ~ (Gouldy)' Thatfis our best' estimate. ) L, 1- I 3- Q. Right. But if you'look.at:your testimony, you get ] n t l 4 thelimpression;that it's only' a one-year dose. ~ Could youlJust j 5 explain th'at:appare'nt. inconsistency?. l, ? b 6: A- -(Gouldy) Dr. Kilp developed the calculations in i L . . . ll 7 response to the safety evaluation. Well, the numbers ---and b ' a 8 I' ll explain -- we have, yes, .the -- we have reracked the spent ; E i [ L 9 fuel. pool, and we had fuel, approximately 500 assemblies'in ! 1 1 o . / 10 there, which'we had moved around to allow the reracking, and l l L L 11 placed'in the racks. Then we off-loaded one cycle of. fuel, and i< . . I j 12 placed those'in the racks. So the best estimate we h' ave for r T i ' 113 that fuel in. region one, which was placed .in with the map from G 14 Dr. Turner, in:that area, and giving the dose of the region two - 15 racks, it is approximately the.one-year dose. 16' O Okay, but is that the highest accumulated dose for 17 the storage. fuel in the spent fuel pool for over two and a half 18- years? 19' A (Gouldy) That's what our estimates tell us is that 20 the region representative of the highest dose, that region 21 there and region one. 22 Q That number is derived by a one-year exposure, or
- 23 one-year storage of fuel with runoff of 36,000 mwd /MTU?
24- A (Gouldy) That is correct. There were several other
/ 25 assumptions in the calculation in that our dose, our burn-up
( Heritage Reporting Corporation (202) 628-4888
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L_/ 312 1 for the fuel that was placed in that region was lower than the . l 2 36,000. The 36,000 assumed being placed in a spent fuel pool 3 four days after the reactor was shut down, which was several 4 months, a month, a month and a half. So those conservatism 5 offset the added time, and that one year estimate was the best 6 calculation we had for the dose in that region. 7 Q Okay, and also on page 2 of the August 20 letter, it j 8 states that, "by the time the next surveillance, Florida Power i
& Light estimates that the accumulated gamma dose would be 1. 2 9
10 x 10$0 rads. Is that correct? 11 A (Gouldy) That is correct.
/] 12 Q The next surveillance, I believe you stated in
/
13 testimony yesterday, is currently scheduled for December 1989? 14 A (Gouldy) Yes. About two years and three months. 15 Q All right, so when you say "approximately three 16 years, you' re using it loosely, or?" 17 A (Gouldy) Yes. The date we had scheduled, when we 18 started to rerack, was December 1985, and five years 19 surveillance from then was December 1989. Is it possible that December 1989 date will slip any 1 20 Q 21 or could you tell us today? 22 A (Gouldy) I can' t. 23 Q At the time of that next surveillance, your revision 24 to your testimony at the page 9, line 15, the footnote to that 25 revision, talks about -- yes your addendum -- is it corrected I Heritage Reporting Corporation l (202) 628-4888 l - - - - - - - - - -
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/ 313 1 properly?
2 A (Gouldy) Yes, ma' am. 3 Q All right, your addendum to your testimony at page 4 39, line 15, has the sentence which talks about " initially 5 during manual fabrication, no adhesive was used to attach the 6 Boraflex panel to the wrapper. Subsequently, the fabrication 7 process was automated and during the automated fabrication, a 8 cut-to-length sheet of boraflex was attached to one wrapper 9 panel with adhesive applies and short-lengths (up to two and a 10 half inches long) at a maximum of 16 places (eight per side) 11 along the Boraflex." EWith a star for the footnote.] You see
"/N) 12 that?
13 A (Gouldy) Yes, I do. 14 Q And the footnote, if I could just paraphrase, 15 basically states, that, "FP&L at the time they performed the 16 test ing wasn' t aware which racks had used the adhesive and f i l 17 which had not." f l 18 A (Gouldy) That is correct. 1 19 O Can you tell me, at the time you performed your next l 20 surveillance in approximately three years, whether you will be ) { l 21 sampling or doing testing of panels that have used glue, or I 22 adhesive? 23 A (Gouldy) The rack modules that have adhesive have j . 24 been identified, and as I stated earlier, the one module has 25 very old fuel in it and will not be much dose there. The other l 1 ! s 1 1 i i Heritage Reporting Corporation l (202) 628-4888 [ t
l l [ t / L;' 314 l 1 modules probably will not have put fuel in by that date. I 2 They' re on the far south side. The area that will still have 3 received the highest dose, at that time, is the area we tested 4 in August. At this time, I would say, I would expect to j l 5 continue to check the region with the highest dose rate, which ) l 6 was the data we got in August. 7 Q Okay, so you would rely solely on the highest f 8 accumulated dose, and not the difference in the fabrication ( 9 process, vis-a-vis the racks with adhesive, or without { 10 adhesive, for the Boraflex? f i 11 A (Gouldy) Yes. We put the modules in place, where 12 the adhesive was used and not used, we were unaware of that at i;f')s I 13 the time in the fabrication. In those modules, on the far 14 south side of the spent fuel pool, we are loadinD fuel from the 15 far north of it, consolidating moving from the south. They ) 16 will be the last racks to receive fuel. And as I stated, the ! 17 one rack that has adhesive, has very low dose rate fuel. Very 18 old fuel, so I would say, if it's a radiation-induced problem, 19 I would expect no problem from those racks. 20 Q Do you know if Florida Power & Light will be 21 reportinD to the NRC the specifics of its surveillance program 22 for the next three years at the time it is ready to do that j 23 surveillance? 24 A (Gouldy) I don' t know. 25 Q Okay, thank you. No further questions for this panel. f Heritage Reporting Corporation (202) 628-4888
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1 JUDGE COLE: Gentlemen, how long has Boraflex been ] 2 in use in our power plants and spent fuel pools? 3 THE WITNESS: (M11p) I personally don' t know exactly 4 but it's been over five years, I think. 5 JUDGE COLE: In the Boraflex in use at Turkey Point, 6 how long has that been in the spent fuel pool? l 7 THE WITNESS: (Gouldy) We reracked in December j l 8 through March -- December 1985 - March 1986, and had shuffled l 9 the fuel back and forth, so free that time on.
)
10 JUDGE COLE: So the latter part of 1985, beginning of j 11 1986? And you did not use it before that time?
'N, 12 THE WITNESS: (Gouldy) That is correct.
13 JUDGE COLE: This estimate of the region of the 14 highest dose, 7.8 x 10' rads, how does that estimate apply to 15 the rad dose, or the gamma dose to the Boraflex? You 16 understand my question or is it not clear? 17 THE WITNEOS: (Kilp) To the extent that that's a 18 calculation and not an actual field around the Boraflex, I l 19 still think it represents essentially what is right, basically. l 1 20 JUDGE COLE: Okay, was the estimate of 7.8 x 10' j i i 21 rads, was that an estimate made of the dose that would be l 22 experienced by the Boraflex from the time it was put in until 23 the time the estimate was made, or was it an estimate of the 24 radiation dose in the fuel pool from the time the fuel pool ; 25 began? Heritage Reporting Corporation ) i (202) 628-4E88 l < l \ 1 ! - _ _ _ _ _ _ . _ _ _ _ . _ d
i L1 316 1 THE WITNESS: (Kilp) It refers to the specific 2 Boraflex panel that we' re talking about here. 3 JUDGE COLE: Okay, so that estimate, looking at the 4 number, 7. 8 x 10', it's almost 10$ O and we' ve had some 5 estimates here made, I guess by Mr. Thomas, where we get a 40 6 year gamma dose of 1.9 x 10$ O and here we' ve Dot in a year and 7 a half, almost half of that, and I want to know what is the 8 explanation for this? 9 THE WITNESS: (Kilp) The explanation is that the 10 radioactivity of the fuel dies off so rapidly with time that 11 the last 20 years or so are contributing a very minimal amount
/' 12 of the dose.
,I 13 Assume you start out with fuel at the burn-up we 14 talked about at the time we took it out of the reactor and you 15 just let it sit there for 40 years. But the actual dose -- the 16 end dose of that whole calculation is 1.9 x 108 0 for 40 years 17 compared to 7.8 x 10' for one year.
18 JUDGE COLE: So that does not sound inconsistent to 19 you? All right, sir. 20 On page 13 of the testimony of Dr. Kilp and Mr. 21 Gouldy, there are several places in there where you refer to 22 " estimates of corrosion rates of different materials," for 23 example, on line 21, you say "it has been estimated that the 24 corrosion of type 304 stainless steel w -11 not exceed 25 6/10000ths inches for 100 years in an oxygenated, borated Heritage Reporting Corporation (202) 620-4888
i s/ 317 1 water." And you have some other estimates of various parts in , 2 that section. Whose estimates are these, sir? What is the - 3 source of that information? ' 4 THE WITNESS: (Kilp) The one for the stainless steel f i 5 was by J.R. Weeks, in a publication, which I don' t remember. 6 The other one which I think you are referring to is probably 7 the zircaloy? { 8 JUDGE COLE: Yes. 9 THE WITNESS: (Kilp) I made that one based on our 10 research -- l 11 JUDGE COLE: That's on page 12? } I f) 12 THE WITNESS: (Kilp) Yes. I made that one based on f
. ,J d 13 our corrosion equations that we had developed. You might want 14 to understand that the corrosion rate is so low at the actual 15 pool temperatures that it's almost impractical to try to 16 measure them over a 10 or 12 year period. So you have to sort 17 of work backwards. There are some studies that have been made k 18 that Johnson mentioned in his 1977 paper that we' ve talked l
19 about here, where they' ve looked at interference film growth at ) 20 lower temperatures and have been able to induce agreement with 21 the number I calculated this way. f 22 JUDGE COLE: All right sir. Getting back to l [ 23 Boraflex, I' m looking at the figure 1, which is page 5 of Mr. l 24 Boyd's test imony, which is entitled " Nominal Dimensions for the 25 Region One Storage Cells." Now, one of you, I believe it was l Heritage Reporting Corporation (202) 628-4888
1 1 i I 1
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L/ 318 1 MR. Gouldy, made a reference to Boraflex being wrapped around a 2 storage cell, and in looking at this figure 1, particularly 3 where the Boraflex is shown as beinD positioned, it appears 4 that there are thin slabs of Boraflex running the length of 5 the storage cell, but not wrapped around the storage cell. Am 6 I reading that correctly? 7 THE WITNESS: (Gouldy) Yes, and I possibly did not 8 state it clearly in my response, then. The design is as-shown. 9 We use a wrapper plate to hold the Boraflex on all four sides. 10 JUDGE COLE: Okay, so you have four wrapper plates 11 and four strips of Boraflex?
' ~') 12 THE WITNESS: (Gouldy) Full-weight Boraflex were put
/
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13 in the wrapper plate and the wrapper plate was spot-welded to 14 the cell, the storage cell in the wall.
'15
. JUDGE COLE: All right sir, with respect to Boraflex 16 between cells, on figure 1, we have one cell shown completely 17 and a half or some portion of another cell adjacent to it, so 18 that this 1.48 inches between, there is a borax -- a Boraflex 19 sheet on each side of that gap?
20 THE WITNESS: (Gouldy) No, sir. On each side of the 21 gap. 22 JUDGE COLE: On each side of this 1.48 inches? Is 23 that correct? 24 THE WITNESS: (Gouldy) That is correct. In the 25 wrapper there. Heritage Reporting Corporation (202) 628-4888
- 319 1 JUDGE COLE: Now, in your testing for of the Boraflex 2 of Turkey Point, you measured 32 cells but only 22 -- or is it 3 just the opposite? Twenty-two sheets of Boraflex -- you did j
4 ont measure certain of them? 5 THE WITNESS: (Gouldy) That is correct. This 6 diagram that you have here is a Region One storage cell. On 7 the reDion ones, we checked eight. And eight -- and eight in 8 each cell has four sheets. And 8 x 4 = 32. The region two 9 racks would not have the double sheets of Boraflex between 10 them. There is only one. I checked 10. The ones on the east 11 side did not have Boraflex because they are facing the one
'] 12 sheet on the region one, and I did not double count those 13 single Boraflex sheets between the adjoining cells.
14 JUDGE COLE: All right, sir, I understand that. 15 The fuel rod that would go down in here. How close 16 is it? I 17 THE WITNESS: (Kilp) You mean the whole fuel 18 assembly? 19 JUDGE COLE: Yes, the one that would fit in this 20 whole 1.75 inch -- 21 THE WITNESS: (Boyd) The fuel assembly is about 8. 4 22 inches in outside diameter. 23 JUDGE COLE: Okay, I am looking at the Boraflex 24 plate, which is 7.5 inches across, so it doesn' t cover the j 25 whole width of the fuel assembly. 1 Heritage Reporting Corporation l (202) 628-4888 ] 1
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LJ 320 1 THE WITNESS: (Boyd) That's true. Yes. 2 JUDGE COLE: So that there are gaps at all the 3 corners? 4 THE WITNESS: (Boyd) There are fuel rods that are 5 not covered by the Boraflex. That's part of the design. 6 JUDGE COLE: So you would expect in trying to make 7 some measurements of some gaps and holds, that you would at 8 least get some response of some gaps and holds if your 9 detectors are facing in the right direction? 10 THE WITNESS: (Gouldy) The detector that we used in 11 the housing we had, the detector was center-line of that
,~') 12 storage cell on all four plates, such that it looked at dead-i , /'
13 center of that sheet of Boraflex. l 14 JUDGE COLE: Okay, and what portion of the Boraflex 15 sheet was it measuring? A half-inch section in width, height? 16 What? Do you know? How are you going to detect the -- well, 17 forget that question. 18 THE WITNESS: (Gouldy) Okay. 19 JUDGE COLE: Well, no, the question I was starting to 20 ask. I was still waiting for your answer. 21 THE WITNESS: (Gouldy) Okay. When you used a point 22 essentially the point source neutron source that would give 23 neutrons out in all directions. 24 JUDGE COLE: Dut that was down in the same cell, 25 right?
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l -: l' THE WITNESS: (Gouldy). Correct. ,The source went (. 2- right down the center,on all'four sides-inside that' same f' . L 3 housing .I had my four detectors. The four detectors I used li 4 were boron triflu( ride, which only see-thermal neutrons. - 5 JUDGE. COLE: Okay, where wereithe detectors.with 6' respect'to the point source of neutrons?
'7 THE' WITNESS: (Gouldy) Right in the center. That"
- 8. point source was halfway in between the top and bottom of an 18 )
s 9 inch detector. I had one. detector for each side, for:each
.10 cell. Each side of a cell. )
1
-11 .THE WITNESS: (Boyd) Based on the thermalization of 12 the neutron, the detector is really looking for a change. It's s,/
/"}
13' calibrated for this design, which. has the 7.5 inch Boraflex, is 14 going down the center and looking for a change and somehow, 15 let's say there's a big piece of Boraflex missing, the 16 detectors will. pick up the. change in the thermalized neutrons, 17 which wil'1 give them the indication that, indeed, there is a 18 change in the Boraflex. 19 THE WITNESS: (Gouldy) That is correct. Part of the i 20 background count we are getting are coming from the gaps on the 21 sides, and two detectors would pick it u p, one from one side f 22 and one from the other. And we took and got our baseline 23 number of counts and then we' d go down the cell and checked 24 that. We were looking for a change in calorie. ( 25 JUDGE COLE: All right, sir. None of the Boraflex Heritage Reporting Corporation (202) 628-4888
) m L/ 322 1 plates that you tested were glued to the sides, is that 2 correct? Adhesive was not used? 3 THE WITNESS: (Gouldy) The information I received 4 this weekend indicates that. 5 JUDGE COLE: All right, sir. Was your system 6 sensitive to any gaps at the very top portion of the cell? 7 THE WITNESS: (Gouldy) Yes, sir. The process we 8 used was to hang the detector above the storage location and 9 take a count of eight minutes or four minutes and get a 10 baseline count. Then we would lower the detector using the 11 hoist in the spent fuel pool down to the very bottom of the f'] 12 cell, making a recording of the response of those detectors j
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/ 1 13 along the full length of the Boraflex panel.
14 JUDGE COLE: How long did that take for a cell? 15 THE WITNESS: (Gouldy) We were spending about 20-25 16 minutes. We would then pull the assembly back up and get 17 another set of counts on that same panel. 18 JUDGE COLE: That doesn' t explain to me how you know 19 anything about the sensitivity right at the top. 3 20 THE WITNESS: (Boyd) When you look at the data from 21 the tracings, you can actually tell where the Boraflex sheets 22 starts. 23 JUDGE COLE: Well, let me tell you why I' m interested 24 in it and that might be able to short-cut some of it. IF we' re h 25 going to get some shrinkage of the Boraflex plate, and I don' t } Heritage Reporting Corporation 1 (202) 628-4888 t_______-.__ 1
323 i 1 know how it's actually fixed in there, a good place for y 1 1 ! 2 shrinkage to occur might be at the top. IT might just drop f f 3 down in the cylinder in its holding place. Did you observe any ) l 4 of this in your testing and was your equipment sensitive enough 5 to detect gaps at the very surface? 7 f I a - 9 10 11 .
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v' 13 $ l 14 15 I 16 + 17 18 19 20 21 l 22 l 23 2. Heritage Reporting Corporation j (202) 628-4888 I _ - - _ _ _ _ _ - _ _ - - - _ - _ _ i
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T7 1 THE WITNESS: (Gouldy) I can, answer the question, i 2 and Bill will help me bere. Is, one, we detected the existence l 3 of the Boraflex material. I agree with you when you say you 4 would have the shrinkage with this design. It would shrink at , I 5 the top. We detected that level where it started. The design 6< was such, and our evaluation we expected the shrinkage, and f 7 Bill had performed calculations to determine what length they
^
8 needed would be anticipated shrinkage. ; 9 THE WITNESS: (Boyd) Our studies have shown that you i l l 10 can uncover 3 and a half inches each and of the active fuel 11 without having any effect on the reactivity of the spent fuel
/7 12 pool.
t, 13 JUDGE COLE: All right. So if you are going to have 14 shrinkage, that would be the place you could aft'ord it; is that 15 what you are saying? 16 'THE WITNESS: (Boyd.) That's right.
.i JUDGE COLE:
17 All right, sir. 18 THE WITNESS: ((Boyd.) Because we expected it. l l 19 JUDGE COLE: That's very helpful. f 20 On page 27 of your testimony, gentlemen, on line 22 21 you refer to a maximum cumulative gap of 4 inches, and I don' t 22 know what that means. What do you mean by the term " cumulative q 23 gap"?. 24 THE WITNESS: (Kilp) I think in the sense it was 13
// 25 used here there was -- there were some plates that had more
(/ i t Heritage Reporting Corporation (202) 628-4888
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I . j 325 1 than one gap. So if you added the sizes of the gaps together, 1 l 2 that's what the words mean anyway. f 1 3 JUDGE COLE: All right, sir. $ 4 THE WITNESS: (Gouldy) That's correct. l 1 5 JUDGE COLE: Could you give me a definition of what 6 you mean by a gap? We talk about gaps of 1 and a half inch, or
]
l 7 3 inches, or 4 inches. That's only one number, and I usually 8 define gaps in terms of two numbers. It's going to be so long 9 and so wide. What do you mean by a 4-inch gap or a 1 and a 10 half inch gap? 11 THE WITNESS: (Gouldy) The gaps as discussed in the
'"] .
12 Quad Cities report was the full width of their Boraflex panel, ! 13 and that is across the cell the full width, and the gap si'ze of l j 14 4 inches would have been no Doraflex for four inches. I 15 JUDGE COLE: So in the case of Turkey Point, a 4-inch 16 gap would be 7 and a half inches wide because that's the width 17 of the Boraflex panel, and 4 inches high. 18 THE WITNESS: (Boyd) That's what we assumed in the 3 19 sensitivity study that we did here. j
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20 JUDGE COLE: So when you say that you are capable of l 21 detecting any gaps larger than 1 and a half inches, you are 22 really talking about a hole in the Doraflex paneling 7 and a 23 half inches wide by 1 and a half inches high; is that right? 24 Or what are you talking about? 25 THE WITNESS: (Gouldy) I would agree with that. Heritage Reporting Corporation (202) 628-4888
l' I i l I-l }" ! () 326 1 Also,'the report' shows that on the traces if the recorder pins i ! 2 came up unusual, or above their baseline,. it would indicate 3 something for us to do other testing. Dr. Turner statistically l l 4 could not come up with the inch and a half. Just do the traces 5 would give some more information. We would done further l~ l 6 testing to evaluate that. l- 7 So gap sizes, locations,, we could have detected other 1 i 8 than just.that square or rectangle shape that you are l l 9 discussing. i l 10 JUDGE COLE: On paDe 37 and 38 you describe various 1 i ( 11 possible options in the event that they might be required, and
/~T 12 I want to make sure I understand some of those.
f ) G' 13 For example, on No. 3 at the top of page 38 you 14 state, "A poison material similar to a control rod or burnable 15 poison could be added to any new fuel assembly to be placed in 16 a storage cell with degraded Boraflex." 17 How would you do that, sir? 18 THE WITNESS: (Kilp) This option was discussed and 19 each fuel assembly is made to accommodate a control rod or a 20 burnable poison. 21 Okay, when I say a control rod, it has a 20-finger 22 poison control rod. There are 20 holes left that -- the 2h sensitivity study Mr. Boyd did was only 4.5 or 4.1 enriched
- 24 fuel, new fuel considering. If we had stuck poison rods in
( ,/ tO 25 there, corit rol rods, old control rods which we had, old V Heritage Reporting Corporation (202) 628-4888
i r' , t__/ 327 1 burnable poisons, we would have reduced their enrichment that 2 way. 3 JUDGE COLE: All right, sir, I understand that. 4 THE WITNESS: (Gouldy) We would have added a poison 5 to the fuel assembly in those 10 locations. 1 6 JUDGE COLE: Okay. Thank you. 7 Now this next one, Item 4, there you' re adding poison 8 panels between fuel assemblies. Is that the space this -- 1 9 what's shown in Figure 1 of Mr. Boyd's testimony? Is that the 10 1.48-inch space in there where you would add poison panels? 11 THE WITNESS: (Gouldy) What we had discussed was the
} 12 gap between the fuel assembly and the cell wall.
13 JUDGE COLE: Oh, it's inside this 8.75 -- 14 THE WITNESS: (Gouldy) It's inside. 15 JUDGE COLE: -- inches. 16 THE WITNESS: (Gouldy) That's correct. We have 17 approximately three-eights of an inch on two sides. Once we 18 detected an anomaly, a gap as such on one plate, we could take l 1 19 a corrective step. . I 1 20 JUDGE COLE: All right, sir, I understand that. i 21 Now at 6, 7 and 8 you talk about things you might do j 22 with storage cells that have degraded Boraflex. How practical < 23 is it to make those kinds of measurements to determine those 24 cells with deDraded Boraflex? j h 25 THE WITNESS: (Gouldy) Well, again, when we i I Heritage Reporting Corporation , (202) 628-4888 1 j
! { l t n \ v 328 1 developed these options, they were based upon an analysis, I 2 blackness testing and further testing which would identify the 3 gaps, and our analysis would show from those further testing i 4 that options would need to be taken. If such case that we j I 5 needed to block off one cell, you know, that is one of tne 1 6 options that we had discussed. 7 JUDGE COLE: Now this testing program that you are 8 going to embark on in two years and three months or so, how 9 many cells will you be testing then? ; 10 THE WITNESS: (Gouldy) If no other industry data 11 brings up any other problems other than Guad Cities, we will 7
/'N 12 stay with the 54 panels we looked at in August, plus pull the j l ,A 13 first set of sample coupons and perform the surveillance 14 testing as stated in the testimony on those coupons.
15 JUDGE COLE: All right, sir. Thank you. 16 D'r . Boyd, in your testimor.y on page 38, I guess it's 17 your testimony, you indicate that Florida Power & Light has 18 taken no credit for the 1,950 parts per million boron in the i 19 spent fuel pool water. 20 Do you know if there is any requirement that that 21 boron be maintained at a certain concentration such as 1,950? 22 Is this a requirement? 23 THE WITNESS: (Gouldy) Yes, it i s. Our technical 24 specifications for Turkey Point require 1,950 parts per million 25 is the minimum boron concentration for spent fuel pool. Heritage Reporting Corporation . (202) 628-4888 )
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_f g U)' .. i !* 329 1 JUDGE COLE: Okay. The absent all Boraflex in the 2 pool, you would still maintain a K-effective of below .957 3 THE WITNESS: (Boyd) Yes, we would. 4 THE WITNESS: (Gouldy) It would be below .90, in. 5 fact.
- 6. JUDGE COLE: All right, s i r. .
7 Just one or two more questions, gentlemen. 8 Mr. Boyd, your Figures 2 and 3, the Boraflex gap 9 sensitivity study graphs. 10 THE WITNESS: (Boyd) Yes, sir. 11 JUDGE COLE: In your calculations in preparing this 7
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12 graph, you used gap sizes, different sized gaps. When you say, b'd 13 for example, a gap size of 3 inches on your Figure 2, what does 14 that mean with respect to. Turkey Point and the four sides of ( 15 the fuel cell? 16 THE WITNESS: (Boyd) It means if -- 17 JUDGE COLE: How big are the holes all the way 18 around? 19 THE WITNESS: (Boyd) If I was to go down to the 20 middle of a fuel assembly, I would have a 3-inch axial gap as 21 far as I can see in all directions through the Boraflex. 22 JUDGE COLE: Okay. On each of the four sides, for example, when you have it shown as gaps in all four plates? 23 24 THE WITNESS: (Boyd) Right. Each of the four sides ['O t-JJ f 25 for every fuel assembly. Heritage Reporting Corporation (2O2) 628-4888
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- [ 330 1 JUDGE COLE: So that would be a Dap of 3 inches high 2 by 7 and a half inches wide on each of four sides all the same i
3 elevation? 4 THE WITNESS: (Boyd) Right. j 5 JUDGE COLE: Okay, thank you. 6 That's all I have. 7 JUDGE LUEBKE: Yes, I have a few questions about 8 nuclear aspects, probably directed at Mr. Boyd. 9 In reading all of the prefiled testimony of these 10 witnesses, I came up with the concept of primary measures of 11 nuclear safety and secondary measures of nuclear safety. Those 12 words weren' t explicitly used in your testimony. But is it 13 correct to think of the boron in solution which was alluded to 14 in one of Judge Cole's questions of the 1,950 parts per million 15 as the primary safety mechanism in the storage pool? 16 THE WITNESS: (Boyd) No, I would say accordinD to my 17 understanding of the ANSI standards and position papers the 18 boron is a secondary measure. The boron at 1,950 ppm is a 19 secondary measure simply because I cannot take credit for under 20 normal storage conditions. 21 JUDGE LUEBKE: You cannot take credit for it? ( l 22 THE WITNESS: (Boyd) Cannot take credit for it under i 23 normal storage conditions. 1 24 JUDGE LUEBKE: Under normal storage conditions. The ' t
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'{ } Q 1 , THE WLTNESS: (Boyd) The OT positi,)o,n,p} aper by the '
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5<' 2 NMC which endornes, and also ANSI Standard 57.2. That's 1983.' 3
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3 ,pThat is,also endorsed by the NR% 4 JUDGE LUEBKE: Well,'am I correct in my undurstapding 5 that beford you got involved typ expanded fuel storage in your 6 original fuel' storage designt you had boron solution as your
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,/ 8 THE WITNESS: (Boyd) No, . wel d ic*) Not.
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. JUDGE UUEBKE: Well, what was'your safety measure?
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5 TME WITNESS: (Boyd) If there was no Boraflex used 11 and ua water and spacing between the fuel assemblies if the
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12 original fuel racks -- I'm assuming you are talking about the
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19 JUDGil LUEBME: As a safety measure. s , i 20 i THE WITNESG: (Boyd) Geometry was dependent on the , 21 safety measure, and then Boraflex if it's used in the rack .
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22 design then can be used'-- considered. /
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J' 23 JUD3E LUEBKE: Is the inferenceM hen that there are v f 24 more problems with maintaining a boron solution than there are, Q what I have listened to all these questions and answers and t 1 s j Heritage Reporting Corporation i l ", (202) 628-4888 ( l <. u _______ _ _ r
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'l Quad Cities reports about Doraflex?
2 THE WITNESS: (Boyd) I don' t know. I' ve of ten asked 3 the same question. There's all that boron there and I can' t ' l 4 take credit for it when I do the criticality analysis. l 5 JUDGE LUEBKE: Perhaps I should defer that question 1 6 until the staff witnesses get on. They can be thinking about 7 it. j 8 Oh, in the past history of nuclear things, I think I l 9 remember boron as being added to metal plates, steel or 10 whatever, as being a form of nuclear poison. Then there has 11 come along a Boraflex salesman? 12 (LauDhter.) 13 THE WITNESS: (Boyd) It started off with borated 14 stainless steel. 15 JUDGE LUEBKE: Yes, yes, I remember that. 16 THE WITNESS: (Boyd) And one of the problems with 17 that was you could not get enough boron in it. 18 JUDGE LUEBKE: I see. It limited the content. 19 THE WITNESS: (Boyd) Then came Boral. ( 20 JUDGE LUEBKE: Oh, yes. 21 THE WITNESS: (Boyd) Which was -- 22 JUDGE LUEBKE: Aluminum. 23 THE WITNESS: (Boyd) boron with aluminum in it, and 24 that had other problems.
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/ 25 JUDGE LUEBKE: It did.
Heritage Reporting Corporation (202) 628-4888 I i
L.Y 333 1 THE WITNESS: (Boyd) One of them being swelling, a 2 lot of swelling. And then came the Boraflex salesman, and this ; l 3 was demonstrated at that time to be a better product than 4 Boral, which was starting to be in use. l 5 JUDGE LUEBKE: Well, thank you. I just wanted to I 6 sort of get the history of events into the record here. This l 7 just didn' t happen. 8 THE WITNESS: (Boyd) No. I 9 JUDGE LUEBKE: Thank you, sir. 10 JUDGE LAZO: Mr. Boyd, I just had one question 11 regarding clarification. 12 In your testimony on Figuro 2 where you are comparing 13 the enrichment, I notice you say 4.5 W over O uranium 235. Is 14 that weight percent? . 15 THE WITNESS: (Boyd) Exactly. 16 JUDGE LAZO: W/O. 17 THE WITNESS: (Boyd) That's only an acronym to the 18 nuclear world; weight percent. 19 JUDGE LAZO: Okay, thank you, sir. f 20 Mr. Frantz, do you have redirect examination? 21 MR. FRATZ : Yes, we do.
- 22 REDIRECT EXAMINATION l
l 23 BY MR. FRANTZ: 1 24 O Dr. Kilp, yesterday you testified that if carried to
/~T l V / 25 an extreme you could have boron in the Boraflex developing into Gi 1
Heritage Reporting Corporation l (202) 628-4888 1 C_._____
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I 1 a powder or flake form which could get outside the wrapper. 2 And for the record, that would be at transcript page 250, would f' 3 you please explain what impact that would have on the ability 4 of the Boraflex to perform its design function? { 5 A (Kilp) Well, we were discussing -- there are two 6 problems with Boraflex that we have been talking about here.
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7 One is the shrinkage which leads to possibly cracks in some f 8 cases. The other is add degradation which was observed in the ! 9 Point Beach coupons. 10 When 1 answered the question yesterday, I think the f 11 inference was that all of the material did what the edges were j 12 doing, then we would have a problem. But we don' t expect that 13 based on the panel of the Point Beach results as well as 14 actually the results at Quad Cities which did not indicate a 15 loss of boron except where they were having gaps. f 16 MR. FRANTZ: That's all. Thank you. 17 JUDGE LAZO: Just before excusing these witnesses, 18 let's check again with Ms. Lorion. 19 Do you have any further questions, follow-up 20 questions? 21 MS. LORION: Can these be on any of the questions? 22 JUDGE LAZO: They really should be limited to the 23 scope of the Board's questions and the redirect by the 24 licensee. If they raise any new issues, then you should ask [q U,) 25 about them. l Heritage Reporting Corporation (202) 628-4888
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U" I i 1 1 i t T.d} - 335 l' . . 1 MS. .LORION: Well, then, I have no questions. 2- JUDGE LAZO Mrs.LYoung, anything further? .
.3- .MS. YOUNG: No questions.
4 JUDGE LAZO: Gentlemen, thank you.very much.. You may 5 be' excused.
'6 (Whereupon, the witnesses were excused.)
7; JUDGE LAZO: .Shall we have a luncheon recess? ] 8' Mrs. , Young, your witnesses are up next.- 9 MS. .JUNG: Yes. l
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- 10. JUDGE LAZO What- is your preference? Do'you.want-to 1 11 get started or shall we take a luncheon break and come back?
q 12 MS. YOUNG: Let's :take a relaxed luncheon break. l 13- JUDGE LAZO: A relaxed luncheon. break. j 1 f.. 14 JUDGE LAZO: 1:30 this afternoon? 15 MS. YOUNG: 1:15? 16 JUDGE LAZO: 1:15. All right, we will recess until 17 1:15. 18 MS. YOUNG: Thank you. 19 (Whereupon, at 11:39 a.m., the hearing was recessed, 20 to resume at 1:15 p.m., this same day, Wednesday, 21 September 16, 1987.) 22 JUDGE LAZO: Would the hearing come to order, please? 23 .Mrs. Young, are you ready to proceed?
'24 MS. YOUNG: Yes, I am. Seated in the box are the 2d' staff's witnesses on the remainder of Contention Six. If you
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(" 336 1 could each state your name and places. of employment for the 2 Record? 3 JUDGE LAZO Why don' t we swear the witnesses. 4 WHEREUPON 5 JAMES WING i 6 CONRAD E. McCRACKEN { 7 LAURENCE I. KOPP 8 having been first duly sworn, were examined as witnesses herein 9 and testified as follows: I 10 DIRECT EXAMINATION 11 BY MS. YOUNG: { 12 O Again, could you each state your name and places of 13 employment for the Record? 14 A (McCracken) Conrad McCracken, U. S. Nuclear . 15 Regulatory Commission, Washington, D. C. 16 A (W i r.g ) I am James Wing, I am a chemical engineer in . 17 the U.S. Nuclear Regulatory Commission in Washington, D. C. l 18 A (Kopp) Laurence I. Kopp, nuclear engineer for the 19 U. S. Nuclear Regulatory Commission, Washington, D. C. 20 0 Gentlemen, did you each jointly prepare a document , i i 21 entitled, " Testimony of James Wing, Conrad E. McCracken, j i 22 Laurence I. Kopp, Regarding Contention Six," which consists of j 23 20 pages and three attachments? l l 24 A (Kopp) Yes. I ' ~'% I / ) 25 A (McCracken) Yes. 1 N ,) 1 l l Heritage Reporting Corporation (202) 628-4888
_/~'N L__ .J 337 1 A (Wing) Yes. 2 O And did you each also prepare a Statement of 3 Professional Qualifications? 4 A (Kopp) Yes. 5 A (McCracken) Yes. 6 A (Wing) Yes. 7 Q And do you have any revisions or modifications to 8 make either to your testimony or your statement of professional 9 qualifications? 10 A (Kopp) Yes, I have two spelling corrections on page 11 4 of my testimony. On the second line of question 4, 12 " technical" is spelled wrong, and on the second line to the 13 answer to question four, " specification" is spelled 14 incorrectly. 15 Q So for the first one you are inserting an "n" in 16 " technical?" 17 A (Kopp) Yes, and in the second, I am inserting an "e" 18 in " specification." 19 Q Does that complete your corrections, Dr. Kopp? 20 A (Kopp) Yes. 21 A (Wing) 1 have two corrections to make. On page 10, 22 the last paragraph on the bottom, in front of the word, 23 "because" it should be inserted my name, " Wing." 24 Q In parentheses? 25 A (Wing) In parentheses. On page 11, eight lines from , Heritage Reporting Corporation f (202) 628-4888
( ) L/ 338 1 the bottom -- I mean from the top -- the word " verifies" should 2 spell, "V-E-R-I-F-Y." 3 O Does that complete your corrections, Dr. Wing? 4 A (Wing) Yes. 5 Q Okay, as corrected, is your testimony true and 6 correct to the best of your knowledge and belief? 7 A (Kopp) Yes. 8 A (Wind) Yes. 9 a (McCracken) Yes. 10 Q And do you adopt this document as your testimony for 11 the purposes of this proceeding? 12 A (Kopp) Yes. 13 A (Wing) Yes. I 14 A (McCracken) Yes. 15 MS. McCRACKEN: I move that the staf f's test imony on 16 Contention Six be received into evidence and bound in the 17 transcript as if read. 18 JUDGE LAZO: Are there any objections? 19 MR. FRANTZ: No objections. 20 JUDGE LAZO: Ms. Lorion, may we proceed? 21 MS. LORION: No objections. 22 JUDGE LAZO: Very well, the testimony may be received 23 in evidence and we' ll instruct the Reporter to bind it into the 24 transcript directly as if read, including the modifications. I 25 MS. YOUNG: I' ll just state for the Record that the Heritage Reporting Corporation (202) 628-4888
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__.i 339 1 copies that have been provided to the Reporter have been 2 conformed per the corrections indicated. 3 (The documents previously ; 4 referred to were entered into 5 evidence as Direct Testimony.) 6 7 i 8 l l 9 10 i ' 11
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1/ a p UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of )
-) Docket Nos. 50-250 OLA-2 FLORIDA POWER AND LIGHT _ COMPANY ) 50-251 OLA-2
)
(Turkey Point Plant, Units 3 & 4) ) (SFP Expansion) TESTIMONY OF JAMES WING, CONRAD E. MCCRACKEN
/ ND LAURENCE l. KOPP REGARDING CONTENTION 6 C1. Pleese state your name, your position, and the nature of your work at the U.S. Nuclear Regulatory Commission (NRC).
[T A1. My name is James Wing. I am employed by the U.S. Nuclear Regulatory Commission as a Chemical Engineer in the Chemical Engineering Branch, Division of Engineering and Systems Technology, Office of Nuclear Reactor Regulation. A summary of my professional qualifications and experience is attached. My current duties include performing safety evaluations of material compatibility and corrosion potentials of the components that are wetted by water in the spent fuel pools of nuclear power plants. My name is Laurence 1. Kopp. I am a Nuclear Engineer in the j Reactor Systems Branch of the Division of Engineering and Systems Technology in the Office of Nuclear Reactor Regulation, Nuclear Regulatory Commission. My duties include performing safety evaluations of criticality analyses of fresh and spent fuel storage
b O racks. A summary of my professional qualifications and experience is attached. My name is Conrad E. McCracken. I am employed by the U.S. Nuclear Regulatory Commission as Acting Chlef of the Chemical Engineering Dranch, Division of Engineering and Systems Technology, Office of Nuclear Reactor Regulation. A summary of my professional qualifications and experience is attached. My current duties include responsibility for safety evaluations of material compatibility and corrosion potentials of the components that are wetted by water in the spent fuel- pools of nuclear power plants. O What is the purpose of your testimony? Q2. A2. (Wing (, McCracken) Our testimony concerns Contention 6 with regard to the issue stated by the Licensing Board in its March 25, 1987 Memorandum and Order concerning summary disposition, specifically in regard to the Boraflex used in the spent fuel racks. (Kopp) The purpose of my testimony is to address Contention 6 regarding the surveillance of Boraflex to assure that the material does not degrade to the extent that spent fuel pool criticality exceeds NRC acceptance criteria. Concerns about the degradation of Boraflex were raised by new information provided to this Board by BN-87-11, " Board Notification Regarding Anomalies in Doraflex Neutron Absorbing Material," dated June 15, 1987.
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' Contention 6 states:
The Licensee and Staff have not adequately considered or analyzed materials deterioration or failure in materials integrity resulting from the increased _ generation and heat and radioactivity, as a. result of increased capacity and long term storage, in the spent fuel pool. In its March 25,1987. Order, the Board denied summary disposition of Contention 6 and raised an issue as to "the modes and effectiveness of surveillance of materials and the monitoring of the fuel storage pool and contents to provide a measured basis for safety during the extended period of use." Order at 33. l Q3. What is the purpose of the Boraflex panels installed in the Turkey i Point spent fuel pool?
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A3. (Kopp) General Design Criterion (GDC) 62, " Prevention of
\J criticality in fuel storage and handling," states that critictllty in the fuel storage and handling system shall be prevented by physical systems or processes, preferably by use of geometrically safe ,
configurations. The NRC's acceptance criterion for assuring that > GDC 62 is met is found in the Standard Review Plan ( SRP) , l Section 9.1.2, which requires maintaining a storage array neutron multiplication factor (k,ff) less than or equal to 0.95 in spent fuel pools during normal and accident conditions. Therefore, even for accident conditions, the Staff requires spent fuel pools to be et least 5 percent subcritical (k,ff no greater than 0.95) to supply adequate margin to assure that the requirement of CDC 62 ( k,ff ) less than 1.0) is met. The Boraflex captures neutrons which would l l l l i l _j
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4} have otherwise been available for fission and tnerefore aids in providing the required subcriticality margin. 1 Q4.. What is the subcriticality margin when considering both Boraflex n and the .Techjcal Specification concentration of boron in the Turkey Point spent fuel pool? A4. (Kopp) With both the Boraflex panels and the Turkey Point Technical S cification concentration of 1950 ppm boron in the pool, the subcriticality margin is approximately 25 percent (kgff = 0.75).
- 05. Have there been any studies done on materials deterioration or failure in material integrity of Boraflex under an environment similar to that of the spent fuel pool water at the Turkey Point plant?
A5. (Wing) Yes. As stated in the NP.C Safety Evaluation (SE), dated November 14, 1984, Section 2.2 at 7, Boraflex has undergone extensive testing to determine the effects of gamma irradiation in various environments and to verify its structural integrity and suitability as a neutron absorbing material. The evaluation tests have shown that Boraflex was unaffected by the pool water environment and would not be degraded by corrosion. Tests were performed at the University of Michigan, exposing Boraflex up to Il 1.03 x 10 rads of gamma radiation with substantial concurrent j neutron flux in borated water. These tests indicated that Boraflex maintained its neutron attenuation capabilities after being subjected . to an environment of borated water and gamma irradiation.
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Irradiation caused some loss of flexibility, but would not lead to breakup of the Boraflex. 1 Long-term borated water soak tests at high temperatures were also conducted. The tests showed that Boraflex withstood a borated j water immersion at 240oF for 251 days without visible distortion or sof tening. The Boraflex showed no evidence of swelling or loss' of 1 i ability to maintain a uniform distribution of boron carbide. l At the Turkey Point Nuclear Plant, the spent fuel pool water temperatures under normal operating conditions are not expected to l exceed 143 F, which is well below the 240 F test temperature. In ( ,\ () general, the rate of a chemical reaction, which could cause maicrial ; deterioration, decreases exponentially with decreasing temperature. On the basis of these tests, the Staff did not anticipate any : significant deterioration of the Boraflex at the pool under normal operating conditions over the design life of the spent fuel racks. I C6. Has materials deterioration or failure in integrity of Boraflex been found in operating nuclear power plants?
/s6. (Wing) Subsequent to the Staff's review and acceptance of the Turkey Point spent fuel pool racks, anomalies (minor physical changes or gaps) were identified in some spent fuel pools using Boraflex. Specifically, by letter dated February 11, 1987, the Wisconsin Electric Power Company provided the Staff with results of W the surveillance program for Boraflex that is used in the spent fuel i /
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{ The results
./'d pools of the Point Beach Nuclear Plant, Units 1 and 2. ,
showed that the 2-inch by 2-inch surveillance coupons, which h'ad a 10 maximum exposure of 1.6 x 10 rads of gamma radiation, experl-enced some physical changes in color, size, hardness ~and
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1' brittleness. A full-length Doraflex assembly, which had a maximum 10 exposure of about .10
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rads of gamma radiation, showed far less physical changes than the surveillance coupons. Neither the ' coupons nor the full-length Boraflex assembly showed any i I unexpected change 'in neutron attenuation properties. By letter , dated May 5,1987, the Commonwealth Edison Company submitted the results of recent inspections of the Boraflex used in the spent fuel pools at Quad Cities Station, Units 1 and 2. The inspection
. discovered numerous gaps in some Boraflex panels which had been
[T 9 exposed to an estimated radiation dose of 10 rads. The Boraflex assemblies showed anomalies in the neutron attenuation profiles. These two reports were provided to the Board as part of Board i Notification BN-87-11, dated June 15, 1987. In addition, Licensee stated that one of the Doraflex surveillance a coupons (8-inch by 12-inch) at the Prairie Island Nuclear Generating Plant , Units 1 and 2, showed some slight physical changes or degradations similar to that of the survelilance coupons of the Point Beach Nuclear Plant. Letter from C. O. Woody, FPL, to NRC, dated July 10,1987 (L-87-279), at 3. t
l e k What caused these observed physical degradations? Q7. A7. (Wing) The exact mechanisms that caused the observed physical degradations of Boraflex have not been confirmed. But the Staff can postulate that gamma radiation from the spent fuel initially induced crosslinking of the polymer in Boraflex, producing shrinkage of the Boraflex material. When crosslinking became saturated, scissioning (a process in which bcnds between atoms are broken) of the polymer predominated as the accumulated radiation dose increased. Scissioning produced porcsity which allowed the spent fuel pool water to permeate the Boraflex material. Scissioning and water permeation could embr!ttle the Boraflex material, in short, gamma radiation from spent fuel is the most probable cause of the physical degradations, such as changes in color , size, hardness, and brittleness, that were four.d in the Boraflex material at the Point Beach plant. The Staff does not have sufficient information to determine what caused the gap formation in some Boraflex pantls of the Quad Cities Station. However, it is conceivable that if the two ends of a full-length Boraflex panel are physically restrained, then shrinkage caused by gamma radiation can break up the panel and lead to gap formation, in a letter dated July 10, 1987 (L-87-279), Licensee attributed the gap formation in Quad Cities' Boraflex to a rack design and fabri-I cation process which did not allow the Boraflex material to shrink without cracking. Licensee stated that the fabrication process, which required the Boraflex material to be glued and firmly clamped
s . 1 in place to the stainless steel fuel rack walls, did not allow for 1 shrinkage of Boraflex, and, as such, gaps developed. Licensee l I. also stated that the Boraflex panels at' the Ouad Cities Station were not constructed from a single sheet of Boraflex , resulting in 1 pre-existing breaks in the Boraflex panels. L-87-279, enclosure at ! 3-4. a Commonwealth Edison Company (CECO) hypothesized that Boraflex shrinkage caused by irridlation resulted in sufficient tensile stress to lead to breakage when it was restrained as in the Quad Cities ; spent fuel rack. BM 87.-11, enclosure letter dated May 5,1987. However, the report done by CECO's contractor, which is appended to the May 5, 1987 letter, states that, while the use of ' (%} discontinuous strips of Boraflex cannot be ruled out, it was unlikely since the Boraflex was received in full lengths for the various matching stainless steel components. " Preliminary
' Assessment of Boraflex Performance in the Quad Cities Spent Fuel Storage Racks" Report No. NET 042-01 (hereafter " Quad Cities Peport"), at 5-2. Thus, shrinkage with physical restraints was postulated as a potential mechanism for the observed gap formation l i
at the Quad Cities Station. In a letter dated July 29, 1987 ( Attachment 1), Bisco Products, inc. , the manufacturer of Boraflex material, stated that the failure of the neutron absorber may be as much affected by the rest of the spent fuel ' racks as by its own properties , and that the Quad
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/m (vj- included manufacturing deficiencies. It Cities' racks some referenced a letter by Dr. Krishna P. Singh, dated July 27, 1987 (Attachment 2), on the lssues of fabrication induced weld damage, warpage, uneven clamping loads, and stretching during installation of Boraflex sheets to the racks. In addition to these issues, Dr. Krishna P. Singh, the former Vice President of Engineering at-Joseph Oat Corporation (the fuel rack fabricator for the Quad Cities Statien), stated in the letter that while he could not " comment on the actual tear [ing) of [Boraflex] material during handling with any certainty, such a possibility should not' be precluded from consideration." Attachment 2, at 2.
4 y From Dr. Singh's statements it can be inferred that if actual tearing took place during installation of the Boraflex panels at the Quad Cities Station, gaps would have formed even before the panels were exposed to any radiation.
- 08. Could the Boraflex material that is used in the spent . fuel pools of the Turkey Point Units 3 and 4 also experience physical degradation caused by gamma radiation?
A8. (Wing) Camma radiation-induced crosslinking and scissioning of the j polymer in Boraflex can take place in the spent fuel pool racks of ( the Turkey Point plant in the presence of spent fuels. The
'Boraflex panel at the plant is attached to a stainless steel wrapper Water can (
panel and the entire assembly is submerged in water. permeate into the Boraflex, especially at the edges of the panel. _______.________J
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V Thus, minor degradations, such as changes in color, size, hardness, and brittleness, can be expected. , l However, the Staff cannot predict with certainty whether or not ) gap formation will occur. This is because the Staff has not identified ~ the- specific mechanism which causes gap formation in Boraflex. While' Licensee may be correct in concluding that
- shrinkage with physical restraints would lead to gap formation, the Staff lacks sufficient information to concur in Licensee's analysis, .
l particularly ' a complete description of the fabrication, quality assurance / quality control and inspection to verify the fabrication. For example, the Staff is not certain whether or not physical ( restraints exist in the Boraflex panels at Turkey Point which are sufficient to cause gap formation. (McCracken) The Staff is collecting operating experience of Boraflex from ' plants that use Boraflex, additional test data from the vendor, and fabrication information from spent fuel rack contractors. The
. Staff will evaluate the informat8on to arrive at the cause(s) of the observed gap formation, h; Because the Licensee has stated (L-87-279, enclosure at 4) that the Boraflex pancis at the Turkey Point plant were constructed from single sheets, the Staff does not expect that there were gaps in all the Boraflex panels prior to exposure to radiation from spent fuels, unless the panels were damaged by some means.
n ( 't V By letter dated August 20, 1987 (L-87-348), the Licensee reported the results of testing. on 54 Boraflex panels _ from storage cells in both Region I and Region 11 of the spent fuel pool, that are representative of those storage locations which have received an 9 estimated radiation dose of .7.8 x 10 rads, the highest cumulated exposure to date. No indication of gaps, voids, or other spatial distribution anomalies was observed. The results of this testing also verifb that'no gaps' existed in these 54 Boraflex panels prior to exposure to. spent fuel, and that probably no physical restraints exist in these panels. On the basis of all available data and information, and if indeed physical restraints do not exist in the Boraflex panels, the Staff can reasonably state that gaps will not likely form in the Turkey Point Boraflex panels.
- 09. What effect does physical degradation have on the neutron j I
attenuation properties of Boraflex7 j I A9. Substantial physical degradation can alter the neutron attenuation properties of Boraflex and reduce the neutron absorption effectiveness of the Boraflex panels. , Consequently, physical l degradation can decrease the margin of subcriticality of the fuel pool. Neutron attenuation of Boraflex is mainly due to boron-10 (a boron isotope with a mass number of 10) that is present in the i boron carbide powder in Boraflex. If the spatial distribution of boron-10 is not disturbed, the neutron attenuation properties of
r ,. i l 1
'\ -
Boraflex should remain unchanged. Minor physical degradations, such as changes in . color, size (shrinkage), hardness and brittleness, that do not disturb the spatial distribution of boron-10, l should not alter the neutron attenuation properties of Boraflex. , I However, large gap formation in a Boraflex sheet could alter the I I neutron attenuation profile. i Q10. If gap formation should - occur in the Boraflex panels at Turkey Point, what maximum gap size would you expect?
' A10. As stated above, the. Staff cannot predict whether or not gaps will form in the Boraflex panels at Turkey Point because it does not have sufficient Information to identify the specific mechanism which
% causes gap formation \ For example, testing at Point Beach and (V Turkey Point indicates there are no gaps at accumulated levels of Irradiation higher than at Quad Cities and there is information which suggests that the Quad Cities gaps may be related to fabrication and design of the racks. Thus, it may be inferred that gap formation may result from a combination of shrinkage due to irradiation and fabrication or rack design deficiencies.
Nevertheless, recognizing that such gaps may not form in the Turkey Point Boraflex panels, a reasonably conservative approach would be to use the limited Quad Cities data -- the only data available indicating the occurrence of gaps -- to estimate the
' potential gap size in the Boraflex panels - at Turkey Point. This k
estimation does not imply that the factors that contributed to gap formatien at Quad Cities are in existence at Turkey Point. I
d . Of the 203 Boraflex panels examined at Quad Cities, 31 gaps were i
. found ' in. 28 panels, and two three- to four-inch . gaps were found '
I among the. 31. gaps. Quad ' Cities Report, at- 40 to 4-4. Thus, three- to four-inch gaps, the largest gap size identified, were found in one percent of the penels tested and 6 percent of. the gaps examined. This largest gap size was found in Boraflex . panels 9 having a nominal length of 152 inches which were exposed to 10 rads of gamma radiation. Therefore, if the conditions which resulted in gap formation at Quad Cities are present, Turkey Point 1 i will not likely have gaps greater than four inches in approximately one percent of its Boraflex panels.
.G ,
() Q11. What actions have been taken with respect to Turkey Point in light of the new information on Boraflex? All. (Kopp) At the Staff's request, Licensee performed a sensitivity study to determine the effect of possible gaps in the Boraflex at Turkey Point on the margin of subcriticality. Since Region 1 of the spent fuel pool contains the higher Boraflex loading as well as the smaller subcriticality margin, the sensitivity study conservatively used the Region I spent fuel rack configuration. As an additional conservatism, the calculations did not take credit for the boron in the pool water, i.e., the racks are flooded with pure water. The results Indicate that for fuel enriched to 4.5 weight percent U-235, the acceptance criterion of k,ff less than or equal to 0.95 is ! met for the case of a 2-inch gap at the same elevation in all of the I
. l
(,) J Boraflex panels in the rack. The acceptance criterion is also met . l for the case of almost a 4-inch gap at the same elevation in one-half , 1 7 [ of the Boraflex panels (2 of 4 panels in each storage cell in Region j
.i r.
I) in the rack. ~ t " The maximum enrichment of tho fuel currently used at Turkey Point 4 is only 3.6 weight percent U-235. Licensee estimates that in approximately three years, the maximum fuel enrichment at Turkey L Point will be less than 4.1 weight percent U-235. L-87-363, j August 27, 1987. For fuel of 4.1 weight percent enrichment, the 0.95 acceptance criterion would be met for a 3.5 inch gap in all the Boraflex panels and a 7-inch gap in one-half of the panels in the A Q rack. The Staff considers Licensee's assumptions regarding the distribution of gaps to be conservative since if gaps were to develop, they would probably not all occur at the same elevation nor throughout the entire storage rack because radiation exposures differ from storage location to storage location within the racks. In Quad Cities, for example, the distribution of gap sizes ranged from 0 to about 4 inches with the maximum size (between 3 to 4 inches) observed in only one percent of the Boraflex panels tested. Therefore, conservatively assuming that the maximum gap size of 4 inches observed at Quad Cities occurs in 50 percent of the panels at Turkey Point, keff for the storage rack would only be 0.93 for 4.1 weight percent enriched fuel at Turkey Point. In fac t, as
l 1 l
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~(.. j)q l previously mentioned, the acceptance criterion of 0.95 would be met j with as much as a 7-inch gap in.50 percent of the Boraflexfpanels for 4.1 weight percent fuel. {
j Q12. liave you verified the Licensee's study? ! A12. (Kopp)' These results have been confirmed by similar calculations performed by the NRC Office of Nuclear Material Safety and Safeguards. Q13. What actions will Licensee take to detect the effects of physical degradation of Boraflex at the Turkey Point Nuclear Plant? A13. (Wing) In order to confirm that Boraflex is acceptable for continued ] ( initial
'\ g% use, Licensee had originally planned to perform an l surveillance of Boraflex specimens after about five years of ;
exposure in the spent fuel pool environment, as. described in Section 4.8 of the Turkey Point Units 3 and 4 Spent Fuel Storage Facility Modification Safety Analysis Report, dated March 14, 1984. In a letter dated July 10, 1987 ( L-87-279) , Licensee described two types of examinations to be conducted on Boraflex to examine and evaluate its physical and nuclear characteristics. First, an in-service surveillance program will evaluate the Boraflex specimens in both Region I and Region 11 of the spent fuel pool for physical and nuclear characteristics, including the determination of uniformity of boron distribution and neutron attenuation measurements. Second, a surveillance program will detect sny spatial distribution anomalies in the full-length Boraflex panels.
- i. -
(Kopp) The second surveillance program, referred to as " blackness testing," is conducted in order to detect any spatial anomalies in the actual Boraflex panels used in the storage racks. These tests are performed using a fast neutron source and thermal neutron . I detectors. Any gaps in the Boraflex will be detectable by'an increase in the number of thermal neutrons reflected back to.the < detectors. This method has been used satisfactorily in other spent fuel pool facilities such as the Ouad Cities Station Units 1 and 2 to detect spatial anomalics in Boraflex. By. retesting at regular intervals, any changes in the neutron attenuation properties or in the spatial distribution of the boron-10 in Boraflex should be detected and corrective actions taken should it be determined that gaps large enough to violate the k,ff acceptance criterion may occur. 4 in early August , 1987, Licensee performed baseline blackness l k testing on the Boroflex panels that have received the highest cumulated radiation exposure to date. Licensee expects to perform ( future surveillance testing of the Boraflex panels within three l
\
years, or sooner if industry experience indicates a shorter period ] l for surveillance is warranted. L-87-348, August 20, 1987. In i addition, Licensee made a commitment not to store any fuel with an enrichment greater than 4.1 weight percent U-235 prior to completion of the next surveillance. L-87-363, August 27, 1987. i i l f l4 . i I, E_----_--.
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- 17: - ;
$ (\ a (V 3 (McCrackeri)'.The. Staff believes that the next proposed surveillance r should include a representative semple- of panels subjected to a range of radiation exposures to provide reasonable assurance that fuel with' enrichment up to 4.5 weight percent U-235 can be stored at' Turkey Point and maintain the 0.95 k,ff acceptance criterion. Q14. What assurance will surveillance of Boraflex provide regarding the a detection of gaps in sufficient time to take corrective actions? A14. Initial surveillance testing was- performed by FPL during the first week of August 1987 in the Turkey Point Unit 3 spent fuel racks. i Storage locations were chosen in which the Boraflex panels .would have experienced the highest accumulated gamma doses to date and, IT therefore, the largest percentage of shrinkage. No indication of v gaps or other spatial anomalies were observed. The maximum accumulated gamma dose during this testing was estimated' by 9 Westinghouse Electric Corporation, the fuel vendor, to be 7.8 x 10 reds. The next survelIlance testing of the Doraflex panels at Turkcy Point is scheduled in three years when the maximum accumulated gamma dose is estimated.,by Westinghouse to be 1.2 x 0 10 rads. L-87-348, August 20, 1987. (Wing) Bisco Products , Inc. submitted additional test data of Boraflex on June 25, 1987 (Technical Report No. NS-1-050 (Interim)) and August 26,1987 (Attachment 3). The data showed 9 that shrinkage in the Boraflex samples at the dose levels of 5 x 10 and 10 10 rads of gamma radiation was essentially the same,
j o . g: b
- - 18 ,y 4 M.. ,
10 V averaging about 2.0 percent. irradiation at 2.5' x 10 rads showed
. an- average ' shrinkage Lof 2.4 percent.
The . data '. indicated that no appreciable ' change In' shrinkage lof Borafie.x. material occurred 9 o,4 between 5 x 10 and 2.5 x 1010 r ads.. .The 54 ' Doraflex . panAls-9' ' testsd!at T'urkey Point had an estimated radiation ' dose of 7.6' x 10
- rads and an estimated maximum dose of 1.2 lx 1010. rads In three These dose: levels are within the. range of 5 x .10k and12;5 -
~
years. 10' rads where no appreciable change in shrinkage .was found.' x 10 Thel Staff- believes that the proposed . Turkey Point surveillance Interval -is . adequate. However., the Staff will continually monitor industry experience with Boraflex to dete.mine whether a shorter time interval is warranted. (Kopp) in addition ' to the Doraflex surveillance, Turkey Point Technical Specification 3.17 requires the minimum boron concentra-tion while fuel is stored in the spent fuel pit to be 1950 ppm and. Table 4.1-2 requires that the boron concentration be sampled monthly. NRC calculations have shown that under normal storage conditions at Turkey Point with the peo! water borated to 1950 ppm of boron, all of the Boraflex panels could be removed and the 0.95 k,77 acceptance critorion would be met , even with 4.5 weight percent fuel . Therefore, the Staff feels that' the boron concentration and sampling requirements provide additional assurance 'of ssfe fuel storage between surveillance of the Boraflex.
u
- 19 '-
3. C15. What corrective actions are available if gaps do develop in the Boraflex panels at Turkey Point?
~A15. .(Kopp) Possible corrective actions to maintain ' the 0.95 k df acceptance criteria would be to:
- 1. Control the placement of. fuel so that some storage locations are not occupied by a spent fuel assembly. This would increase the effective spacing between assemblies and thus reduce the k
df value.
- 2. Consolidate two or more fuel assemblies into one cell location by removing the Individual fuel rods and replacing them in a more compact configuration. This consolidation process reduces the number of thermal neutrons available to cause fission and thereby reduces the k df value.
- 3. Insert control rods or burnable poison rods into the fuel assembly to reduce k,f f. This would require measures to prevent these movable poisons from inadvertently being removed at a later time.
- 4. Insert poison panels into the space between the fuel assembly and the cell wall to reduce k,ff.
. i in addition, by letter dated July 27, 1987 . (L-87-363) , Licensee listed other possible corrective actions such as (a) preventing the loading of any fuel assembly into storage cell with degraded Boraflex and (b) replacing the degraded Boraflex. ,
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, 0 016. .Please summarize your testimony eYogarding the acceptability ofa *
..Borafle,x.
y? ' A16. The i recent examination of the Boraflex material with the 'h'Ighest !
., cumulated . radiation' exposure at Turkey _
Point uncovered no i anomalies in the Boraflex assemblies. " Based en the . data and
,,;, ,, ,V Inforraation" available to date, the Staff does notc exMet screty i
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'significant degradation .in tb.e Tur,-key Point Boraflex penols. v 3
Licensee plans ' to conduct surveillance prog rams , which -(ncWde
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blackness testing, on 'Boraficx specimens and panels at 'specified schedules that are adequate to detect physical degradations, . , ,'
\ y including gaps. If . g&ps should form in the Boraflex panels at a-a !
Turkey Point, the surveillance program will provide reasonable Oj a,ssurance that gap . formation will be detected in sufficient tirne to enable Licensee to take corrective actions such that the FNRC
]
acceptance criterion of k,ff less than or equal to 0.95 is ' met. ,, I Therefore, Boraflex material continues to be acceptable for use; in safe storego of the spent fuet at the Turkey Point Nuclear Plant.- l 1 11 1 1 a l t i l l l
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PROFESSIONAL QUALIFICATIONS JAMES WING ; My name is James Wing. I am a Chemical Engineer in the Chemical Engineering Branch, Division of Engineering and Systems Technofogy, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. I received a Bachelor of Science degree in Chemistry from the University of Tennessee in 1949, a Master of Science degree in Chemistry from Purdue University in 1953, and a Ph.D. degree in Chemistry from Purdue University in 1956. Before Joining the Commission, I was employed by Argonne National Laboratory from 1955 to 1969 first, as Assistant Chemist and later, as Associate Chemist. In this capacity, i performed basic research in nuclear chemistry. From 1969 to 1975, I was employed by National > Bureau of Standards as a research chemist and computer programmer. In these two positions, I did research work on radiochemistry and wrote computer programs for laboratory automation. I have written 28 technical papers and to laboratory reports on various topics, including nuclear chemistry, radiochemistry, air pollution, applied mathematics, and food technology. In the academic year of 1964-1965, I n) '" was a Fulbright Lecturer. Society. I am a member of the American Chemical > I have been a staff member of the U.S. Nuclear Regulatory Commission since January 1975. I have served in the following capacities in the Office of Nuclear Reactor Regulation: a Nuclear Chemist in the Accident Analysis Branch, a Senior Nuclear Engineer in the Effluent Trcatment Systems Branch, a Chemical Engincer in the Plant Systems Branch, and, , currently, a Chemical Engineer in the Chemical Engineering Branch. l My duties included: Independent assessments of the radiological consequences of postulated accidents; control room habitability following a j postulated accidental release of toxic chemicals; radioactive waste y treatment systems; control of impurities in reactor coolant water, steam { generator shell-side water, post-accident emergency cooling water, and j spent fuel pool water; material compatibility and corrosion potential; 1 process sampling; post-accident sampling; protective coating (paint) { cystems inside containment buildings; and fission product removal j following a postulated loss-of-coolant accident. Additional duties included management of technical assistance programs. l l
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, ' PROFESSIONAL QUALIFICATIONS" CONRAD E." MCCRACKEN '
l am Acting Chief of the Chemical Engineering Branch of the Division of Engineering and: Systems Technology, . Office of Nuclear Reactor Regulation. My responsibliltles . In . this position include supervision of, the evaluation of all PWR's for compilance with chemical and . corrosion ~
-g requirements of .the Commission, material compatibility for spent fuel pool components and materials. of nuclear power plants.- 1, have served in this .
capacity since April 1987. .. . Between February 1981 - and November 1985, i served as a senior chemical , engineer ' and section. leader with the . same branch, where my duties" included the evaluation.of' materials compatibility 4 ' y' - and degradation . Issues 'at both .o'perating plants and plants iin the licensing process.- From November 1985 until April 1987 -i served as a section leader in the , Division of Licensing and as Acting Chief of' the Plant Systems Branch of Nuclear Reactor Regulation. From 1966 to 19'81, I was employed by Combustion Engineering Corporation
.s ~ in a. variety of management and engineering positions, the last of which ,
.was- Mrnager of Chemistry Development from .1977 to 1981. During this 15-year period, my prime technical responsibility was support .to operating nuclear power - plants and nuclear plants in ~ construction in the area of
~
? ;w chemical- and radiochemical sampling, analysis, data Interpretation,
> establishing chemistry specifications and conducting laboratory
- experiments to verify or support nuclear plant > requirements. In this capacity, I made frequent visits to nuclear power plants where i physically conducted sample and analysis programs or audited the utilities' capabilities in the. chemistry and 'radlechemistry area. During this )
period, I--
-was responsible for review, testing and approval of. various organic and inorganic compounds for use in nuclear power plants.
From 1958 to 1966, I served in the United States- Navy where I was qualified in submarines for all nuclear duties. For three years of this period, I was an instructor, responsible for teaching office and enlisted riersonnel in the area of , chemistry, corrosion and meclianical systems operation and control. My final duty station in the Navy was on the USS Nautilus where f was responsible for all chemistry and corrosion control i and personnel radiation exposure. Education
! ettended the University of Hartford School of Engineering and completed course work in 1970. I am a Registered Professional Corrosion Engineer.
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~,1 ;x' ETATEMENT OF PROFESSIONAL QUALIFICATIONS OF i
DR. LAURENCE 1. KOPP Education: Fairleigih Dickinson University, B.S. Physics,1956 Stevens institute of Technology, M.S. Physics,1959 University of Maryland, Ph.D., Nuclear Engineering,1968 j Professional Experience: U.S. Nuclear Regulatory Commission i Nuclear Engineer (1965 - present) Safety evaluations of reactor core design as described in j applications for Construction Permits and Operating l f' Licenses, topical reports submitted by reactor vendors and j
- licensees on safety-related subjects, criticality analyses cf i fresh and spent fuel storage racks. i
^
Westinghouse Astronuclear Laboratory
, Senior Scientist (1963 _1965)
Design and analyses of reactor physics aspects of nuclear propulslon systems related to NERVA program including (h'% ,1 development of computer programs. Martin-Marietta Corporation Senior Engineer (1959 - 1963) Design and analyses of reactor physics aspects of advanced concept reactors such as the fluidized bed and compact space reactors. Development of analytical methods and computer codes for nuclear reactor design and analysis, s Federal Electric Corporation Senior Programmer (1957 - 1959) Developed and programmed various computer codes for DEWLINE project including payroll, statistical analysis of failure rates, and inventory control. l Curtiss Wright Research Division l Physicist (1956 ,1957)
' Assisted in development and programming of reactor !
analysis methods. Professional . American Nuclear Society (June 1985 - present) ! 4 Societies: Chairman of ANS-10 national committee on Mathematics and Computations Standards. ;
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'ETATEMENT .OF PROFESSIONAL QUAL'I FICATIONS OF y
DR. LAURENCE 1. KOPP m Education:' Fairleigh D8ckinson University,' B.S. Physics,1956 Stevens- Institute of Technology, M.S. Physics,~ 1959 . University of Maryland, Ph.D., Nuclear Engineering,1968 4 Professional ' i Experience:. U.S. Nuclear Regulatory Commission, 14uc! car Engineer (1965 - present) Safety evaluations of. reactor core ' design as ' described in applications . for Construction Permits and Operating Licenses, topical' reports submitted by reactor vendors and
. llcensees on safety-related subjects, criticality analyses of.
fresh and spent fuel storage racks. m
' Westinghouse Astronuclear Laboratory Senior- Scientist (1963 - 1965)'
Design and. analyses of reactor physics aspects of nuclear g propulsion- systems related to NERVA program ' including development of computer programs. Martin-Marietta Corporation Senior Engineer (1959 - 1963) Design and. analyses of reactor physics -aspects of advanced concept reactors such as the fluidized bed and compact sr,0ce reactors. Development of analytical ' methods and computer codes for nuclear reactor design and analysis, j Federal Electric Corporation Senior Programmer (1957 - 1959) Developed and programmed various computer codes for e DEWLINE project including payroll, statistical analysis of failure rates, and inventory control. Curtiss Wright Research Division Physicist (1956 - 1957) b. Assisted in development and programming of reactor analysis methods. Professional Societies: American Nuclear Society (June 1985 - present) 4 Chairman of ANS-10 national committee on Mathematics and Computations Standards. j i i j
Attachm:nt 1 E l 4 bisco { July 29, 1987 Dr. C. Vernon Hodge bIseo products, In,c. l uso renaissanu arive l Reactor Engineer Generic Communications Branch (([IN I2 rein 2824s2 brane prid l Division of Operational. Events Assessment j Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commiscion Washington, D.C. 20555 i
Dear Dr. Hodge:
I have reviewed the draft issue of the information notice entitled " Gaps in Neutron Absoring Material in High Density Spent Fuel Storage Racks." Ther,e are a number of points which I feel ;
- add to the factual accuracy of it's content, as well as minimize - speculation or risk of misinterpretation. I felt the best way to .
I identify the points was to return to you a re-drafted notice, which is enclosed, and comment on the differences in this letter. r~
's,N As a preamble, I think it is important to consider that the') observed ga may not be encountered elsewhere. This premise considers that j cr the high density rack must be considered as a system, with the 4 t
- - neutron absorber one component of that system. As such, the function or failure of the absorber may be as much affected by . the rest of the rack as it is limited by its own properties. There is no doubt that the Quad Cities racks included some manu- i i facturing deficiencies, as evidenced by the NRC Preliminary Noti-fication PHO-III-82-12, Commonwealth Edison Company (Quad Cities Nuclear Plant) - Bowed Spent Fuel Storage Racks, a copy of which is enclosed. The fabrication concerns are further amplified in the July 27, 1987 letter from Dr. Krishna Singh, Holtec ! International to Mr. Conrad McFadden, NRC, a copy also enclosed. Of specific relevance to the gap situation are references in Dr. Singh's lotter to the issues of fabrication induced weld damage, warpage, uneven clamping loads, tearing during installation and stretching during installation. While none of Dr. Singh's comments constitute proof that the gap problem is unique to Quad Cities, they do outline numerous conditions, some or all of which are unique to Quad Cities, which could cause or exaserbate the gap phenomenon. Given the plausibility of the above premise, the following is a section by section reasoning for the differences between the 4dra,ftnoticean'dmyre-draftedcopy:
.A h 1. Statement of Purpose ,
A general change throughout was made from the term I'degrada-tion" which implies various degrees of partial to total failure or disintegration depending on the orient.ation of the reader, to the term " gap" which defines the observed condition. , The fuel rack and absorber are also identified as a " system" , since they are highly interactive and considerations of rack design, as well as environment, have significant impact on the function of the absorber. h
- 2. Description of Circumstances The manufacturer of the rack as well as the absorber are identified. The lipe,nsee usually has a contract with the rack manufacturer and not with the absorber supplier, 5 therefore may be unaware of the source. The identification further alerts the licensee to the possibility of design similarities betwen the Quad Cities rack and his own. ;
The description of Boraflex is corrected to reflect actual Composition.
)) Nusurtec was added as an additional investigating agency, gfr contracted by CECO for neutron radiography.
The reference to the preliminary status of the NETCO report was taken from the document itself and is an important con-sideration for the reader. The gap formation mechanism was also directly taken from the report summary. The reference to the location of the gaps was ommitted since the table displaying the data in the NETCO Report indicates the gaps occur throughout the upper 2/3rds of the cell, with insufficient data points to conclude that only two peak , locations exist. The reference to the neutron radiograph was added. The description of the Pt. Beach coupon sample evaluation was re-written for clarity with comment taken directly from ; the Wisconsin Electric report to the NRC. I felt the addi- 1 tion of the statement that no evidence of gaps or breakage existed was germain to this issue.
- 3. Discussion .
, A list of sites using Oat designed and fabricated racks is t included along with the Boraflex sites since this notice may be of greater interest to the licensee's who have a similar fuel rack system to that of Quad Cities, i
The EISCD program was rewritten to summarize the intent of in-progress tests which are being conducted with the assis-tance of outside consultants. The <TNsign of a special test l nethod to measure gaps was not part of BISCO's program,.and ! BISCO.does not dispute the actual measurements reported, but does dispute the conclusions of the UETCO report where !
" worst case" assumptions were made in the absence of data now evolving from the current test programs.
The EPRI program was al'40 rewritten from specific task de-scriptions in the EPRI project guidelines paper, and the wording of the rewritten paragraph was verbally presented to Mr. Ray Lambert of EPRI.for his concurrence on accuracy The reference to isotropic / anisotropic behavior was deleted since it is purely speculative and is unimportant in the presence of actual test data now available. . The reference to radI5 tion damage mechanisms was also deleted because it is speculative and the interpretation of -
"darnage" is primarily a function of intended use. Again, actual' test data defining shrinkage and stability is now available decreasing the need to forecast performance on the basis of mechanism theory. ;
rx '
,) Although stress, temperature, and chemical environment impact Boraflex, it is the interactive effect of the rack and Ecr handling on the stressed or exposed Boraflex that governs primary performance, therefore, the concept of " system" is again, introduced.
The goal of improving industry understanding is clarified to reflect the study of all aspects related to the observed ; gaps at Quad Cities, and to determine whether there are com-mon elements which should be evaluated elsewhere. We are not aware of a general condition of degradation of Boraflex as implied in the first draft. I hope the comments and background reasoning behind our rewritten draft is clear. We would welcome the opportunity to discuss further with you any of the points raised. Sincerely, if-
. S. Anderson l
President BISCO PRODUCTS, INC. JSA32
?NIIIt!! NARY NOTIFICATION OF IVIh'T OR UNUSUAL OCCURRENCE--PNO-III-82-in Dato: October is,1982 This preliminary notification constitutes EARLY notice of events of POSSIBLE safety or goblis interest-significance. The information is as initially' received without veri- ' - n or evaluation, and is basically all that is known by the staff on this date.
111ty: Commonwealth Edison Company Licerisee Emergency Classification: f Quad Cities Nuclear Plant Notification'of Unusual Event Alert Units 1*and 2 Site Area Emergency Docket Nos. 50-254 - General Imergency 50-265 Cordova, IL 61242 . xx Not Applicable
.5ubjcets BOWED SPENT FUEL STORAGE RACKS , i The licensee informed Region III (Chicago) that three high density fuel storage racks installed at the Quad Cities Station do not meet the design criteria for !
spacing between the installed racks because of a bowing condition. The separation ' criteria, intended to prevent contact between the racks during a seismic event, rsquire a 3-inch separation. , The bowing c'ondition has reduced the separation to cbout 2-1/2 inches. Joseph Oats Corporation, manuf acturer of the racks, has reanalyzed the seismic response of the racks and concluded.,that a 2-1/2 separation is acceptable for fully
- toaded racks and partially loaded racks with a symetrical distribution of the fuel .
~
ossemblies. One rack at Quad Cities is fully loaded; a*second is partially loaded and the fuel has been rearranged in a symetrical array; and the third is empty, f bOion III is considering the generic' potential of the bowing condition. Joseph Cats Isrporation has supplied storage racks to at least two other sites - Point Beach and
- 2'Oconee. The Point Beach resident insoector and the Region II (Atlanta) office have.
- been notified. The Office of Nuclear Reactor Regulation has also been advised of the Cuad Cities rack bowing.
Neither Region III nor the Licensee plans to itsue a news announcement. The State of Illinois wiLL be advised. I Region III was notified of the bowing condition on October 15, 1982. Subsequent ' information was obtained on October 18. This information is current as of 2:30 p.m. (CDT), October 18, 1982.
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'"l Attachment 2 jOLTEC DTERNATIONAL
- 139 A. Gaither Drive, Mount Laurel, N.J 000541713 * (609) 234-6666
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July 27, 1987 . i*' ~' Mr. Conrad McFadden l chief, chemical Engineering Eranch
- office Nuolear Reactor Regulations U.S. N.R.C.
Washington, DC 20558
Dear Mr. McFadden:
I have had an opportunity to review the draft issue of the NRC information notice No. 57-XX, entitled, " Gaps in Neutron- 1
~ Absorbing Material in High Density spent ruel storage Rtchs", i since I have been deeply involved in the Quad Citiaa high density rack during its design and licensing, I believe it is incumbent '
en 'ne to share some factual information with you, which may help you reevaluate th9 tone and the substance of notice. t the time the Quad Cities racks were designed and licensed, I as Vice-Pre 3ident of Engineering of the contractor, Joseph Ost
,-. Corporation of Camden, New Jersey. .I-an also co-inventer of the
-design patent of the BWR racks, which CAT employed in
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manufacturing the Quad cities racks. The Quad Cities rack design and licensing was carried out under my leadership. As such, I might be expected to have an intimate knowledge of the anatomy of ^ the hardware and its particular attributes. The present issue of the draft notice scene to ignore the special nuances of the Quad Cities' hardware, and draws generalized conclusions on "Boraflex degradation". In my opinion, a correct diagnosis of the event calls .for a sarstul consideration of the " specifics" surrounding the event. I attempt to provide some of the "specificsa in the following. - The Quad Cities reexa saploy the so-called "cruciforma construction wherein angles are welded together along the edges in a fixture (please see attached patent description) to form a cruciform. The Borsfiex is contained between the faces of the Cngle. Cruciforms are attached to each other by welding along their junction. This welding must be done remotely, and therefore, its quality depends on the flatness, and straightness of the cruciform places the welding surfaces. heat inpu8 light dislocation ofto thethe weld edge t dangerously class Boraflex . material.
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; HOLTEC INTERNATIONAL i
Quad Cities raohs were among the first to be built by CAT'. fabrication team learned in time to improve the accuracy ofCAT's the
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remoteCities Quad welding racks, and minimits the warpage of the cruciform panels. however, showed the markings of a manufacturing team learning its eats. The early group of Quad cities racks vera substantially out-of-tolerance (as much as 0.7$ inch in one module!!); later modules were much better. Evan the forming of the angles was done usin found to land to tolerance problems.g a aprocess" which was later One consequence of this evolving manufacturing techniques was in the uneven clamping 1 cad on Boraflex. vertical cont;.guration Boraflex was not held in a without scattered clamping. An
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inadvertent outcome would surmise,.was randomly restricted. was that the in-plane dimensional change, I - While I cannot handling with any comment on the actual tear of the material during certainty recluded from consideration., such a possibility should not be The stretching of Boraflex during a gluing operation to the angles is another rather unique Pact of the Quad cities rack fabrication. E CAT went on to overcome many of the above mentioned fabrication problems: years. and produced racks of much improved quality in later I trust that your notice should take account of the special centiguration of Quad cities' racks, and the special manufacturing problems encountered during their fabrication. The closing paragraphs of the notica appear to draw heavily from the field, NETCO report, which in the opinion of'many experts in the fact. Perhaps mekes speculative proposition sound like unimpeachable a dispassionate critique of NETCO's hypotheses is warranted before the NRC anbraces it as an established fact. d
.a -
;. . HOLTEC INTERNATIONAL i
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l Finally I should inform you fron first hand knowledge, that the
*, gap in ,the Quad cities poison panel. was . confirmed by underwater -l neutron radiography conducted by NUSURTIC, INC.
Circle palm Barbor FL 33563, phone 413-747-4625(230 Normandy s notice,also arrs 'en,this vital piece of information.) . The draft i Sincerely, M @ f w.4 5 Erishna P. fingh, Ph.D. President KP8 at s
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August 26, 1987 blsco products, Inc. 1420 renaissance drive park ridge, Illinois 60068 (312)298 1200 telex 282482 brand prid Dr. C. Vernon Hodge Generic Communications Branch Division of Operational Events Assessment Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555 l
Dear Dr. Hodge:
This letter will serve to confirm several of the points covered in 'our recent conversation. t
'A study was initiated some time ago at the University of Michigan to characterize the effects of radiation on shrinkage in
,x Boraflex. A preliminary report was issued which presented data 4, ,)
~ through a cumulative dose of 1E10 rads gamma and greater than 3E18 neutrons /cm2. The Boraflex used in the test was produced under the same production procedures and raw material specifica-tions which apply to that material used in Turkey Point and other spent fuel storage racks.
The data collected indicates the shrinkage at both the SE9 and 1E10 levels' of irradiation was essentially the same, averaging in all dimensions 2.1% with a length to width swing of about
+/-0.2%. Preliminary evaluation of the 2.5E10 data shows an average of about 2.4% with a length to width swing of about 0.4%.
The cause of the swing is being evaluated, but could be caused by some anisotropy or by increasing measurement error coincident with a small observed loss of sharpness of the edge. The . relatively small sample size causes a measurement of only 0.01 inches to represent about 0.6% size change, therefore, it would be expected that the measured shrinkage would err on the high side as the sharpness of the sample edge declines. Since the accuracy factor is a significant limitation of small size samples, we recommend that test coupons be as large as possible. Bisco has entered into a new agreement with the ' University of Missouri in which samples measuring about 5" x 12" will be irradiated in order to minimize the measurement accuracy factor. f-) ( s In addition, since the reduction of edge sharp-
, s ) ness about .04 inches, thesamples in the high dose range from larger sample less than .01eliminate will essentially inches to this affect from the determination of shrinkage.
one of the brand companies
i 4 Dr. C. Vernon Hodge August 26, 1987 Page 2. l As. usual, we will keep you informed of future data as it is , j generated. , Sincerely, James S. Anderson President JSA:lfh O . 4 P
Q , t:. i l L i .
. Dr. C. Vernon Hodge August 26, 1987 Page 2.
As usual, we will keep you informed of future data as it is generated. Sincerely,
. l(..I
, d' James S. Anderson President JSA:lfh I
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J 1 l I 340 1 1 The panel is ready for examination. 2 CROSS EXAMINATION l 3 BY MS. LORION: Okay, Dr. Kopp, on page 3 of the 4 testimony, it states that A-3, the general design criterion, i 5 GDC-62, " prevention of criticality and fuel storage and l l 6 handling," states that " criticality in the fuel storage and 7 handling system shall be prevented by physical systems or 8 processes preferably by use of geometrically safe 9 configurations. The NRC's acceptance criteria for assuring
. 10 that GDC-62 is met, and found in the standard review plan SRP 11 Section 9.1.2, which requires maintaining a storage array a 12 neutron multiplication factor, less than or equal to .95 in 13 spent fuel pools during normal and accident conditions."
14- Going back to the testimony of Florida Power & Light, 15 does this mean it has to meet the .95 K-effective, not taking 16 into account the boron in the water? 17 A (Kopp) Yes, that would be considered the worst 18 criticality type accident possible with boron. 19 Q Okay, could gaps in the Boraflex in the pool be 20 considered an abnormal condition if they became very bad and 21 say you had many gaps in the spent fuel pool? As relates to 22 criticality? Could that be considered an " abnormal condition?" 23 A (Kopp) Well, we certainly didn' t expect it so I 24 guess you would consider it to be an " abnormal condition." h 25 Q Going back to Mr. Boyd's test imony, I think he Heritage Reporting Corporation (202) 628-4888
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-( 1- testified that, at certain' levels the.4.1. percent enriched fuel !
I 1 2 would,1at gap sizes greater than 3.5 inches, would exceed the 3 .95 K-effective. If that abnormal" condition did exist, that
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4 there were gaps in all four, I guess it was, plates, would that 5a meet the design criterion that you have spelled out here? If 6 you want to look at his charts, if you have his testimony? 7 A (Kopp) You' re saying what ? A four-inch gap in wall? 8 The wall plates? l 9 Q Do you have Mr. Boyd's testimony? I don' t have Mr.- 10 Boyd's testimony. Okay, if we look at figure 2, and we look at 11' a gap size, gaps in all four plates and the gap size greater r 12 than 3 inches, I guess it's even greater than 2 inches in this b* 13 case, in the'more conservative case? Would that meet the 14 design criterion that you have outlined in your testimony? 15 A (Kopp) If you had a gap size greater than 2 inches
.1 6 in every single Boraflext panel throughout the entire pool, and 17 at the mid-plane, no, it would exceed the .95.
18 G Excuse me, we' re looking at the 4.5 enrichment here. 19 Okay, in gaps in two of four plates in fuel with the 4.5 20 enrichment and a gap size of almost 4 inches, if we look at a 21 gap size of four inches, would that meet the .95 K-effective as 22 described by the desiDn criterion? 23 A (Kopp) Well, I assume what the gaps in two of four 24 plates mean is that you would have these gap sizes in 50 l f) hd) 25 percent of the Boraflex plates in the entire pool. In that i Heritage Reporting Corporation (202) 628-4888 1 l
{. 1 i [ V 342 l 1 case you would exceed the .95 criterion with little less than 4 6 , H 2 inches, i i 3 Q Okay, if you want to go, then, to figure 3, and we' re i 4 using the 4.1 percent enrichment there. And with gaps in all l 5 four plates, is at about 3.5 inches, would that exceed the .95 6 K-effective? l 7 A (Kopp) For a 3.5 inch gap in every single plate? I- 8 Yes. 9 Q Okay, in gaps in two of four plates, and we' re 10 looking at a gap size of about 5. 5 inches. Would that exceed 11 the .95 K-effective? 12 A (Kopp) I think it's closer to 7 inches. r~) U 13 Q Excuse me, 7 inches, I' m sorry. 14 A (Kopp) Yes, a7 inch gap in 50 percent of the i 15 Boraflex plates in the pool would exceed the .95. 16 Q Would it be a fair statement to say~that, if this 17 kind of abnormal condition were -- this, I know this is a large 18 amount of gaps to have in the Boraflex, but if this condition 19 did exist at Turkey Point, they would not meet the .95 K-20 effective criteria in the instances we just talked about? 21 A (Kopp) That's right. 22 O Dr. Wing, on page 4, you' re talking about tests here 23 that have been performed on Boraflex and these are all 24 laboratory tests, is that correct? r) 25 A (Kopp) (" J Yes. U Heritage Reporting Corporation l (202) 628-4888 l
p'N L M 343 1 Q On paDe 7, Dr. Wing, again you state that "the exact 2 mechanisms that cause the observed physical degradations of 3 Boraflex have not been confirmed." That's st ill accurate? I
'4 mean, people don' t know what's causing the Boraflex to degrade?
5 A (Wing) That's correct. 6 0 "But the staff can postulate that the gamma radiation 7 from the spent fuel initially induced cross-linking of.the 8 polymer in the Boraflex, producing shrinkage ~of the boraflex
') material. When cross-linking becomes saturated, scissioning, a 10 process in which bonds between atoms are broken of the polymer, 11 predominated as the cumulative radiation dose increased, ,/~} 12 scissioning produced porosity, which allowed the spent fuel i /
b"O 13 water to permeate the boraflex material." And it says, 14 "scissioning and water permeation could embrittle the boraflex 15 material." 16~ Your inforu.ation on that, where does it come from? 17 Is it from a certain plant or documents? About the j 18 scissioning, and you know, at certain levels? l 19 A (Wing) The mechanism of bond scissioning can come j i 20 from several sources. One is from the Quad City report, the f 21 other one is the Point Beach report. l 22 Q On page 8, I think it's still Dr. Wing there. It 23 states that, " licensee," this is at the top of the page, k 24 " Licensee also stated that the Boraflex panels at the Quad City p ; [f~D h /J
/ 25 station were not constructed from a single sheet of Boraflex, l l .
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f L 9, l \ /- 344 l l 1 resulting in pre-existing breaks in the_Boraflex panels, L 2 279, enclosure at 3-4." 3 Isn' t there more recent information from the licensee 4 that attached a lett,er from the Joseph Dates Corporation that 5 states that "only full sheets of Boraflex were used in the Quad 6 Cities spent fuel racks?" . 7 A (Wing) Yes. 8 Q So then, would that no longer be accurate? 9 MS. YOUNG: If you could define your question a 10 little more? What are you referring to as "it?" ; 11 BY.MS. LORION:
/~h 12 Q Okay, could this statement that -- oh, no, I guess
_/ 13 the Licensee stated that as true. I' m sorry. l' 14 Why would this be important if at Quad Cities they 15 were not -- the sheets of Boraflex were not constructed from a 16 single sheet of Boraflex? Why would this -- would this be a 17 positive thing for Florida Power & Light as far as Turkey Point 18 is concerned? 19 A (Wing) If a Boraflex panel was constructed from two 20 sheets of Boraflex material, two or more, and they were abut-21 fitted together, ther; you would have what we call a " pre-22 existing Dap." ; 1 23 Q So are you saying that it was maybe thought that they l 24 weren' t, if the Doraflex at Quad Cities was not in a single f'\ 25 sheet, that that could have caused the gap formation? ) (
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. O 345 1 1 A (Wing) Yes.
,- ~ 2 Q And so that's no longer known to be accurate, is that B
'3 correct? 'That --
I' ll rephrase that again: in other words, 4 the Boraflex at Turkey Point is in a single sheet, and the 5- Boraflex at Quad Cities is also in a single sheet, is that 6 correct? There are no differences in the sheets of Boraflex in
- 7. the plants? I.know there is a difference in the design, but is 8 there differences in the Boraflex itself? i 9 A (Wing) I have no problem with the Licensee's 10 statement that " single sheets wer used at Turkey Point." The i
11 staff has not' resolved it -- problem of whether single sheets !
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- 12. or strips of sheets were used in Quad Cities.
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b" " 13 Q O'kay, so that has not been resolved? 14 A (Wing) Yes, that has not been resolved. 15 Q On paDe 9 and 10 of your testimony of Dr. Wing again, i 16 Answer 8, " Gamma radiation induced cross-linking and i 17 scissioning of the polymer in Boraflex can take place in the t 18 spent fuel pool racks in the Turkey Point plant in the presence > 19 of spent fuels. The Boraflex panels at the plant is attached 20 to a stainless steel wrapper panel and the entire assembly is 21 submerged in water. Water can permeate into the Boraflex ! 22 especially at the edges of the panel. Thus, minor degradation, l 23 such as chanDes in color, sizen, hardness and brittleness, can > l 24 be expected. However, the staff cannot predict with certainty l [) 25 whether the gap formation will occur. This is because the l s_a i i i ! Heritage Reporting Corporation j (202) 628-4888 i l l
I y I_/ 346 1 staff has not identified the specific mechanism which causes 2 gap formation in Boraflex. While Licensee may be correct in j 3 concluding with physical restraints would lead to gap l l 4 formation, the staff lacks sufficient information to concur in ! 5 Licensee's analysis, particularly a complete description of the 6 fabrication quality assurance, quality control, and inspection 7 to verify the fabrication." 8 Are you saying that, although we' ve heard experts 9 here testify that gap formation would not occur at Turkey Point 10 Florida Power & Light, that you cannot agree with that 11 testimony? 12 MS. YOUNG: I' d like to pose an objection. I' m not (, s) 13 sure Ms. Lorion is accurately depicting the state of the , 14 record? 15 JUDGE LAZO: Sorry, a little louder _please? 16 MS. YOUNG: I' m not sure Ms. Lorion has accurately 17 represented the state of the Record in this case? I mean, l 18 witnesses for Florida Power & Light have said " gap formation 19 will not occur at Turkey Point." 20 JUDGE LAZO: Well, she read a long portion from the 21 testimony and then finally did get to her question. 22 MS. YOUNG: But she wasn' t referring to the staff 23 testimony which she cited from. She was referring to testimony f 24 from other witnesses, from the Licensee's panel. I 25 JUDGE LAZO: Oh, very well -- it's a proper Heritage Reporting Corporation (202) 628-4888 1
r l d 347 1 objection. 2 MS. YOUNG: If I' m wrong, I mean, she can clarify. 3 JUDGE LAZO: I thought she intended to refer '.o this 4 testimony she had just read. - 5 DY MS. LORION: : 6 Q Okay, is it your conclusion that -- or your statement. 7 here, that you -- the staff cannot predict with certainty 8 whether or not gap formation will occur at Turkey Point? 9 A (Wing) That is correct. i 10 0 Could you explain a little bit what you mean by the j 11 line, "while Licensee may be correct in concluding that i
/~} 12 shrinkage with physical restraints may lead to gap formation, j
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b-U 13 the staff lacks sufficient information to concur in Licensee's i 14 analysis, particularly a complete description of the 15 fabrication, quality assurance, quality control, and 1 16 inspection, to verify the fabrication?" 17 Could you explain what you' re saying there to me? 18 A (Wing) The Licensee believes that their formulation 19 may be a result of shrinkage and physical restraint. And the 20 Licensee states that this may not happen at Turkey Point 21 Boraflex panel. The staff has not established the fact that 22 physical restraints are or are not present in the Boraflex l 23 panel in Turkey Point until we have a complete description of 24 the fabrication process, the quality control of the
,O l" / 25 " application, and inspection, to verify the application.
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r (O / 348 1 Q Can you tell me exactly what you mean by " physical 2 restraint?" Do you mean the rack design? Or the adhesives? , 1 3' A (Wing) It could be a design or a process that can --
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q 4 that will give physical restraint to a Boraflex panel. 5 Q So an adhesive would also be a restraint, or would it 3 6 not? 7 A (Wing) An adhesive is possible, is also physical i 8 restraint. 9 Q Thank you. 10 Dn page 11, and I guess it's Dr. Wing again, "By 11 letter dated August 20, 1987, L-87-348, the licensee reported pr 12 the results of testing on 54 Boraflex panels from storage cells C/ 13 in both Region 1 and Region 2 of the spend feel pool; that a 14 representative of those storage locations which have received 15 an estimated radiation dose of 7.8 times 10 to the 9 rads, the i 16 highest accumulated exposure to date, no' indications of gags, f 17 voids or other spatial distribution anomalies was observed." 18 Would you expect gaps, void and anomalies to occur at l 19 that gamma exposure, 10 t o t he 9, as far as laboratory 20 experience goes with Boraflex? 21 A (Wing) If there were no physical restraint, I would
. 22 not expect any voids or gaps in the Boraflex. f 23 Q Do you agree with Dr. Kilk who testi fied that in the 24 laboratory they see degradation of Boraflex at about 10 to the ;
) 25 10 rads of gamma radiation?
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L/ 349 '] I 1 A (Wing) I' m not sure which laboratory test you refer ! 2 to 3 Q That he referred to in his testimony. De do you know 4 anything about that? At what gamma radiation level the -l I 5 Boraflex would experience degradation, or would be expected to? i j 6 A (Wing) There are two different kinds of degradation 7 we are talking about here. One I would classify as minor. The ) 8 other one would be gap formation. k l 9 For minor physical degradations such as the changes 10 in color, size and so forth, you would expect at this gamma 11 radiation level. r 12 For gap formations to occur, you need shrinkage and "d' 13 physical restraints to combine to give you the gap formation. 14 THis is how we conceive the mechanism. 15 Q Would you then not expect gaps to occur at 7.8 times 16 10 to the 9 rads? 17 A (Wing) If there were no physical restraints, then at 18 this level I do not expect any gap formation. 19 O In the same paragraph it's also stated, "The results 20 of this testing also verifies that no gaps existed in these 54 21 Boraflex panels prior to exposure to spent fuel, and that i 22 probably no physical restraints exist in these panels." 23 Why would there be gaps before exposure to the spent 24 fuel? Would that be some damage during the process, or putting f \kd () 25 the racks toDether or? l Heritage Reporting Corporation (202) 628-4888
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1' L.) 350 1 A (Wing) That's one possible way to have gaps before
-2 radiation.
3 Q Your next'line is, "On the basis of all available l 4 data.and information and if indeed physical restraints do not 5 exist in the Boraflex panels, the staff could reasonably state 6 that gaps will not likely form in the-Turkey _ Point Boraflex , 7 panels." 8 Does this mean that if you found that physical 9 restraints do exist in'the Turkey Point spent fuel pool racks, 10 including adhesive, would that change your statement here? 11 A If there are physical restraints that are sufficient y 12 to cause gap formation, and you have shrinkage due to 13 radiation, then gaps would likely form in.Boraflex panel. ! 14 Q Same page 11, your answer 9. " Substantial physical 15 degradation can alter the neutron attenuation properties of 16 Boraflex and reduce the neutron absorption effectiveness of the 17 Boraflex panels. Consequently, physical degradation can 18 decrease the margin of suberiticality of the fuel pool." 19 Is there any perceivable situation in which the 20 degradation could decrease the margin of suberiticality so that 21 the spent fuel pools would not meet the .95 K-effective 22 criteria? 23 A (Wing) I will refer this question to Dr. Kopp. 24 (Kopp) Well, the most likely way that we can think [ 25 of would be what referred to initially, those figures that A Heritage Reporting Corporation (202) 628-4888
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1 showe'd the effective gap formation on the K-effective of the ) l 2 spent fue1~ racks. j 3 Q So if the gap formation became severe enough, then it j
- 4. could affect the suberiticality? ]
5' A (Kopp) Yes. . 6 And.if it extended to the entire length of the fuel. 1 7 racks, not just any localized region. I l 8 Q On page 12, and I don' t know who it is. 9 _ MS, LORION: Is that Mr. McCracken?- On page 12, 10 answer No.'10', who gave that answer? Was it Mr. McCracken? 11 l' m having trouble going back and finding the name. l 12 MS. YOUNG ' If there is no name indicated, then . it's r
"Q
- 13. a joint answer.
14 THE WITNESS: (McCracken) No name, it's a joint ; 15 answer. It's hard to tell until you ask a question. 16 MS. LORION: Okay. 17 BY MS. LORION: 18 Q Again, in that answer it's stated that the staff 19 cannot predict whether or not gaps will form in the Boraflex 20 panels at Turkey Point because they don' t have enough 21 information, and I paraphrased that. 22 But down at the bottom of the paragraph it says, 23 "Nevertheless, recognizing that such gaps may not form in the 24 Turkey Point Boraflex panels, a reasonably conservative N 25 approach would be to use the limited Quad Cities data, the only I-o 1 Heritage Reporting Corporation f (202) 628-4888 L - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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l 1 data available indicating the occurrence of gaps, to estimate 2 the potential gap size in the Boraflex panels at Turkey Point." 3 Is this why when Florida Power & Light did their 4 reanalysis of criticality, they used the -- they used the 5 conservative values and used a 4-inch gap and above? 6 MS. YOUNG: I' m going to have to object to that 7 question. 8 9 10 11 12 13 14 15 16 17 18 19 I 20 21 22 23 l
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l - V 1 / 1 Y MS. LORION: 1, L 2 O Did the staff ask them to look at certain gap sizes? , l 3 MS. LORION: No, I can' t ask that? I 't? ! No, I was objecting f r/ .om the standpoint 4 MS. YOUNG: l ! / l 5 it's difficult to ask this panel why Florfda ' P9wer & Light did L1>> 6 certain things. / ,' 7 MS. LORION: Okay. , 8 MS. YOUNG: And the question is better posed to 9- Florida Power 8 Light. y
,4 10 MS. LORION: Okay. ,
11 MS. YOUNG: So try to just phrase your qu$stion in # I (- L< 12 terms of something that the staff panel can answer.
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g 13 MS. LORION: Okay. 14 DY MS. LORION: 15 O When you asked Florida Power & Light to perform the s 16 reanalysis of criticality, did you ask them to use the Quad 17 Cities data? js 18 A (Kopp) We asked them to look at a barometric survey 19 of different gap sizes to see the effect on K-effective. 20 Q And you asked them to use it conservatively. In 21 other words, gaps larger than the size you would expect. , 22 A (Kopp) We didn' t know what to expect, so we asked ' l 23 all the way from complete in tact Boraflex sheet O gap, up to, l l 24 I think they went up to 10 inches in come cases. r^ I f )% 25 Q On page 13, Dr. Kopp, at the bottom of the page, and l kJJ 1 ii l 4 Heritage Reporting Corporation '
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i 1' I think you are talking about the renults of Florida Power & 2 Light's sensitivity study to determine the effect of gaps. 3 "The results indicate that fuel enriched to 4.5 4 weight percent U-235, the acceptance criterion of K-effective 5 less than or. equal to .95 is met for the case of a 2-inch gap 6 at the same elevation in all of the Boraflex panels in the
- v ;. . i 7 rack. ,The acceptance criterion is also met for the case of 1
8 almost a 4-inch at the same el'evat ion in one-half of the 1 9 Boraflex panels, two of four panels in each storage cell in s
-10 Region 51 in the rack."
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11 Are you saying here that the acceptance criterion is 12 : not met for all of the panels in a 4-inch gap, looking at a O r 13 1 4-inch gap? 14 MS. YOUNG: I would like to object. I think the t 15 question has been asked and answered. 16 MS. LORION: But I d idn' t ask him. I asked Florida 17 Power & Light, a different witness. 18 MS. YOUNG: About 10 - 15 minutes ago, I believe you 19 asked him. 20 MR. FRANTZ: Yes, I concur in that objection.
.c 21 MS. YOUNG: We can get a ruling from the Board based 22 on their recollection.
23 JUDGE LA7.0: All right, we' l l sustain the objections. 24 BY MS. LORION: l j (~ 25 Q On page 16, I think it's Dr. Kopp again, at the L ( 1 ) l l' Heritage Reporting Corporation (202) 628-4888
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355 V l 1 bottom of the page. "In early August 1987, licensee performed a s I' ' ' ' 2 baseline blackness testing on the Boraflex panels that have 3 received the highest cumulative' radiation exposure to date. l E 4 Licensee expects to perform future surveillance testing of the 1i. 5- Boraflex panels within three years or sooner if industry
,1 M 6 experience indicates a shorter period for surveillance is-7 warranted. L-87-384, August 20, 1987. 4
, j 8 "In addition, licensee made a commitment not to store 1 9 any fuel with an enrichment greater than 4.1 weight percent 10 U-235 prior to completion of the next surveillance.
11 L-87-363, August 27, 1987."
,r- 12 In some of the cases we looked at, Dr. Kopp, on those i
N" " 13 figures with many gaps in the pool, I guess you are aware of 14 the testimony, or I may be misstating this, but the tests that 15 Florida Power & Light did, they can predict gaps I believe up 16 to,'was it 1. 5 inches? Or excuse me, more.than 1.5 inches. 17 A (l(opp) I believe so, yes. 18 MS. YOUNG: Did you mean predict or detect? I 19' MS. LORION: Detect. I' m sorry. I misspoke. l l 20 THE WITNESS: (Hopp) Yes.
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21 BY MS. LORION: 1 1 22 Q And they don' t plan to do another blackness testing l 23 for three years. is there any possibility, or would you expect 24 the gaps to grow - gaps to occur in a three year period? f fN6)/ 25 Say if they could not detect a gap of 1. 5 inches, is Heritage Reporting Corporation (202) 628-4888
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(, ik a 356 j 1 there any possibility that in that three-year period they could k 2 have gaps of a significant size if gaps they did not debeet ) 3 were in the pool, present in the Boraflex in'the pool? l 4 MR. FRANTZ: I' m not sure the term "significant" is 1 5 defined here. What do you mean, "to grow in significant size"? 6 MS. LORION: Well, I guess 3 to'4 inchen. 7 THE WITNESS: (Kopp) I think we really answer that j l 8 in the following question, but we feel that the level of 9 radiation both at the time of the previous blackness testing 10 and the next one, in two and a half years, the accumulated dose 11 will be sort of in the plateau range where we would not expect 12 any additional shrinkage, or very little additional shrinkage. V 13 Therefore, if there were any gaps that were not 14 detectable less than 1.5 inches, we would not expect theri to 15 grow any by the time the next surveillance is done. 16 BY MS. LORION:
- 17. Q The other statement I read was about the licensee 18 making the commitment not to store any fuel with an enrichment 19 grade greater than 4.1 weight percent U-235 prior to completion 20 of the next surveillance.
21 I would like to know what you mean by commitment. I 22 know there was a letter and a statement that they would, or 23 that they would not be storing that fuel, but what is meant by 24 commitment?
\ 25 A (Kopp) Well, I guess they stated -- what we mean is
(!
%s Heritage Reporting Corporation (202) 628-4888
L+ l l 357 1 they stated in the letter that based on their fuel management - l 2 scheme and the amount of increased enrichment they plan of I 3 going to at any recycle, oy the time the next testing came l 4 around there would be no fuel of the size 4.1 weight percent 5 enriched U-235. 6 I' m not sure it was really a commitment or just a 7 statement based on their loading procedures and so forth, fuel . 8 shuffling arrangements. 9 O Does this have any significance as to criticality -- 10 excuse me, as to some of the testimony of Mr. Boyd that we 11 looked at that showed fuel with 4.5 weight percent at certain 12 Dap formations would not meet the .95 K-effective?
- J 13 I' m just wondering why it's stated over and over 14 again that they are not going to store more than 4.1 percent.
15 Is there some reason that they shouldn' t store more than 4.1 16 percent? 17 MS. YOUNG: Excuse me, Dr. Kopp, before you answer 18 that. 19 Do you have any objection to me showing him the copy 20 of the letter you asked for? 21 MS. LORION: No. 22 JUDGE LAZO: Ms. Lorion, where does that language in 23 the answer regarding the commitment appear? I can' t find it in 24 my copy. 25 MS. LORION: Oh, it's at the bottom of the page. n .J Heritage Reporting Corporation (202) 628-4888
i l '. i I ?- [ /"m-358 1 JUDGE LAZO: Page?
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2 MS. LORION: Page 16, the last four sentences. 3 JUDGE LAZO: Very well. Thank you. 4 MS. YOUNG: Dr. Kopp, do you understand the question? 5 THE WITNESS: (Kopp) I don' t recall -- could you 6 please repeat it?
'7 BY MS. LORION:
8 Q The other statement, I had asked you why the word ! 9 " commitment" was use, because we have seen letters -- 10 MS. YOUNG: What was the date? 11 (Pause.)
-s 12 BY MS. LORION: l
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13 O Such as the August 27th letter which is stated here 14 where Florida Power & Light stated that they would not be 15 storing fuel more highly enriched than 4.1 weight percent 16 before.the next surveillance. 17 And why is that significant? 18 A (Kopp) Well, first of all, I think the word i 19 " statement" probably would have been better than " commitment". 20 The last statement says that they will not store fuel, but 21 there is no commitment as far as a letter goes. ! 22 And, of course, the lower enriched fuel you have for j 23 the same gap size, the lower- your K-effective will be. ; 1 24 O So they made no commitment and the NRC staff is not l
) 25 going to ask them to make any commitment not to Do above the Heritage Reporting Corporation (202) 628-4888 i
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# A h___, 359 1 4.1. percent enrichment in the ncxt three years.
2- A (Kopp) Well, there is really no basis to at this 3 point. No gaps have been found, and we do not think any will 4 be found by the next surveillance interval. 5 Q I think, following along with this on page 17, Mr. 6 McCracken, "The staff believes that the next proposed 7 surveillance should include a representative sample of panels 1 8 subjected to a range of radiation exposure to provide 9 reasonable assurance that fuel with enrichment up to 4.5 weight 10 percent U-235 can be stored at Turkey Point and maintain the 11 .95 K-effective acceptance criterion."
;,e- 12 Does this mean that you have some doubt as to whether b"
13 they would be able to maintain the .95 K-effective storing fuel 14 with_ enrichment up to 4.5 percent if there gaps in the Boraflex 15 A (McCracken) As we said earlier, we have doubts as to 16 the mechanism for gap formation, and if there are restraints at 17 Turkey Point which would result in gap formation upon shrinkage 18 of Boraflex. 19 Until we have adequate data to show that they aren' t 20 going to have any gaps, that's a conservative approach to take. 21 Q So there might be a reason for Florida Power & Light 22 stating that they would limit their enrichment to 4.1 percent, 23 or did they just decide, you know, that that's what it was? I ( 24 I' m just trying to get at something here that I don' t f O 25 quite understand. It seems that in some instances if there is i h- - i Heritage Reporting Corporation I (202) 628-4888 _- -_- i
,O l U 360 1 gap formation, especially at_the 4.5 percent enrichment, 2 Florida Power & Light is not coing to meet the .95 K-effective.
3 A (McCracken) I don' t think that's a correct 4 statement. 5 Q Okay. Tell me why, please. 6 A If they do have gap formation based on the data they 7 have shown to date, or they have a exposure of 7.8 times 10 to 8 the 9th rads, and at that exposure they do not see gaps of 9 anything over 1 and a half inches, then the Boraflex has 10 already achieved the radiational level that will give it 11 maximum shrinkage. 12 Therefore, even under additional radiation, you would (g ') 13 not anticipate a much greater shrinkage. So even if gaps were 14 to occur, they would probably not be very large. But from a 15 conservative point of view, we felt their surveillance program 16 needed to show that the next time before they went to the 4.5 17 percent just to provide added assurances that there is not a 18 problem with them meeting the shutdown margin. 19 Q And is this in reference to the reanalysis that, the 20 criticality reanalysis that was performed by Florida Power & 21 Light?, I mean, isn' t that what you asked them to show in that l 22 reanalysis? 23 A (McCracken) In that reanalvsis, they showed what 24 they would have at various gap sizes with various enrichments.
) 25 And in that particular analysis, In believe in Mr. Ko pp' s l
Heritage Reporting Corporation ! (202) 628-4888 i
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'361 1- testimony, they said that at a 2-inch-gap at 4.5. percent, I 2 through all the panels, that's a gap across the whole pool, L 'EndT9 3 that at'that' point you would exceed the.K-effective, .95 l ^T10 4- :D- On page'18, Dr. Kopp, it states in your testimony l
l 5 that, "NRC calculations have'shown.that'under normal storago [ 6 conditions at< Turkey Point with the pool water borated to 1950 7 ppm of boron, all of the Boraflex. panels could be removed and 8 the .95 K-effective acceptance criterion would be met even with 9 t'e h 4.5' weight percent fuel." 10- I understand your statement, but again, doesn' t the' 11 criterion call for it meeting the K-effective without the boron
- 12. in the pool? I' m trying to understand why the statement keeps Dec'l- 13 being made when the criterion calls for the .95, or I think it 14 does, to met'without boron.
15 A (Kopp) Well, this just provides us with added 16 assurance that there is additional type of surveillance that 17 they are doing at a more frequent basis than the Boraflex 18 surveillance which would indicate any other abnormalities such 19 as loss of boron in the water. And . it's j ust something that
- 20. provides us with added insurance. j 21 Q Do the witnesses have a copy of the NRC Information 22 Notice No. 87-43, Gaps in Neutron-Absorbing Material in High l 1
23 Density Spent Fuel Storage Racks, September 8, 19877 ) l l 24 A (McCracken) Yes. '
) 25 O I would just like to ask a few questions on that.
u l -' l Heritage Reporting Corporation I (202) 628-4888 1 _..---_________j
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i Under purpose, it states, "This notice is to alert , I i 2 recipients to a potentially significant' problem pertaining to , J 3 gaps identified in the neutron absorber component of the high 4 density spent fuel' storage racks at Quad Cities Unit 1. The l 1 5 safety concern is that certain gaps might excessively reduce l i l 6 the margin of nuclear suberiticality in'the pool." l 1 7 And then it goes on to ask recipients to review the 8 information. ] 9 Would any of you agree that what's happening at Quad Cities is a potentially significant prob 1dm pertaining to gaps? 1 10 j
-1 11 I mean the' language here, would you agree with that language )
,-m; 12 that what's happening at the Quad Cities plant with the gap 13 formation is a potentially significant problem?"
14 (McCracken) I concurred in this when it was issued. 15 Therefore, I must agree with whatever is in it. 16 Q Well, do you also agree then that the safety concern 17 is that certain gaps might excessively reduce the margin of 18 m clear suberiticality in the fuel pool? 19 A (McCrackun) Yes. 20 Q So gap formation could be a very serious problem. 21 A (McCracken) You would have to define what you'mean 22 by very serious. 23 0 Well, if certain gaps might excessively reduce the 24 margin of nuclear suberiticality in the fuel pool, would that }. 25 be considered a significant safety problem, or safety hazard? l f-w) ) Heritage Reporting Corporation (202) 628-4888 a 4
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..- 1 1- 'A That would be consideredian, event that could-wind up 1;
2' violating'a plant technical specification. 'And anything~that d h. would' violate a plant technical specification, we would ! Al consider to<beisignificant. ' 5 Q' On page 2 of the report under " Discussion - ."Further 6L Notification," I' m . sorry.. j 7- "The concern is that the separation of the neutron - i 8 absorbing. material used in high density fuel storage racks j i 9 might. compromise safety, although Quad Cities reports that.'its l l
.10 - racks.. Even with the gaps in the Boraflex as large-as-4 i
, i 11 inches can meet the criticality. criterion of K-effective less. {
i i
- 12 than1or equal to .95, this may not be the case for larger gaps j
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. (# - " 13 or for other plants." 'l I
-14i Why would this not be the case for other - perhaps. ]
15 for other pools or other plants? 16 ft (M-Cracken) Different plants have different fuel. 1 i I 17 stored and different field arrays. Therefore, each plant would 1 18 have-to do its own individual analysis to determine the i 19 effective gap size in that particular fuel pool for,those
]
20 conditions. ) I 21 O So if you had a greater margin before meeting the .95 l I r 22 K-effective, you would have more room for more gaps; is that ) ! l i 23 true? ! 1
.l 24 A (McCracken) Yes. !
l f 25 O So in other words, if at Quad Cities they started ; j h/ ' Heritage Reporting Corporation (202) 628-4888 l C J
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.1 with a .9105 K-effective and then they ended upolooking,at the- j I
2' gaps and doing the kindtof analysis Florida Power & Light did j I 3 and ended up with a .941, they would still1be within the i 4- margin; is that correct? Assuming those -- 5 A (McCracken) Yes.- ) 6' Q' -- figures are correct. j
'7 MR. FRANTZ: I' m going -to object to that question.
8 There-is no' basis in-the' record for postulating wnat Quad ! t 9' Cities initial-K-effective was, what-the impact of.these gaps l I 10 was'on QuadDCities. !
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- 11 MS. LORION: I don' t know what to say except thatJI .!
12 took the figures from the Quad Cities report and their. O 13 criticality analysis. 14 MR. FRANTZ: That may be true, Ms. Lorion, but that 15 hasn' t been established on the record. 16 JUDGE LAZO: Well, that's easy enough fto do if you 17 are going to insist upon it. The reports are available and the 18 witness can look at them. 19 Why don' t you proceed, Ms. Lorion. 20 MS. LORION: Okay. 21 BY MS. LORION: 22 Q And I believe, or 1 would like to refer to a Florida 23 Power & L;ght letter July 10, 1987, where they attach their 24 original criticality analysis from the safety analysis report. 25 This is the original analysis for the amendments. Heritage Reporting Corporation (202) 628-4888 1- --_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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.Lp-] 365 1 Okay, and when they requested the amendments, the 4 2- criticality analysis showed a K-effective of .9403. Would that i
3 mean there would be less margive at Turkey Point according to ] 4 this information notice? Would they be perhaps one of the 1 5 plants that might not meet the criterion if significant gaps 6 developed? 7 MR. FRANTZ: I object to that question. Less margin 8 than what? I 9 MS. LORION: Than the Quad Cities plant. ' 10 MS. YOUNG: I also object. The question got value 11 because you started an exchange in Turkey Point and Quad
,-s. 12 Cities, and I think the point of your question got lost. You N.")"
13 might try to rephrase it. 14 MS. LORION: Okay. 15 BY MS. LORION: 16 Q Okay, the information states that, "Although Quad 17 Cities reports that its racks, even with gaps in the Boraflex 18 as large as 4 inches, can meet the criticality criterion of 19 K-effect less than or equal to .95. This may not be the case l 20 for larger gaps or for other plants." ; 21 What I think I am trying to ask -- I know what I' m 22 trying to ask but I can' t get it out -- is if Quad Cities 23 starts with a K-effective of .9105 from their safety analysis l 24 report, and Turkey Point starts with criticality of .9403, 25 assuming that they experience the same kind of gap formation in {n) a l Heritage Reporting Corporation ! (202) 628-4888 l l c l . _ _ $
;p i
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. rp LI 366 i 1l the pools, would. Turkey. Point'have less of a margin before they' l 2 met the .95 K-effective criter3a?
i 3 A (McCracken) I assume you are asking about margin:as' :) (4 far as gap size. 5 y Q 1 I' m asking about margin of safety, or. margin'before l' 6' meeting the 95/95 standard av.d .95 K-effective criteria.
. a 7- A. (McCracken) Unless you relate it to gap size, I t
8 really don' t think I can give.you an answer on it.
.9 10 Okay.-
10 MS. LORION: I haveino more questions. , l 11- JUDGE LAZO: Mr. Frantz, licensee did not indicate 12- whether or not they had any cross-examination of these
.13 witnesses.
14' M R. FRANTZ: If we could just have a moment, Your 15 Honor. 16 (Pause.) q
% 17 MR. FRANTZ: Licensee has no questions. l 1
18 JUDGE LAZO: Let me just ask one question while Judge j 19 Cole is looking in his notes. And that the definition of the
)1 20 word " gap". I am still having a little difficulty know exactly I 21- what a gap is. I mean, is it a void, a hole, a space, some 22 kind of a crack? -)
23 There was some discussion by Dr. Wing that he said he , I 24 would not expect to see gaps or voids at a dose of 7.8 times 10 ( 25 to the minus 9 rads if there were no physica1' restraints. But l
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Heritage Reporting Corporation (202) 628-4888 l l
I 1 l 1 3 y -] Fd 367 1 if there were no physical restraints, wouldn' t one expect to )
- 2. see some shrinkage, some shortening of the panel?
3 THE WITNESS: (Wing) Yes.
' 4' JUDGE LAZO: And does that shortening or shrinkage 5 which might produce a gap, if that's what we properly c:all it, 6 of 7.5 inches across the panel, is that space caused ~by the 7 shrinking.also included in the definition of " gap", or does it 8 have to be a hole, or a space, or a void?
9 THE WITNESS: (McCracken) I think I noticed some 10 problems on that question this morning, and part of it was 11 addressed in testimony yesterday by the licensee. 12 We anticipated shrinkage of Boraflex. That was not 7s k" ~' 13 new. 14 JUDGE LAZO Yes. 15 THE WITNESS: (McCracken) And when the panels were 16 installed, if you assume this was a panel to full 139 inches 17 long. 18 JUDGE LAZO: Right. 19 THE WITNESS: (McCracken) If you have shrinkage and 20 nothing restrains it and it simply either slides down or if it 21 slid up 3 and a half to 4 inches, that was allowed for~in the 22 design, and that's not a gap. 23 JUDGE LAZO: That's not considered to be a gap. 24 THE WITNESS: (McCracken) A gap is when the thing n J' La
) 25 has a tear basically across the whole thing.
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1 JUDGE LAZO: Whole thing. 2 THE WITNESS: (McCracken) That's a gap. l l 3 JUDGE LAZO: 'All right. l l 4 THE WITNESS: (McCracken) And the definition we have ) i 1 5 been'using. But if it simply went up or down, you didn' t get a ! 6 gap.
. 7 JUDGE LAZO: All right. I was a little confused I 8 think by Mr. Boyd's testimony on the subject, and that j-9 clarification is veryJhelpful.
10 Thank you, Mr. McCracken. 11 JUDGE COLE: I just have a couple very short 7-~, 12 questions, gentlemen. 13 On page 5 in the first full paragraph on the page, 14 you refer to a borated water immersion test of Boraflex, and 15 the temperature of the test is 240 degrees Fahrenheit. Is this 16 a pressurized test, or do you know anything about the 17 conditions of this test? , 1 18 THE WITNESS: (Wing) I don' t believe it's 19 pressurized in the sense of like a pressurized water in the 20 pressurized water reactor. 21 JUDGE COLE: I guess my point is how come it d idn' t 1 22 boil before you reached 240, because I didn' t think you would i 23 have enough solids in it to bring up the boiling point to 240 l 24 and conduct a test like that if you are talkinD about boron (\J ) 25 concentrations close t o, you know, 1950 parts per million. Can Heritage Reporting Corporation f (202) 628-4888 i
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- l' I 1 you reach.240, keep it from boiling?
2 THE WITNESS: (McCracken) That test was conducted in 3- an autoclave. So it was at the saturation pressure and 4 temperature for 240. 5 JUDGE COLE: Okay, fine. 6 Just a general question about the state of 7 informational knowledge on Boraflex and its shrinkage wit,h 1 8 respect to dose. There is some research -- has been done or is 5 9 being done at the University of Michigan. l 10 Do you gentlemen have any knowledge of the effect of I i 11 radiation on Boraflex with respect to shrinkage? Do we have l 12 some idea of how it reacts at different accumulated doses I [c M" 13 enough to predict when we should start measuring? 14 THE WITNESS: (Wing) The recent Bisco test indicated 15 that at the gamma radiation dose of 5 times 10 to the 9th to 1 I li 16 times 10 to the 10th rad, the shrinkage is about 2.1 percent on 17 average. And when it gets up to 2.5 times 10 to the 10th rad, 18 the shrinkage was about 2.4 percent. 19 JUDGE COLE: All right, sir. - 20 Do you know if the shrinkage occurred after a certain 21 dose level, or was it a gradual shrinkage, uniform shrinkage 22 associated with dose? 23 We' ve got one on point on a curve, or we' ve got two 24 points on a curve. Do we know what the rest of the curve looks 25 like in a curve of shrinkage versus dose?
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-1 THE WITNESS: (Wing) Are you referring to laboratory 2 test, or any kind of test?
3 JUDGE COLE: Any kind of tests; information in t 4 general. 5 THE WITNESS: (Wing) Well, the test data that I just 1 6 quoted to you from the laboratory test of Bisco Products. You 7 take the shrinkage at Quad City as a data point, and it would O be something like 2.6 percent shrinkage. 9 JUDGE COLE: OKay. At a certain accumulated dose. 10 THE WITNESS: (Wing) Certain accumulated dose. 11 That's about 10 to the 9th rad. ,. s 12 JUDGE COLE: If we had half the dose, would we have h 13 half the shrinkage, or don' t you know? 14 THE WITNESS: (Wing) I' m sorry, I don' t understand l 15 your question. 16 THE WITNESS: (McCracken) The data that Bisco 17 submitted from the University of Michigan included information 4 18 I believe as low as, and I' m sure that Dr. Wing has a report 19 somewhere, 5 times 10 to the 8th rad. l 20 JUDGE COLE: All right, sir.
]
21 THE WITNESS: (McCracken) And at 5 times 10 to 8th, t 22 they were showing a smaller amount of shrinkage, and as they i 23 went up to the 5 times 10 to the minus 9th, they were seeing I' 24 what they considered to be an approximately linear relationship 7g j 25 as they got up to the 2 percent. So they were seeing a very l l l Heritage Reporting Corporation I (202) 628-4888
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7,; ! ~ .k ) 371 1 small amount at 5 times 10 to the minus 8th, and then by the I . . . l 2' time they reached 5 times 10 to the minus 9th, they were at 3 approximately 2 percent. And above the 5 times 10 to the minus
)
4 9th, it stayed at 2.1 or 2.4 percent. ) l 5 MR. FRANTZ: Judge Cole, if I may. ; 6 JUDGE COLE: Yes. 7' MR. FRANTZ: That's also discussed on page 28 of the 8 Kilp and Gouldy testimony. i
)
9 JUDGE COLE: Of what testimony? 10 M R. FRANTZ: The Kilp and Gouldy testimony by the 11 licensee.
- 12 THE WITNESS: (McCracken) While you are looking
'^" for that, Dr. Kopp just informed me that I was saying minus 13 14 instead of plus. So it should be 5 times 10 to the plus 8th.
15 JUDGE COLE: That was understood, sir, yes. 16 All right, that -- ca, page 28 of that testimony it 17 indicates we had a three-quarters of 1 percent shrinkage at 5 18 times 10 to the 8th rads, and a 2 percent shrinkage at 5 times 19 10 to the 9th rads. I 20 Okay, t hat ' s fine. Thank you. That's all I have. ! l 21 JUDGE LUEBKE: Well, I' d like to get back to the 22 nuclear aspects of various safety mechanisms in these reactors, 23 and there is a sentence at page 18 of the staff prefiled 24 testimony, the bottom paragraph by Kopp, which says something f) two 25 nice about water borated in the pool, borated water in the Heritage Reporting Corporation (202) 628-4888
p-w., s, ) 372 1 pool. 2 My earlier question of the licensee suggested that 3 there was something bad about boron solution,in the cooling 4 water of the pool. So I ask the staff what's bad about it, 5 what's so bad about it? 6 THE WITNESS: (Kopp) There's nothing bad about it. 7 It's just an assumption that has to be made in in doing the 8 calculations. 9 JUDGE LUEBKE: Oh, but I got the sense -- I guess I' m 10 trying to make boron solution in the cooling water the primary 11 nuclear safety measure, and this Boraflex a secondary backup 12 safety measure. And if the solution is so good, then that's a 0 13 rational approach. 14 THE WITNESS: (Kopp) Yes, but the staff requirement 15 is that the .95 criterion must be met not only for normal 16 storage conditions which would be with the 1950 ppm boron in 17 the pool, but also for accident conditions. And the worst 18 reactivity type accident that one could conceive of would be 19 losing all the boration in the pool, and just moderating'the 20 fuel assemblies with pure water. 21 JUDGE LUEBKE: And to get that accident you have to 22 lose it suddenly. If it's lost gradually, you can watch it by 23 surveillance. 24 THE WITNESS: (Kopp) If it's lost during the monthly , n
/) 25 surveillance intervals, yes. I guess there is a monthly L/
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l: L , . m 373 , , j., i surveillance of the bors. tion in the pool area. l , 2 JUDGE LUEBKE: Well,- if you were really worried about u
; 3 it, you might have' daily surveillance.
t 4 THE WITNESS: (Kopp)., It is a technical -- 5 JUDGE LUEBKE: I guess what I' m getting at is; as the 6 years go by, I think we are just at-the beginning of'1 earning
^ 7 about Boraflex'.. And"as the years go by, I think you want to ,
8- prepare yourself for what are you. going to do. I mean,.you had 9 a page, or the licensee has a page full of options, you see. - 10 And one of.those is how you do-the solution with boron better. ' L 11 and what.it carefully, ta-da, ta-da.
,, , . 12 And so if that's the case, then all of this cross- ~ h"# 13 examination questions and answers about what happens to gaps, 14 et cetera, . et cetera, has less significance if boron solution 15 is any good at all. And I guess you are suggesting it's not ;
it all that bad.really. 17 THE WITNESS: (Kopp) Well, that's right. If the 18 surveillance intervals are daily, there appears to be no reason l 19 why one has to assume the loss of boron in doinD th6 l 20 calculations. 3 l 21 JUDGE LUEBKE: And that doesn' t sound to me to be l 1 22 very expensive. You know, just watch it daily. ! l 23 THE WITNESS: (Kopp) And with all the boron in the 24 pool water, you can leave out all the Boraflex plates and it [LL 25 would still be well below the .95 criterion. l Heritage Reporting Corporation l (202) 628-4888
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374 ( , 1 " JUDGE LUEBKE: Not'a very complex precaution. 2- -THE WITNESS: (Kopp) 'Right.- 3 JUDGE LUEBKE:' Thank you, sir. 4 Oh, a couple more questions;-maybe one more question. ~!
.~
5 I had;heardLQuad Cities 1 mentioned quite frequently j
.i 3 6 and Point Beach mentioned quite frequently. There are many 7 other-fuel storage expansions either in design, being built.or i
8 in recent. operation. Do.all'of these people use.Boraflex i'
- 9. 'THE' WITNESS - (Kopp) A lot of themido. Some of them 10 do 11 JUDGE LUEBKE: Fifty?l 12 THE WITNESS: (McCraclen) O n t h e --
q, 13 JUDGE LUEBKE: I' m trying to get the magnitude of it. 14 THE WITNESS: (McCracken) Thirty-one. 15 JUDGE LUEBKE: Thirty-one fuel' expansions --
. 16 THE WITNESS: (McCracken) On the.back of the 4 -
i 17 information notice all plants that are using i t) are identified. 18 JUDGE LUEDKE: And'this is in the record, is it? a 19 MS. YOUNG: No, it is not. 20 THE WITNESS: (McCracken) The information notice is 21 not in the record. 1 22 JUDGE LUEBKE: Oh. Well, I guess it's in the record I f 23 now that I have said it and you have answered it. 24 MS. YOUNG: The information notice was distributed by 25 letter of staff counsel dated September 10, 1987. Heritage Reporting Corporation (202) 628-4888
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i I 7-, f__, , 375 1 JUDGE LUEBKE: All right. So my impression o'f that 't 2 answer is that there will be a great increase in the amount of a 3 information that the NRC staff is going to accumulate on 4 Boraflex. I mean it will keep coming in. 5 THE WITNESS: (McCracken) Yes. ! 6 JUDGE LUEBKE: And so a year from now, two years from ; Y F 7 now, three years from now you will have a thick notebook full. 8 THE WITNESS: (McCracken) I' d like if it will be a 9 small thick notebook, but I doubt if it will be that small. i 10 JUDGE LUEBKE: Thank you, sir. i' 11 JUDGE LAZO: Mrs. Young, does the staff any redirect jg 12 of your witnesses? i ) 5"# 13 MS. YOUNG: I might have brief redirect, but I need 1 14 to confer shortly. 15 JUDGE LAZO: I' m sorry? i 16 MS. YOUNG: I need to confer shortly with co-counsel. 17 JUDGE LAZO: Fine, surely. I 18 (Pause) 19 REDIRECT EXAMINATION 20 BY MS. YOUNG: 21 Q Mr. McCracken, I' d like to refer back to a question 22 that Ms. Lorion posed to the panel on question regarding page { 23 16 of your testimony. If you look at the bottom of that page, 1 f 24 there is generally a statement that the licensee made a j 25 commitment not to store any fuel with an enrichment greater ftu)f Heritage Reporting Corporation (202) 628-4888
J 376 1 than 4.1 weight percent U-235 prior to completion of the next 2 surveillance. 3 A (McCracken) Yes. 4 Q Okay, and I believe we heard testimony from Mr. Kopp, 5 or Dr. Kopp that he did not consider that a commitment, the 6 statement in the letter. Do you recall that? 7 A (McCracken) I recall that. 8 Q Okay. How does the NRC treat information provided in 9 letters from licensees and/or their vendor? 10 A (McCracken) That a letter like that where they 11 stated they will not store the fuel would be treated as a 12 commitment. O 13 MS. YOUNG: I have no further questions. ! 14 JUDGE LAZO: One last chance. Does anyone else have 15 any questions of this panel? 16 MR. FRANTZ: No, sir, we do not. 17 JUDGE LAZO: Mrs. Lorion? 18 MS. LORION: No. ) t { 19 JUDGE LAZO: Very well, thank you, gentlemen. You ; i l 20 may be excused. 21 (Whereupon, the witnesses were excused.) l 22 JUDGE LAZO: Well, unless any of you can convince us 23 otherwise, we are prepared to close this record. And hearing 24 no objections we will rule that the record is closed.
,j x-25 We are going to direct the parties to file proposed l l
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1 1 i l l l p ,, l L) 377 1 findings of fact and conclusions of law. You know when I say l 1 2 the parties are directed to do that, we very much want to have 3 proposed findings and conclusions from all of the parties. 4 The licensee, of course, has the burden of proof, and 5 we would expect the findings and conclusions to be filed by 6 October 19th. That's 30 days or a little bit more. 7 The date for filing intervenor's proposed findings 8 would then be October 29th, and for the staff, November 9th. 9 The licensee may file a reply if they desire five days later 10 which would be let's say November 16th. 11 And if all goes well, and the Board survives the 12 holiday season, we would expect an initial decision by mid 13 January or first of February. That's not a promise but a -- 14 not a commitment. 15 (LauDhter) 16 Are there any other matters that we may profitably 17 deal with here this afternoon? Mrs. YounD, you have a 18 quizzical look on your face. 19 MS. YOUNG: No, just thank the Board for their 20 indulgence. 21 JUDGE LAZO: Well, we want to commend all of the 22 parties for the way you have handled this proceeding. I think 23 you have done your clients and your representatives well. We 24 appreciate that. I hope we have a good record. I think we do. f J 25 Just before we adjourn then sine die, I wonder if L4 Heritage Reporting Corporation (202) 628-4888 l l_ _ _ _ _ _
\ 378 1 counsel for the licensee could approach the bench. We will go 2 off the record, and close this proceeding now, Mr. Reporter. 3 (Whereupon, at 2:36 p.m., the hearing Has 4 concluded) 5 6 7 8 9 10 11
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c- _.3n-1 , CERTIFICATE
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3 This is to certify ~that the attached proceedings before the 4 United States-Nuclear Regulatory Commission in the matter.of: 5 ' Name: Florida Power & Light-6 - 1
.7 Docket' Number: .50-250-OLA-2 8' Place s Miami, Florida 9 Date: September 167 1987 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear' 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the' direction
,_ 14 of the court reporting company, and that the transcript is a 15 true and accurate recor f the foreg ing proceedings.
16 /S/ D\ .Q . /l&htt.u.J W 1 17 (Signature typed): Kent Andrews 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25
\N Heritage Reporting Corporation (202) 628-4888
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