ML20247A762

Forwards Corrected Pages 15,24,25 & 26 to NRC 890317 Findings of Fact,Per Stated Clarifications & Corrections

ML20247A762
Person / Time
Site:	Saint Lucie
Issue date:	03/24/1989
From:	Patricia Jehle NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Bright G, Cole R, Cotter B Atomic Safety and Licensing Board Panel
References
CON-#189-8361 88-560-01-LA, 88-560-1-LA, OLA, NUDOCS 8903290184
Download: ML20247A762 (7)

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-B.' Paul Cotter, Jr., Chairman Dr. Richard F. Cole Administrative Judge- Administrative Judge

. Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Cocrd Panel U.S. Nuc16er Regulatory Connission U.S. Nuclear Regul6t.ory Connission Washington, D.C. 20555 Washington, D.C. 20555-Glenn 0. Bright Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter cf FLORIDA POWER & LIGNT COMPANY (St. Lucie Plcnt, Unit No. 1)

Docket No. 50-335-01.A; ASLHP No. 883560-01-LA

Dear Administrative Judges:

TheNRCstaff(Staff)hasdiscoveredtwoareasofitsproposed"Findingsof Fact" (findings) filed in this' proceeding on March 17, 1989, which it, believes require clarification and correction. These are as follows:

1. The first sentence of paragraph 38 on page 15 presently states that:

38. The Staff and +.he Licensee have reviewed nud evaluated the performance records of Boraflex used in the storage racks at four facilities.

This sentence should be revised to read as follows:

38. The Staff has reviewed and evaluated the performance records of Boraflex used in the storage racks at four facilities.

In cddition, the fc110 wing record reference, ubich was inadvertently omitted on the final version of the Staff's findings, should be inserted following the above revised sentence.

Wing on Contention 3, ff Tr. at 4-5.

2. At line 6 of finding 57 on page 24, the last line on page 25 (finding 61) and the third line from the bottom of finding 61 on page 26 of the 8903290184 B90324 5 .

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( l s findings, the Staff inadvertently stated that Dr. 5tanley E. Turner's criticality analyses assumed "one-half inch gaps every 6 inches in the Boraflex in the St. Lucie racks". The number "6"'should read "12" in all .

three of the above cited' places in the findings. (See Turner on

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Contentions 3 and 6, ff Tr. 110 at 19 (fni).

The Staff inadvertently used the number "6" in its findings because it was focusing on the fact that the Boraflex sheets in region one have scallops or cut outs on each side. Each side has the scallop or c.at out twelve inches apart. However, the scallops or cut outs are not lined up directly on both sides of the Boraflex sheets. They are offset by six inches. (See, for example, Exhibit 10-Boraflex Panel in Region I, copy attached). However, the use of the number "6" in the context of the above-noted findjngs was, in fact, incorrect.

For the convenience of the Board and parties, enclosed are corrected pages 15, 24, 25 and 26 of the Staff's findings which include the above changes. These pages should be substitued for the current pages 15, 24, 25, and 26.

The Staff apologizes for any inconvenience caused by the above corrections to its findings.

Sincerely, fden. d bd/4 Patricia A. Jehle 8 Counsei for NRC Staff Encis.: As stated cc w!Encls.: Sarvice List l l

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37. We find that Boraflex is a material with proven neutron f ,

absorption characteristics and that minor degradations will not l

, significantly affect the. neutron attenuation capability of Boraflex. We g conclude that 'Boraflex is .a satisfactory poiron material and that it is ,

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, . t suitable for use in the Ett Lucie 1 spent fuel pool. In fact, the record il 1 amply demonstrated that trie naterial ~ ~ been subjected to testing environments more severe than environmental cs 41tions which will be encountered.in the St. Lucie 1 spent fuel pool, an ' still retained its I;eutron absorptt:n capability and physical integrity.

6. In Plant Performance of Boraflex

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38. The Staff has reviewed and evaluated the performance records of Boraflex used in the storage racks at four facilities. Wing on Contention 3, ff Tr. 110 at-4-5. The Staf f learned that gaps (separations) of up to 4 inches had formed in some k raflex panels at the Quad Cities Nuclear Power i

Station, Units 1 and 2.in April of 1987. Wing on Contention 3, Tr. 110, 1 l

at 3. The NRC I,1 formation Notice No. 67-43 " Gaps in Neutron Absorbin0 '

Material in High-Density Spent ftiel Storage Racks" (September 8, 1987) on I page 1:

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"[A] lerted recipient; to a potentially significant problem

_' pertaining to gaps identified in the neutron absorber component of the high density spent fuel storage racks 1

at Quad Cities Unit 1 [a BWR facility]. The safety concern ... [was] that certain gaps might excessively reduce the margin of nuclear subcriticality in the fuel pool." )

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f7. The NRC : staff did not' perform its own criticality analyses for  ;

St. lucie because that is not generai practice in an NRC review of a' l4#6 I . kl .

licensee's sut,mittal for 3 spent fuel pool expansion. ' Testimony of.

Laurence 1 ,Kopp,' transcript at'495 [ hereinafter Kopp, Tr. at ). The' .]

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j Staff did not review the criticality analyses performed by Dr. Stanley E. ,,

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l Turner, which assumed .oehalf inch. gaps every 12 inches in the Boraflex in the St. Lucie racks, because these were not ava'11able at the time the l j \

Staff conducted its' review. Kopp, Tr. at 530; s_ee gene; ally Tourigny, Tr.

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i at 507-14. However,3 Maf f mecber reviewed the written direct testimony j q

and heard.the oral testimony of Dr. Stanley E. Turner on these criticality -)

analyses and concluded that there would be no adverse effect on k,ff which I ,

would violate the acceptance criteria of 0 295. Kopp, Tr. at 535. Dr. ]

Kopp olso reviewed generic criticality calculations and criticality calet:- i g

lations performed by the Staff for the Turkey Point Mant Units 3 and 4

-which verified these findir.gs. Kopp,.Tr. at 531-537. )

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58. Although the various parameters such as U-235 enriche nt, fuel  ;

l assembly center-to-center spacing and B-10 a m i density in these.

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calculations are not identicci to those in'the St. Lucie spent fuel recks, l

1, they are similar enough so that one would not expect changes in reactivity  !

due to postulated varying gap size to be significantly different. Kopp, Ti. at 532. The base reactivity assuming no gaps would be dependent on

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all of these parameters. Kopp, Tr. at 536. Changas in reactivity due to a given gap size, however, would not be dependent on these parameters.

Kopp, Tr. at 536. {

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59. An analysis of the reactivity consequerites of a physically ]

1 impossible condition, namely, the tote f 'ross of Boraflex in the storage j l

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, racks, was analyzed to demonstrate the very large reactivity margin in the 3

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St. Lucie 1 pool. . Turner on Contentions 3 ;ar.d 6, ff. TP. 139, at 9. With consideration of the double contingency principle and with credit for the soluble boron present, calculations for the hypothetical loss ~of all the i

Boraflex resulted in a maximum k,ff of 0.875 for Region 1 and 0.831 for e Region 2, both of which are still well below the limit of K eff 0.95.

, Turner on Contentions 3 and 6, ff. Tr. 139, at 9.

60. Prior to the issuance of the St. Lucie 1 spent fuel amendment, the design basis k,ff limit was 0.95. Turner on Contention 7, ff. Tr. 21, at 13. The spent fuel pool expansion did not modify this design basis limit. Turner on Contentions 3 and 6, ff. Tr.139, at 8d. Thus, the LRensee and the Staff have established on the record that the amendment has not decreased the margin of safety for preventing a criticality l sccident at St. Lucie 1. l

61. The central issue to be resolved is whether unsafe and unpredictable gap formation will develop in the St. Lucie 1 racks. The-Staff did not identify a mechanism for gap development based on the FSAR i

submitted by the Licensee. Wing, Tr. at 543-47. The Licensee, however, has postulated a possible mechanism for gap development in the St. Lucie 1 i

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storage racks; that is, the use of a cut-out design in conjunction with spot-welding every 12 inches along the sides of the Boraflex panels.

Singh, Tr. at 310-14. The Licensee has concluded that gaps may occur in a i

systematic pattern. Id. The Licensee's conclusion is based on additional analyses which were not available to the NRC when the Staff reviewed the FSAR enti prepared its SER and the written direct testimony. Tourigny Tr.

l at 507-14. Using a conservative assumption that 1/2 inch gaps every 12 I

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1n N inches, the Licensee established that the degree of gapping would not 11 effect reactivity in the~ spent fuel pool. Turner on-Contentions 3 and 6 j <

ff. Tr. ^139, at 6. Furthermore, the NRC staff evaluated the sworn written testimony and heard the oral testimony of the Licensee's witnesses which-described: 1) ths rack design in. detail; 2) the conservative' assumptions concerning gap formation; and 3) the effects on the reactivity of the -

pool. Kopp Tr. at 534-36; Tourigny, Tr. at 499-504, 507-14, 540-48; Wing Tr. at 544 45. The Staff concluded that'should the maximum-projected' gap formation, of 1/2 inch gaps every 12 inches, occur there will O '

be no criticality concern. .Kopp, Tr. at 534-36; Tourigny , Tr. at 540-48;-

' Wing, Tr. at 544-45.

62.- The Intervenor raised the issues that the Boraflex racks at St.

Lucie 1 spent fuel pool 1) use a significantly modified. design and are-essentially the result of new. technology and fabrication process; 2) that the'designis.unprovenanduntested;3)thatgapformationproblems-reported with in-service Boraflex panels at other plants are unresolved; l

and 4) that gap formation, the separation of neutron absorbing material, may compromise safety. The Licensee established _that both the design and the materials used to fabricate the St. Lucie'I spent fuel pool racks are based on established technology which has been tested. The Licensee also established that the reported incidents of gapping have been resolved and that gapping will not compromise safety.

8. Licensee's In-Service Surveillance Program

63. Boraflex is a satisfactory neutron absorber, capable of performing its intended function of criticality control, Turner on  ;

Contentions 3 and 6, ff. Tr. 139, at 15. The Licensee and the Staff

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