ML20247D960
| ML20247D960 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/21/1989 |
| From: | Bauser M FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#389-8945 LBP-89-12, OLA, NUDOCS 8907260014 | |
| Download: ML20247D960 (42) | |
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'89 JUL 24 P3 :43 GQ
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAT BOARD July 21, 1989
)
In the Matter of ) Docket No. 50-335 OLA
)
FLORIDA POWER AND LIGHT COMPANY )
) !
(St. Lucie Plant, Unit No. 1) ) (Spent Fuel Pool .
) Expansion) '
)
LICENSEE'S RESPONSIVE BRIEF Co-Counsels Harold F. Peis Michael A. E' user John T. Butler . Patricia A. oomella Steel, Hector & Davis 4100 Southeast Newman & Holtzinger, P.C.
Financial Center 1615 L Street, N.W.
Miami, Florida 33131-2398 Washington, D.C. 20036 Telephone: (305) 577-2939 Telephone: (202) 955-6600
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Counsel for Licensee Florida Power & Light Co.
BjRo7260014 g9o7p3 g ADOCK 05000335 PDR 9)
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r TABLE OF COMTENTS Page Table of Authorities.................................... iii I. Introduction and Background....................... 1 II. The'Intervenor's Allegations of Error Are Without Merit............................................. 3 A. The Licensing Board did not err in its finding that the combined effects on Boraflex of heat and radiation have been studied well enough and are understood well enough so that no synergistic effects are likely to occur in the St. Lucie.1 spent fuel pool which would cause unexpected change in the neutron absorp-tion capability of the material............... 3 B. The Licensing Board.did not err in placing reliance on the testimony of certain Licensee and NRC Staff witnesses as to the effects of heat and radiation on Boraflex................ 6
- 1. Dr. Wing's Testimony (6)
- 2. Dr. Singh's Testimony (10)
C. The Licensing Board did not err in finding that the maximum shrinkage of the Boraflex would not exceed 4 percent.................... 12 D. The Licensing Board did not err in finding that the design of the Region 1 racks is such that any gaps that might form due to the combination of radiation-induced shrinkage and mechanical restraint would not exceed 1/2 inch and form only at those locations where the Boraflex panels were mechanically restrained.................................... 15 E. The Licensing Board did not err in concluding that, because of the normal use of Region 1, Boraflex panels in that Region would not generally be exposed to such irradiation as might result in shrinkage and the formation.
of gaps....................................... 22
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F.- The Licensing Board did not err in relying-on the testimony of the Licensee's witnesses concerning the criticality calculations for
- a. the St. Lucie l' Region 1 spent fuel racks..... 26 1' NRC Staff Verification (26)
- 2. NRC Staff Understanding (28)
G. The Licensing Board did not err in finding that' operation of theLspent! fuel pool, as modified by the Board's condition to-the spent. fuel reracking amendment, "is and would be in compliance with:the Rules and Regula-tions of the Commission."..................... 31 III. Conclusion........................................ 35 e
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TABLE OF AUTHORITIES Page(s)
NUCLEAR REGULATORY COMMISSION PROCEEDINGS Atomic Safety and Licensing Appeal Board Duke Power Co. (William B. McGuire Nuclear Station, Units 1 and 2), ALAB-669, 15 NRC 453 (1982)....... 8, 12 Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2), ALAB-819, 22 NRC 681 8, 11 (1985)............................................
Wisconsin' Electric Power Co. (Point Beach Nuclear Plant, Unit 2), ALAB-78, 5 AEC 319 (1972)......... 11, 12 REGULATIONS
-10 C.F.R..S 2.732 (1988)............................ 27 10 C.F.R. S 2.762(c) (1988).......................... 2 10 C.F.R. S 2.762(d)(1) (1988)....................... 2 10 C.F.R. Part 2, Appendix A, S V(d)(1) (1988)...... 27 10 C.F.R. S 50.58(b)(6) (1988)....................... 31 10 C.F.R. S 50.91(a)(4) (1988)...................... 31 MISCET.LANEOUS Fed. R. Evid. 702.................................... 8
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UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SRFETY AND LICENSING APPERT- BOARD July 21, 1989
)
In the Matter of ) Docket No. 50-335 OLA
)
FLORIDA POWER AND LIGHT COMPANY )
)
(St. Lucie Plant, Unit No. 1) ) (Spent Fuel Pool
) Expansion)
)
I LICENSEE'S RESPONSIVE BRIEF l
I I.- Introduction and Backaround On May 9, 1989, the Atomic Safety and Licensing Board in the above-captioned proceeding (hereinafter
" Licensing Board") issued its " Initial Decision (Authorizing the Spent Fuel Pool Reracking)" (hereinafter " Initial 1 Decision") for the St. Lucie Plant, Unit No. 1 (hereinafter "St. Lucie 1"), following three days of evidentiary hearings on January 24-26, 1989. Florida Power & Light Co. (St.
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,Lucie Plant, Unit No. 1), LBP-89-12, slip, op. On May 18, 1989, the Intervenor in this proceeding, Campbell Rich (hereinafter "Intervenor"),' filed a notice of his intent to appeal the Licensing Board's decision, and, on June 16, 1989, filed "Intervenor's Appeal of Initial Decision (Authorizing Spent Fuel Pool Reracking)" (hereinafter "Intervenor's Brief").
Pursuant to 10 C.F.R. S 2.762(c)-(1988) of the regulations of the Nuclear Regulatory Commission -
(hereinafter " Commission" or "NRC"), Florida Power & Light Company (hereinafter "FPL" or " Licensee") hereby files
" Licensee's Responsive Brief" in opposition to Intervenor's Brief. .
Intervenor's Brief did not " clearly identify the errors of fact or law that are the subject of the appeal,"
as required by the Commission's regulations. 10 C.F.R. S 2.762(d)(1) (1988). However, the Licensee believes that, in most cases, the essence of the errors alleged is reasonably clear; and, as understood by the Licensee, each of the alleged errors is addressed in the following section of this brief.
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- g-II . - The Intervenor's Allegations ~of' Error
-Are'Without Merit A. The Licensing Board did not-err in its finding that the combined effects on Boraflex of heat and radiation have been studied well enough and are
- understood well enough:so.that no synergistic .
effects are likely.to occur'in the St. Lucie l'apent fuel pool which.would'cause unexpected changeJin the.
neutron absorption capability of the material.
In its Initial Decision,athe Licensing Board made a series of: findings concerning the temperatures at which Boraflex hadlbeen tested and.the temperatures to be expected in the St. Lucie'l'apent fuel. pool. 1[ Initial o -
Decision at 15-17. The Intervenor does not appear to be-attacking the Board'r findings concerning'these l :.
temperatures. (San'Intervenor's Brief at 1-3.). Rather, i the Intervenor, in ' criticizing: the testimony. of the NRC '
Staff witness, Dr. James Wing, and the Licensee's I-A witness, Dr. Krishna P. Singh, appears to be questioning 1.
the adequacy of tests which do not expressly address the combined, or synergistic,. effects of radiation and heat on Boraflex. (Sea id.)
1/ Boraflex is used as a neutron absorber in tl.e St. Lucie 1 L
spent fuel racks and is produced by uniformly dispersing-Boron carbide particles in a polymeric silicone enc,apsulant,
.which performs as the matrix element. (Testimony of Dr. i Krishna P. Singh on Contentions 3 & 6, following Transcript 139, at 6-7 (hereinafter "Singh on Contentions 3 & 6, ff.
Tr. 139, at ").) {
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The Licensing Board did not err in its finding that the synergistic effects of heat and radiation on the neutron absorption capability of Boraflex have.been adequately concidered. Tests performed on Boraflex do reflect the combined effects of temperature and l radioactivity on the neutron absorption capability of Boraflex, as does operating experience.
Extensive radiation tests on Boraflex were conducted at the University of Michigan's Ford Nuclear Reactor as early as 1979-81, as part of the qualification of Boraflex'for use as a neutron absorber in spent fuel racks. Subsequently, Boraflex was tested in a precise manner under carefully controlled conditions to determine the dimensional changes that occur in Boraflex when it is irradiated. (Sea Singh on contentions 3 & 6, ff. Tr.
i 139, at 15-16; Testimony of Dr. Stanley E. Turner on Contentions 3 & 6, following Transcript 139, at 10 (hereinafter " Turner on Contentions 3 & 6, ff. Tr. 139, at ").) l The 1979-81 test program was designed to establish the physical and chemical characteristics of Boraflex under a variety of radiation levels and severe . :
environments, including elevated temperatures. (Singh on
- Contentions 3 & 6, ff. Tr. 139, at 15.) In this regard, j
- s' the water' temperatures in the Ford Nuclear Reactor were substantially greater than the temperatures existing in-the St. Lucie 1 spent fuel pool. (Id.). In the subsequent program, the Licensee's witness, Dr. Turner, collated and-analyzed laboratory data acquired from the University of Michigan's Ford Nuclear Reactor. (Singh on Contentions 3
& 6, ff. Tr. 139, at 16.) He performed, or had performed under his direction, measurements on the' irradiated samples of'Boraflex. He also confirmed his. observations through measurements of actual surveillance coupons from' reactor spent fuel pcols. These coupons had undergone signiff at, concurrent exposure to both radiation and typical spent fuel pool environments. (Sha Turner on Contentions,.3 & 6, ff. Tr. 139, at 2, 10; Singh on Contentions 3 & 6, ff. Tr. 139, at 16; Wing, Tr. 436-37, I
L 442-43.)
As the NRC Staff witness, Dr. Wing, testified, the results of the tests reflect any synergistic effects from i both heat and radiation, even though the results were not specifically reported as such. (Sea Wing, Tr. 548-49.)
Moreover, as indicated above, results are available from in-pool surveillance experience from reactor spent. fuel pools. Based on the results from tests and experience, the environment of the St. Lucie 1 spent fuel pool should
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not have any significant effect upon the neutron
^ absorption capability of Boraflex. (See Turner, Tr. 368.)
Thus, the foregoing demonstrates that the record conclusively supports the Licensing Board's finding that "the results of in-reactor Boraflex irradiation studies would include the effects of reactor temperature along with radiation effects." Initial Decision at 16. ~
B. The Licensing Board did not err in placing reliance on the testimony of certain Licensee and NRC Staff witnesses as to tha effects of heat and radiation on Boraflex.
The Intervenor presented no witnesses at the hearing. The Staff and the Licensee each presented three witnesses. The Licensing Board determined thati "All of the witnesses had appropriate credentials to support their expert testimony." Initial Decision at 12. The Intervenor appears to question the qualifications of two of the witnesses, and/or the weight which the Licensing Board accorded to their testimony.
- 1. Dr. Wing's Testimony The Intervenor asserts that the Licensing Board erred in relying on the testimony of the NRC Staff expert witness, Dr. James Wing, because of the
manner in which Dr. Wing responded to the Intervenor's questions during cross-examination.
(See Intervenor's Brief at 1-2.) It appears that the Intervenor is asserting that the Licensing Board erred either because the Intervenor believed that Dr. Wing was not qualified to be an expert witness, or because he believed that no weight should be 1
given to his testimony. 2/ The Licensing Board did z.at err in either regard. .
Dr. Wing's testimony addressed the effects of '
radiation and heat on Boraflex. Een Initial (
Decision at 11. (Ene also Testimony of James Wing, l 1'
Edmond G. Tourigny and Laurence I. Kopp on j 1
Contentions 3, 6 and 7, following Transcript 110, at 1-2, (hereinafter "NRC Staff Testimony, ff. Tr. 110, -
1 at ").) Dr. Wing has been employed by the NRC l 1
since 1975. He is currently serving as a Chemical j
(
Engineer. His duties include evaluation of the 2/ In the portion of the Transcript immediately preceding the passage quoted by the Intervenor on page two of his brief, the Intervenor had moved to strike Dr. Wing's testimony '
because, among other things "he's revealing extremely little knowledge as to the suitability of these tests in drawing a comparison between the environmental conditions to be 1 encountered in the St. Lucie pool and the environment in which the tests actually occurred." (Tr. 476.) The statement of the Licensing Board Chairman, quoted on page two of the Intervenor's Brief, then followed.
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- v. .? ' k A' 1 materials compatibility of components wetted by.
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waterfin the' spent' fuel pools of nuclear power i
plants. In that capacity, Dr.' Wing reviewed-the u L
materials integrity.of Boraflex in connection ith the St. .Lucie 1, spent fuel pool' expansion. .(NRC Staff Testimony, ff. Tr.:110, at 1, 2, 15.) Prior
'toijoining the NRC, Dr. Wing worked as a research -
chemist for many years.. Dr. Wing holds B.S.,.M.S.
4 .and!Ph.D. degrees in Chemistry. He is the author of a. -
numerous technical papers and laboratory reports on' ~
such subjects as nuclear chemistry and radiochemistry. (Id. at 15.) Thus, the Licensing Board did not err in its finding that, along with t the'other' witnesses, Dr. Wing had-appropriate.
credentials to support expert testimony. 2/ 1
- The Intervenor, citing to Section III.A.3.a of the In# 41al' Decision (concerning testing done to determine the effects of heat on Boraflex), also appeared to assert that, given the manner of Dr.
l/ The' qualifications of an expert witness are established by
. knowledge, skill, experience, training or education.
Philadelphia Electric Co. (Limerick Generating Stat. ion, Units 1 and 2), ALAB-819, 22 NRC 681, 732 n.67 (1985)
(citing Fed. R. Evid. 702). San Duke Power Co. (William B.
McGuire Nuclear Station, Units 1 and 2), ALAB-669, 15 NRC 453, 475 (1982) (citing Fed. R. Evid. 702).
Wing's responses, the Licensing Board erred in assigning any weight at all to Dr. Wing's testimony. 1/
(San Intervenor's Brief at 1-2.) Sna Initial Decision at 15-17. The Licensing Board did not err.
Although it was critical of Dr. Wing's lack of responsiveness at one point (Tr. 476-77), the fact remains that his testimony regarding the physical effects of heat on Boraflex was uncontradicted, as was his testimor.y to the effect that the radiation .
tests reflect the combined effects of radiation and elevated temperatures. In addition, the testimony of I both Drs. Singh and Turner corroborated Dr. Wing's testimony. (Sen, e.o., Singh on Contentions 3 & 6, ff. Tr. 139, at 14-16; Turner.on contentions 3 & 6, i i
ff. Tr. 139, at 2, 10. San also supra section II.A.) j
):
I A/ In Section III.A.3.a the Licensing Board cited the testimony of Dr. Wing as to (1) the physical effects that occurred when Boraflex test specimens were exposed to elevated temperatures for j
extended periods of time (citing NRC Staff Testimony, ff. Tr. 110, at 2, 3, 6); and ,
(2) the fact that the in-reactor Boraflex irradiation studies included the combined effects of radiation and heat (citing Wing, Tr. 548-49).
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- 2. Dr. Singh's Testimony ,
The Intervenor asserts that the Licensing Board erred in admitting the testimony of Dr. Singh because he is "a metallurgical specialist and not a chemist and so must rely upon the work and knowledge of others with regards to the integrity and suitability of the polymer, Boraflex."
(Intervenor's Brief at 2.)
First, the Intervenor misstates the .
qualifications of Dr. Singh. Dr. Singh stated that' he was not a metallurgist. (Singh, Tr. 145.) Dr.
Singh is by education a mechanical engineer, holding B.S., M.S. and Ph.D. degrees in Mechanical Engineering. (Singh on Contentions 3 & 6, ff. Tr.
139, Exhibit A at 1.) As part of his education, Dr.
Singh took courses in organic chemistry and analytical chemistry and acquired knowledge of polymers through his work as a mechanical engineer.
(Singh, Tr. 144.) In that work, Dr. Singh uses polymers just as he uses metals: he acquires data on the materials and their properties and participates in the selection of materials and configurations most suitable for particular equipment. (San Singh, Tr. 144-45.) Dr. Singh has had extensive experience
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in the design of spent fuel storage racks. utilizing Boraflex~ . (Sag Singh on Contentions 3 & 6, ff. Tr; 139, fable B and Exhibit A at 2-3.) As with Dr.
Wing, it is irrefutable that, on the basis of his education, knowledge and experience, Dr. Singh was i
qualified to testify as an expert in this proceeding concerning the design of the St. Lucie 1 spent fuel -
racks, including the choice of materials. (Saa supra Section'II.B.1.) Thus, the Licensing Board. a did not err in allowing Dr. Singh to testify as an '
expert witness.
Second, the Licensing Board did not err in allowing Dr. Singh to rely on the knowledge of other experts for data on the materials properties of .
Boraflex. This is especially true because, concerning the properties of Boraflex, Dr..Singh' ,
relied in large part upon the expertise of Dr.
Turner, a co-witness in this proceeding whose qualifications were not questioned. (San Singh, Tr.
146-47.) It is well established that an expert may rely upon analyses performed by other experts.
Sgg Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2), ALAB-819, 22 NRC 681, 718
~(1985) (citing Wisconsin Electric Power Co. (Point
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Beach Nuclear Plant, Unit 2), ALAB-78, 5 AEC 319, 332-33 (1972); and Duks Power Co. (William B.
McGuire' Nuclear Station, Units 1 and 2), ALAB-669, 15 NRC 453, 477 (1982)). l H
C. The Licensing Board did not err in finding that the maximum shrinkage of the Boraflex nould not exceed 4 percent. j The Intervenor asserts that he " agrees with the Board that shrinkage of 3-4% is to be anticipated during
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-the normal, service life of the material." (Intervenor's Brief at 3 (citing Initial Decision at 18 and Exhibit 1 (the Electric Power Research Institute's December 1988
-report entitled, "An Assessment of Boraflex Performance in Spent-Nuclear-Fuel Storage Racks," EPRI NP-6159) at 4-21 (hereinafter "EPRI Report")).) The Intervenor errs in his reading of both the Initial Decision and Exhibit 1. ..
The Licensing Board in no way characterized 3 to 4 percent shrinkage as " anticipated" with respect to the
" normal, service life." To the contrary, the Licensing ;
Board found that ,
The EPRI Study (Ex. 1) also concluded that shrinkage stops when cross-linking saturates at a gamma exposure of 10" 8 rade with projected maximum shrinkagg ,
at 3-4%.
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Initial Decision at 18'(citing Exhibit 1, at 5-12, 6-2).
(emphasis added).
Moreover, the evidence in this record does not support the Intervenor's assertion. For example,-Dr.
Turner's measurements on Boraflex coupons-irradiated in spent fuel pools showed the maximum shrinkage to be 2 to 2 1/2 percent. (Turner on Contentions 3.& 6, ff. Tr. .
139, at 6-7. Sag also NRC Staff Testimony, ff. Tr. 110,.
e at 3.) The EPRI Report projects maximum shrinkage to.be 3 to 4 percent, based on considerations other than observations. (San Turner, Tr. 217-18, 356-57.)
-The Intervenor further asserts that " Licensee's own witness, Dr. Turner, provided data that'showed shrinkage of 4% and even greater at radiation levels that will be encountered by the material in service." (Intervenor's .
- Brief at 3 (citing Turner, Tr. 387) (emphasis added).).
That portion of the Transcript contains the Intervenor's cross-examination of Dr. Turner concerning width measurements made on Boraflex samples of small size.
These measurements indicated dimensional changes of 4 percent and greater when subjected to cumulative radiation doses of 5 x 10' rads. Both Dr. Singh and Dr.
3 Turner testified that these measurements reflected contributions from both shrinkage and edge deterioration.
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(Ema Singh,-Tr. 385-86; Turner,' Tr. 387.'). Thus, Dr.
a Turner provided neither data nor testimony to the effect thatlthe shrinkage.of Boraflex would be:-4 percent.or greater.- Rather, Dr. Turner testified that dimensional changes would be on.that order, but not' shrinkage. (San Turner, Tr. 403-06.) , Dimensional changes include hath
, shrinkage and edge effects. (Saa id.) In this regard, ~
the record clearly shows that, in projecting maximum
. shrinkage, the author of the EPRI Report discarded those -
samples showing edge deterioration effects as being of no value in determining shrinkage. (San Turner, Tr. 401.)
- Moreover,-edge deterioration effects were encountered at radiation doses beyond those expected in the St. Lucie l' I spent fuel pool. (Turner, Tr.-398.)-
In short,.the record does not support the .
Intervenor's assertions regarding " anticipated" shrinkage .
of.the Boraflex. And the Licensing Board did not arr in accepting a maximum Boraflex shrinkage of 3 to 4 percent.
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D. The Licensing Board did not err in finding that the design of the Region 1 racks is such that any gaps that might form due to the combination of radiation-induced shrinkage and mechanical restraint would not exceed 1/2 inch and form only at those locations where the Boraflex panels were mechanically restrained.
Boraflex shrinkage, in conjunction with restraint of the material, can result in tearing and the formation of gaps. In the Initial Decision, the Licensing Board .
evaluated the effect of possible gap formation on criticality. With respect to Region 1, the Board ,
l considered a scenario involving 4 percent shrinkage resulting in 1/2 inch gaps at 12 inch intervals throughout all panels. The Board noted that calculations indicate a maximum k-eff of 0.771 under normal operating conditions; and 0.948 under a scenario involving the simultaneous loss of soluble Boron in the spent fuel pool water. Initial Decision at 21. The Licensing Board noted that both of these values were "within the acceptable bounds for reactivity" of a k-eff not greater than 0.95. Id. (Eng also Testimony of Dr. Stanley E.
Turner on Contention 7, following Transcript 21, at 11- !
13 (hereinafter " Turner on Contention 7, ff. Tr. 21, at ;
") (concerning acceptable bounds for reactivity)..)
l The Intervenor, however, appears to take the position that, rather than considering the formation of l
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1/2 inch' gaps every 12 inches in the Region 1 Boraflex' E panels, the Licensing' Board should'have judged spent fuel rack performance in terms of s necent Boraflex shrinkage resulting-in the formation of single,'5.72 inch' gaps at identical elevations in Boraflex panels throughout'the Region. 5/ (San Intervenor's Brief at 6-8.) -
This, the Intervenor notes, would result in e calculated k-eff of -
0'992 if.a simultaneous loss of all Boron in the spent-fuel' pool water is also assumed. (Id. at 8.) The 5 Intervenor asks rhetorically:
If the Region I rack design is intended to form gaps in order to operate safely, then does the presence of the gaps become a normal situation and not fall under the Double Contingency principal (sic) of ANSI N16.1-1975? If not, then no credit.for soluble boron may be taken in the criticality calculations. Then the calculations that Dr. Turner made for a gap a size'of 5.72 in. corresponding to 4%
maximum shrinkage which produced a.k-eff of
.992 would have to be viewed as exceeding the Standard Review Plan guidelines [which require a k-eff of'not greater than 0.95).
(Id.)
In fact, however -- and as the Licensing Board i specifically noted -- the formation of single, large gaps
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5/' This refers, of course, to Region 1. The Intervenor does not take issue with the Licensing Board's analysis of Region 2 and the acceptability of its performance. (Saa 1 Intervenor's Brief at 4.)
at identical locations throughout Region 1 is " extremely unlikely" (age Initial Decision at 22); indeed, virtually impossible. (San Turner,.Tr. 366.)- Accordingly, it is not appropriate to consider.the Intervenor's hypothetical ,
of the simultaneous occurrence of single, large (5.72 inch) gaps along with the loss of all soluble Boron from spent fuel pool water under the double contingency -
principle. The performance of Region 1 has, thus, been properly judged to be satisfactory. . , . g
'As the record clearly shows for Region 1, square cross-section tubes are produced by seam welding two identical channelc. Each Region 1 box (or " cell" or "can," as individual spaces for fuel assemblies within the storage racks are sometimes called) is equipped with a continuous sheet of Boraflex on each of its four sides.
The Boraflex panels are affixed in position by stainless steel sheathing, which also serves to protect the Boraflex material from accidental dents. The boxes are held in a vertical position and connected to each other by longitudinal connector channels to produce a honeycomb construction. (Singh on Contentions 3 & 6, ff. Tr. 139, at 8-9.) ,
The stainless steel plates covering the Boraflex panels in Region 1 are held in place by spot-welds to the I
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- l stainless steel' cans. Cutouts, every six inches along j
.l the' edges of the Boraflex panels, allow this welding to be performed-without damage to the panels. (Singh on Contentions 3 & 6, ff. Tr. 139, at 11.) Each cutout'is a I
~ scallop, ' semicircular in shape.- (Singh, Tr. 305-06; I
Weinkam, Tr. 309.)- The scallops'are found along the
- length of.the Boraflex at the edges on both sides. (San -
1 Singh, Tr.-308-10.) As any shrinkage. progresses, the
. edge of the scalloped cutout will eventually impinge on a the spot-weld, thus -- in'effect - . pinning the'Boraflex' in. place and preventing further movement. (Singh, Tr.
310-11.) By having_these spot-welds'and. cutouts at repeated intervals along the. length of each panel, there are well-defined locations where' stresses will
- concentrate and a panel may separate -- 12am, form gaps - 4
- due to-shrinkage. (Singh, Tr.: 311.) .
The presence of the scallops guarantees that gaps will form at the locations of the cutouts, because this is where the cracks which precede the gaps will initiate.
(Singh, Tr. 311-12.) ....en the stress level at the location of a cutout exceeds the tensile strength of the material, then a crack will appear across the Boraf. lex panel -- from one scallop cutout to another -- and a gap i
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will develop, thus making the stresses go to zero. (San Singh, Tr. 333.)
The size of the gap will be proportional to the free ,
j length between locations of the scallops. (Id.) The I scallops occur every 12 inches on the same side of the panel, but the scallops on the two sides are staggered so that there is a cutout and spot-weld every 6 inches along -
the entire length of the panel considering both sides.
(San id.; Singh, Tr. 418.) Assuming 4 percent shrinkage .,
of the Boraflex panels, any gaps forming 12 inches apart' would not exceed 1/2 inch; and any gaps forming 6 inches apart would not exceed 1/4 inch. (See Singh, Tr. 333-34; Turner, Tr. 363-64.)
In terms of reactivity, numerous small gaps distributed randomly in size and location would have only .
a minor effect.- (Turner on Contentions 3 & 6, ff. Tr. ,
i 139, at 6.) As discussed above, 4 percent shrinkage would be expected to result in 1/4 inch gaps at 6 inch j intervals (the distance between the scalloped cutouts !
when both sides are considered). For the sake of i
conservatism, however, the calculation described by the j Licensing Board was performed; i.e., under a set of, assumptions involving larger, 1/2 inch gaps at 12 inch intervals, throughout the Region 1 Boraflex panels at the i
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same elevations everywhere. San Initial Decision at 21.
(See also Turner on Contentions 3 &'6, ff. Tr. 139, at 7, i Table 1 at 19.) The calculations were also based on the 'f additional conservative assumption of an infinite number of fuel assemblies in the storage cells, all of infinite length. (Turner on Contentions 3 & 6, ff. Tr. 139, at 7.) As noted earlier, under the design basis condition -
of a concurrent loss of all soluble' Boron in the St.
Lucie 1 pool water, the calculations indicate a maximum a -
k-eff of 0.948. Sea, e.g., Initial Decision at 21.
The " double contingency principle," referred to by i the Intervenor,-is set forth in American National Standard Institute (or " ANSI") standard ANSI N16.1-1975.
It "provides that operations with fissionable materials outside reactors are acceptable if at least two unlikely, independent and concurrent accidents are necessary before a' criticality incident would be possible." (Sea Turner on contentions 3 & 6, ff. Tr. 139, at 9.) As described earlier, the probability of single, large (almost 6 inch) gaps forming in the Boraflex panels throughout Region 1
-- all at the same elevation -- is virtually nil, since, among other things, the spot-welds through the scal, loped cutouts along the edges of the Boraflex would constrain shrinkage after a point and result in the formation of
individual gaps at those locations. Accordingly, and contrary to the Intervenor's position, the double contingency principle does not require that such an occurrence be treated as an expected condition, and --
under such assumed conditions -- it is perfectly proper to take into account the presence of soluble Boron in the spent fuel pool water. E/ Thus, in finding spent fuel -
pool rack performance to be acceptable, the Licensing Board was fully justified in not considering a scenario ca involving the formation of large, single gaps --
equivalent to 4 percent shrinkage -- in Boraflex panels throughout Region 1 together with a concurrent loss of soluble Boron in the pool. 2/.
S/ Section III.l.2 (Postulated Accidents) of an April 14, 1978 NRC Staff letter, providing guidance on criticality' ~
analysis, invokes the double contingency principle of ANSI N16.1-1975 for fuel pool analyses and states that: -
The double contingency principle of ANSI N16.1-1975 shall be applied.
It shall require two unlikely, independent, concurrent events to produce a criticality accident.
Realistic initial conditions (e g ,
the presence of soluble boron) may be assumed for the fuel pool and fuel assemblies.
(Turner on Contention 7, ff. Tr. 21, at 12-13.) ,
1 1/ As noted in the Initial Decision, (continued...)
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.E. The Licensing Board did not err in concluding that,-
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because ofLthe normal use of Region 1, Boraflex panels in that Region'would not-generally be exposed
, to such irradiation'as,might result in shrinkage and p 'the' formation of aaps.
In its decision, the Licensing; Board noted that, Spent fuel is normally discharged'to Region 2,,while Region'l is used~to store fresh fuel prior to refueling and for
- contingencies such as the.possible need for a full core offload. -Weinkam at Tr. 140;-
~
Tunner.at Tr. 350. Because.of the normal
- usa of Region 1, shrinking and subsequent gap formation should.thus be nonexistent-or-minimal in the Region.1 racks . . .. The ;;
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'one exception which does result in some. '
. gamma' irradiation'of Region 1-cells occurs because of:the in-service surveillance-program which-Licensee has undertaken.
'This: program includes two cells in Region 1 with separate sets of sample coupons.
Turner ff.'Tr. 139 at 15-16; Weinkam ff.
Mhr. 139 at 5.
Initial ~ Decision.at 37-38. The'Intervenor takes issue- ,
with the Board's conclusion that normal-usage of Region 1 -
will-not result in the irradiation of Boraflex panels in 1/(... continued)'
Under these extremely unlikely conditions,
[of'large individual gaps and loss of all soluble Boron,RDr. Turner) . .-. calculated a k-eff of 0.992, a value below criticality. !
Turner at Tr. 412. The k-eff for the same 5.72-inch aap condition with water borated at 1720 nom would be considerably less.
~
Id., at Tr. 413.
Initial Decision at 22 (emphasis added). The' cited portion of the Transcript reveals that the 5.72 inch. gap condition with' borated water results in a k-eff of less than 0.875, well within the 0.95 limit.
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that. Region and.that, .as a consequence,-shrinkage and the possibility of gap formation there-should be1 nonexistent -
or minimal. (Intervenor's Brief at'5-6.)
The issue is irrelevant' insofar as rack acceptability,is concerned since -- as discussed in Section II.D, above -- the 0.95 k-eff limit is met even assuming. full. shrinkage and maximum gap formation. It is -
addressed here,'however, to avoid confusion.
In fact, the record on the matter is simple, clear,-
i and unambiguous. ' Region 1 is not generally subjected to' .i irradiation. Spent irradiated fuel is normally i discharged to Region 2. Region 1 is held opent-(a)-for i storing fresh, unirradiated fuel prior to refueling; and (b) for contingencies such as the possible.need to store I failed fuel (which has not reached a burnup level'
"[ sufficient to allow its placementfin Region 2), or for a full-core offload. (Sam, e.g.,.Weinkam Tr. 140; Turner, Shrinkage -- and, therefore, gapping -- should 1
Tr. 350.)
thus be nonexistent or minimal in Region 1, and nothing cited by the Intervenor supports a contrary conclusion.
Of course, even the temporary storage of any amount of spent fuel in Region 1 will result in (albeit limited) irradiation of the Boraflex. It is for this very reason i that FPL established its surveillance program for both
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Regions 1 and 2. (Sen,.g g , Testimony of Edward J.
Weinkam,'III on Contentions 3 & 6, following Transcript 139, at 3 (hereinafter "Weinkam on Contentions 3 & 6, ff.
Tr. 139, at ").) This program includes the loading of two cells in Region 1 with separate sets of sample coupons. Spent (irradiated) fuel is placed in' storage
. cells around the two cells containing the-Boraflex test -
coupons to expose them to the effects of radiation, R/ so that they can be studied. (San Turner on Contentions.3 &
6,-ff. Tr. 139, at 15-16; Weinkam on Contentions 3.& 6, ff. Tr. 139, at 5.) Any deterioration of Boraflex --
resulting from irradiation or otherwise -- will be detected so that remedial action can be taken. (San Turner on Contentions 3 & 6, ff. Tr. 139, at 15-18; Weinkam on Contentions 3 & 6, ff. Tr. 139, at 3-6.)
In addition to the test coupon surveillance program, I'
the Licensing Board has required a supplementary study program which "should include blackness testing or a state-of-the-art equivalent approved by th NRC Staff." 1 Initial Decision at 38-39. Under this program, the in-eervice condition of the Boraflex panels in Region 1 will H/ As the Licensing Board noted this, in and of itself, results in some exposure of Region 1 Boraflex panels to radiation.
San Initial Decision at 37-38. ;
I be determined under an NRC approved test regime. Id.
t(See also Kopp, Tr. 550-52;-Tourigny, Tr. 551-52 (providing background on blackness testing).) This program further assures proper neutron absorber I performance and criticality control in Region 1. 1/
R/ In this connection, a review of those portions of the Intervenor's Brief dealing with the utilization of Region 1 strongly suggests that Mr. Rich may be confusing i
" reactivity" with " radioactivity." (Sna Intervenor's Brief at 5-6.) For example, he states that the " spent fuel of inadequate [ low) burnup that will be stored in Region I emits the greatest amount (of] gamma radiation during this initial, storage period." (Id. at 6.)
In essence, fresh fuel is the most reactive. (Turner on Contention 7, ff. Tr. 21, at 4.) Region 1 cells are specifically designed to safely accommodate fuel of the highest reactivity authorized to be stored in the pool; i.e., fresh, unburned uranium fuel, enriched to 4.5 weight percent in the uranium-235 nuclide. (Id.) Since fresh fuel is more highly reactive than burned fuel, fuel of any burnup may be stored in Region 1 with assurance that the k-eff will be less than the maximum design case. (Id.) Region 1 is intended to provide safe storage for fresh fuel, to accommodate a full core off-load when required, and to store .
fuel whose burnup does not satisfy the criteria for storage ;
in Region 2 of the pool. (Id.)
However, fresh fuel -- while very reactive, is not very ,
radioactive. In fact, as discussed in the text, supra, )
except for cells around the sample coupons, Region 1 will J j
not normally see any gamma radiation. (Ega also Turner, Tr.
348-50.) Thus, the Licensing Board was perfectly justified in concluding that Boraflex panels in Region 1 would not generally be exposed to radiation that might result in shrinkage and the formation of gaps.
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F. LThe. Licensing Board did not err in relying on the
.c testimony of the Licensee's witnesses'concerning the criticality calculations'for the St. Lucie 1 Region 1 noent fuel racks.
The Intervenor asserts that the Licensing Board ~
erred because:
- 1) the NRC Staff did not verify the criticalit/
calculations of the Licensee upon which t' e Board relied in making its findings; and
, 2)' .the.NRC Staff's failure to verify the -
x calculations was predicated upon their failure, to understand the design.
(SaR Intervenor's Brief at 7.)
- 1. NRC Staff Verification The Intervenor appears to be asserting that, since the NRC Staff.did not independently verify the Licensee's calculations, the Licensee could not meet its burden of proof and, therefore, the Board erred in making findings based on these calculations. The Intervenor did not challenge or criticize the
! calculations upon which the Licensing Board relied. 1 Rather, in effect, the Intervenor appears to be a i asserting that, if the NRC Staff does not independently perform calculations to verify a
_ . - - _ _ _ _ _ _ - - - ----_ _-- _ _ ___ _ _ _ _ _ _ __ _ _ _ a
L p licensee's' analysis, a Licensing Board may not find that the licensee has met its' burden of proof. In the particular instance, the Intervenor appears to be asserting that the Licensing Board could not rely.
on those calculations of the Licensee concerning the worst credible case of gap formation in Region 1; i.e., the formation of 1/2 inch gaps every 12 inches in each Borkflex panel, as assumed by Dr. Turner in his criticality calculations. (Eng Intervenor's Brief at 7.)
The Intervenor errs in two respects. First, unless otherwise ordered by the Licensing Board,'the applicant (and not the Staff, as the Intervenor, in effect, asserts) has the burden.of proof. Egg 10 C.F.R. S 2.732 (1988).- See also 10 C.F.R. Part 2, Appendix A, S V(d)(1) (1988).
s Second, the Licensee has met its burden of proof. Dr. Turner's testimony demonstrates that the worst credible case has been considered. (San Turner on Contentions 3 & 6, ff. Tr. 139, at 7, 19.
Sag also supra Section II.D (describing design considerations related to gap formation).) Not only was no evidence presented controverting Dr. Turner's testimony, but the NRC Staff's expert witness, Dr.
Kopp, testified that, on the basis of his review of the Licensee's calculations concerning gap formation and of the testimony of Dr. Turner, the Licensee's calculations were acceptable. (Eng Kopp, Tr. 530-36.) la/ Thus, the Licensing Board did not err in its findings.
- 2. NRC Staff Understanding As to the NRC Staff's understanding of the St. .
Lucie 1 Region 1 rack design, the Intervenor is in*
error. Contrary to the Intervenor's assertions, the record provides ample evidence that the NRC Staff had available, during the review of the Licensee's application for a license amenament to expand the St. Lucie 1 spent fuel pool, information concerning the design and construction of the St. Lucie 1 spent fuel storage racks; including the general design of f the Region 1 racks, and the use of the spot-welds in at least twenty locations, through cutouts along the i i
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l 1D/ It appears that the Intervenor is asserting that Dr. Kopp may not rely upon the analyses of other experts. This is the same assertion that the Intervenor made regarding Dr. 1 Singh's testimony. (Ene supra Section II.B.2.) As with Dr.
Singh, the Intervenor's assertion has no merit, i l
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E edges of certain of the Region:1 Boraflex panels.
(San Tourigny, Tr. 507-12.)
This.information was contained in the original Safety Analysis Report submitted with the June 12, 1987 application for the license amendment (Exhibit 11),'the revised Safety Analysis Report submitted by the Licensee to the NRC Staff on January 29, 1988 (Exhibit 6), and Licensee's Letter No. L-87-424, submitted to the NRC Staff on October 20, 1987 ,,
(Exhibit 12). Following its review of these submittals, the NRC Staff found "the criticality aspects of the design of the St. Lucie Unit 1 spent fuel racks to be acceptable," and concluded.that, "from a public health and safety perspective, it was acceptable to authorize the reracking of the spent fuel pool." (Tourigny, Tr. 518-19.) The record also shows that the NRC Staff's apparent confusion over
.the design and construction of the Region 1 racks, which appeared during cross-examination, was, except as may be indicated in the paragraph immediately below, minor and related to problems with t.cminology, such as use of the terms " picture frame" and'" envelope," in describing the Region 1 racks. (San Tourigny, Tr. 507-09.)
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d The Intervenor is correct in stating that the NRC Staff did not expect gaps to form in Region 1.
(Een Intervenor's Brief at 7; Tourigny, Tr. 511-13, 539-42.) The NRC Staff continued to maintain this position throughout the hearing, even after listening to the testimony of the Licensee's witnesses when there was no confusion whatsoever regarding rack design and construction. (Ene, e.g.,
Tourigny, Tr. 519-20, 539-43; Wing, Tr. 543-46.)
However, the " gap /no gap" issue is immaterial.
The Licensee's criticality analysis of the reactivity effects of gap formation in Region 1 racks considered the worst credible case, as discussed in Section II.D, supra. This analysis demor2strates that the maximum k-eff remains within acceptable limits. (Een Turner on Contentions 3 &
6, ff. Tr. 139, at 7, 19; Kopp, Tr. 535.) For the foregoing reasons, the Licensing Board did not err in relying on the Licensee's witnesses concerning the criticality calculations for the St. Lucie 1 Region 1 spent fuel racks.
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i G. The Licensing Board did not err in finding.that operation of the spent fuel pool, as modified by the Board's condition to the spent fuel reracking amendment, "is and would be in compliance with the ;
3 Rules and Regulations of the commission." i The Intervenor asserts that two acceptance criteria were not met and that, therefore, the Licensing Board should not have found compliance with the Commission's rules and regulations. 11/ One basis for these contentions is that Section 2.a of Standard Review Plan 9.1.2.III is not met. (Intervenor's Brief at 8.) As discussed in Section II.D, supra, however, the record amply demonstrates that the Staff's acceptance criterion of k-eff.not greater than 0.95 is not violated in the design of the St. Lucie 1 Region 1 racks.
The Intervenor also asserts that the Board erred in approving the issuance of the St. Lucie 1 spent fuel pool ruracking amendment because "[o]ne of the Staff's acceptance criteria for continued use of the Boraflex
. . . [--] a dimensional change of no more than 2.5% from 11/ The Intervenor also asserts that the NRC Staff erred in making its no significant hazards consideration determination. Such a determination affects only the timing of any hearing and not the issuance of the amendment. Egg 10 C.F.R. S 50.91(a)(4) (1988). Moreover, only the Commission, on its own initiative, has jurisdiction to review a Staff no significant hazards consideration determination. Een 10 C.F.R. S 50.58(b)(6) (1988).
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th s> original" is " violated." (Sea Intervenor's Brief at 3'(citing the Staff's Safety Evaluation Report at 5).)
The Intervenor has. misconstrued the meaning of this acceptance criterion. The criterion is related to the in-service surveillance program which the Licensee is conducting at St. Lucie 1 in order to monitor the integrity and performance of'Boraflex on a continuing basis. (Sea Weinkam on Contentions 3 & 6, ff. Tr. 139, at 4-5; Turner on Contentions 3 & 6, ff. Tr. 139, at 15- -
17; Staff Exhibit 1 (which includes the Safety Evaluation by the Office of Nuclear Reactor Regulation relating to the Reracking of the Spent Fuel Pool at the St. Lucie Plant, Unit No. 1 as related to Amendment No. 91 to Unit 1, Facility Operating License No. DPR-67, Florida Power and Light Company, Docket No. 50-335) at 5; NRC
- Staff Testimony, ff. Tr. 110, at 6-8.) In Region 1 12/
two sets of Boraflex coupons are irradiated -- one set exposed to high radiation levels and the other exposed to radiation levels representative of normal use. (Turner on Contentions 3 & 6, ff. Tr. 139, at 15-16; Weinkam on Contentions 3 & 6, ff. Tr. 139, at 5.) Test coupons are i
12/ Only Region 1 is addressed because only Region i is the subject of the Intervenor's Brief. (Sag Intervenor's Brief at 4.)
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subjected to careful examination. (Saa Weinkam on contentions-3 & 6, ff. Tr. 139, a 4-5; Turner on f a
' Contentions-3 & 6, ff. Tr. 139, at 16-17.) These examinations are designed to evaluate the continuing suitability of Boraflex for use in the St. Lucie 1 spent i
fuel pool. (Weinkam on Contentions 3 & 6, ff. Tr. 139, at 4.)
Among the principal evaluation criteria is the criterion cited by the Intervenor; i.e., dimensional -
changes in width and length no more than 2.5 percent from the original. If the examinations, within the precision of the measurements, reveal changes in the materials
< properties of the Boraflex significantly in excess of what is expected (that is, if the Boraflex shows evidence
- of degradation), the Licensee will initiate additional evaluations and, if necessary, additional tests.
(Weinkam on Contentions 3 & 6, ff. Tr. 139, at 4-5.)
This surveillance program, particularly by virtue of the accelerated testing and examination component, will reveal any degradation of the Boraflex in ample time to l take any necessary corrective action. (Sea Turner ,on f Contentions 3 & 6, ff. Tr. 139, at 13. San also Weinkam L
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'/'s R , on Contentions 3 & 6, ff. Tr. 139, at 5-6 (concerning-options for corrective action).)
In short, it is clear from the record established in this proceeding that the 2.5 percent acceptance criterion relates to surveillance testing and follow-on actions should dimensional changes exceed the criterion and not, as the Intervenor asserts, to "an acceptance criteria for continued use of the Boraflex."
i: In sum, the Intervenor has erred with respect to both the k-eff acceptance criterion and the 2.5 percent surveillance test criterion. The Licensing Board was
. correct in its finding that the Commission's Rules and Regulations would be met.
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I III. Conclusion For the foregoing' reasons, the Intervenor's contentions of error lack merit and the Licensi:ag Board's Initial Decision should be affirmed.
Respectfully submitted, l
A Co-Counsel Har61d F. Reis Michael A. Bauser i John T. Butler Patricia A. Comella Steel, Hector & Davis i 4100 Southeast Newman & Holtzinger, P.C.
Financial Center 1615 L Street, N.W.
Miami, FL 33131-2398 Washington, D.C. 20036 Telephone: (305) 577-2939 Telephone: (202) 955-6600 Counsel for Licensee Florida Power & Light Co.
July 21, 1989
i ,
gt . a i- DOVi?.V c9et ,
4 UNITED STATES OF AMERICA
". h hb'O NUCLEAR REGULATORY COMMISSION y, ,
BEFORE THE ATOMIC EAFETY AND LICENSING APPEAL h RD W'
)
In the Matter of ) Docket No. 50-335 OLA
)
FLORIDA POWER AND LIGHT COMPANY )
)
(St. Lucie Plant, Unit No. 1) ) (Spent Fuel Pool
) Expansion) .
)
CERTIFICATE OF SERVICE I hereby. certify that copies of the " Licensee's Responsive Brief" were served on the following by deposit in the United States mail, first class, postage paid and properly addressed, on the date shown below:
Thomas S. Moore
- Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Alan S. Rosenthal*
Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Howard A. Wilbur*
Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washir,yton, D.C. 20555
- Additional service by messenger.
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B. Paul Cotter, Jr., Chairman
- Atomic-Safety and Licensing Board Panel U.S.-Nuclear Regulatory Commission Washington, D.C. 20555 GlennLO. Bright
- Atomic Safety and' Licensing Board Panel l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Richard F. Cole
- Atomic Safety and. Licensing Board Panel ;
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Adjudicatory File Atomic Safety and Licensing Board Panel Docket U.S. Nuclear Regulatory Commission Washington, D.C. 20555 (Two copies)
Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,
Attentions Chief, Docketing and Service Section (Original plus two copies)
Benjamin H. Vogler, Esq.*
Office of General Counsel U.S. Nuclear Regulatory Commission
-Washington, D.C. 20555
- Additional service by messenger.
7 Vic Bernard.Bordenick, Esq.*
Patricia A. Jehle, Esq.*
Office of General Counsel U.S.; Nuclear. Regulatory Commission Washington, D.C.. 20555 Mr. Campbell Rich
'4626 S.E. Pilot Avenue 'I
.Stuart, Florida 34997 Dated this 21st day of July, 1989.
r 7 Michael A. . Babser Newman & Holtzinger, P.C.
1615 L Street, N.W.
Washington, D.C. 20036 Telephone: (202) 955-6600 Counsel for Licensee Florida Power & Light Company
- Additional service by messenger. .
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