ML20024E906

Affidavit of Lh Martin Supporting Util Summary Disposition Motion Re Eddleman Contention 64(f) on Spent Fuel Shipping Cask Pressure Relief Valve.Target Rock 73-J Valve Will Be Replaced W/Rupture Disk Prior to Spent Fuel Shipment

ML20024E906
Person / Time
Site:	Harris
Issue date:	08/31/1983
From:	Martin L CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20024E900	List: ML20024E899 ML20024E903 ML20024E906 ML20024E910 ML20024E915 ML20024E916 ML20024E917 ML20024E919
References
ISSUANCES-OL, NUDOCS 8309070192
Download: ML20024E906 (13)

Text

P-r e .

September 1, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

AFFIDAVIT OF LOUIS H. MARTIN

-IN SUPPORT OF

SUMMARY

DISPOSITION OF INTERVENOR WELLS EDDLEMAN CONTENTION 64(f)

STATE OF NORTH CAROLINA )

) SS:

COUNTY OF WAKE )

LOUIS H. MARTIN, being duly sworn according to law, deposes and says as follows:

1. I am the Manager - Nuclear Fuel Section of Carolina Power & Light Company. My business address is 411 Fayetteville Street, Raleigh, North Carolina 27602. A summary of my professional qualifications and experience is attached hereto as Exhibit A. I have personal knowledge of the matters stated herein and believe them to be true and correct. I make this affidavit in support of " Applicants' Motion for Summary Disposition of Intervenor Wells Eddleman's Contention No. 64(f)" in this proceeding.

l o

i 8309070192 830901 PDR ADOCK 05000400 0 PDR

n.

~ g,

. 2. Carolina Power'& Light-Company ("CP&L") owns.a model IF-300 stainless steel encased, depleted uranium shielded rail shipping cask ("IF-300 Cask")

manufactured by the General Electric Company. The IF-300 cask is licensed by the Nuclear Rigulatory Commission for the shipment of spent nuclear fuel by Certificate of Compliance No. 9001 attached hereto-as Exhibit B.

3. CP&L has safely transported 304 PWR assemblies in 44 shipments from the H.B. Robinson Plant near Hartsville, South Carolina, to the Brunswick Plant near Southport, North Carolina, using the IF-300 cask. These shipments were all made without incident or radioactive release in excess of Federal regulations or the cask license.

4. In the event that Applicants are authorized to store spent fuel from CP&L's Robinson and Brunswick Plants at the Harris Plant, such shipments of spent fuel from CP&L's Robinson and/or Brunswick Plants to the Harris Plant in the forseeable future are likely to be made utilizing CP&L's IF-300 rail cask.

5. The IF-300 cask is equipped with one pressure relief valve connected to the cask cavity. The pressure relief valve presently installed on the IF-300 cask was manufactured by the Target Rock Corporation (" Target Rock 73-J pressure relief valve") . The purpose of the pressure relief valve is to provide controlled venting under design basis accident conditions for wet shipments and to be leak tight at all other times.

6. In 1981, General Electric Company was notified by the Target Rock Corporation that a spare 73-J pressure relief valve being fabricated for use on an IF-300 cask had failed to meet all of the specified leakage requirements following an operational test performed at the Target Rock Corporation.

General Electric Company notified CP&L of the failure of the Target Rock 73-J

F' pressure relief valve to meet certain test specifications, and on June 24, 1981, CP&L informed the NRC and withdrew its IF-300 cask from wet shipment service.

7. Certificate of Compliance No. 9001 was amended on 4/6/82, to permit only dry shipments with the IF-300 casks.

8. CP&L intends to remove the Target Rock 73-J pressure relief valve and replace it with a " rupture disk" prior to any future spent fuel shipment. CP&L does not intend to use the Target Rock 73-J pressure relief valve or another

-valve of that particular design on its IF-300 cask in the future.

9. The rupture disk is made of nickel material and marked per ASME code i

Section VIII, Division I requirements. The stamped bursting pressure of each rupture disk is between.350 and 400 psig consistent with the requirements of Certificate of Compliance 9001. For dry shipments of spent fuel the maximum allowable heat load is 40,000 btu / hour. As conservatively calculated in Section 6.3.20.4 of the Cask Safety Analysis Report, the maximum cavity

~

pressure generated under accident conditions for dry shipments is 248 psig.

The design pressure of the IF-300 cask itself is 400 psig. Since the maximum cavity pressure generated under accident conditions is well below the cask's design pressure, the cask will not vent and, therefore, a cavity pressure relief valve is not needed for over-pressure protection for dry shipments.

10. Neither the rupture disk nor any other component on the IF-300 cask, which is used as an integral barrier to the cask cavity, utilizes any " plastic component."

11. In the event CP&L elects to ship spent fuel from its Robinson and/or Brunswick Plants to the Harris Plant, any such shipments in the foreseeable future would be dry. CP&L is presently not authorized to use the IF-300 cask

I-9 for other than dry shipments, pursuant to Certificate of Compliance 9001. An alternative pressure relief system must be developed and approved by the NRC-before the Certificate of Compliance could be amended to permit wet shipments.

Because CP&L has a significant inventory of spent fuel which has been discharged from a reactor for three years or more, dry shipments of spent fuel are adequate to meet CP&L's requirements for the near term. CP&L is not, at the present time, pursuing an amendment to Certificate of Compliance 9001 to permit wet shipments.

12. Pursuant to the Nuclear Waste Policy Act, and 10CFR Part 961 48. Fed.

R m 16, 590 g seq (April 18, 1983), Carolina Power & Light Company, on behalf of Applicants, entered into an agreement with the U. S. Department of Energy (DOE) on June 3, 1983. DOE is responsible for shipments of spent fuel from the Harris Plant to a nuclear waste repository, in accordance with the terms and conditions of that contract which are substantially identical to the standard contract found at 10CFR Part 961.

LOUIS H. MARTIN Sworn to and Subscribed before me, this the 3 } " day of Ou.cu d , 1983 5A ~

Notary Public My Commission Expires:

/

M8 D 108

i

' ' EXHIBIT.A Louis H. Martin Manager - Nuclear Fuel October 31, 1942 Education and Training A. BS Degree in Nuclear Engineering - North Carolina State University -

1965 B .' MBA Degree in Business Administration - University of South Carolina -

1971 Prof essional Societies A. Member of American Nuclear Society B. Registered Professional Engineer - Nort h Carolina - 1975 Experience A. Savannah River Plant - Savannah, Georgia e

1. 1965 to 1970

2. Various nuclear engineering and reactor operating positions B. Carolina Power & Light Company ,

1. April 1972 - Employed an a Senior Engineer in the Fuel Section of the Bulk Power Supply Department. Located in the General Office.

2. July 1973 to January 1977 - Principal Engineer in the Fuel Section of the Bulk Power Supply Department. Located in the General Of fice.

l l

3. January 1977 to May 1977 - Principal Fuel Analyst in the Fuel Analysis l Unit of the Fuel Department. Located in the Cencral Office.

l i 4. May 1977 to Present - Manager of the Nucicar Fuel Section in the Fuel

! Department. Located in the General Office, i

{

i i

I l

[

! - - - - - - , - . . . . ~ . . _ , , . . . . . - _ - _ , , _ _ _ _ , _ _ _ _ _ _ . ___ _ _ _ _ _, _ _ _ _ _ _ .

.w.*

a

3 UNITE] STATES a . /j ocq%, NUCLEAR REGULATORY COMMisslON EXHIBIT B

[Y ,. , [" k WASHINGTON, D. C. 20555

3. s ,38,/ }

s o.m , ~~

MAR 2 21983 1 FCTC: RHO k b b b f Y [is 71-9001 W 28 1983

' General Electric Company RA0l0 LOGICAL & CHEMICA ATTH: fir. D. M. Dawson, MC-861 SUPPORT SECTION 175 Curtner Avenue San Jose, CA 95125 Gentlemen:

As requested by your application dated October 21, 1982, as amended, enclosed is Certificate of Compliance No. 9001, Revision No.15, for the Ebdel No. IF-300 shipping container. This certificate supersedes, in its entirety, Certificate of Compliance No. 9001, Revision No.14, dated

. September 30', 1982.

Changes' made to the enclosed certificate are indicated by vertical lines in the margin.

Those on the attached list have been registered as users of this package under the general license provisions of 10 CFR 571.12(b) or 49 CFR 5173.393a.

This approval constitutes authority to use the package for shipment of radioactive material and for the package to be shipped in accordance with the provisions of 49 CFR 5173.393a.

Sincerely, Charles E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle ahd Material Safety

Enclosures:

1. Certificate of Compliance No. 9001, Rev. 15

2. Approval Record cc: w/encls Mr. Richard R. Rawl Departmen* of Transportation

r _-.

e

' - Model No. IF-300 Packaoino USA /9001/B( )F g

J

..iAR 2 21903 Addressees: w/encls Ltr. d td :

Commonwealth Edison Company ATTN:

• Director of Nuclear Licensing P. O. Box 767 Chicago, IL 60690 Carolina Power & Light Company ATTN: Mr. B. H. Webster Route 1, Box 327 New Hill, NC 27562 General Electric Company ATTH: . Mr. D. M. Dawson, MC-861 175 Curtner Avenue San Jose, CA 95125 Nebraska Public Power District ATTU: Mr. Jerry V. Sayer P.O. Box 98 .

Brownville, NE 68321 G

l l

l 1

ISirm NRC418 U.S. NUCLEAR REGULAT6RY COf.tMlWIM S

• CERTIFICATE OF COMPLIANCE cR 1 -

For Radioactive M:terids Packages

~

Certi8icate %moer 1.(b) Revision No. 1.tc) Pacmace luentification No. 1.(d) Pages No. 1.(el Total No. Pages 15 USA /9001/S( )F 1 6 c001

3. FnEAMBLE 2.f al This certificate is issued to satisfy Sections 173.393a 173.394,173.395. and 173.396 of the Cepartment of Transportation Hazardous Materials Regulations (49 CFR 170189 gno 14 CFR 103) and Sect 4cns 146-19-10s and 146-19-100 of the Ceoartment of Transportation Dangerous Cargoes Regulations (46 CFR 146-149), as amendea.

2.lb) The packaging and contents described in itera 5 below, meets the safety standaros set forth in Subpart C of Title 10, Code of Federal Regulations, Part 71. ** Packaging of Radioactive Materials for Transport and Transportation of Radioactive Material Urider Certain Conditions."

2.(c) This certifieste does not relieve the consignor from compliance with any requirement of the regulations of the U.S. Geoartment of Transportation or other applicable regulatory agencies, including the government of any country through or into which the package will be transported.

3. This cartificate is issued on the basis of a safety analysis report of the package design or application-3.fa) Propered by (Name and address): 3.tbl Title and identification of report or application:

General Electric Company General Electric Company application dated 175 Curtner Avenue October 8, 1979, as supplemented.

San Jose,,CA 95125 3.(c) Docket No. 71-9001 4 CONDITIONS This certificate is conditional upon the fulfilling of the reouirements of Suboart O of 10 CFR 71, as applicable. and the conditions specified in item 5 below.

5. Description of Packaging arid Authorised Contents. Model Number, Fissile Class, other Conditions. .rt*

References:

(a) Packaging ,

(1) Model No.: IF-300 (2) Description A stainless steel encased, depleted uranium shielded cask. The cask is cylindrical in shape, 64 inches in diameter and a maximum of 210 inches long with maximum cavity dimensions of 37-1/2 inches in diameter by 180-1/4 inches long. Shielding is provided by 4 inches of depleted uranium, 2-1/8 inches of stainless steel and a mininun of 4-1/2 inches of water.

Two closure heads are provided for the shipment of BUR and PWR fuel assemblies. The heads are 304 stainless steel forgings and end plates which encase the 3-inch thick depleted uranium shielding.

~

The closure heads are secured to the cask body by means of 32,1-3/4 inch studs and nuts. The cask is sealed with a netallic ring gasket.

The cavity is penetrated by a vent line at the top and a drain line at the bottom. These lines are sealed by bellows seal stainless steel globe valves and valved quick-disconnect couplings. The vent line is also equipped with a 375 psig relief valve or a 350-400 psig rated rupture disk. All valves are housed in protected boxes on the cask exterior.

r

? age 2 - Certificate No. 9001 - Revision No.15 - Cocket No. 71-gC01

5. (a) Packaging (continued)

(2) Description (continued)

Neutron shielding is provided by a liquid-filled, thin-walled, ccrrugated containment on the cask exterior. This cylindrical structure is separated into two longitudinal compartments, each equipped with two expansion tanks, fill and relief valves. The fill line from each compartment is terminated by a stainless steel globe valve in a protected box (separate .from cavity boxes) on the cask exterior. The vent line from each compartment goes to an expansion tank which is provided with a pressure relief valve set at 200 psig.

The cask has two types of fuel baskets which can be interchanged to accommodate various fuels. The PWR basket holds 7 assemblies, the BWR basket hold 18 assemblies. The BWR fuel basket may be provided with supplementary shielding (depleted uranium) near the cask closure.

The cask is shipped horizontally with the bottom supported in a tipping cradle between two pedestals and the upper end resting in a semi-circular saddle; the upper end is pinned to the saddle. The cask supports are welded to the framing of a 37-l/2-foot long by 8-foot wide structural steel skid. The skid also holds the cask cooling system which consists of two diesel engines driving two blowers which discharge into common ducting. Four ducts run the length of the cask and direct cooling air to the corrugated surface. Operation of the auxiliary cooling system is not a requirement of this package approval.

The entire cask and cooling system is covered by a retractable aluminum enclosure. Access to the enclosure is via locked panels in the side and a locked door in one end. Although the tiodel No. IF-300 cask can be transported for short distances on the highway, its principal mode of transportation is by railroad.

The gross weight of the cask is approximately 140,000 pounds. The skid and other external components weigh approximately 35,000 pounds.

l (3) Drawing The Model No. IF-300 shipping cask is described by the following General Electric Company Drawing No.: 159C5238 - Sheets 1 thru 2, Rev. 3; Sheet 3, Rev. 5; Sheet 4, Rev. 6; Sheet 5, Rev. 5; Sheet 6, Rev. 5; Sheet 7, Rev. 4; Sheet 8, Rev. 5; Sheet 9, Rev. 4; Sheet 10, Rev. 5; and Sheet 11, Rev. 2.

l

' Fage 3 - Certificate E. 9001. - Revision flo.15 -- Occket tio. 71-9001 s '(ai '(4) Basic Ccmponents The Basic Components of the Podel tio. IF-300 shipping cask that are important to nuclear safety are listed. in Subsection 10.5.

(b) Contents - air as primary coolant (1) Type and form of material Irradiated PWR and BWR uranium oxide fuel assemblies. PWR assemblies may be shipped with or without control rods. Partial . fuel assembiies c that is, assemblies from which fuel pins are missing, must not be shipped unless dummy fuel pins are used to displace an amount of watcG equal to that displaced by the original pins. The specific power of each fuel assembly must not exceed 40 Kw/KgU and the burnup' of each fuel assembly must not exceed 35,000 MWD /f1TU. The mininum cooling time of each assembly mur,t be no less than '120 days. Prior to irradia the BWR and PWR fuel assemblies must have the following dimensions and specifications:

( i). Group I fuel assemblies PUR BWR Fuel form

~

Clad U02 pellets Clad U02 pellets Cladding material Zr or SS Zr or.55 Maximum initial U content / assembly, kg 465 198 Maximum initial U-235 enrichment, w/o 4.0 4.0 Maximum bundle cross section, inches 8.75 5.75 Fuel pin array 14x14/15x15 7x 7 Fuel diameter, inch -

0.380-0.460 0.500-0.600 Fuel pin pitch range, inch 0.502-0.502 0.647-0.809 tiaximum active fuel length, inches' 145 146

e

- Fag.e a, - Certificate Ho. 9001 ' Revision No.15 - Docket No. 71-9001 t .5.' (b): Contents - air as primary: coolant- (continued)

(ii) Group II fuel assemblies

\

PUR BWR Fuel form Clad UO2 pellets . Clad UO2 pellets .;

Cladding material Zr or SS Zr-or SS Maximum initial U

[

i content / assembly, kg. 475 198 l' Maximum initial U-235 l enrichment, w/o 4.0 4.0 i Maximum bundle cross section, inches 8.75 5.75 .

Fuel pin array 16x16/17x17 8x8 1 Fuel diameter, inch 0.376-0.400 0.475-0.505 )

Fuel pin pitch range,  !

inch 0.496-0.507 0.630-0.645  !

I Maximum active fuel i length, inches 150 150 '

(2) Maximum quantity of material per package Maximum decay heat per package not to exceed 40,000 Btu /hr. Maximum 5,725 Btu /hr/PWR assembly. Maximum 2,225 Btu /hr/BWR assembly. l Seven (7) PWR fuel assemblies, or eighteen (18) BUR fuel assemblies. [

Above assemblies to be contained in their respective fuel baskets as l shown in GE Drawing No.159C5238 - Sheet 6, Rev. 5.

(c) Unloaded package - contents and maximum quantity of material Greater than a Type A quantity of residual radioactive material consisting of mixed-fission and activation products adhering to interior cavity and fuel basket surfaces.

(d) Fissile Class I l

l

F ,.

q >

The end of life total calculated residual' gas that -could become available 'from

• the' fuel pins must not exceed 0.23 lb moles for content 5(b) an'd individual calculated fuel pin pressure must not exceed 2,500 psia, at 900cF.

7.

The maximum gross weight of the cavity. contents must not exceed 21,000 pou

\

S.

For the contents described in 5(b), the cavity fill specifications must' include the following: An air void must be established such that not more than 1.0 cu f t of water (corresponding to a bulk water -tenperature of 70*F) remains in the cavity.

The licensee must take' sufficient time-temperature-pressure data to ensure that the cavity pressure will not exceed A5 psig, and that the average cavity wall temperature will not exceed 210 F during the 130*F day with no auxilary cooling.

For the contents described in 5(b) and (c) the air coolant is considered par The radioactivity limits specified in 10 CFR 571.35(a)(4) the package contents.

do not apply.

9.

Prior to each shipment, the licensee must confirm that the cask is properly sealed by ter'.ing as subsection 11.3.3.1.

10. The cask contents shall be so limited that under normal conditions prior tolus transport,111 times the neutron dcsc rate c will not exceed 1000 mrem /hr at a distance of (6) feet from the -

(10 feet from the cask center-line) .~

i

~

11 .

The neutron shielding tanks anst be' filled with 'app Pay . .

12. to first use must meet all of the acceptance tests and Subsections 6.7. 6.2, ' 11.3.1.1, and 11. 3.1.7.

~

13.

Each cavity relief valve, typical-glove valves, and typical shielding tank (barrel expansion tank) relief. valves must be tested as stated in Subsectio 6.5.3.3, 6.6.1.1, a'nd 6.6.1.2.

In lieu of the requ'irementsf of.10'CFR 571.5a(h), valve testing and maintenance frequency must be as stated ~in Subsections 6.5;3.a - 6.6.2.1, and during periods of cask inactivity. shipments, the ruptureDuring disk: device Subsection 6.5.8.2 in lieu of the requirements of 10 CFR 511.54(h) .

l inactive periods :the maintenance and testing frequency may be disregard that the package is brought into full compliance with tnese requirements pri to the next use of the package.

'14.

The cask cavity must be equipped with either (1) a The Target Rock valve 73J pressure is shown in relief va1ve set at a pressure 'cf 375 psig (450 F).

~

l ' Target Rock Corporation Drawing i

$o.'73J-001, Rev. H, J, K, or L; or (2) disk device with a bust pressure f tnin the range of

~

all tolerances.

u

/

--- -..-g - - - ,

F lPagefl CertIMcaWe t (Nm

.;y.3 ,s ,

2 .

4 ri5.

The uranium shielding material must be separated; from all steel surfaces with a m'inimum copper thicknessf of 4-mils, except that the stud bolts attaching the m

shield assemblies to top of sthe EUR basket must be coated ~with a minimum of 1/2-

~ mil'of copper.

11 6 . llo shuto'ff valve shall be installed between each neutron shield tank and its respet'tive' thermal expansio'n tank. -

'l yA ~ s i.

17. The package authorhed by the certificate is hereby approved for use under the general license provisions of 10 CFR 671.12(b).

$8. Expi rati on 'da te: 'OctoSer 31, 1984.

> , .~ ,

y e "

'N REFEREllCES General Electric Company consolidated application dated October 3,1979.

~

Supplements dated: May 12, July 21, and November 26, 1980; February 6 and *

.,Cece,mbe r 29,1981; March 15 and September 20, 1982; and March 18, 1983.

3ection XI, Quality Assurance-and Testing, is deleted from the application.

FOR THE U.S. tiUCLEAR REGULATORY COMMISSI0tl t'

=Y^

Charles E. fiacDonald, Chief Transportation Certification branch Division of Fuel Cycle and Material Safety Date:

f

' * \

a

' r Ls l~ .s

<