ML20236C331
| ML20236C331 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/19/1987 |
| From: | Frantz S FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER |
| To: | |
| Shared Package | |
| ML20236C255 | List: |
| References | |
| OLA-2, NUDOCS 8710270101 | |
| Download: ML20236C331 (67) | |
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UNITED STATES OF MIERICA .17 ET 22 A7:57 l NUCLEAR REGULATORY COMMISSION.
a #FFICE OF SEcanggy-L BEFORE THE ATOMIC SAFETY AND LICENSING BOAMC6ETING 4. SERVICE 8 ANCH ,
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In the. Matter of.
') Docket Nos. 50-250-OLA-2 i
) 50-251-OLA-2 FLORIDA' POWER'& LIGHT COMPANY )
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(Turkey _ Point Plant, ) (Spent Fuel Pool Expansion) .l Units 3 & 4) ' )
October 19, 1987
)
LICENSEE'S PROPOSED FINDINGS OF.
FACT AND CONCLUSIONS OF LAW t
I. INTRODUCTION AND BACKGROUND Florida Power & Light Company.(N?L or! Licensee) is- .I licensed to possess, use and operate the Turkey Point Plant, Units
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3 and 4, two pressurized water nuclear reactors located in Dade
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County, Florida.;
q On March 14, 1984, the Licensee applied for amendments to allow the expansion of the capacity of each-unit's spent fuel j pool. 1/ This application was supported by a Safety Analysis Report which addressed various safety matters related to the expansion and concluded that the proposed modification.of the Turkey Point spentXfuel pools would continue to provide safe storage of spen't fuel. On June 7, 1984, pursuant to 10 CFR l
~/1 . Letter from Mr. J. W. Williams, Jr. (FP&L) to Mr. D. G.
Eisenhut (NRC) (March 14,'1984) (Turkey Point Units 3 and 4, I
~ Docket Nos. 50-250 and 50-251, Proposed Amendment to Spent. ;
i Fuel Storage Facility Expansion).
1 8710270101 871019 PDR ADOCK05000ggO.
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-2.105(a)(4)(i), the Nuclear Regulatory Commission (NRC or Commission) . published in the Federal Register a notice of consid-eration of:the issuance of amendments'to the facility operating )
i licenses and offered the opportunity for a hearing on these l l
amendments. 49 Fed. Reg. 23715 (1984). On July 9, 1984, the Center-for Nuclear Responsibility, Inc. (Center) and Joette Lorion-
- (collectively referred to herein as Interveners)' filed a timely
' request for a hearing and petition for leave to intervene in the J -license.' amendment proceeding. 2/
The NRC-Staff applied the standards of 10 CFR 50.92 and made a final determination that the amendments involved'no signi-
'ficantfhazards consideration. 49 Fed. Reg. 46832.(1984). Conse-quently, on November 21, 1984, the NRC issued the license amend-ments to allow the expansion of the capacity of the spent fuel pools notwithstanding the pendency of the Interveners' petition to intervene. ~In conjunction with the issuance of the amendments, the'NRC Office of Nuclear Reactor Regulation issued a Safety Evaluation for the expansion which concluded that there is reason-t able assurance that the health and safety of the public will not
'be endangered by the expansion. 3/
i on March 7, 1985, Interveners submitted an Amended !
1 Petition to Intervene which included ten proposed contentions. On j March 27, 1985, the Licensing Board held a prehearing conference jb/ Request For Hearing And Petition For Leave To Intervene, July 9, 1984. 3 3/ NRC Staff Exh. 1.
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g T in order to consider Interveners' petition to inttivene. Bn Order j
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of. September 16, 1985, .the Licensing Board admitted the 9 u
Interveners as parties and seven ofjtheir proffered conte;ntions
., .o r (Contentions 3, 4, 5, 6 , - ' 7 , B. , and 10),,as issues in be litigated inthe.pcoce$ ding. Florida h wer ' and Lietht Co. (Turkey Point 'I Nuclear'Gejierating Plant, Units 3 and 4)r LBP"8T-36, 22 NRC 590 j' ,
3 (1985). Contention l'was rejected because it sought to litigate an issue'not cognizable by.the-Board and Contentions 2 and 9 were 3
. a rejected because Interveners failed to specify an adequate basis q for those contentions. In several cases, the Board noted tdid the admitted contentions'were supported by,only a " minimal y suffi- l cient basis." Id_. at 596-599. /
^ ;i e rr On. October 28, 1985, the Licenses served intgvEgat,ories L /
upon the Interveners. 4_/ .
The. Interveners file 31a response to these interrogatories on November 27, 1985. 5/ The/ Interveners
.j did not conduct any dfscovery, and no other discovery wxs con-ducted in this proceeding.
l' On January 23, 1986, yicensee filed a.motica(for summary
- r-disposition of each contention raised by Interveners. 6/
,i ,l Licensee's motion was supported by the'NRC Staff with respect to 4/. Licensee' Interrogatories to Center for Nuclear "sespodsibility and Joette Lorioii,1 October ' 28, 1985.
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5/ Interveners' Response to Licensee's Interrogatories to Center
.for Nuclear Responsibility and Joette Lorion,jNovember 27, 1985~ .
6_/ Licensee's Motion For Summary Disposition'Of Interveners' ~
Contentions,.7anuary 23, 1986.
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4 every contention except for part of. Contention 4. 7/
Subsequently, the NRC Staff submitted its own motion for summary
. disposition of Contention 4. 8/
Interveners did not file a response to the NRC Staff's gi motion for-summaryLdisposition. Interveners' response to n
Licensee's motionLfor summary disposition was filed on March 19,
< oi 1986. 9/ This response was not supported by an affidavit.from any I expert or by any other evidence. The only affidavit provided in
-( f support of Interveners' response was that of Joette Lorion, who is O/# one of the Interveners. 10/
in n After considering the motions for summary disposition, the Licensing Board determined that there were no genuine issue of material fact to be litigated with respect to Contentions'3, 4, 7, 8, and 10. Florida Power and Licht Co. (Turkey Point Nuclear Generating Plant, Units:3 & 4), slip. op. at 62 (March 25, 1987).
The Licensee's motion for summary disposition of Interveners' l
Contentions.5 and 6 was denied.
7/ NRC Staff Response to Licensee Motion for Summary Disposition of. Contentions, February 18, 1986.
8/- NRC Staff Motion for Summary Disposition of the Personnel Exposure Portion of Contention 4, July 14, 1986.
9 /_ ~ Interveners' Response to Licensee's Motion for Summary Disposition of Interveners' Contention 3, etc., March 19, 1986.
10/ Egg Affidavit of Joette Lorion on Contentions 3, 4, 5, 6, 7, 8, and 10, March 19, 1986.
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) 6 Hearings were held before the Board on Contentions 5 and 4 6 in Miami, Florida, on September 15, 1987 and September 16, 1987, after which the record was closed. 11/ During the hearing, the i Licensee and Staff presented testimony from a series of witness panels. As discussed below, these witnesses generally were in
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agreement with respect to resolution of Contentions 5 and 6.
Interveners did not sponsor any testimony and did not offer any exhibits or other evidence. Furthermore, with respect to Contention 5, Interveners did not cross-examine the direct testi-mony of the Licensee's panel of witnesses. 12/ Consequently, the evidence submitted by Licensee and Staff regarding Contentions 5 and 6 is essentially undisputed.
This initial decision is based upon the record developed at the hearing. The decision incorporates the Findings of Fact that follow. Any proposed findings submitted by the parties that are not incorporated directly or inferentially in this decision are rejected as being insupportable in law or in fact or as being unnecessary to the rendering of this decision.
II. FINDINGS OF FACT A. CONTENTION 5
- 1. Interveners' Contention 5 states:
That the main safety function of the spent fuel pool, which is to maintain the spent fuel assemblies in a safe configuration through all environmental and abnormal loadings, may not be met as a result of a recently brought to 11/ Tr. 376-378.
12/ Tr. 104. ;
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light unreviewed safety question involved in the current rerack design that allows racks whose outer rows overhang the support pads in the spent' fuel pool. Thus, the amendments should be revoked.
The bases advanced by the Interveners for the contention were as .
follows: l In a February 1, 1985 letter from Williams, FPL, to Varga, NRC which describes the poten-tial for rack lift off under seismic event conditions (sic). This is clearly an unre-viewed safety question that demands a safety .
analysis of all seismic and hurricane condi- I tions and their potential impact on the racks in question.before the license amendments are issued, because of the potential to increase the possibility of an accident previously evaluate (sic), or to create the possibility of a new or different kind of accident caused by loss of structural integrity. If integrity is lost, the damaged fuei rods could cause a criticality accident.
In admitting Contention 5 for litigation, the Licensing Board stated that the jssue raised in this contention "is not whether the potential for lift off during a seismic event is an unreviewed safety question, but whether there is a deficiency in the current rack design and a necessity for a restriction on loading to prevent potential lift off." Florida Power and Licht Co. (Turkey Point Nuclear Generating Plant, Units 3 and 4), LBP-85-36, 22 NRC 590,597-598 (1985). The Licensing Board also rejected hurricane loads as a basis for Contention 5. Id. at 598.
- 2. The Licensing Board denied Licensee's motion for summary disposition of Contention 5. Florida Power and Licht Co.
(Turkey Point Nuclear Power Generating Plant, Units 3 and 4), slip op at 18-24 (March 25, 1987). The Licensing Board had no ques-l
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T tion that properly executed administrative controls would prevent lift off during a seismic event. However, the Board noted that s l
the NRC Staff had not taken a position on the matter of lift off j l
during a seismic event absent a requirement for administrative controls incorporated into the license amendment. Consequently, j the Board denied summary disposition of Contention 5. Id. at 24.
- 3. The Appeal Board has provided direction for deter-mining the circumstances under which administrative controls should be included in a license condition. In Portland General <
Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979), the Appeal Board stated:
(T]here is neither a statutory nor regulatory requirement that every operational detail set forth in an applicant's safety analysis report (or the equivalent) be subject to a technical specification, to be included in the license as an absolute condition of operation which is legally binding upon the licensee when and until changed with specific Commission approval. Rather, as best we can discern it, the contemplation of both the Act and the regulations is that technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and ,
safety. 13/
13/ Egg alsQ Sacramento Municipal Utility District (Rancho Seco Nuclear Generating Station), ALAB-746, 18 NRC 749, 754 n.4 (1983); Commonwealth Edison Co. (Zion Station, Units 1 and 2), ALAB-616, 12 NRC 419, 422 (1980); Virginia Electric Power Co. (North Anna Nuclear Power Station, Units 1 and 2), ALAB-578, 11 NRC 189, 217 (1980).
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Thus, in determining whether a license condition should be. imposed-which incorporates administrative controls on loading of assem-blies into the Turkey Point spent fuel pool, the Board has evalu-ated whether such controls are necessary to prevent an abnormal situation which would pose an immediate threat to the public j
- l. health and safety. !
- 4. The Licensee called a panel of three witnesses to
. address Contention 5: Edmund E. DeMario and Harry E. Flanders, Jr., of Westinghouse Electric Corporation (Westinghouse) and Russell Gouldy of FPL. The NRC Staff called a panel of two witnesses to address this matter: Sang Bo Kim and Mr. Daniel G.
Mcdonald, Jr. These witnesses are well qualified to address the
' issues raised by Contention 5. In particular, the witnesses who submitted testimony regarding the seismic analysis of the Turkey Point spent fuel racks and assemblies have extensive experience in this area as is indicated by the following:
o Mr. DeMario's professional experience and back-ground includes 27 years of engineering experience including over i
18 years as a nuclear engineer for Westinghouse. Since joining q J
Westinghouse in January'1969, Mr. DeMario has been responsible for l the mechanical design of advanced fuel assemblies. (DeMario, ff. l l
Tr. 103, at 6).
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o Mr. Flanders has been a practicing engineer for over 24 years. Since joining Westinghouse in April of 1974, Mr. Flanders has been responsible for the seismic and structural analysis of the internal components of pressurized water reactors and of spent fuel racks. (Flanders, ff. Tr. 103, at 20).
o Mr. Kim has over 24 years of nuclear experience.
While at the NRC, his duties have included the evaluation of the structural and earthquake engineering aspects of safety-related structures, systems and components, and the performance of inde-pendent calculations and engineering analyses to confirm appli- ;
cants' or vendors' assessment of structural integrity and response under pertinent load combinations, including postulated transient and accident conditions. (Kim, ff. Tr. 129, at Attachment 1).
- 5. The Turkey Point spent fuel pools have two storage regions, Region 1 and Region 2. The Region 1 storage racks consist of three major sections, which are the leveling pad assembly, the upper and lower grid assemblies, and individual storage cells made of stainless steel. The cells within a rack 3 1
are interconnected by grid assemblies to form an integral structure. Each rack is provided with leveling pads connected to the lower grid assembly which contact the floor of the spent fuel pool and are remotely adjustable from above to level the racks during installation. The racks are free-standing and are not anchored to the floor or braced to the pool walls. Support pads for the new racks sit on the existing floor embedment plates which are located at various places along the bottom of the pool liner.
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e, Due to the location of the floor embedment plates, some of the support pads for some of the new racks in Region 1 cannot be
-i situated'at the corners'of the racks. Therefore, some of the outer storage locations on these racks overhang (extend beyond)
I the support. pad. (Flanders, ff. Tr. 103, at 3-4). )
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. 6 '. The Region 2 storage racks consist of two major sections, which are the leveling pad base assembly and stainless I steel cells. The cells are assembled in a checkerboard pattern, l
producing a honeycomb-type of structure. The cells'are welded to a base support assembly and to one another to form an integral l
structure, without the use of grids of the type employed for the I
Region 1 racks. The Region 2 storage racks, like the Region 1 j 1
racks, are provided with leveling pads connected to the base support assembly, which contact the pool floor /embedment plates,
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and which are remotely adjustable from above to level the rack j i
during installation. The racks are free-standing and are not ]
l anchored to the floor or braced to-the pool walls. Some of the j storage locations in some of the Region 2 racks also overhang their support pads. (Id., at 4).
- 7. In support of its amendment application, FPL provided the NRC with the results of an analysis which showed that lift-off of the storage racks would not occur during a seismic event. This analysis assumed that FPL would establish admin-istrative controls to prohibit the loading of overhanging rows of a rack while the remaining rows of the rack were empty. The NRC issued the Turkey Point spent fuel pool expansion amendments in l
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November 1984 on the basis that, with these administrative con-l trols.in place,-rack. lift-off would not occur. (Gouldy, ff. Tr. {
t 103, at 4).
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- 8. A restriction was added to the fuel movement proced-ure for Turkey Point which prevents loading of the overhanging rows while the remainder of the rack is empty. This procedure is '
. currently being used at Turkey Point. (Gouldy, ff Tr. 103, at 5-6). 14/.
- 9. In its testimony, the Licensee presented the results of a fuel rack seismic analysis which had been performed for two cases involving different assumptions regarding the loading pattern of fuel assemblies in the storage racks. Case 1 assumed that administrative controls are in place to prevent loading of 14/ This procedure prohibits the loading of spent fuel-into over-hanging rows if the remainder of the rack is empty.
Additionally, this procedure requires the preparation and use of a fuel handling data sheet which designates a specific location within a spent fuel rack for each spent fuel assem-bly (identified by number). The fuel handling data sheets are prepared with the aid of fuel status boards which contain diagrams of the reactor and the spent fuel pool that show-the locations of currently-stored fuel assemblies and the loca-tions where fuel assemblies may be placed. By assigning a specific location for each assembly, the fuel handling data sheet controls the loading of the racks and prevents the loading of assemblies into overhanging locations until after L fuel assemblies are placed into the other storage locations.
Prior to their use, the fuel handling' data sheets are subject to review and approval by the Plant Nuclear Safety Committee p to assure that, among other things, fuel assemblies are not
} placed into the overhanging rows of an empty rack. These l types of administrative controls are common in the nuclear industry and have been used successfully for loading assem-blies in spent fuel racks as well as loading fuel assemblies i into the reactor. (Gouldy ff. Tr. 103, at 5-6.) The Board L finds that this procedure is reasonable and provides an acceptable method for preventing loading of the overhanging rows while the remainder of the rack is empty.
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fuel assemblies into the overhanging locations until after assem-blies are loaded into the other storage locations. Case 2 is an analysis. performed by Westinghouse at the request of FPL, after NRC approval of the license amendments, to determine the potential effect of loading fuel assemblies into overhanging locations while the remainder of the fuel rack is empty. (Flanders, ff. Tr. 103, at 14).
- 10. The NRC Staff has identified criteria which it will accept for the performance of seismic analysis of spent fuel Standard Review Plan (SRP) Section 9.1.2 states storage racks.
that the storage racks should be designed to Seismic Category I requirements (i.e., able to withstand the effects of a Safe Shutdown Earthquake (SSE) and remain functional).Section III of the "OT Position for Review and Acceptance of Spent Fuel Storage and Handling Applications" (NRC Position Paper) identifies criteria for performing criticality analyses for spent fuel pools under accident conditions, and it states that the presence of soluble boron in the pool water may be taken into account when analyzing the effects of earthquakes. Also,Section IV of the NRC Position Paper identifies criteria for performing evaluations of the mechanical and structural integrity of spent fuel racks.
Among other things, these criteria state that compliance with the
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American Society of Mechanical Engineers (ASME) Code provides an acceptable basis for deriving allowable stresses in spent fuel racks, and that the design of the storage racks is acceptable if 1
the amplitudes of sliding motion are minimal, if impact between '
storage racks and the pool walls is prevented, and if the factors l
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e of safety.against tilting of the racks are within specified '
. values. LThe criteria discussed above are widely used in the-nuclearJindustry for performing seismic analyses of spent fuel racks, and they a're. recognized as being conservative. (14., at
'4-7).
- 11. The' Licensee's seismic analyses of the new spent fuel storage racks-for Turkey Point were performed in accordance with the'NRC Staff's criteria. The racks were designed in accord-ance with seismic Category I requirements.
The structural analy-sis of:the storage racks was based upon the allowable stresses of the-ASME Code, and the remainder of the mechanical and structural analysis'of the racks was performed in accordance'with Section IV
.of~the NRC Position Paper. (14., at 7-8).
- 12. More specifically, the Licensee's seismic analysis of the Turkey Point-spent fuel storage racks utilized the fol-inwing-conservative assumptions:
i o The maximum seismic. acceleration used-in the analyses was the design basis Safe Shutdown Earthquake (SSE) acceleration for the Turkey Point Plant specified'in the Updated Final Safety Analysis Report (FSAR) for Turkey Point.
-o The structural damping of the seismic acceleration provided.by the storage racks was consistent with
,,.n the value provided in the Updated FSAR for welded 4 steel frame structures, and damping provided by the spent fuel pool water was conservatively neglected.
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s o A range of coefficients o,f friction between the U
racks and the pool floor embedments were used which bounded the maximum possible rack horizontal displacement (sliding) and.the maximum rack hori-zontal overturning force (tilting).
o The storage racks were assumed to be hydrodynamic-cally coupled, thereby producing maximum'deflec-i tions, loads, and stresses for sliding or tilting.
o No loads on the racks were assumed.as a result of sloshing of the pool water during a seismic event, because such sloshing would occur in the upper elevations of the pool above the top of the racks.
(Id., at 8-11).
- 13. The Licensee's seismic analysis was performed in ;
two phases. The first phase employed a two-dimensional nonlinear model of an individual rack cell. The results of the first phase provided input to the second phase of the analysis, which employed a three-dimensional linear model for the purpose of calculating loads and stresses in the storage racks. Use of these two models i
enabled the Licensee to account for both the nonlinear and three- '
' dimensional responses of the storage racks. In particular, the model used in the first phase directly accounted for nonlineari- i ties and provided input for correcting the loads calculated by the linear model used in the second phase. Similarly, the model used
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in the-second phase provided three-dimensional response data for loads and stresses, and use of a two-dimensional model in phase
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- 1 one to calculate displacements was appropriate because each fuel assembly and storage cell is structurally symmetric about either the x or y horizon'al axis. (16., at 11-12).
- 14. This methodology was applied for both Case 1 and Case 2. The results of the analysis for Case 1, which considered full fuel loading (i.e., fuel assemblies in a.'l storage locations) and various partial loading conditions were as follows:
1 o The fuel rack support points did not lift off or lose contact with the floor of the spent fuel pool 1
when subjected to the specific seismic ground accelerations. The factor of safety against overturning was much greater than the 1.5 value specified by Section 3.8.5.II.5 of the Standard Review Plan.
o The maximum relative displacement of a fuel rack was calculated to be 0.256 inches (relative dis-placement accounts for sliding, structural, and thermal movement of two adjacent racks toward each other). The gap between adjacent fuel racks is 1.11 inches, and the gap betwuen a fuel rack and the spent fuel pool walls is even larger. Thus, impact between adjacent rack modules or between a rack module and the pool wall is prevented and the leveling screws will not slide off the embedment plates.
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e o The fuel. rack stresses are within ASME Code allowa-ble limits, i.e., the minimum ratio of allowable stress divided lby applied stress is greater than 1.
L The minimum ratios of allowable stress' divided by applied stress for the leveling pads, grid assem-blies, and cell assemblies, are 1.27, 1.15, and I 1.11, respectively. It should be noted that allowable stresses do not represent the point of material' failure, but are values which. include ,
conservatism inherent in the ASME Code.
2 Thus,:the results of the Case 1 analysis conform with the accept-
.ance criteria in the NRC Position' Paper and demonstrate that the spent fuel storage racks will be maintained in a safe configura- ;
tion during postulated seismic events. (Id., at 15-16).
- 15. - The Licensee also analyzed the potential effects of loading fuel assemblies into overhanging locations (Case 2). In Case 2, the models were1 adjusted'to account for the mass of the fuel in the overhanging rows, and the analysis was conducted for various partial fuel loading conditions with the appropriate i
seismic ground acceleration inputs. The results of the Case 2
, analysis were as follows:
o The rack module was predicted to rock and result in lift off of one side of the rack from the support point. The maximum lift off of 0.18 inches was produced by loading the three outboard rows on the side of the rack with the most overhanging storage l
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locations. Lift off of support points is not uncommon for freestanding racks under seismic conditions and the structural members of the racks ,
are designed to accommodate the stresses produced-
., by lift ~off. The lift off distance.was used in an overturn stability calculation, and it was shown that the rack is stable and will not overturn and that the minimum factor of safety against overturn is 8 (which is substantially greater than the 1.5 factor of safety against overturning recommended by Section 3.8.5.II.5 of the SRP).
o The maximum relative displacement of a fuel rack is 0.709 inches (relative displacement accounts for sliding, rocking, structural, and thermal movements of two adjacent racks toward each other). This is less than the gap between adjacent fuel racks and l
'I between the fuel racks and the spent fuel pool !
l walls. Thus, impact between adjacent rack modules '
or between a rack module and the pool wall is
_ prevented and the leveling screws will not slide 1
off the embedment plates.
o Structural loads and stresses are enveloped by the condition of a fully loaded rack. Thus, the maximum stresses produced by the partially loaded racks in Case 2 are less than the maximum stresses l
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calculated in Case 1. Therefore, the applied stresses in Case 2 are also within the ASME Code ;
I allowable stresses. (Id., at 16-17). l
- 16. . Thus, the results-of the Case 2 analysis conform with the acceptance criteria in the NRC Position Paper and demon- i i
strate that the spent-fuel storage racks will be maintained in a safe configuration during postulated seismic events. The Case'2 1
analysis demonstrates this to be true without administrative controls to assure _that spent fuel is not loaded into overhanging portions of the racks until other portions of the racks have been j i
filled. (Id., at 16-18).
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- 17. In its Safety Evaluation for issuance of the license amendments, the NRC Staff performed a review of the Licensee's Case 1 analysis and found that the analysis and its
'results were acceptable. The Staff review consisted of an evalua- l ti'on of the Licensee's description of the structural configuration i of the spent fuel racks and storage pool, load combinations, )
l calculations including rack response to an earthquake, resultant {
stresses in the rack, and comparison of final stresses with
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allowable stress limits prescribed in the NRC Position Paper. The NRC Staff concluded that design of the racks satisfied the structural aspects of the requirements of 10 C.F.R. Part 50. The NRC Staff conclusion was based on the fact that (a) the Licensee ]
considered all the required loading conditions including earth- 1 i
i quakes and accidents; (b) the analysis methods that calculate j stresses and earthquake response were in accordance with industry
practice; and (c) the resultant stresses and overturning safety factors satisfied the allowable limits specified in the NRC Position Paper. (NRC Staff Exh. 1; Kim, ff. Tr. 129, at 5-6).
- 18. Prior to the hearings, the Staff also evaluated Licensee's Case 2 seismic analysis. Based upon this evaluation, the Staff found that the fuel rack stresses would be within ASME Code' limits, the safety factors against overturning are accepta-ble, and the total displacement due to seismic motion and thermal growth would be less than the gap between the fuel racks. Thus, I
~the Staff concluded that the rack design satisfies the structural aspects of the NRC acceptance criteria and that there is reasona- I ble assurance of safe storage of the fuel in the event of an i earthquake. The Staff also concluded that the administrative controls on fuel loading are not necessary. (Kim, ff. Tr. 129, at 12-13).
- 19. During the hearings, Interveners implied that FPL should be prohibited from possibly using 10 C.F.R. S 50.59 in the future to eliminate administrative controls on the loading of fuel J l
assemblies into the storage racks. (Egg, e.a., Tr. 133-146).
Interveners' arguments appear to be based, at least in part, on the' supposition that FPL would not correctly apply the provisions of the section. Interveners presented no evidence in support of l these arguments. In any case, Interveners' arguments essentially constitute a challenge to the Commission's regulations, and the
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l Licensing Board,has no authority to prohibit FPL from utilizing the provisions of a regulation promulgated by the Commission.
Therefore, Interveners' arguments must be rejected.
- 20. Based'on the evidence presented, the Board con-cludes that Licensee's seismic analysis for the new Turkey Point
, spent. fuel pool. racks, and the results of those analyses, comply
-with applicable NRC criteria. In particular, the results of the I Case 2 analysis demonstrate that, even if fuel assemblies are loaded in overhanging rows while the remainder of the racks are empty, the resulting configuration would still meet NRC acceptance criteria. Based on those results, the Board concludes that the design of the' racks is acceptable for all loadi ng conditions and that it is unnecessary to impose a license condition requiring FPL to utilize administrative controls which regulate the loading of spent fuel assemblies into the storage racks.
B. CONTENTION 6
- 21. Contention 6 states:
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The Licensee and Staff have not adequately considered or analyzed materials deterioration or failure-in materials integrity resulting from the increased generation'and heat and i radioactivity, as a result of increased J capacity and long term storage, in the spent fuel pool.
The bases for the contention are as follows:
The spent fuel facility at Turkey Point was originally designed to store a lesser amount of fuel for a short period of time. Some of the problems that have not been analyzed properly are:
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1 (a) deterioration of fuel cladding as a result of increased exposure and decay i heat and radiation levels during extended I periods of pool storage. 4 (b) loss of-materials integrity of storage ;
rack and pool liner as a. result of ;
exposure to' higher levels.of radiation 1 over. longer periods. ,
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(c) deterioration of concrete pool structure 1 as a. result of exposure to increased heat over extended periods of time.
In' admitting Contention 6 for litigation, the Licensing Board I
limited the phrase "long term storage" to the storage period i authorized by'the amendments. Florida Power and Licht Co. (Turkey Point Nuclear Generating Plant, Units 3 and 4), LBP-85-36, 22 NRC 590,.598 (1985).-
- 22. In its Memorandum and Order denying-the Licensee's motion for summary disposition of Contention 6, the Licensing j i
Board requested that the parties " address the' matter of the. modes !
4 and. effectiveness of surveillance of materials and the monitoring (
of the' fuel storage pool and contents to provide a measured basis A for safety during the extended period of use." Florida Power and Licht Co. (Turkey Point Nuclear Power Generating Plant, Units 3 ]
and 4), slip op. at 33 (March 25, 1987).
i Qualifications of Licensee and-Staff Witnesses
- 23. The Licensee provided two witness panels to address contention 6. These panels consisted of (1) William C. Hopkins
,and Eugene W. Thomas from Bechtel Eastern Power Company (Bechtel),
and (2) Russell Gouldy from FPL and William A. Boyd and Dr. Gerald l-L l L l l l 1 __-__-____-___-__a
l.
L to:
R, % . . 22 -
1 i
i i
I R..Kilp from Westinghouse.
i The Licensee's' witnesses have exten- :
sive experience regarding the integrity of the materials in the !
spent fuel pool, as indicated by the following: ;
o Mr. Hopkins addressed the impacts of radiation on !
l the spent-fuel pool liner and concrete structure. !
He has 16 years experience with Bechtel as a '
Nuclear Engineer engaged in the analysis of opera-tion of plant systems in radiation environments. ;
(Hopkins, ff. Tr. 163, at 9-10).
o Mr. Thomas addressed the impacts of heat on the sper.' fuel pool liner and concrete structure. He is an Assistant Chief Civil Engineer for Bechtel and has over 23 years engineering experience.
Since joining Bechtel, Mr.. Thomas has over 17 years
, experience as a civil engineer in the design and seismic qualification of fossil and nuclear power 3
, plants. (Thomas, ff. Tr. 163, at 12-14),
o Mr. Boyd addressed the impacts on K-effective of postulated gaps in the Boraflex poison material 15/
in the spent fuel racks. Mr. Boyd obtained a masters degree in Nuclear Engineering from the i
Massachusetts Institute of Technology and has over 10 years of nuclear engineering experience. Since joining Westinghouse, Mr. Boyd has had respon-t sibilities for the design of the reload for nuclear 15/ Egg 5 66 for a description of Boraflex.
i
. 4 i
.s - i I
reactor cores at Turkey Point and the development
]
and coordination of methods used to perform fuel rack and. shipping container criticality analyses i
for the Nuclear Fuels Division of Westinghouse.
]
(Boyd, ff. Tr. 222, at 10-11).
o Mr. Gouldy. addressed the potential for degradation of Boraflex and FPL's surveillance program for Boraflex. Mr. Gouldy:has over 10 years of ,
engineering experience. Among other things, he was a shift technical advisor and licensed senior-reactor operator for the Turkey Point Plant, and he represents FPL on the Electric Power Research l Institute (EPRI) committee on Boraflex. '(Kilp and Gouldy, ff. Tr. 222, at 48-49).
o Dr. Kilp addressed the integrity of the materials in the fuel assemblies and storage racks. He has over 30 years experience in the evaluation of nuclear reactor materials and has been responsible for the research, development and deployment of materials in Westinghouse pressurized water reac-tors and the selection and evaluation of materials to be used in the long term storage of light water reactor fuel. Dr. Kilp is currently responsible l for selected materials development programs and L
l L__
acts as.an advisor on materials performance ques-tions for: Westinghouse Nuclear Fuels Division. ;
(Id., at 45-47).
- 2 4 '. "The NRC called four witnesses to address Contention 6: David Sellers,-Lawrence I. Kopp, Conrad E. McCracken and James
' Wing. These. witnesses have extensive experience regarding the integrity of materials in the spent fuel pool, as indicated by the sfollowing:
o Mr. Sellers addressed the materials integrity of the fuel assemblies, the stainless steel storage racks, and the concrete pool and pool liner. He has over 36 years experience in metallurgy, and 25 of.those years involved.the analysislof particular materials problems caused by radiation exposure. ..
In the last 15 years, Mr. Sellers has been employed by the NRC where he has been involved:in the review and evaluation of the safety of materials used in the construction and. maintenance of nuclear power plants. (Sellers, ff. Tr. 188, at 15-16).
o Dr. Kopp addressed the impacts on K-effective of postulated degradation of the BoraflexLpoison material. He has over 28 years nuclear experience.
His duties at NRC have included the safety evalua-tions of reactor core designs and criticality analyses of fresh and spent fuel storage racks.
(Wing, McCracken, and Kopp, ff. Tr. 339, at 23).
i
( ;
j 1
w o Dr. Wing addressed the materials-integrity of Boraflex. He has been a practicing chemist for over.32 years. In the last 15 years, Dr. Wing has i
been employed at the NRC where his duties have included' independent assessments of the compati-
-bility and corrosion potential of materials. (Id., ,
I at 21).
o Mr. McCracken also addressed the materials integ-
-rity of Boraflex. He has over 29 years experience in chemistry, corrosion and mechanical systems operation. Since joining the NRC in 1981, his l i
duties have included the evaluation of materials compatibility and degradation issues at both operating plants and plants in the licensing ,
process.- He is currently responsible for the evaluation of all PWR's for compliance with chemi- 4 cal and corrosion requirements of the Commission ;
and independent studies in material compatibility for spent fuel pool components and materials of ,
nuclear power plants. (14., at 22).
- 25. The Licensing Board finds that the Licensee's and NRC Staff's witnesses are well qualified to address the issues raised by contention 6.
l l
r
Materials in the Turkev Point Soent Fuel Pools
- 26. The components in the spent fuel pool consist of a steel-reinforced concrete pool structure with a 1/4" thick Type '
304 stainless steel pool liner; fuel assemblies composed of Inconel, Type 304 stainless steel and,Zircaloy; stainless steel storage racks; and Boraflex as a neutron absorbing material in the fuel storage racks. (Kilp and Gouldy, ff. Tr. 222, at 4).
Heat and Radiation Levels in the Soent Fuel Poolg
- 27. Calculations were performed by the Licensee to determine'the heat and radiation. loads which will be present in the spent fuel pools following the reracking. Under normal operations, temperatures in the pools are not expected to exceed 143 F and will usually be less. This temperature represents only a slight increase over the 127 F maximum temperature which was predicted to occur under normal conditions' prior to the spent fuel i
pool expansion. The maximum temperatures during abnormal condi-l tions could approach boiling. (14., at 4-5) j
- 28. Four types of radiation (alpha, beta, gamma and neutron) will be present in varying degrees in the spent fuel l pool. For the types of structural materials in the spent fuel pool (concrete, stainless steel, Inconel, and Zircaloy), alpha and beta radiation are not a concern because these types of radiation !
do not have the ability to penetrate these materials deeply enough to appreciably affect their structural integrity. (14., at 5).
, 8-l 27 - l
- 29. Cumulative radiation doses in the spent fuel pool are dependent upon the burn-up of the. spent fuel stored in the !
pool. The average burn-up for any individual core off-load varies i
and, to date, has been less 36,000 Negawatt-days per metric ton of uranium (mwd /MTU) at Turkey Point.
~
For example, core off-loads at !
Turkey Point Unit 3 have ranged between 15,000 mwd /MTU and 32,000 mwd /MTU, and the average of all the off-loads is less'than 29,000 mwd /MTU. FPL is considering increasing its fuel burn-up beginning with Cycle 12'in 1988. As a result, the average burn-up for an !
individual core off-load may become as high as 42,000-45,000 mwd /MTU; individual fuel assemblies may have burn-ups as high as I 50,000 mwd /MTU. FPL has no plans to increase the burn-up of its fuel to above an average of 45,000 mwd /MTU for any single core off-load. (Id., at 5-8). ;
- 30. The Licensee performed two sets of calculations to determine the cumulative gamma and neutron exposures of materials present in the Turkey Point spent fuel pool over 40 years. One l set of calculations assumed that each fuel assembly in the pool has an average burn-up level of 36,000 mwd /MTU, which.is conser-vative based upon the fuel assemblies currently stored at Turkey i Point. The second set assumed that each fuel assembly in the pool has an average burn-up level of 55,000 mwd /MTU, which is conser-vative based upon the maximum expected burn-up of the fuel assem-blies~at Turkey Point. Each set of calculations conservatively assumed an infinite array of stored fuel assemblies. (Id., at 5-10). l i
r m_._.___________
n
,p - 28.-
1
- 31. Using the assumptions described above, Licensee I calculated that materials in the spent fuel pool would receive cumulative gamma and neutron radiation doses as follows: j Tvoe'of Radiation Assumed Average Burn-u_o .40-Year Dose Gamma 36,000 mwd /MTU 10 1.9x10 rads 55,000 Mwd /MTU 10 2.9x10 rads 1
Neutron 36,000 mwd /MTU 13 2 4.8x10 n/cm 55,000_ mwd /MTU 14 2 1.7x10 n/cm g (14.). ,
Effects of Heat and Radiation on the Spent- !
Fuel Pool Struc.ture and' Liner 1 i
- 32. The generation of heat in the spent fuel pool-raises two potential concerns regarding the integrity of the concrete pool structure and pool liner. First, thermal stresses may be induced as a result'of the temperature differential between the pool _ water and ambient conditions. Second, the temperature of the concrete structure and pool liner may affect their materials integrity. (Thomas, ff. Tr. 163, at 4).
- 33. To determine the effects of thermal stresses on the I pool structure, Licensee evaluated the heat load carrying capacity of the pool structure through a detailed computer analysis. The pool structure was mathematically modeled as a large number of solid finite elements with sufficient detail to accurately capture the response to the heat load. All loads imposed on the structure I
i i
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i Q fil W 1
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, . were c considered, including the effect of heat from the pool water c . .
u as'wellias.the postulated extreme environmental ~ conditions y
addressed in the' original licensing documents. (14., at 4-5). '
,34. :! Licensee's.- analysis assumed pool watsr/ temperatures up.to 212 FL(boiling)L which is-the maximum temperature the pool; water-could; approach'during1 normal or abnormal ~ conditions.. Since the .most severe loads 1x1 the~ structure are due to heat loads ,
1 l
Lcaused- by temperature. gradients :( f .e. . large temperature. differ-
.q , , .encesion' opposite sides =of?the. pool. walls), the-ambient tempera-iture outside thefpoolswas acs'umed to be'as low as 30 F,Lresulting; l
t -i 0
-in a gradient +oUias-much'as 182 F through the wall thipkness for. ~j
~
- analytical purposes. lThe~30 F tem'perature specified on the outside?surfacdI of"the pool is extremely conserva(ive.for the site ~ ~
environment of southern Florida. .(.1d., at 5-6). 1 1
- 35. The loads 1 generated by-the.comput'er analysis were.
1
\
' converted intofreinforcing steel and. concrete stresses at.various
. critical' locations en~eachLof,the walls;and the floor. These
- stresses lwereishown to-be within the licensing conditions imposed
.on the original, design as. identified;in.the[ Turkey Point Units 3 .
l and 4, " Updated. Final Safety Analysis Report," Appendix 5A.
Further, the, analysis showed tha't the pool would Waintain its .I L
.st'ructural integrity even'under severe thermal stress conditions
.offpostulated boiling' water. combined with the effects of the i
design basis earthquake. This analysis conservatively assumed j i
'thatLthe pool's' steel liner plate would not provide structural
.1-capacity to-the pool' structure. (14., at 6).
k~ __________n .i.i________.___ - -
1
--30 -. !
t W I-
.3 6. . The? Licensee, also: performed an analysis to deter-mine the' effects of thermal, hydrostatic and hydrodynamic loads on Lthe liner plate system.
This analysis reviewed?the buckling _
potential.of-the. liner plate, as well as stresses in. welds and
. embedded metal = associated with the liner system. The analysis
, considered the: thermal and mechanical. effects of the. increased
. spent fuel; pool capacity for. normal, abnormal and postulated
-boiling water 1 conditions,.-in~ conjunction'with postulated accident
-conditions as specified in the Updated Final Safety Analysis
. Report. The results of the analysis demonstrate that the pool structure and liner; plate meet theforiginal licensing acceptance.
condit' ions and maintain their' structural integrity under all
. postulated ~ conditions. -(M. , at 6-7 ) .
'37. The NRC Staff and its' consultant, Franklin Research
- Ceriter, reviewed Licensee's~ analysis of the temperature-induced
. stresses on the pool structure and liner'and concluded that the stresses.were' acceptable. (NRC Staff Exh.'l (Safety Evaluation at 10; Technical Evaluation Report at 25-26)).
- 38. - The concrete and reinforcing steel of the spent fuel pool are capable of maintaining their integrity, durability and.long-term stability under the thermal environment imposed by the increased pool capacity. For concrete materials, such as those in the~ Turkey Point spent fuel pool structure, which have
' met the minimum requirements of the' controlling ASTM standards and l
4 i
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1
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-( e j
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. (/ 4
/
.c arecombinedinaccordancewithapprdpribt[eACIguidelines, temperatures below approximately 300 F have an insignificant i
effect on their properties. (Thomas, ff. Tr.
163,at}).
- 39. Free, water, which is the result of excesp water in ,
the wet concrete mix which is not utilized ik,the hydratian
)
l l ,,
//
'/ /
process, can be a concord' for some structuress witih temperatures 3 above approximately 200 F. However, in the case of the Turkey
/
/ / ,
Point spent fuel pool concrete struct re r more than adequate time (the plant has been its operatior, for/ ore b than a dozen y' ears) hasi been available for any free water, which was nc't utilized in the hydration process, to egress. Therel' ore, f ree water does not present a concern with regpectEto the con 6 rete pool structures at f Turkey Point, 6.n these structures will not be adversely a$fected by the heat 1 vels expected in the spent fuel pools. ( M ., at y 9-10). et
/ t . , l'
- 40. The re'jnforcintj steel in the concrete structure is similar to ot r steels in that it maintains its integrity sad stability at t' temperatures far above that which will be experienced by the pool structure. Consequently, any'reducri n'in strength of the reinforcing steel as a result of the heat loads., experienced in l the sp1nt fuel pool will be insignificant. ( M. , a t 10 ) .
1 l
- 41. The stainless steel spent fuel pool liner will be
) /
similarly unagfected.by jhe levels of heat which could occur in the Turkey Poibd speri fuel pool. ,The liner plate is made from A-240 Type 304sthinlesssteel. Stainless ateel maintains its integrity and long-term stabilit'y' for temperatures in excess of l
/
) '
P M.-
.g, - l
,, < 1
' 0 1000 F, which'is far above the, temperatures expected in the spent f u e l5 p o o l'. Reductions in' strength.may occur-with increased. steel ;
1 temperature; however, for.the temperatures under consideration' d 0
T(212 F:and less), no appreciable reduction occurs.. (14., at 8).
1
- 42. Stress' corrosion cracking of sensitized steels ]
Ladjacent to welds in the spent' fuel pool liner is a possibility.
However, should it' occur, it would be highly localized and would j l
notilead to gro'ss degradation of the liner. Furthermore, stress j corrosion: of the stainless steel-liner is: effectively. prevented at i
-Turkey. Point by.FPL's controls'on chloride levels in the fuel
]
pools. -(Sellers, ff. Tr. 188, at 6-7).
- 43. Licensee and NRC' Staff witnesses also testified
' that: the Turkey Point spent. fuel pool-expansion would not result in' deterioration of the spent 1 fuel pool concrete structure and liner due'to radiation.. Concrete is used throughout a nuclear
. plant for its structural support and radiation shielding charac-teristics'. Gamma-radiation has a negligible effect on the mechan-ical properties of concrete. A concrete structure can also withstand neutron fluences up to 10 21 n/cm 2 without loss of l
-material integrity, which is many orders of magnitude higher than ;
the fluence expected in the Turkey Point spent fuel pool. Reports on theLirradiation of concrete have-not identified any defects in concrete which'can be directly traced to direct radiation damage.
The effect-of nuclear heating on concrete is negligible for the radiation levels incident to the Turkey Point spent fuel pool I
1 structure. 'In addition, the use of concrete in spent fuel pc-1s
h.
p i
and-the dismantling of.many concrete structures used as shielding !
I have not_ produced any evidence of degradation due to radiation or radiation heating. Consequently, no material deterioration or loss in integrity of the concrete fuel pool structure will result !
l from the'long-term radiation exposure.to discharged fuel assem- j l
blies in'the spent fuel pool. (Hopkins, ff. Tr. 163, at 5-7; i Sellers, ff. Tr. 188, at 10, 13-14; Tr. 212-14.)
1
- 44. Licensee and NRC Staff witnesses also testified as to.the effects of radiation on the stainless steel pool liner. l Gammr radiation, which is the predominant source of radiation in the spent fuel pool, has a negligible effect on the mechanical properties of stainless steel through direct radiation damage mechanisms. Neutron irradiation tests have shown that stainless steel can withstand neutron radiation levels which are orders of magnitude higher than those predicted in the Turkey Point spent fuel pools without loss of integrity from direct radiation damage.
The effect of nuclear ~ heating on stainless steel is negligible at !
I the levels of radiation which will be present in the spent fuel l 1
pool. (Hopkins, ff. Tr. 163, at 3-5, 7; Sellers, ff. Tr. 188, at 5).
- 45. Based upon the evidence presented by the NRC Staff i and Licensee, the Licensing Board finds that the heat-induced stresses in the Turkey Point spent fuel pool concrete structures and stainless steel liners will be acceptable, and that the i
!ll
L i 1
1' l
temperature and radiation levels in the spent fuel pool will not result in any loss of integrity or degradation of the concrete pool structure or stainless steel pool liner.
- 46. The evidence reflects that Turkey Point does not have a materials surveillance program for the spent fuel pool concrete structures and stainless steel liners. Surveillance, as j used in the context of materials engineering, means the installa-i tion of specially prepared test specimens which are removable for l 4
testing after exposure to an environment which may degrade certain material' properties. In this narrow context, no surveillance program for materials in the Turkey Point fuel pools is provided ;
or is necessary. The Turkey Point spent fuel pools were designed and licensed to store fuel for the lifetime of the plant. As noted above, the heat and radiation levels which will be present in the pools are well below levels which would result in any significant deterioration in the spent fuel pool concrete structure or stainless steel liner. In fact, there are several 1 nuclear plants with spent fuel pools that have been used for five to ten years longer than Turkey Point without any reports of materials degradation due to radiation. The witnesses testified that, to their knowledge, no utilities had such materials surveillance programs for concrete pool structures and liners.
(Hopkins, ff. Tr. 163, at 7-8; Thomas, ff. Tr. 163, at 10-11; Sellers, ff Tr. 188, at 12; Tr. 173, 206-207).
-e l
1 i
- 47. In the broad (dictionary) sense, the Turkey Point j l
spent fuel pool' materials are subject to surveillance, including i monitoring of the spent fuel pool building atmosphere'.for radia-tion, monitoring of the spent fuel pool water for chemistry and l
radiation, and routine visual underwater surveillance of the spent i fuel and storage racks. Additionally, the Turkey Point spent fuel pools have a leakage detection and collection system, which includes a monitoring trench behind the liner. If the liner were f to deteriorate and develop a leak, the leakage would be collected k s
in the monitoring trench and would be retained there until plant personnel open valves in the system to direct the leakage-to a waste disposal system. This system is currently operational, and procedures require.a daily check of the leakage collection and detection system to determine whether there has been any leakage i
from the spent fuel pools. The routine surveillance or monitoring is adequate to assure the safety _of the spent fuel pools and their controls over long periods of time.- (Kilp and Gouldy, ff. Tr. !
222, at 43; Sellers, ff. Tr. 188, at 12-13; Tr. 208-209, 301). {
- 48. Based upon the evidence presented by the NRC Staff
.and the Licensee, the Licensing Board agrees that FPL's monitoring
_ programs are reasonable and acceptable for assuring the integrity i of the Turkey Point concrete pool structures and stainless steel
. liners, and that no other materials surveillance program is warranted for the structures and liners.
r-r , ,
L r l
l: ;,. l j Effects of Heat and Radiation on the Fuel Assemblies ;
- 49. The' fuel assemblies in the. Turkey Point spent. fuel pools are composed of.Inconel, Type 304 stainless steel, and Zircaloy. These fuel assemblies were designed to withstand the temperatures and heat loads present during operation of the Turkey Point' reactors, which are far more severe than those present in
.the spent fuel pools. (Id., at 10-11). j l
- 50. Neutrons are the cause of virtually all the irradi-ation induced changes in Zircaloy, Inconel, and the. stainless ,
d steel used for the fuel assemblies. These materials are essen-tially unaffected by the alpha,' beta, and gamma radiation, which comprise the major fraction of the radiation in the spent fuel l pool. In particular, although gamma radiation is a penetrating radiation, its primary effect on these materials is heating and not structural damage at the levels of radiation: expected in the Turkey Point spent ~ fuel pools. (Jd., at 11-12).
- 51. The neutron fluence levels that the fuel assem-blies, including the Zircaloy cladding, are subject to during storage in a spent fuel pool are orders of magnitude lower than those which the assemblies and cladding experience when exposed in a reactor _during full power operation. Specifically, the total 22 neutron fluence exposure of the cladding is approximately 10 2 14 neutrons /cm while in the reactor, compared to about 1.7 x 10 2
neutrons /cm during a forty-year exposure in the spent fuel pool (assuming storage of fuel with burn-up of 55,000 mwd /MTU). The difference is approximately 8 orders of magnitude. Put another !
l i
way, the cumulative radiation dose that the fuel assemblies would receive during 40 years in the spent fuel pool is approximately equal to the dose received during one second in the reactor operating at full power. The Licensee and the NRC Staff deter-mined that the neutron radiation levels in the spent fuel pool will have an insignificant impact on the integrity of the fuel assemblies and the fuel cladding. (Id., at 10-12, 15-16; Sellers, ff. Tr. 188, at 11-12; Tr. 211-12).
- 52. The only realistic threats to fuel rod cladding integrity during storage in the spent fuel pool are stress corro-sion and hydriding. However, the zirconium used in the Zircaloy cladding is considered immune to stress corrosion cracking in water environments like the spent fuel pool. Thus, corrosion is not expected to have any appreciable impact upon the structural integrity of the Zircaloy cladding. Hydriding, which at very high levels can lead to embrittlement of the cladding, is a direct function of cladding corrosion in a water environment. Since the )
corrosion rate is virtually nil, hydriding in the spent fuel pool will be nil also. (Kilp and Gouldy, ff. Tr. 222, at 12-14. Sgg also Sellers, ff. Tr. 188, at 5-6; Tr. 235-236).
- 53. Similar conclusions may be made regarding other fuel assembly components (stainless steel and Inconel) which mechanically support the fuel rods. All of these materials have I
been shown by test and experience to be virtually immune to ]
corrosion at spent fuel pool temperatures. For example, it has i
been estimated that the corrosion of Type 304 stainless steel will
]
l l
1
+ ,.
not exceed 6/10,000 inches for one hundred years in an oxygenated borated water environment similar to that in the Turkey Point _j spent' fuel pools. Corrosion rates for Inconel are at least as low as those-for-stainless steel. Additionally, since stainless j steel, Inconel and Zircaloy all form protective oxide' films, no significant. galvanic attack is expected among these materials.
(Id.; Tr. 193-94, 214-215). i
- 54. Convincing evidence that fuel assemblies will not deteriorate in the spent fuel pools comes from actual experience.
Visual observations and radiation monitoring of pool water have demonstrated that spent fuel has been stored safely for more than !
J two decades. The results of a number of hot cell examinations on fuel. stored for more than ten years show no measurable changes due to corrosion or hydriding and no loss of. fuel integrity. There is I i
no evidence that Zircaloy-clad fuel or stainless steel structural elements' degrade significantly during wet storage, as demonstrated i
by continuous storage of fuel elements for as many as 25 years.
This experience includes storage of assemblies with high burn-ups. )
1 In short, wet storage of spent fuel is a fully-developed technol-ogy with no associated major technological problems. (Kilp and I Gouldy, ff. Tr. 222, at 14-17; Sellers, ff. Tr. 188, at 4, 11-12; l Tr. 195). .j
- 55. The Commission has concluded that sper.t fuel can be i safely stored at a reactor's spent fuel storage pool for at least thirty years beyond the expiration of that reactor's operating license. In particular, the Commission found that the cladding
- _ _ _ _ _ I
i ,.
r which encases spent fuel is highly resistant to fuel failure'under pool storage conditions and that corrosion would have a negligible effect during several decades of extended storage. Rulemakina On 1
The Storace And Disposal Of Nuclear Waste (Waste Confidence Rulemaking), CLI-84-15, 20 NRC 288, 353-7, 366 (1984).
j
- 56. During the hearings, Interveners argued that the j spent fuel pool expansion amendments'should not be issued because' conclusions regarding the materials integrity of the spent fuel assemblies are based upon scientific assumption and engineering j i
judgment and not upon actual experience with storage of spent fuel j for.40 years. (E a., Tr. 93). A similar argument was raised in the Waste Confidence Rulemakina and was rejected by the i Commission. Although the Commission agreed that conclusions regarding the integrity of spent fuel assemblies during long term storage were based on extrapolation of existing experience, the Commission stated that "the extrapolation is made for conditions l in which corrosion mechanisms are well understood" and that "this extrapolation is reasonable and is consistent with structural engineering practice." Waste Confidence Rulemakina, 20 NRC at 356-57. The Licensing Board similarly rejects the arguments raised by Interveners.
- 57. Based on the evidence submitted by the Staff and Licensee, the Licensing Board concludes that no significant deterioration of the materials in the fuel assemblies will occur j l
as a result of corrosion, hydriding or exposure to radiation.
I
i
- 58. Turkey Point has no materials surveillance program
~
for the spent fuel assemblies' stored in the spent fuel pools. I Licensee's and NRC Staff's witnesses testified that.such a program r is not warranted. Spent fuel assembly failure is not expected given the relatively low levels of radiation and heat in the spent
~
~ fuel pool, the ability of the fuel assembly to withstand radiation-and heat, and industry experience with wet storage of spent fuel.
Finally, even if it is unrealistically assumedithat all spent fuel- I assemblies were to fail simultaneously, the resulting. doses would be well within the guidelines of 10 CFR Part 100 for offsite radiation doses. Although' Turkey Point does not have a materials surveillance program for spent fuel, it does have two different radiation monitors'which will identify increased radiation levels in'the' spent fuel pools if radioactivity were released into the pools as a result of a pin hole leak of the cladding of a' spent fuel rod. These monitors are the area radiation monitor located o on the wall in each spent fuel pool area and the' radiation monitor located in the spent fuel pool exhaust vent, both of which are operational. If these monitors detect a significant increase in radiation levels, operating procedures require FPL to perform a radiation survey of the entire spent fuel pool area and, if i
warranted based upon the results of the survey, to determine j whether there has been any increase in the radioactivity in the i
spent fuel pool water. The NRC Staff concluded that the current l programs for monitoring the materials in the Turkey Point spent j 1
fuel pools are adequate to assure the safety of the spent fuel '
l i
pool and its contents during the period of storage authorized by the spent fuel pool expansion amendments. (Kilp and Gouldy, ff.
Tr. 222, at 17-19; Sellers, ff. Tr. 188, at 12-13; Tr. 208-209, 239). 16/
- 59. Based upon the evidence pr(Jented by the Licensee and NRC Staff, the Licensing Board finds that existing monitoring programs are reasonable and sufficient for monitoring the integ-I rity of the spent fuel assemblies. No further surveillance 1
)
programs to monitor fuel assembly materials integrity are warranted.
Effects of Heat, Radiation and Corrosion on the Stainless Steel in the Storace Racks
- 60. The new spent fuel pool storage racks at Turkey Point are constructed of stainless steel. The stainless steel in the Turkey Point storage racks can be used in the spent fuel pools for the period authorized by the spent fuel pool expansion amend-ments without appreciable deterioration. The temperature levels that the spent fuel storage racks will encounter in the spent fuel pools will not result in stainless steel material deterioration.
Stainless steel is essentially unaffected by gamma radiation, j 16/ In its Memorandum and Order of March 25, 1987, the Licensing l Board quoted from an article by A.B. Johnson regarding sur- l veillance programs for spent fuel assemblies to determine i whether any slow degradation mechanisms may exist. In context, it is clear that Johnson did not expect corrosion of -
fuel assemblies to occur, and that he did not believe it is justified to requ' e each spent fuel pool operator to establish a mater. . surveillance program for spent fuel assemblies. (Fz r and Gouldy, ff. Tr. 222, at 19-20).
Furthermore, h are ongoing industry surveillance programs which look for .o possibility of slow degradation, and such degradation has not been observed. (Tr. 192, 237-38).
l I
Similarly, the neutron. radiation levels in the spent fuel pool are I orders of magnitude below those levels sufficient to produce'any appreciable impact on the structural integrity of stainless steel.
- (Kilp and~Gouldy, ff. Tr. 222, at 20-22; Sellers, ff. Tr. 188, at 5-7, 13-14).
- 61. Stainless steel has been shown by test and experi- !
ence to be virtually immune to corrosion at spent fuel pool -
Temperatures. As discussed above, it has been estimated that the corrosion of Type 304 stainless steel will not exceed 6/10,000 inches for one hundred years in an oxygenated borated water environment similar to that in the Turkey Point spent fuel pool.
Additionally, since stainless steel forms a protective oxide, no significant galvanic attack is expected to occur. Additionally, ,
stress corrosion is not expected given FPL's controls on chloride i
. levels in the spent fuel pools. (M. )
{
- 62. No service-induced defects have been observed in l
spent fuel storage racks that have been removed from plants j 1
involved in reracking programs. Both the IN O Staf f 's and the Licensee's witnesses concluded that no significant corrosion of the stainless steel storage racks is likely to occur. (M. )
- 63. Based on the evidence presented by the Staff and Licensee, the Licensing Board finds that the spent fuel pool expansion will not result in material degradation or loss of integrity of the stainless steel in new fuel racks.
I 4 L i
- 64. FPL has no materials surveillance program for the' stainless steel in the spent fuel pool storage racks. Licensee's witnesses. concluded that such a program is unnecessary. The levels'of radiation and heat which will be present in the Turkey Point. spent fuel pool are'far below the levels which would cause any= appreciable effect on the stainless steel. The type of stainless steel in the spent fuel racks has a demonstrated ability to withstand radiation and heat for long periods of time beyond what would be expected in the Turkey. Point spent fuel pools. ;
Surveillance programs are typically not used to monitor spent fuel-pool storage rack materials. (Id.)
- 65. Based upon the evidence presented by the Staff and
- Licensee, the Licensing Board finds that a material surveillance i
program for the stainless steel storage racks is not-warranted. ;
i Effects of Heat, Radiation, and Corrosion.
on the Boraflex Poison Material
- 66. Boraflex is a neutron absorbing material, or poison, used in the spent fuel storage racks. Boraflex is made by
, uniformly dispersing fine particles of boron carbide in a homogen-ous, stable matrix of a methylated polysiloxane elastomer (a l
polymer). (Kilp and Gouldy, ff. Tr. 222, at 23). The geometrical configuration of the racks, boron in the spent fuel pool water, and the use of Boraflex or other poison material in the racks are independent methods of preventing spent fuel pools from becoming l
critical. (Tr. 330-33). i i
1 l
l
1
- 67. There are two regions in the Turkey Point spent q fuel pools.- The Region 1 racks are designed to hold fuel assem-blies with a maximum enrichment of 4.5%. The Region 2 racks are !
designed to hold fuel assemblies with a maximum reactivity equiva-lent to the reactivity of assemblies having an initial enrichment )
of 1.5%. The Region 1 spent fuel storage rack modules at Turkey Point-are each composed of a number of cells with Boraflex panels ,
I which run along the length of each of the four sides of the cell. !
The Region 2 rack modules have a somewhat similar structure, but spacing between individual cells is smaller and the density of the !
Boraflex panels is lower than in the Region 1 racks (Boron-10 l
i areal density of 0.02 gm/cm 2 for Region 1 versus 0.012 gm/cm 2 for Region 2).- (Boyd, ff. Tr. 222, at 4-5). i
- 68. Boraflex has undergone extensive testing to evalu- ;
ate its ability to withstand the effects of gamma and neutron
' irradiation in various environments and to verify its structural i integrity and suitability as a-neutron absorbing material. In tests performed at the University of Michigan, Boraflex was !
1 exposed to 1.03 x 10 11 rads of gamma radiation and a total neutron l
20 2 fluence of 10 neutrons /cm in borated water. These doses are substantially higher than the cumulative doses of 2.9 x 10 10 rads of gamma radiation and 1.7 x 10 14 neutrons /cm 2 which would occur i
in the Turkey Poirit spent fuel pool under the extremely conserva-
- tive assumption that the fuel used in the core had an average burn-up of 55,000 mwd /MTU. These tests indicate that Boraflex maintains its neutron attenuation capabilities after being
g_ -- . -
s -t
.e' Z
subjected to'an. environment of borated water and these radiation doses. 1Long term' borated water soak tests at high temperatures !
were also conducted.- -In'these later tests,'Boraflex maintained its functional performance characteristics and showed no evidence j
~\
of swelling or loss of ability to maintain a uniform distribution of boron carbide. (Kilp and Gouldy, ff. Tr. 222, at 23-24; Wing, McCracken'and Kopp, ff. Tr. 339, at 4-5; NRC Staff Exh. 1 (Safety Evaluation at 7)). ,
- 69. Boraflex has been used in spent fuel racks for several plants, including Point Beach, Quad Cities, and Prairie Island. (Kilp and Gouldy, ff. Tr. 222, at 24-25).
- 70. Point Beach removed and examined two of its full-length (152 inches long) Boraflex poison inserts.used in its spent fuel racks (one of which had an accumulated gamma dose of approxi-mately-1010 rads) and several of its 2" x 2" Boraflex surveillance coupons (which had a range of accumulated. gamma dose of about 1.10 x 1010 to 1.6'x 1010 rads). The full-length Boraflex poison inserts had good integrity with no cracking or degradation (approximately 1-2% of the surface area, located along the edges of the insert, had some gray discoloration which yielded a powder
>when rubbed). In contrast, the surveillance coupons experienced thinning and degradation and had a gray powder' on their surfaces. l However, tests showed that the coupons also retained almost all of l
their neutron attenuation properties. Point Beach concluded that i
the degradation of the coupons appeared to be attributable to !
': i permeation of water-in the Boraflex, which occurred at the edges !
L i
B of the Boraflex beginning with exposures of about 1 x 10 10 rads gamma. Point Beach also concluded that the full-length inserts were less susceptible to overall degradation than the surveillance coupons because the full-length inserts had a lesser amount of area near the edge in proportion to the overall area of the insert. (Id., at 25-26; Wing, McCracken, and Kopp, ff. Tr. 339, at 5-6).
- 71. Prairie Island removed two large Boraflex surveil-lance coupons (8"x12") encapsulated in stainless steel, which had been in the spent fuel pool for 6 and 12 months, respectively.
The coupons were subject to various examinations, including visual inspections, dimensional measurements, and hardness tests. The six-month sample had an appearance similar to the as-manufactured Boraflex, and the twelve-month sample had some discoloration similar to the Point Beach full-length Boraflex panels.
Additionally, there were slight changes (less than 5%) in the hardness and density of the twelve-month sample relative to the six-month sample. (Kilp and Gouldy, ff. Tr. 222, at 26).
- 72. Quad Cities performed an in-place examination of its Boraflex poison panels and determined that less than a third of the Boraflex poison panels (which had an accumulated exposure of about 1 x 10 9 rads) had gaps or breaks. These gaps occurred at random locations along the upper two-thirds of the panels. The gaps were 1.35 inches long on the average and the maximum gap was 4 inches in length (which occurred in only one or two panels).
Some panels had more than one gap, resulting in an average cumula-
tive gap size of 1.5 inches and a maximum cumulative gap of 4 inches for an entire panel. Cumulative gaps in each Boraflex panel were generally less than 2% of the length of the panel and the maximum cumulative gap sizes were less than 3% of the length of the Boraflex panel. Quad Cities stated that these gaps were caused by stresses induced.from shrinkage of the panels which were restrained in the racks. Quad Cities recalculated the neutron multiplication. factor for its spent fuel pools and concluded that the K-effective of the spent fuel pools was still within applica- l ble limits. (16., at 27-28; Wing, McCracken, and Kopp, ff. Tr.
339, at 6-8).
- 73. Testing by the University of Michigan and examina-tions at Quad Cities indicate that exposure of Boraflex to gamma radiation may result in a maximum shrinkage of approximately 2% to 3% of the length of the Boraflex. Calculations indicate that shrinkage will be complete at about 10 10 rads. These calculations are consistent with interim test results at the University of Michigan, which showed essentially no additional shrinkage of Boraflex with exposures beyond 5 x 10 9 rads, and with the data from Quad Cities. Additionally, qualification tests and inspec-tions of the Boraflex at Point Beach indicate that the edges of the Boraflex panels may experience some discoloration with expo-sure to gamma radiation beginning at 10 10 rads but that the Boraflex will retain its neutron attenuation properties. The NRC l
1 1
I l
__..._____._________________J
Staff classified this latter type of degradation as " minor".
(Kilp and Gouldy, ff. Tr. 222, at 28-29; Wing, McCracken and Kopp, ff. Tr. 339, at 17-18; Tr. 230-32, 241, 311-12, 349, 369-71).
1
- 74. The Turkey. Point rack design and fabrication -1 1
differs significantly from Quad Cities. Shrinkage of the Boraflex panels, as well as possible embrittlement of the panels, was anticipated'and accounted for in the design of the Turkey Point storage racks. At Turkey Point, a single sheet of Boraflex is j i
held to a stainless steel cell wall by enclosing i t in a wrapper.
None of the Region 1 racks, and only some of the Region 2 racks, utilized adhesive to affix'the panel to the wrapper or storage cell during fabrication. On those Region 2 racks which used adhesive, the sheet of Boraflex was attached to one wrapper panel during fabrication with adhesive applied in short lengths along 1 the Boraflex. The purpose of the adhesive is to provide temporary support during-the spot welding process where the wrapper is attached to the cell wall. The wrapper provides an enclosure
-i which protects the Boraflex from the flow of water, and maintains it in a space in which there is a several mil clearance between the Boraflex and the rack cell wall. The clearance is large enough to allow shrinkage of the Boraflex without binding, but small enough to prevent dislocation of the Boraflex to occur should it become brittle or crack. The arrangement is very similar to that used in the original Boraflex qualification testing. (Kilp and Gouldy, ff. Tr. 222, at 39-40 as corrected; Tr. 242-44).
f
- 75. In' contrast, the Quad Cities fabrication process used a~ sealant applied along the entire axial length of the Boraflex to attach it to the side of the rack. This element and l the'other side of the rack wall were then placed in a fixture for J
subsequent welding.. Apparently, this process did not allow for the predicted shrinkage of the Boraflex and, as a' result, gaps developed. The~ design and fabrication process at Turkey Point is more similar.to.the design and fabrication process used for the ;
Point Beach storage racks tPan for the Quad Cities racks. The l
Boraflex plates at Point Beach were not restrained from shrinking inside the iacks,.and these plates did not develop any gaps.
Licensee's witnesses do not expect gaps of any significant size.or i
extent to develop at Turkey Point. Similarly, in the absence of physical restraints, the Staff's witnesses stated that gaps were not likely to form in the Turkey Point Boraflex panels. (Id.;
i Wing, McCracken and Kopp, ff. Tr. 339, at 11).
7
'6. In early August 1987, the Licen,see conducted testing to determine whether gaps were present in the Boraflex panels in the Turkey Point Unit 3 spent fuel pool storage racks.
This testing included a sample of those panels which have received y the highest radiation doses. This testing, which was capable of j detecting any gaps of approximately 1" to 1 1/2" or greater, showed no indications that gaps existed. (Kilp and Gouldy, ff.
Tr. 222, at 33 and 39, as corrected). I i-l i
i
)
j o
i l
l
- 77. Subsequent to the August 1987 testing, FPL deter-mined that none of the racks which had-been tested used adhesive l to attach Boraflex to the wrapper. It is unclear whether the use of adhesive was a contributing cause of the gaps in the Boraflex at Quad Cities. 17/ In any case, the purpose of the adhesive in the Turkey Point racks was to provide temporary support for the Boraflex during rack fabrication and not for long-term support or adherence. Furthermore, FPL's witnesses did not expect gaps to develop in the Boraflex used at Turkey Point in the future 1
(whether or not adhesive was applied to the Boraflex), due to other differences in the design and manufacturing process between j t
Turkey Point and Quad Cities. (Id. at 39 and 40, as corrected; 4 Tr. 286-87).
- 78. The panels which were subject to the August 1987 testing had received a dose of approximately 7.8 x 10 9 rads. As discussed above, testing shows that shrinkage of Boraflex stops with exposures of about 5 x 10 9 to 1 x 10 10 rads. Therefore, if the Boraflex at Turkey Point currently has not developed any gaps {
(or if the Boraflex only has gaps of less than 1-1/2 inches), gaps l
{
i f
l l
17/ Gaps in the Boraflex for the Region 1 racks would have a greater impact on the K-effective of the spent fuel pool than similar gaps in the Region 2 rates. (See 1 82, infra). As discussed above, none of the racks in Region 1 used adhesive to attach the Boraflex to the wrapper. Therefore, if the adhesive was a contributing cause to the gaps at Quad Cities, the absence of adhesive in the Region 1 racks would be beneficial to FPL.
I l
l .
of any significant size would not be expected to occur in the -
future. (Kilp and Gouldy, ff. Tr. 222 at 36; Wing, McCracken, and I Kopp, ff. Tr. 329, at 8; Tr. 230-32, 311-12, 356, 360, 369-71).
- 79. The NRC Staff concluded that, based on available j data, significant degradation of the Turkey Point Boraflex panels is not expected. (Wing, McCracken, and Kopp, ff. Tr. 339, at 20).
- 80. Based on the evidence submitted by the Staff and Licensee, the Licensing Board finds that significant materials degradation of the Boraflex panels in the Turkey Point spent fuel storage racks, including the formation of gaps in the panels, is unlikely to occur.
- 81. Should gaps or degradation of the Boraflex unexpec-i l
tedly occur at Turkey Point, there would be no impact on the public health and safety. As explained in the Licensing Board's Memorandum and Order of March 25, 1987, the boron in the Turkey Point spent fuel pool water would keep the pools within their K-effective limits even if it is assumed that the spent fuel storage racks do not contain any Boraflex. Florida Power and Licht Co.
(Turkey Point Plant, Units 2 and 3), slip. op. at 58 (March 25, 1987). See also Wing, McCracken, and Kopp, ff. Tr. 339, at 18; Tr. 267-69, 329. NRC criteria allow credit to be taken for the presence of boron in the pool water under abnormal conditions, such as gaps in the Boraflex. (Tr. 271, 340).
- 82. After the reports of gaps in the Boraflex in the storage racks at Quad Cities in Spring 1987, the Licensee requested Westinghouse to perform a sensitivity analysis to i
~
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1
- - _ _ _ - _ b
l - 52'-
4 determine the' impact of various types of gaps in the Boraflex-panels. The analysis was' performed for the Region 1 storage racks, because (1) the K-effective'is higher for Region 1 than for Region'2, and (2) the Region 1 spent fuel racks utilize a greater-thickness of Boraflex (Boron-10 areal density of 0.020 gm/cm 2) {
than the Region 2 racks (Boron-10 areal density of 0.012 gm/cm 2),
Thus, any gaps in the Boraflex in Region 1 racks would have more effect on the K-effective levels than similar gaps in the Region 2 racks and would be more likely to cause spent fuel pool reactivity i levels to exceed-the 0.95 K-effective limit.' (Boyd, ff. Tr. 222, ;
at 5-6).
- 83. The assumptions upon which the sensitivity analysis was based were very conservative and. unrealistic given the experi-ence at Quad Cities and the actual conditions in the Turkey Point spent fuel pools. For example:
o An infinite array of new fuel assemblies was assumed. I o The analysis assumed that the gaps were aligned.at the center of the Boraflex panels. The gaps at Quad cities were located at different elevations l along the Boraflex and were not aligned at the center of the fuel assembly. Gaps which are out of alignment by more than approximately 5" (along the I
139" length of the Boraflex panels) would have a much smaller effect on K-effective levels.
l
_ _ = _ _ _ _ _ - - _ .
l'
.(
i o 1The method used to calculate the effect on K- J I
effective of postulated gaps contained a number of- j
(
other conservatism.
Based on these conservative assumptions, Westinghouse calculated j the impactHon K-effective of-various postulated gaps in.the
~
Boraflex panels.. Two sets of calculations were performed. One set assumed a 4.1% fuel enrichment' level, which is'the highest i
fuel enrichment which will be used at Turkey Point until the next a surveillance testing of the Boraflex in the spent fuel pools. The H l
other set assumedia'4.5% fuel' enrichment level which is the I highest level authorized to be stored in the Turkey Point spent fuel pools. Each set of calculations was performed assuming the j absence of boron in the spent fuel pool. water. (Id., at 6-9).
i 84.- If a 4.5% fuel enrichment level is assumed, the j calculations demonstrate that the Turkey Point design basis K-effective limit of 0.95 is not exceeded in the Region 1 racks even if aligned gaps up to 2" in length are postulated to exist in all of the Boraflex panels. If gaps are postulated to exist in only one-half of the panels, aligned gaps of up to 3.5" may exist without exceeding the 0.95 K-effective limit. (Id.)
- 85. If a fuel enrichment level of 4.1% is assumed, the calculations demonstrate that aligned gaps of up to 3.5" may exist h
in all panels without exceeding the 0.95 K-effective limit, and I aligned gaps of up to 7" may exist in one-half of the panels '
without exceeding the 0.95 K-effective limit. (Id.)
1 I
- __ _ _-_ _ l
m= ,
7
- 86. As discussed above, less than one-third of the Boraflex panels at Quad Cit'es i developed gaps, and the cumulative size of these gaps-(sum of the sizes of the individual gaps) was !
only 1.5 inches per panel. Therefore, Turkey Point is capable'of sustaining more gaps and gaps of larger size than experienced at Quad Cities, without exceeding the .95 K-effective limit. 18/
- 87. :The NRC Staff reviewed the sensitivity analysis performed by.the Westinghouse and considers the assumptions made i for that analysis to be conservative. The results of the sensi-
'tivity analysis have been confirme'd by calculations performed by i the NRC Office of Nuclear Material Safety and Safeguards. (Wing, McCracken and Kopp, ff..Tr. 339, at 13-15).
- 88. - Based upon the evidence submitted by the Licensee and Staff, the Licensing Board finds that even if gaps substan- l 1
tially more severe than those detected at Quad Cities were to I develop in the Boraflex panels at Turkey Point, these gaps would i not result in the 0.95 K-effective limit being exceeded.
- 89. FPL has a materials surveillance program to evalu-ate the physical and nuclear characteristics of the Boraflex in the spent fuel pool. Within each of the Unit's spent fuel pools there is a series of Boraflex coupons which are suspended around the periphery of Region 1 or Region 2 rack modules. The coupons j 18/ In designing.the Turkey Point spent fuel racks, shrinkage of j the Boraflex was expected and allowed for in the design, and shrinkage at the ends of the Boraflex is not considered to be s a " gap". There would be no impact on the calculated K-effec-tive of the spent fuel pools even if 3 1/2 inches of each end of the active fuel assemblies were uncovered as a result of the Boraflex shrinkage. (Tr. 324, 367-68). l L--__=__-___-_.
+ ,
_ 5s _
g,-
E arevlocated around the' pool so that they receive a representative.
' exposure.to gamma 1 radiation. (Kilp and Gouldy, ff. Tr. 222, at-30).
l 90. FPL willl perform an' initial surveillance of the l
coupons.after five years of exposure in the pool environment.
This willLoccur in December 1989. This surveillance will involve removal of several specimens from the pool and will include visual L
examination and other. tests. -Based on the results of this initial surveillance, and industry experience with.Boraflex, further surveillance'will be scheduled. (14., at 30-33; Tr. 312).
- 91. -The surveillance testing'will evaluate several physical characteristics of the Boraflex and will include the following: examinations of the stainless steel jacket for the i
, coupons to determine whether: the' jacket material is smooth or exhibits any visible damage; examinations of the Boraflex to determine whether_the Boraflex material is smooth or exhibits any visible changes-(such as-changes in color, pitting, or cracking); 1 i
measurements of the weights and volume of the Boraflex and calculation of its density; and measurement of the hardness of the Boraflex. The evaluation of the nuclear characteristics will
' include the taking of a neutron radiograph of the specimen to determine the uniformity of boron distribution, and the performance of attenuation measurements of the specimen to determine the Boron-10 loading. (14.) {
l
N ,
- b. 5 '
- 1 l
- 92. FPL.willlalso perform Blackness Testing tofdeter-1'
~m ine whether there are any gaps lin the Boraflex panels.-
FPL.
1
, performed baseline. Blackness Testing in early August of 1987 forc j 1 554.Boraflex panels'in Region'1 and Region 2 of the new storage
, racks, including'some thatlhave. received the highest cumulative 1 l
exposure to date in. Turkey Point-Unit 3. FPL will' retest these.
cells.in' December 1989 19/-(in-conjunction with the five year 4 i
surveillance-period for.the Boraflex surveillance coupons). The (
a need for further. retests will be based upon'FPL's results and EPRI l and industry: data. (M. ) k
- 93. The NRC Staff has reviewed.the Licensee's materials
~
surveillance; program for Boraflex and has concluded that the surveillance interval is adequate and the program would allow any gap formation to be detected in sufficient time to enable Licensee I
to take corrective actions. 20/ (Wing, McCracken and Kopp, ff. .j Tr. 339,.at 20). I
'94. The Licensing Board finds that FPL's surveillance j l
program and Blackness Testing will be sufficient to detect any .
changes in the physical distribution of the Boraflex in a timely f
.l_9/
9 .During its next surveillance and testing of the storage !
racks, FPL expects to check the same racks which'FPL tested j in August 1987. These racks are among those which have-re- '
ceived the highest dose to-date. FPL does not expect to test other racks which have received little or no dose, since !'
degradation of Boraflex is believed to be caused by a radia-tion-related mechansim. (Tr. 313-314). Accordingly, the Board finds ~FPL's testing plans to be reasonable and acceptable.
20/ '
The NRC Staff does not expect any gaps to develop in the Boraflex during this surveillance interval. (Tr. 359).
i
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4 ,. - 57:-' l
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p, , y ,,". -
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j manner. As a resulti the sOrve111'ance and testing-will assure. 1 1 ,o ,
i
- i that'the'Boraflexlin the Turkey-Point;spentifuel' racks wil'1 be.
l
" acceptable;for. continue,d t3se for the lifetine of'the: plant.
y
- 9 5. - If FPL's suivgillance and testing program detects l
degradation'of-the Boraflek at7 Turkey Point,-there are several options which;would assure'the continued safe storage of fuel. ,
.These: options include: analyzing the K-effective of the pool to verify _that it is'within' limits, establishing administrative' .I l
controls on the placement of fuel in cells with degraded Boraflex,
\
and: insertion.of. poison 1 rods inithe fuel assemblies. (Kilp and-I Gouldy,1ff._Tr. 222, at-37-38; Wing, McCracken and Kopp, ff. Tr. -
q 339,,at.19).
. 96. 1The Licensing Board ~ finds.that_significant degrada-
- tion of the Boraflex at. Turkey Point.is not likely tos occur, that FPL's1 surveillance:and testing program will be'sufficieht to detect in a timely manner any significant degradation if were it t i
to -occur,: and. that, there are several options which would assuye the. continued safe storage of' fuel if significant degradation is found1to occur.- Therefore, the Licensing Board concludes that it is reasonable'and acceptable to use Boraflex in theJOV.rkey Point spent fuel storage racks. l ORDER ,
n On the basis of'the foregoing Findings of Fact it is, this day of , 1988 i
J l
L.
b '
e
~ ORDERED:
- 1. Contentions 5 and 6 are resolved as set forth in this deci-sion and in favor of the Licensee, Florida Power & Light Company.
a 2.- License Amendment Nos, 111 and 105 to License Nos. DPR-31 and ;
DPR-41-respectively, issued by the Office of Nuclear Reactor Regulation on November 21, 1984 shall remain in full force and effect without modification.
- 3. In accordance with 10 C.F.R. SS 2.760, 2.762, 2.764, 2.785 and 2.786, this Initial Decision shall become effective im-mediately and will constitute, with respect to matters resolved herein, the final decision of the Commission thirty (30) days after issuance hereof, subject to any review pursu-ant to the above cited Rules of Practice. Any party may appeal from this decision by filing a Notice of Appeal.within.
ten.(10) days after service of this Initial Decision. Each appellant must file a brief supporting its position on appeal within thirty (30) days after filing its Notice of Appeal
~
(forty (40) days if'the Staff is the appellant). Within thirty (30) days after the period has expired.for the filing and service of the briefs of.all appellants (forty (40) days in-the case of the Staff), a' party who is not an appellant
~
may file a brief.in support of, or in opposition to, any such .
appeal (s). A responding party shall file a single, respon-rive brief only, regardless of the number of appellants' briefs filed.
Respectfully submitted,
@ ? ,
Steven P. Frantz !
William E. Baer j Newman & Holtzinger, P.C. '
1615 L Street, N.W.
Washington, D.C. 20036 Norman A. Coll Coll, Davidson, Carter, Smith ;
Salter & Barkett, P.A. l 3200 Miami Center l 100 Chapin Plaza Miami, Florida 33131 October 19, 1987 k
s q e, g- k.-
C' 17 yr
,6 / I
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PROPOSED CORRECTIONS.TO TRANSCRIPT.OP HEARINGS 40CKETED USNRC ON SEPTEMBER 15-16, 1987
/ .
'87 OCT 22 A7:57
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PAGE LINE CORRECTION <
a
.F 0FFICE OF-SECRETARY- b Index --
change "Edmonete" to "Edmund E." SOCKETING u SERVICC l 87 18 o changq "i ntervenor 's" to interveners" BRANCH ')
- 89. 14./ ' change " sever" to'" severe" -
97 18; t chanop "Edmonete" to "Edmund E."
98 '13' change "Edmonete" to.,"Edmund E."
98 22 change."Ednonete" '.o "Edmund E."
100 3 change "New Junia Betch" to "new Juno Beach" 107 12 chango'"four"'to " floor"~
l 108 '21 change " slide" to " slot' )
110 8-9 change " rocking-in loads" to " rocking and loads" 111 6 change ".08" to ".8" 112 12 change " assumptions different" to " assumptions using different" 114 14 change " track" to " rack" ;
1 118 4 . change " overhanging,a nd" to " overhanging, and" 120 21 change "The ray ~ size meaning the member" to "The array size meaning the number" 121 10 change " overhead" to " overhang" 122 18 change " bring in" to " bring in the cask" 123 6-7 change " comment that, there" to " comment on q that. There" ;
'124 18 change " Liaison C" to " Licensee" 125 8 change "1504" to "1404" 125 22 change "need" to "do not meet" 129 1 change "Larian" to "Lorion" 12? 2,7,10 change "LARIA>1" to "LORION" j 130 5-6 change " Licensee, Ms. Lorian" to " Licensee, and Ms. Lorion" 131 6,1. change "Lorian" to "Lorion" 131 21 change "Lorian" to "Lorion"
)
132 6 change "A" to "Q" )i 133 14 change " evaluation?" to .: valuation."
l 134 2 change " fact that" to " fact was that" 1
PAGE LINE CORRECTION 134 9 change "6.8. Which" to "6.8, which" 135 13 change " Excused" to " Excuse" 135 13 change "Lorian" to "Lorion" 135 17 change "LORIAN" to "LORION" I 138 16 change " place, and it" to " place, it" 144 14. change " Power and Lights" to " Power and Light" 144 20 change " Florida Power & Lights, and calculation" to " Florida Power & Light, and a calculation" 145 11 change " submitted" to " submittal" 148 13 change'" residence" to " Residents" 150 6 change "old" to " hold" 150 25 change "that as I stated briefly before." to "that, as I stated briefly before,"
151 1 change "I believe. And" to "I believe, and" 151 3 change "tip of" to " lift off" 152 17 change " reanalysis is still" to " reanalysis still" 153 6 change "the year," to "the hearing,"
153 17 change " proposed that" to " proposal was that" 154 4 change " spend" to " spent" 154 11 change " final element necessary" to " finite !
element analysis" 154 16 change "had and" to "that" 155 22 change " conformed" to " confirmed" 156 11 change " wrap" to " racks" 161 4,6 change " company" to " Company" 162 1,5 change " company" to " Company" 165 1 change "10'4 and this is set" to "1014 and this is at" 165 2 change "i" to "I" 165 3 change "our" to "a power" 167 12 change "hadn't" to "had" 169 2 change "was the" to "was what the" 170 15 change "55,036" to "55,000 and 36,000" 171 1 change " rage" to " range" 171 23 change "and space" to "in space" l 172 10 change "outside testimony." to "outside the scope of the testimony."
.)
V L PAGE' LINE. CORRECTION-174 5 change "about" to "above" "179 ~9- change "an" to "at" 180 10 change'"49" to "40" 180- 13 change "by us to" to "to us by" 181 1 change " liner on" to " liner and" l
.181 15 change "to a" to "two" 182 11' change "much a" to "much of a" ,
183 6 change " Bigot" to " Big Rock"'
184 8 change "It" to "It's" 185 14 change "199"'to "1.99" 185 15 change "10 of the.17th" to "10.to the 17th" 185 19 change "10'4" to "1014" 185 24 change " Reg Guide have 199 are for beta 450" to'" Reg Guide 1.99 have are for' greater.than
.450" 186 21 change " origin" to "ORIGEN"
'186 24 change."43,000 was that" to "45,000 was what it" 187 8- change "That's for the- " to "That's where the" 188 4 change " Licensing" to " Licensee" 191 3 change "9" to "19" 194. 11 change "33,00" to "33,000"
'199 19 change " ink. canal" to "Inconel" 203- 6 change "Tithiated" to "Lithiated"
.208 24 change "then" to "they" l
211 1 change "it" to "that" )
i' 220 10-11 change " nuclear field division" to " Nuclear Fuel Division" 220 15 change "Junia Beach" to " Juno. Beach" i 1
221 25 change " Body" to "Boyd"
)
223 19 chan~' " Kelp" to "Kilp"
)
224 22 change "come" to "could" I l
225 19 change "off" to "of the" j 229 8 change "If the first year it was 30 percent, at then" to "In the first year it was 30 percent, and at the" 1
229 20 change " accurate" to " accurately" '
232 10 change " spend" to " spent" J_____L_ L. - _
d'~
- 6 L .PAGE- 'LINE- CORRECTION l .
233 4 ' change " proof." to " proved."
- 235 10 . change " Corrosion in hydriding" to'" Corrosion ;
and hydriding"
'235 18L change "CR02" to "ZrO 2" 237 17- change "and even" to "even in" 238 1 change " times" to " times of"
-239 -1 change "on page 17' to "Q On page 17" 239 23
~
change "for an" to "for in" 241 '12' change "if I" to "what.I" 241- 17- change " 'Its" to "it's" "
241' '23 change "100".to "1010n 242 11 change "is no," to "is'not,"
243; 1 change " Westinghouse, knew" to " Westinghouse kn'w" e l 1243 12 change " housed,'would" to " housed would" 243; 21 change " demonstrated the" to " demonstrated to" 243 22 change " gaps, shrinkage," to " gaps, if shrinkage" 245 16- change " Light. Alternatives" to " Light alternatives" 247 14 change "10 to the rads" to "10 to the-10th rads" 247 15 change "Kilps" to "Kilp" 1
-247 -18 change "10'0" to "1010n
'247 24 change "1010" to "1010n j
'248 2,6 change "10'0" to "1010n 13,14 17,21 248_ 3 change "1010" to "1010n 248 3 change "109?" to "10 9 ?"
248 14 change "would expect" to "would be expected" 249 9 change "and the" to "and then" 249 17 change "10'0" to "1010n 249 22 change " cross-leaking" to " cross-linking" 250. 15,16 change " racker" to " wrapper" 252 9-10 change "which At P&L we have omitted" to "to which at FPL we have committed." i 253 9 change "252, in" to "252, and" 253 12 change " cells, thermalize" to " cells; if not, the neutrons would thermalize" l
l l
1
_ _ _ _ _ _ _ _ _ _ _ _ J
l
's: i 3
PAGE LINE CORRECTION 256 17- change " area which made this region vacant out"uto " area, which made this region vacant, out" 257 8 change "at testing" to "of testing" 257 9 change "went back" to "took back" 258 13 . change " June is" to " June as" 258 14 change "come out" to "came out," ;
l 258 22 change " pool" to " pull" !
264 -3 change " Kelp" to "Kilp" 265 8 change " KELP" to'"KILP" :
265 19 change " Surveillant" to " Surveillance" 265 24 change "MPd" to " mwd"
'268 12 change "is unborated" to "in'unborated" .
268 19 change "is it" to "it is" 269 14 change "4.2" to "4.1" 270 22 change " percent, you can array" to " percent' fuel in an infinite array" 270 25 change " fissure parts"-to " fission products" 271 23 change "there if" to "there is, if" 272 8 change "be fully" to "be a fully" 272 16 change " evaluation or" to " evaluation of" 276 20 change " gaps and" to " gaps on" 278 20-21 change " margin for criticalities reached" to
" margin before criticality is reached."
279 3 change "the elements." to "other elements."
280- 4 cha'nge "X -- infinity of" to "a K-infinity or" 280 22. change "can, an" to "can, then an" 282 12 change "1 or 2" to ".1 or .2" 282 22 change "wouldn't the" to "wouldn't that" j
'282 25 change " applied or" to " applied, or" 283 11 change " panel" to " panels" 286 14 change " Limited amount" to "FPL limited the amount" 286 15 . change "In that area" to "That area" 287- 23 change " Beach have" to " Beach which have" 292 15 change ".85" to ".95" 293 19 change "811" to "8-11" l
c
- ,. _6-s
- .
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PAGE- LINE CORRECTION 295 4 change "811" to "8-11" 296- 12 change "I'll have" to "I had" 298 10,12 change "(Gouldy)" to "(Boyd)"
299 21- change "4.5"'to ".95" H 299 24 change "at least times" to "at least three' !
times" 1 300 19 change "818" to "A18" l 307 1 change "a test" to "the testing" 309 1 change "you" to "he" 310 4 change " monitor date" to "my letter dated" 311 23 change " runoff" to "burnup".
]
312 10 change "10'0" to "1010a 314 15 change "from" to "to" 316 4,6,16 change "10'0" to "1010n 318 12 change " Full-weight" to " Full-length" 320 8 change " holds" to " holes" !
321- 13 change "Boraflex, is" to "Boraflex, and is"-
321 20 change "getting are" to "getting is" 321 24 -change " calorie." to " count rate."
324 2 change "Is," to "It's,"
324 6 change "our evaluation we" to "our evaluation was that" 324 10 change " inches each" to " inches on each"
'326 4 change "with the inch" to "with less than the. inch" 326 4 change "Just do" to "However, just doing" 326 5 change "would done" to "would have done"
'326 18 change "(Kilp)" to "(Gouldy)"
-327 5 change "10" to "20" 328 3-4 change "would show from those further testing that" to "would show, from those further testing, which" 328 25 change "is" to "as" 329 1 change "The absent" to "Then absent" 331 2 change " endorses," to " endorses this,"
331 10-11 change "used and was water" to "used, there was water"
l 4 . I PAGE LINE CORRECTION 331 11 change " assemblies if the" to " assemblies l in the" 331 20 change " dependent on the" to " depended upon as the" 334 2 change "250, would" to "250. Would" )
334 8 change " add" to " edge" 346 3 change "with" to "that" 348 23 change "Kilk" to "Kilp" 353 18 change " barometric" to "parometric" 360 25 change "In believe" to "I believe" 365 10 change "value" to " vague" ,
373 11 change "what" to " watch"
- p stLKETE0; UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION BEFORE THE. ATOMIC SAFETY AND LICENSING BOARD '87 @ E N
-8FFICE 0F3E@ETART btCKEilNG & SERVICI.
) BRANCH In.the Matter of )
~)
FLORIDA POWER & LIGHT COMPANY' ) Docket Nos. 50-250.0LA-2 i
) 50-251 OLA-2
-(Turkey Point Nuclear Generating )
Units 3 &'4) -).
-)
CERTIFICATE OF SERVICE I hereby certify that copies of- (1) the attached' letter, (2) Licensee's Proposed Findings of Fact and Conclusions oof Law, and (3) Proposed Corrections to Transcript of Hearings on September 15-16, 1987, in the above captioned proceeding were' served on.the following by deposit in the United States mail, first class, properly stamped and addressed,.on the ~
date shown below.
-Dr.-Robert M.'Lazo, Chairman Atomic SafetyLand Licensing ~ Board Panel U.S. Nuclear Regulatory Commission Washington, .
D.C. 20555 Administrative Judge Emmeth A. Luebke 5500 Friendship Boulevard Apartment 1923N Chevy Chase, MD 20815 Dr. Richard F. Cole Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.- 20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief, Docketing and Service Section (Original plus two copies)
L
I' s
t I y Joette Lorion 7210 Red Road #208 Miami, FL 33143 Mitzi Young Office of Executive Legal Director U.S.-Nuclear Regulatory Commission Washington, D.C. 20555 Norman A. Coll Coll, Davidson, Carter, Smith, Salter & Barkett 3200 Miami Center 100 Chopin Plaza -
Miami, FL 33131 M
Steven P. Frantz Newman & Holtzinger, P.C.
1615 L Street, N.W.
Washington, D.C. 20036 Dated: October 19, 1987 1
1 I
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