ML20237L799
| ML20237L799 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/31/1987 |
| From: | Soon Kim, Mcdonald D Office of Nuclear Reactor Regulation, NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20237L782 | List: |
| References | |
| OLA-2, NUDOCS 8709090079 | |
| Download: ML20237L799 (18) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of
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Docket Hos. 50-250 OLA-2 FLORIDA POWER AND LIGHT COViPANY )
50-251 OLA-2
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(Turkey Point Plant, Units 3 & a)
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(SFP Expansion)
TESTIMONY OF SANC BO KIM AND DANIEL C. MCDONALD, JR. REGARDINC CONTENTION 5 i
01, Please state your name, your position, and the nature of your work at the Nuclear Regulatory Commission (NRC).
A1.
My name is Sang Bo Kim.
I am employed as a technical staff mem-ber in the Plant Systems Branch, Office of Special Projects. At the time the rerack amendments were issued, I was a Structural Engi-neer in the Engineering Branch in the Office of Nuclear Reactor l
Regulation.
My duties included evaluation of the structural and earthquake engineering aspects of safety-related structures, sys-tems and components and performing independent calculations and engineering analyses to confirm or verify applicants' or vendors' assessments of atructural integrity and response under pertinent load combinations.
A summary of my professional qualifications and experience is appended hereto as Attachment 1.
My name is Daniel G. Mcdonald, Jr.
I am a Senior Project Manager in Project Directorate 11-2 of the Division of Reactor Projects - 1/ll in the Office of Nuclear Reactor Regulation, U.S.
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Regulatory Commission.
I am responsible for the management, coor-dination and integration of all licensing activities related to the Turkey Point Plant, Units 3 and II.
A summary of my professional.
qualifications and experience is appended hereto as Attachment 2.
Q2.
What is the pGrpose of your testimony?
A2.
(Kim) The purpose of my testimohy is to address Contention 5 with i
regard to the issue of whether there is a deficiency in the Turkey Point design and the necessity for a restriction on loading to pre-vent potential lift-off. Order at 18.
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(Mcdonald) The purpose of my testimony is to address Contention 5 l
with. respect to the need for a Technical Specification or -license i
condition concerning loading restrictions as long as there are writ-ten procedures and administrative controls in place at Turkey Point.
Contention 5 states:
i That the main safety function of the spent fuel pool which is to mainta!n the spent fuel assemblies in a safe configuration through all environmental and abnormal loadings, may not be met as a result of a recently brought to light unreviewed safety question involved in l
the current rerack design that allows racks whose outer l
rows overhang the support pads in the spent fuel pool.
ThiJs, the amendments should be revoked.
This contention questions the safety of the fuel in the storage poof based on a Licensee letter which indicated that the structural de-sign of the racks, whose outer rows overhang the support pad, could cause the racks to lift-off (or more likely tip-off) from the I
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pool. floor durl'ng seismic - events.
See Letter - from J. W.
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Williams, Jr.,- FPL, to Steven A. Varga,. NRC, dated February 1,
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.l 1985.
Contention 5 asserts that due to a potential for lift-off,'the
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high density rack design is deficient.
In its March 25,1987 Order denying summary disposition, the Board found that there is. no question that properly executed administrative controls-would pre-vent rack Ilft-off during a seismic event, Order at 21, but ob-serve'd that "there are sufficient doubts as to the basis for issuance of tF,c amendments, particularly the structural analysis involving the safe shutdown'eerthquake and various loading' conditions other than fully loaded and involving the overhanging rows, conditions l
which the Staff apparently has not evaluated. Order at 24.
U Q3.
Please - describe the spent. fuel pools at.the. Turkey Point Plant.
A3.
The spent fuel pools for Units 3 and 4 each have a total of, twelve free standing racks.
Each of the racks have support assemblies on the bottom which include remotely adjustable leveling screws.
Four of the twelve rackr, beve the support assemblies located at each of the four corners.
The remaining eight racks have support assem-biles recessed from the corners.
The location of the support as-semblies for all the racks was determined by the location of preexisting steel support plates which are permanently embedded in the concrete floors of the spent fuel pools.
The racks that have support assemblies recessed from the corners allow storage of fuel assemblies in the rows which overhang the support assemblies with the remainder of the racks empty.
Since the racks are free
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- standing, i.e., they are not anchored to the floor nor braced to the pool walls, the loading of fuel assemblies in the overhanging row:; with the' remainder'of the racks empty would increase the like-lihood of. lift-off during a seismic event.
Q4.
Whai NRC structural design requirements must the Turkey Point spent fuel storage racks satisfy?
A4.
(Kim) The structural design of spent fuel pool racks as well as the spent fuel pool must s6tisfy General Design Ctiterion 2, " Design bases for protection against natural phenomena."
GDC 2 provides that fuel storage be designed to withstand the effects of earth-quakes without loss of capability to perform its safety function.
in addition, the spent fuel pool and pool storage racks must be de-signed to assure adequate safety under normal and postulated acci-dent conditions (GDC 61,
" Fuel storage and handling and radioactivity control") and geometrically safe configurations of the fuel storage system should be used in order to prevent fuel criti-cality (GDC 62,
" Prevention of criticality in fuct storage and handling").
QS.
Describe the Staff's review of Licensee's structural analysis con-cerning the safe shutdown earthquake and various loading condi-tions involving the overhanging rows and the pctential for rack Ilft-off, AS.
(Kim)
The St6ff evaluated Licensee's submittals in two phases.
l The first Staff evaluation was initiated by the Licensee's March 14, i
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' c 1983 submittal entitled " Spent Fuel Storage Facility Modification, f
Safety Analysis' Report." Our ref3y scope was primarily in Section 4.c, Mechanical, Material and Structural Considerations.
Franklin Research Center (FRC) in Philadelphia was contracted as our tech-nical consultant for the review. The review consisted of our evalu-ation of the Licensee's description of the structural configuration of-j the spent fuel racks as well as the spent fuel storage pool, load
- c. combinations, calculations including rack response to an earthquake, resultant stresses in the rack, and comparison of final stresses with allowable stress limits prescribed in the Staff OT position.
The Staff OT position (OT Position For Review and Acceptance of Spent Fuel Storage and Handling Applications, dated April 14, 1978, and i
later amended on January 18, 1979) describes Staff review scope and acceptance criteria intended to assure conformance with the CDCs.
Upon completing their review, FRC issued a Technical Eval-uation T,eport entitled, " Evaluation of Spent Fuel Racks Structural Analysis, Florida Power and Light Company, Turkey Point Units 3 i
and 4,"
dated October 25, 1984.
Based on this report, the Staff concluded 'in Section 2.3.6 of the November 21, 1984 SE that the design of the racks satisfied the structural aspects of the Appendix A requirements of 10 C.F.R. Part 50 (GDC 2, 4,
61
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and 62), as applicable to structures.
The Staff conclusion was based on the fact that (a) the Licensee considereo all the required loading conditions including earthquakes and accidents; (b) the l
analysis methods that calculate stresses and earthquake responte were in accordance with industry practice which Staff's Eonsultant l-l i
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reviewed and found to be acceptacle as detailed in the TER that is appended to the Staff's SE: and (c) the resultant stresses and overturning safety factors satisfied the allowable limits specified in the Staff OT Position.
Subsequently, Licensee, by letter dated February 1,1985, stated it had performed an additional rack earthquake response analysis con-cerning the loading of the overhanging outer rows upon being in-formed by Westinghouse Electric Corporation, the rack vendor, (a) that lifting of a rack could occur during a seismic event if the outer rows are fully loaded while the rest of the rack is empty and (b) that administrative controls on fuel loading would be needed for those spent fuel racks whose outer rows overhang the support pads.
Therein, the Licensee stated that the analysis results dem-l onstrated that the design of racks with fuel overhang continues to satisfy the OT position in that there are adequate safety margins against overturning and stresses in the racks and pool.
In addi-tion, Licensee stated it would provide administrative controls on 1
fuel placement in order to preclude the possibility of rack lift-off.
l Op.
Why did the Staff find the use of administrative controls acceptable
.es a means of restricting fuel loading in the Spent Fuel Pool (SFP) racks subsequent to issuing the amendments?
i A6.
(Mcdonald) The Staff is aware that new information or circumstance-es can arise subsequent to its evaluation and approval of a design or modification to a safety-related structure, system or component.
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Two means are available for handling any changes necessary subse-quent to NRC staff approval if the changes do not result in a change to the technical specifications or result in an unreviewed safety question.
One is the use of 10 C.F.R. 50.59 " Changes, tests and experiments," which is discussed in the February 26, 1965 letter from Daniel Mcdonald, NRC, to J. W. Williams, FPL (At-4 tachment 3).
That regulation provides that a licensee may make changes in the facility or procedures as described in the Safety Analysis Report (SAR) and conduct tests or experiments not de-scribed in the SAR without prior Commission approval, unless the proposed change, test or experiment involves a change in the tech-nical specifications incorporated in the license or an unreviewed safety question.
The other means is the use of procedures and administrative controls.
All technical specifications of licensed nu-clear plants include requirements for the development and use of procedures and administrative controls.
FPL chose to utilize proce-dures including administrative controls to implement loading restric-tions to assure that the racks with outer rows overhanging the support pads would not be loaded while the remaining portions of the racks are empty.
As stated in the February 26, 1985 letter to FPL, the conclusions in the NRC's SE and supporting Technical Evaluation Report (TER) remained valid based on the administrative controls initiated by FPL when they became aware of the potential need for restricting the loading of fuel in the. SFP racks with overhanging rows.
FPL had
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029100 7269 SW 54 Avenue Miami, Florida 33102 Miami, Florida 33143 Mr.
M. R. Stierheim Mr. Chris J. Baker, Plant Manager County Manager rf Metropolitan Turkey Point Nuclear Plant Dade (cunty Florida Power and Light Compary Miersi, riorida 33130 P.O. Box 029100 Miami, Florida 33102 Resident inspector Ture.ey Poir.1 Nuclear Generating Station Attorney General U.S. Nuclear Regulatory Commission Departnent of legal Af f airs Post Office Box 57-1185 The Capitol Mieni, Florida 33257-)]85 Tallahassee, Florida 32304 Regional Radiation Representative Mr. Allan Schubert, Manager EPA Regior }V Public Health Physicist 345 Courtland 5t reet, N.k.
Department of Health and Atlanta, G4 30308 Rehabilitative Services 2323 Winewood Blvd.
Interguvernnental Coordination Tallahassee, Florida 3230) and Review Office of Plannina & Budaet Executive Office of the dovernor The Canitol Euilding l
Tallahassee, fl orica 3?301 1
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