ML20238A042

Testimony of R Gouldy on Contention 5.* Testimony of R Gouldy on Contention 5 Re Administrative Controls for Loading Spent Fuel Into Spent Fuel Pool Storage Racks. Related Correspondence

ML20238A042
Person / Time
Site:	Turkey Point
Issue date:	08/31/1987
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML20237L743	List: ML20237L739 ML20237L816 ML20238A021 ML20238A042 ML20238A075 ML20238A130 ML20238A236 ML20238A273
References
OLA-2, NUDOCS 8709090109
Download: ML20238A042 (10)

Text

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s 1 2

UNITED STATES OF AMERICA 3

NUCLEAR REGULATORY COMMISSION 4

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5

6 In the Matter of ) Docket Nos. 50-250-OLA-2

) 50-251-OLA-2 FLORIDA POWER & LIGHT COMPANY ) (Spent Fuel Pool Espansion) 7 (Turkey Point Nuclear )

Generating Units 3 & 4) )

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9 TESTIMONY OF RUSSELL GOULDY 10 ON CONTENTION NUMBER 5 11 01: Please state your name and address. l 12

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13 A1: My name is Russell Gouldy. I am a senior engineer in the Nuclear Licensing Department of Florida Power &

Light Company (FPL). My business address is 700 Universe Boulevard, Juno Beach, FL 33408.  !

18 02: Please describe your professional qualifications and 19 experience.

21 A2: A summary of my professional qualifications and experi-ence is attached as ExhAbit A to this testimony and is incorporated herein by reference.

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• 2 03: What is the purpose of your testimony?

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i 4 A3: ? tie purpose of my testimony is to address Contention No. l S 5 as limited to the administrative controls for loading j 6 spent fuel into the Turkey Point spent fuel pool storage 3 I

77 racks. The Testimony Of Harry E. Flanders, Jr., On 8, Contention Number 5 and the Testimony Of Edmund E.

9 DeMario On Contention Number 5 address the seismic 10 analysis of the spent fuel storage racks and spent fuel 11 , ,, assemblies.

12 (

, Contention No. 5 and the bases for the contention l 13 ar ras follows:

14 Contention 5 15 That the main safety function of the 16 spent fuel pool which is to maintain the spent fuel assemblies in a safe configur-17 ation through all environmental and abnormal loading, may not be met as a 18 result of a recently brought to light '

unreviewed safety question involved in 19 the current re-rack design that allows racks that overhang the support pads in 20 the spent fuel pool. Thus, the amendment should be revoked.

21 Bases for Contention 22 In a February 1, 1985, letter from 23 Williams, FPL, to Varga, NRC, which

. describes the procedures for rack lift 24 off under the seismic event wonditions

[ sic). This is clearly an unreviewed 25 safety question which demands a safety analysis of all seismic and hurricane 26 conditions and their potential impacts on p the racks in question before the license 27 amendments are issued. Because of the potential to increase the possibility of 28

1 e

2 an accident previously evaluate [ sic), or to create the possibility of a new or 3- different kind of accident caused by loss of. structural integrity. If integrity is 4 lost, the damaged fuel rods could cause a criticality accident.

5 (Hurricane loads were rejected as a basis for Contention 6

5 in the Licensing Board's memorandum and order of 7

September 16, 1985).

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04: Is it possible for the new Turkey Point spent fuel 10 storage racks to lift-off the bottom of the spent fuel 11 pool as a result of a seismic event?

12 13 A4: Yes. The new storage racks for the Turkey Point spent 14 fuel pools are free-standing and are not anchored to the 15 floor or braced to the pool walls. Some of the outer-16 storage locations of the new racks overhang (exten'd 17 beyond) the support pads for.the racks. As explained in 18 the Testimony Of Harry E. F1m ders, Jr., On Contention 19 Number 5, it is possible that the spent fuel storage 20 racks may rock and one side of the rack may lift-off the 21 bottom of the poo3 by 0.18 inches during a safe shutdown earthquake (SSE). However, lift-off would only occur if the overhanging rows of the racks were filled with spent l fuel assemblies while the remaining rows were empty.

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3 2 05. Is the pattern for loading spent fuel into the racks a 3 part of the basis for licensing the new Turkey Point l

4 storsge racks? i 5 j 6 A5: Yes. In support of its application for the Turkey Point 7 spent fuel pool expansion amendments, FPL provided the 8 NRC with the results of an evaluation which showed that 9 lift-off of the storage racks would not occur during a 10 seismic event. This evaluation assumed that FPL would 11 establish administrative controls to prohibit the 12 loading of overhanging rows of a rack while the 13 remaining rows of the rack were empty. The NRC issued 14 the Turkey Point spent fuel pool expansion amendments in 15 November 1984 on the basis that rack lift-off would not f I

16 occur. I 17 f 18 Q6: Please describe the events surrounding the letter dated 19 February 1, 1985, from FPL to the NRC, which is refer-20 enced in the bases for Contention 5.  ;

21 22 A6: This letter presented a seismic analysis of the new 23 Turkey Point storage racks, assuming that the over-24 hanging rows of the rack were fully loaded with fuel 25 assemblies while the rest of the rows were empty. This 26 analysis (which is discussed in the Testimony Of Harry 27 E. Flanders, Jr., On Contention Number 5 under " Case 2")

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2 demonstrated that rack lift-off could occur during an 3 SSE but.that the results of this lift-off would be j i

4- acceptable. FPL requested the NRC to review the'results l

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l '5 of this analysis and.to concur that it is acceptable.

l 6 On February 26, 1985, the NRC responded to FPL's i

7 February 1,.1985, letter. The NRC stated that FPL's

, 8 request for review of the analysis represented a change 9 in a basis supporting NRC issuance of the amendments 10 authorizing the Turkey Point spent fuel pool expansions.

11' The NRC further stated that FPL could make such changes '

12 without prior NRC approval provided that a review 13 performed in accordance with the provisions of 10 CFR 14 50.59 determined that neither a technical specification j 15 change nor an unreviewed safety question is involved.

16 Accordingly, FPL withdrew its February 1, 1985, request 17 by letter dated November 13, 1985.

18 19 07: Has Turkey Point established administrative controls to 20 prevent loading of fuel assemblies into the overhanging 21 locations until after fuel assemblies are loaded into 22 the other storage. locations?

23 24 A7: Yes. Turkey Point's procedure governing refueling core 25 shuffles has been revised and is currently being used to 26 control the loading of fuel assemblies in the Turkey 27 Point Unit 3 storage racks. This procedure prohibits 28

1 l 2 the loading of spent fuel into overhanging rows if the 3 remainder of the rack is empty. Additionally, this i

4 procedure requires the preparation and use of a fuel ]

I 5 handling data sheet which designates a specific location l I

6 within a spent fuel rack for each spent fuel assembly 7 (identified by a number). The fuel handling data sheets j i

8 are prepared with the aid of fuel status boards which 9 contain diagrams of the reactor and the spent fuel pool 10 that show the locations of currently-stored fuel assem-11 blies and the locations where fuel assemblies may be 12 placed. By assigning a specific location for each 13 assembly, the fuel handling data sheet controls the 14 loading of the racks and prevents the loading of assem-15 blies into overhanging locations until after fuel 16 assemblies are placed into the other storage locations. '

17 Prior to their use, tbc fuel handling data sheets are 18 subject to review and approval by the Plant Nuclear 19 Safety Committee ':o assure that, among other things, 20 fuel assemblies are not placed into the overhanging rows 21 of an empty rack. These types of administrative 22 controls are common in the nuclear industry and have 23 been used successfully for loading assemblies in spent )

I 24 fuel racks as well as loading fuel assemblies into the 1 25 reactor.

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1 2 08: At page 22 of its Memorandum and Order of March 25, 3 1985, the Licensing Board questioned whether there is a 4 need for an administrative controls requirement attach-l 5 ment to the alrr:ady issued license amendment. Is such a 6 requirement necessary or appropriate to ensure the 7 safety of spent fuel storage at Turkey Point?

I 8

9 A8: No. In general, license conditions and technical 10 specifications provisions are reserved for those condi-11 tions needed to prevent abnormal situations giving rise 12 to an immediate threat to public health and safety.

13 Many aspects of operation of a nuclear plant do not rise 14 to this level of significance and are not subject to 15 license conditions or the technical specifications. In 16 fact, the administrative controls for loading of the 17 spent racks are not the type of controls which are 18 typically included in the technical specifications or 19 license conditions. Furthermore, as Mr. Flanders' 20 analysis of Case 2 demonstrates, the new Turkey Point 21 spent fuel racks would conform with the NRC Staff's 22 guidance even if administrative controls were not in 23 place to govern the pattern of loading spent fuel into 24 the storage racks. Consequently, incorporation of these 25 administrative controls into the technical specifica-26 tions or the license is not necessary.

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, 1 2 09: Does this conclude your testimony?

3 4 A'9 Yes.

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, 1 2 Exhibit A 3 I PROFESSIONAL QUALIFICATIONS AND EXPERIENCE OF 4 RUSSELL GOULDY l

5 Education l 6

f Courses in High Energy & Nuclear Physics, University of i 7 Tennessee, Knoxville, 1970-1972 i B.S. in Nuclear Engineering, University of Tennessee, i 8 Knoxville, June 1978 9

Work Experience:

10 1979- Present Florida Power & Licht Comoany -- Mr.

11 Gouldy has been a Nuclear Licensing Engineer since January 1985 with respon-12 sibility for providing operating reviews  !

and assistance in maintaining Turkey  !

13 Point's operating License. From December 1 1979 to June 1983, Mr. Gouldy was a Shift 4 14 Technical Advisor for the Turkey Point Plant. f In this position, he was respon- q 15 sible for advising the shift supervisor (

on matters of safety, including response l 16 and analysis of plant transients. .From i June 1983 to January 1985, Mr. Gouldy was I 17 a senior Plant Engineer in the Reactor l Engineering Department at Turkey Point '

18 wit'.h responsibility for reactor physics, .'

refueling operations, and design and 19 installation of the safety assessment system computers. l 20 1 1978-1979 Alpbama Power Comoany -- Mr. Gouldy was a 21 Technical Engineer at the J.M. Farley Nuclear Plant. In this position, he was 22 responsible for systems testing and plant start-up assistance.

23 1977-1978 Tennessee Vallev Authority -- Mr. Gouldy  :

24 was a Technical Writer in the Engineering i Design Division. In this position, he 25 developed computer programs for materials l handling for TVA's nuclear projects.

l 26 j 1975-1977 Continental Tool and Encineerino -- Mr. 1 l 27 Gouldy was a Draftsman and Designer of pneumatic tools.

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i 2- Licenses:

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} Professional-' Engineer - Florida #31965 (1982 - Present)

Senior' Reactor Operator - NRC #4284 (1982-1986) 4' Certified General Contractor - Florida #CAC.41804

. Certified Structural Inspector - Florida #608 5

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