ML20247M201
| ML20247M201 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/27/1989 |
| From: | Bauser M FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER |
| To: | |
| References | |
| CON-#289-8365 88-560-01-LA, 88-560-1-LA, OLA, NUDOCS 8904060011 | |
| Download: ML20247M201 (18) | |
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UNITED STATES-OF AMERICA
'89 tiAR 28 LP4 :22 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIN
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. March 27, 1989
)
In the Matter of
)
Docket No. 50-335 OLA
)
FLORIDA POWER AND LIGHT COMPANY
)
(ASLBP No. 88-560-01 LA)
)
(St. Lucie Plant, Unit No. 1)
)
(Spent Fuel Pool Expansion)
)
LICENSEE'S REPLY TO PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW Co-Counsel Harold F.
Reis Michael A. Bauser
. John T.
Butler Patricia A. Comella Steel, Hector & Davis 4100 Southeast Newman & Holtzinger, P.C.
Financial Center 1615 L Street, N.W.
Miami, Florida 33331-2398 Washington, D.C.
20036 Telephone:
(305) 577-2939 Telephone:
(202) 955-6600 Attorneys for Licensee Florida Power & Light Company (to#obooti efetat i'I bR $ back 06*op p 5 3f P o rt
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UNITED. STATES OF AMERICA-NUCLEAR REGULATORY COMMISF> ION' BEFORE THE ATOMIC SAFET AND LICENSING BOARD
~ March.27, 1989-
)
Inithe Matter'of
). Docket No. 50 33! OLA
)
' FLORIDA POWER AND LIGHT COMPANY
)
(ASLBP No. 88-560-01 LA)
)
.(St..Lucie Plant, Unit No.~1
).(Spent Fuel Pool Expansion).
)
LICENSEE'S REPLY TO PROPOSED FINDINGS OF FACT
'AND CONCLUSIONS OF LAW-
- ~
I.
Introduction'and Background 1.
Pursuant to 10 C.F.R. 5 2.754(a)(3), Florida Power
& Light' Company (hereinafter "FPL" or " Licensee") hersoy files
" Licensee's Reply to Proposed Findings of Fact and Conclusions of Law" in the above-captioned proceeding.
2.
This reply concerns the Intervenor's Proposed 1 Findings of Fact and Conclusions of Law (hereinafter "PFFCL").
'The PTFCL identify a number of areas with respect to Contentions 3 and 6, relating to the use of Boraflex, where the Intervenor asserts that the preponderance of the. evidence does not support a finding that the utilization of Boraflex as a neutron absorber in the St. Lucie 1 Plant, Unit No. 1 (hereinafter "St. Lucie 1")
spent fuel storage racks provides reasonable assurance that the r
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I health and safety of.the public will not be endangered.
(See' q
l PFFCL at 5.)
The Intervenor maintains that:
The testing that has been conducted'concerning.the suitability of Boraflex in neutron absorption applications is insufficient.- (See PFFCL at 6-8.)
There is a lack of in-service experience with Boraflex in the temperature range to which Boraflex-
~
will be subjected in the St. Lucie 1 pool.
(See.
PFFCL at 5-6.)
Neither the Licensee nor the NRC Staff has provided.
any data regarding the combined ~ effects from the exposure of Boraflex to both heat and-radiation for extended periods of time.
(See PFFCL at 6.)
3.
With respect to the rack design and. construction, the Intervenor asserts that:
NRC Staff was not familiar with the details of the design and construction of the St. Lucie 1 Region 1 spent fuel racks, and did-aot review pertinent analyses.
(See PFFCL at.ll-12.) 1/
Lastly, the Intervenor asserts that blackness testing is necessary.
(See PFFCL at 16.)
4.
With respect to Contention 7, the Intervenor does not address that part of the contention that relates to measures which prevent the disinsertion of a fuel assembly into a storage cell (see PFFCL at 14-16), and therefore appears to have abandoned The Intervenor's only remaining concern relating to the point.
Contention 7 is the issue whether criticality can occur in the St.
Lucie 1 spent fuel pool in the abser ce of water.
The Intervenor took no issue with the Region 2 rack design 1/.
and construction.
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I.
5.
We address each of these disputed areas-in the sections which. follow.
The evidence more._than' amply 1 supports a' grant of:the subject amendment.
i II.
Contentions 3 and 6 A.
Theirecord in this proceeding. establishes that adequate information has.been acquired to support the use of Boraflex in spent fuel storage racks.
i 6.-
~In general, the Intervenor has. emphasized data which he contends should have been collected, while ignoring the~
actual, available' data, tests-and experience which provide information about the performance of Boraflex as a neutron absorber.
In particular, the Intervenor puts great weight on the absence'of data "to warrant the life of the Boraflex for its intended service life," the absence of a method to " predict'the
' synergistic effects of-long-term exposure to radiation and heat in an aqueous pool environment," and the absence of " proof that the material will be able to perform its intended function over the expected life."
(See PFFCL at 8-9.)
However, the Intervenor ignores the relationship between the use of ongoing surveillance 2/ and the fact that no study findings suggest a i
L
~/
The Intervenor may not understand the importance of the 2
absence of reported problems from NRC licensees in assessing the performance of Boraflex.
(See PFFCL at 10-11.)
NRC reporting requirements, such as 10 C.F.R. Part 21 and 10 f.
C.F.R. SS 50.9, 50.72, and 50.73, require the reporting of I-problems.
Therefore, although not conclusive, the absence of such reports from NRC reactor licensees reflecting problems (continued...)
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-rapid or dramatic change.in the physical. properties of Boraflex-that would affect its neutron absorbing function. ~(See Singh,
~ Transcript 179, 256 (hereinafter "Tr.
").)
~
7.
Boraflex is composed of boron. carbide and a silicone encapsulant, both of which have beer. 'shown. to be chemically inert in the spent. fuel pool water environment.
(See Testimony of Dr.. Krishna P. Singh on Contentions 3 & 6, following
- Tr. 139, at 6-7,.(hereinafter "Singh-on Contentions 3 & 6, ff. Tr.
139, at
"); Singh, Tr. 190, 193, 248, 256-57.)
Thus, any changes in physical properties would be very gradual in nature.
'(Singh, Tr. 256, 264-65; Turner, Tr. 370.)
Consistent-with the practice of monitoring a material which is subject to gradual changes in its physical properties (see Singh, Tr. 256-59), an in-service surveillance program will be conducted at-St. Lucie 1 to monitor the integrity ~and performance of Boraflex on a continuing basis.
(See Testimony of Dr. Stanley E. Turner on Contentions 3 & 6, following Tr. 139, at 15 (hereinafter " Turner on Contentions 3 & 6, ff. Tr. 139,'at
");. Turner-Tr. 337, 370,'372, 377; Singh, Tr. 264-65; Testimony of Edward J. Weinkam, III on Contentions 3 & 6, following Tr. 139, at 3-6 (hereinafter "Weinkam on Contentions 3 & 6, ff. Tr. 139, at
").)
'2/(... continued) with Boraflex is indicative of the absence of conditions that l
trigger public health and safety concerns.
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. 8.
. The Intervenor suggests that in-service experience with Boraflex at other spent fuel pools is irrelevant because the temperatures in those pools are not known with enough precision.
(See PTFCL at 5-6.)
To the contrary, the record shows that the bulk pool temperatures in typical spent fuel pools are in the same
]
temperature range as the St. Lucie 1 spent fuel pool.
(See Weinkam, Singh, Tr. 266-72.)
Therefore, the in-service experience at other spent fuel pools as to temperature effects is relevant.
9.
Additionally, Boraflex was subjected to heat aging tests at temperatures of up to 350'F, simulating worse-than-possible scenarios with respect to the temperatures to be encountered in the St. Lucie 1 spent fuel pool.
Under these conditions Boraflex was shown to be stable.
(Singh on Contentions 3& 6, ff. Tr. 139, at 14; Singh, Tr. 340.)
In a boric acid solution maintained for an extenied period of time at 240*F, Boraflex was also shown to be stable.
(Singh on Contentions 3 &
6, ff. Tr. 139, at 14.)
Thus, the record amply demonstrates, on the basis of both test and in-service experience, that Boraflex remains stable when subjected to typical spent fuel pool temperatures, as well as to much higher than expected temperatures.
l 10.
The Intervenor asserted that "neither Licensee nor i
staff provided us with any other data as to the suitability of this material when exposed to elevated temperatures and radiation for extended periods of times."
(PFFCL at 6.)
Contrary to these
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assertions,' however, tests have been performed'under. conditions in which Boraflex was simultaneously subjected to the combined effects of temperature and radiation.
For example, the 1979-81 tests at'the University of' Michigan's Ford Nuclear Reactor were designed to identify physical and chemical effects on the characteristics of Boraflex under a variety of radiation levels and. severe environments, including elevated temperatures.
(See Singh on Contentions 3 & 6, ff. Tr. 139, at 15; Win;. Tr. 436-37, 4 4 2 - 4 3.~ ) - As the NRC Staff witness,-Dr. Wing, testified, the results of these tests thus reflect any synergistic effects from both heat and radiation, even though the results were not specifically reported as such.
(See Wing, Tr.: 548-49.)
- Moreover, results are available from both tests and in-pool surveillance experience from reactor spent fuel pools, where Boraflex has undergone significant, concurrent exposure to both radiation and typical spent fuel pool environments.
(See Turner on Contentions 3& 6, ff. Tr. 139, at 2, 10; Singh on Contentions 3 & 6, ff. Tr.
139, at 16; Wing, Tr. 437, 442-43.)
11.
Based on the results of tests, the St. Lucie 1 environment in the spent fuel pool should not have any significant effect upon Boraflex.
(Turner, Tr. 368.)
Tests have confirmed that no significant loss of boron occurs under irradiation up to levels in excess of those expected through the expiration of the St. Lucie 1 operating license.
(Turner on
. Contentions 3 & 6, ff. Tr. 139, at 11.)
However, the Licensee
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recognizes that~it is.not possible to get actual lifetime test results in less than'an actual lifetime.
(See Turner, Tr. 337, 370, 372, 377.)
This is why the Licensee is conducting a surveillance program at St. Lucie 1 to monitor the integrity and performance of the Boraflex on a continuing basis, and why the F1petric Power Research Institute (hereinafter "EPRI") recommends the conduct of meaningful surveillance programs to ensure long-term performance of the Boraflex.
(See Turner on
' Contentions 3 & 6, ff. Tr. 139, at 14-15.
See also_Singh, Tr.'261-265 (concerning EPRI's December 1988 report, "An Assessment of Boraflex P'erformance in Spent-Nuclear-Fuel Storage Racks," EPRI NP-6159 (hereinafter "EPRI Report"); in particular, the section entitled, "Boraflex Service Life," at 5-27 to -
29).) 3/
12.
In summary, contrary to the Intervenor's i
assertions, both tests and in-service experience have provided 3/
The summary of the referenced section reads in relevant part:
From the available data there are no indications that combined exposure to gamma radiation and the pool aqueous environment result in the onset of rapid or gross j
f degradation of the polymer matrix that would cause the loss of boron carbide, Factors have been identified which are likely to affect service life and some of these will vary from plant to plant.
Accordingly, a formal surveillance program at each plant appears a prudent course to verify the continued serviceability of the Boraflex.
EPRI Report at 5-29 (emphasis added).
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _______________i
a-
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information about the combined effects of temperature and
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radiation on the integrity and performance of Boraflex.
The long-term surveillance program being conducted at St. Lucie 1 will-ensure the integrity and performance of Boraflex on a continuing basis.
B.
With respect to the St. Lucie 1 Region 1 rack design and construction, the " gap /no-gap" issue is immaterial.
13.
The'Intervenor asserts that "[t]he analysis of the NRC staff of the racks being utilized at St. Lucie 1 is of-absolutely no use to the Board in this case," and that the "NRC-Staff had no' idea of the nature or intent of the manufacturer's design of the St._Lucie 1, region 1 racks."
(PFFCL at 11.)
contrary to these assertions, as the record reveals,'the NRC Staff nad available,.during the review of the Licensee's application for a license amendment 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 design of Region 1 racks and the use of spot-welds in at least twenty locations, through cutouts along the edges of the Boraflex panels.
(See Tourigny, Tr. 507-09, 511-12.)
14.
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
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i on January 29, 1988 (Exhibit 6), and Licensee's Letter No. L 424, submitted to the NRC Staff on October 20, 1987 (Exhibit 12).
l Following review of these submittals,.the NRC Staff found "the 1
criticality. aspects of the design of the St. Lucie Unit 1 spent fuel racks to be acceptable," (Tourigny, Tr. 518), and concluded that "from a public health and safety perspective, it was-acceptable to authorize the reracking of the spent fuel' pool" (Tourigny, Tr. 519).
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 paragraph 15, below, minor and related to problems in the use of terminology, such as use of the terms
" picture frame" and " envelope," to describe the Region 1 racks.
(See Tourigny, Tr. 507-09.)
Such terms are more often used'in describing other rack designs, such as that utilized in Region 2.
(See Tourigny, Tr. 509.)
Thus, the'NRC Staff did not base its safety determination upon an " incorrect understanding" of the rack l
- design, as the Intervenor asserts.
(PFFCL at 11.)
15.
The Intervenor is correct in his statement that the NRC Staff did not expect gaps to form in Region 1, based upon expected shrinkage.
(See id.; Tourigny, Tr. 511-13, 539-41.)
However, the NRC Staff continued to maintain this position throughout the hearing, after listening to the testimony of the Licensee's witnesses, when there was no confusion whatsoever regarding rack design and construction.
(See, e.g.,
- Tourigny, l
~
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Tr. 519, 539-43; Wing, Tr. 543-46.)
Moreover, based upon calculations that the NRC Staff witness, Dr. Kopp, reviewed concerning gap formation and based upon the testimony of the Licensee's witness, Dr. Turner, the NRC Staff testified that it saw "no criticality concerns since the staff's acceptance criteria of k-eff no greater than.95 is still not violated."
(Kopp, Tr.
535.
See also Kopp, Tr. 530-36.) 4/
16.
Initially, the St. Lucie 1 rack design allows the Boraflex in Region 1 to contract freely until it encounters a spot-weld.
(See Singh, Tr. 310-11.)
There was some dispute as to how much shrinkage is necessary before the Boraflex will constraint encounter a spot-weld, and whether there was sufficient following such an encounter to cause gap formation if further shrinkage occurs.
(See, e.g., Singh, Tr. 415-16, 564-66; Tourigny, Wing, Tr. 539-46.)
17.
However, the " gap /no gap" issue is immaterial.
The Licensee's criticality analysis of the reactivity effects of 4/
The Intervenor asserts that "(s]ince the staff did no analysis of gap formation, we do not know whether this [that the worst case of gap formation for Region 1 racks is the formation of 1/2 inch gaps located every 12 inches along the vertical plane of the Boraflex sheet) is true or not."
(PFFCL at 12.)
In fact, we do know from Dr. Turner's testimony that this is the worst case.
(See Turner on Contentions 3 & 6, ff. Tr. 139, at 7, 19.)
And, as Dr. Kopp testified, it is not necessary that the Staff perform each and every criticality study in order to form an expert opinion on criticality concerns.
(See Kopp, Tr. 534-36.
See also Singh on Contentions 3 & 6, ff. Tr. 139, at 11; Singh, t
Tr. 305-06, 310-12, 333-34, 363-64, 418-19 (regarding the bases for the assumptions as to maximum gap size).)
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gap 1 formation.in Region 1' racks is bounding. 5/
This bounding analysis demonstrates that the maximum k-eff remains within
- acceptable limits.- (Turner on Contentions'3 & 6, ff. Tr. 139, at 7.)
In this' regard,_the NRC Staff saw no criticality concerns because the Staff's acceptance criterion (k-eff no greater than n,9%) was not violated.. (Kopp, Tr. 535.)
C.
There is no basis for the Licensee's undertaking blackness testing at this time.
18.
There is a suggestion that, in spite of FPL's surveillance program,. blackness testing should be undertaken.
(See, e.g., PFFCL at 17.)
Such testing would be unwarranted at-St. Lucie 1 for several reasons.
5/
A maximum 4 percent shrinkage was assumed for the limiting condition of 1/2-inch gaps in the Boraflex every 12 inches at the same height everywhere.
(Turner on Contentions 3 & 6, ff. Tr. 139, at 7,'19.)
The location and size of any gaps is a function of the rack design:
the Region 1 design is such that any shrinkage-induced gaps will be small.
(See Singh, Tr. 211-12, 311-13.)
Small gaps have only a minor effect on reactivity.
(See Turner, Tr. 313.)
Although Dr. Turner's measurements showed the maximum shrinkage to be 2 to 2-1/2 percent, Dr. Turner assigned a value of 4 percent for his criticality calculations, which was at the top of the 3 to 4 range projected in the EPRI Report as the maximum percent shrinkage, based on considerations other than observation.
(See Turner on Contentions 3 & 6, ff. Tr. 139, at 6-7, 14; Turner, Tr. 217-18, 356-58.)
In choosing its maximum, EPRI discarded those samples showing edge deterioration effects as being of no value in determining shrinkage.
(See Turner, Tr.
401.)
Edge deterioration effects were encountered at radiation doses beyond those expected in the St. Lucie 1 l
spent fuel pool.
(Turner, Tr. 398.)
Dimensional changes, L
such as mentioned in paragraph 19 of the PFFCL, at 7, include L
both shrinkage and edge deterioration effects.
(See Turner, Tr. 404-05.)
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- 19.
- Fi r st, the design of the St. Lucie 1 racks restricts the gapping which has occurred at other plants.
Both Region 1 and Region 2 of the St. Lucie racks are designed so that the Boraflex is initially unconstrained and free to shrink, without the formation of gaps which restrictions might cause.
(See, e.g_._, Singh on Contentions 3 & 6, ff. Tr. 139, at 11; Exhibit 12, Attachment, Response to Question #1.) 6/
20.
Some gap formation is theoretically possible in the Region 1 racks.
As indicated above, this is due to the use of spot-welds, which are used to attach Boraflex cover sheets to interior cells.
Sufficient shrinkage will cause the edges of the semi-circular cutouts in the Boraflex -- through which the welds are made -- to come into contact with the spot-welds themselves.
This, in turn, will tend to restrain the Boraflex, and can result in gap formation.
(See, e.g., Turner on Contentions 3 & 6, ff.
Tr. 139, at 5-6; Singh, Tr. 565-66.)
Indeed, Dr. Singh expects that small gaps will occur.
(See, e.g.,
Singh, Tr. 310-12, 415-16.)
21.
Region 1, however, is generally not subject to irradiation.
Spent fuel is normally discharged to Region 2.
Region 1 is held open for staging fresh fuel prior to refueling, 6/
There are implications in the PFFCL that the design approaches used for the St. Lucie 1 racks are unique.
(See PFFCL at 11, 13.)
In fact, the record amply shows that the design approaches have been used before.
(See, e.g.,
- Singh, Tr. 206-16.)
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and for: contingencies, such as the possible need for a full-core offload.
(See, e.g.,
Weinkam, Tr. 140;' Turner, Tr. 350.)
Shrinking'and, therefore, gapping should,-thus, be nonexistent or minimal in the Region 1 racks.
In the Region 2 racks'Boraflex is a
unconstrained and no gapping should occur.
(See Singh on contentions 3 & 6, ff. Tr. 139, at 11.)
22.
The one exception, which does result in some irradiation of Region 1 cells, occurs because of the in-service I
surveillance program which FPL has undertaken.
This program includes the loading of two cells in Region 1 with separate sets of sample coupons.
One set of coupons is exposed to accelerated irradiation by surrounding it with freshly discharged spent fuel assemblies each refueling.
The other set of coupons is exposed to normal irradiation by surrounding it with'the same spent fuel assemblies during the entire irradiation period.
(See Turner on Contentions 3 & 6, ff. Tr. 139, at 15-16; Weinkam on Contentions 3
& 6, ff. Tr. 139, at 5.)
However, the reracking was only completed last spring (see Letter to the Members of the Board from Michael A. Bauser, dated June 8, 1988), so relatively little irradiation has occurred thus far.
23.
Further, even under full irradiation resulting in maximum Boraflex shrinkage, gaps would not be larger than one-half inch.
(See, e.g.,
Turner on Contentions 3 & 6, ff. Tr. 139, at 6-7, 19; Turner, Singh, Tr. 357-64.)
This is at the lower range of detection for blackness testing.
(Turner, Tr. 321-22;
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. Tourignyj Tr. 552.)
Thus,' blackness'testingLof those Region 1 cells ~ undergoing irradiation as a result of FPL's in-service surveillance program might not detect the presence of gaps,.if they were to occur, even after' maximum irradiation and' shrinkage.
24.
Finally, blackness testing would necessitate'the tcVement of spent fuel in order to provide clearance within the irradiated cells for' neutron sources and detectors.
'(Kopp, Tr.
550-52.)
This would be time-consuming and result in additional l occupational exposure and expense.' (Kopp, Tr.;550-51.)
In view of the minimal (if any) benefits to be derived from
-blackness testing, no additional exposure or cost can be
. justified.
III. Contention 7 25.
As indicated above, the Intervenor does not refer, in any way, to that part of Contention 7 concerning measures which prevent the disinsertion of a fuel assembly into a storage cell.
This issue appears to have been abandoned.
1 I
26.
With respect to the remaining issue affecting Contention 7, there is simply no case to be made concerning criticality in the absence of water serving as.a moderator in the spent fuel pool.
The record is clear:
criticality cannot occur under such conditions, and there is no evidence whatsoever to the contrary.
In particular, criticality will not occur in the St.
Lucie 1 spent fuel pool, regardless of the amount of fissionable
L. 'g.
- material assumed.
Under_the conditions which would exist, a F
critical mass could not form even' assuming an infinite amount of material.
(See, e.g., Testimony of Dr. Stanley'E. Turner on Contention 7.following Tr. 21, at 19-22;. Testimony of Lawrence I.
Kopp on Contention 7, following Tr. 110, at 14; Turner, Tr. 65-66, 73,.83-84; Kopp, Tr. 123-24.)
Further, the Intervenor's pro-testations to the contrary notwithstanding, zirconium will not-act as a moderator in a dry spent fuel storage pool.
Zirconium is not a moderator within the technical meaning of that term, and will.not operate as a moderator regardless of the amounts which might be present.
(See, e.g.,
Turner, Tr. 61-62, 78-79; Kopp, Tr.
'116-18, 126-27.)
Respectfully submitted, L
An -
Co-Counsel Harold F. Rbis' Michael A. Bauser John T. Butler Patricia A. Comella Steel, Hector & Davis 4100 Southeast' Financial Newman & Holtzinger, P.C.
Center 1615 L Street, N.W.
Miami, FL. 33131-2398 Washington, D.C.
20036 Telephone:
(305) 577-2939 Telephone:
(202) 955-6600 Counsel for Florida Power & Light Company
UNITED STATEfi OF AMERICA L
NUCLEAR REGULATSRY COMMISg}ON.e 28 P4 22
~59 NAR 28 p BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
?, 4-
)
In the Matter of
)
Docket No. 50-335 OLA
)
FLORIDA POWER AND LIGHT COMPANY
)
(ASLBP No. 88-560-01 LA)
)
St. Lucie Plant, Unit No. 1)'
)
(Spent Fuel Pool Expansion)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Reply to Proposed Findings of Fact and Conclusions of Law" were served on the following by deposit.in United States mail, postage prepaid and properly addressed or, as indicated by a single asterisk, by messenger, on the date shown below:
B.
Paul Cotter, Jr., Chairman
- Atomic Safety and Licensing' Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
.Glenn O.
Bright
- Atomic Safety and Licensing _ Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Richard F. Cole
- Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Nashington, D.C.
20555 Adjudicatory File Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 (Two Copies)
l
! Secretary U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Chief, Docketing and Service Section (Original plus two copies)
Benjamin H.
Vogler, Esq.*
Office of General Counsel U.S.
Nuclear Regulartory Commission Washington, D.C.
20555 Bernard Bordenick, Esq.*
Patricia A.
Jehle, Esq.*
Office of General Counsel U.S.
Nuclear Regulatory Conmission Washington, D.C.
20555 Campbell Rich **
4626 S.E.
Pilot Avenue Stuart, Florida 34997 Dated this 27th day of March, 1989.
94-,
2'M Michael A.
Bauser Newman & Holtzinger, P.C.
1615 L Street, N.W.,
Ste. 1000 Washington, D.C.
20036 Telephone:
(202) 955-6669 Counsel for Florida Power & Light Company Also served via Federal Express for delivery on March 28, 1989.
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