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Category:AFFIDAVITS
MONTHYEARML20141F5711997-06-13013 June 1997 Supplemental Affidavit of B Hughes & Ta Peebles.* Affidavit Re Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam.W/Certificate of Svc ML20138J2331997-05-0202 May 1997 Affidavit.* Affidavit of B Hughes Re Denial of Application for SRO License for Rl Tetrick.W/Certificate of Svc ML20136F2721997-03-0606 March 1997 Supplemental Affidavit of B Hughes.* Supports Staff Motion for Reconsideration of Presiding Officer Initial Decision of 970228.W/Certificate of Svc ML20134A6661997-01-23023 January 1997 Affidavit of B Hughes & Ta Peebles Re Denial of Application for SRO License.W/Certificate of Svc.Served on 970124 ML19325E0111989-10-20020 October 1989 Affidavit of J Lorion on Contention 2.* ML20247F2461989-09-11011 September 1989 Affidavit of SA Collard on Contentions 2 & 3.* Collard Prof Qualifications,Supporting Info & Certificate of Svc Encl ML20247A3081989-09-0505 September 1989 Affidavit of Bj Elliot.* Advises That Author Responded to Interrogatories 1,3,4,6-10,12,13,16 & 17.Related Correspondence ML20246F6651989-08-28028 August 1989 Affidavit of GE Edison.* Advises That Author Provided Response to Interrogatory 5.Supporting Documentation Encl. W/Certificate of Svc ML20246J7161989-08-28028 August 1989 Affidavit of GE Edison.* Advises That Author Provided Response to Interrogatory 5.Certificate of Svc Encl.Related Correspondence ML20207B6311986-07-14014 July 1986 Affidavit of ML Wohl Re Contention 4 Concerning Personnel Exposures.Related Info,Including Prof Qualifications,Encl ML20207B6411986-07-14014 July 1986 Affidavit of Jl Minns Re Contention 4 Concerning Personnel Exposures.Related Info,Including Prof Qualifications,Encl. W/Certificate of Svc ML20140D7781986-03-19019 March 1986 Affidavit of J Lorion Re Contentions 3,4,5,6,7,8 & 10 ML20140D5491986-03-19019 March 1986 Affidavit of J Lorion Supporting Intervenor Contention 3 Concerning Util Motions for Summary Disposition.Certificate of Svc Encl ML20205K5501986-02-21021 February 1986 Supplemental Affidavit of Jl Danek Correcting 860121 Affidavit on Contention 7 to Indicate That Actual Exposure Incurred During Reracking Is 13.20 Not 13.17 person-rem. Notice of Appearance & Certificate of Svc Encl ML20153D2441986-02-18018 February 1986 Affidavit of Jn Ridgely Supporting Util 860123 Motion for Summary Disposition of Contention 8 Re High Density Design of Fuel Racks ML20153D2521986-02-18018 February 1986 Affidavit of LI Kopp Supporting Util 860123 Motion for Summary Disposition of Contention 10 Re Spent Fuel Pool Capacity.W/Certificate of Svc & Two Notices of Appearance ML20153D2041986-02-18018 February 1986 Affidavit of B Turovlin Supporting Util 860123 Motion for Summary Disposition of Contention 6 Re Matls Integrity ML20153D1721986-02-18018 February 1986 Affidavit of SB Kim Supporting Util 860123 Motion for Summary Disposition of Contention 5 Re Main Safety Function of Spent Fuel Pool ML20137W8501986-02-18018 February 1986 Affidavit of LI Kopp Supporting Licensee 860123 Motion for Summary Disposition of Contention 3 Re Increased Fuel Enrichment ML20153D1501986-02-18018 February 1986 Affidavit of ML Wohl Rejecting Util 860123 Motion for Summary Disposition of Contention 4 Re Radiological Analysis of Spent Fuel Boiling Event ML20153D1081986-02-18018 February 1986 Affidavit of ML Wohl Supporting Util 860123 Motion for Summary Disposition of Contention 3 Re Calculation of Radiological Consequences Resulting from Cask Drop Accident ML20140C8661986-01-23023 January 1986 Affidavit of He Flanders Re Contention 5.New Spent Fuel Storage Racks Designed in Accordance W/Seismic Category 1 Requirements.Design Conforms W/Srp Section 9.1.2.Summary of Prof Qualifications Encl ML20140C8441986-01-22022 January 1986 Affidavit of Rk Carr Re Contention 3.Offsite Doses for Postulated Cask Drop Accident Calculated Conservatively Using Appropriate Peaking Factors & Resultant Radiation Doses within Guidelines.Qualifications Encl ML20140C8581986-01-22022 January 1986 Affidavit of Rk Carr Re Contention 4.Assumptions Re Saturation Noble Gas & Iodine Inventories,Percent Fuel Failure & Gap Activity Used for Analysis of Spent Fuel Pool Boiling Appropriate & Doses Calculated Acceptable ML20140D1551986-01-22022 January 1986 Affidavit of Ew Thomas Re Contention 6.Analysis Shows That Pool Maintains Structural Integrity Even Under Severe Conditions of Postulated Boiling Water Combined W/Effects of Design Earthquake.Summary of Prof Experience Encl ML20140D1301986-01-22022 January 1986 Affidavit of Rk Carr Re Contention 6.Spent Fuel Pool Liner & Pool Structure Consists of Matls Commonly Used in Nuclear Applications & Have Proven Ability to Withstand Radiation Exposure.Qualifications Encl ML20140D1811986-01-22022 January 1986 Affidavit of Rk Carr Re Contention 7.Occupational Exposure from Reracking Spent Fuel Pool at Plant Was Substantially Lower than Original & Revised Estimates,Thereby Demonstrating Conservatism.Prof Experience Encl ML20140D2331986-01-22022 January 1986 Affidavit of DC Patton Addressing Contentions 6 & 8.Util Committed to Upgrade Spent Fuel Pool Cooling Loop to Ensure Adequate Cooling of Spent Fuel Pool in Event of SSE ML20140D2241986-01-22022 January 1986 Affidavit of Jl Danek Addressing Contention 7.Radiation Protection Policies of Util Require Establishment & Implementation of Formal ALARA Program.Prof Experience Encl ML20140C8781986-01-21021 January 1986 Affidavit of Lt Gesinski Re Contention 5 Concerning Seismic Loads on Fuel Assemblies.Methodology Used in Analysis Appropriate & Results Obtained from Analysis Accurate. Summary of Experience Encl ML20140D1371986-01-20020 January 1986 Affidavit of Gr Kilp Re Contention 6.Spent Assemblies & Cladding of Fuel Rods Designed to Withstand Very High Radiation Levels Present in Reactor.Summary of Experience Encl ML20140D2531986-01-20020 January 1986 Affidavit of Wa Boyd Addressing Contention 10.Critical Analyses Performed for Spent Fuel Pool Expansion Amends Conform W/Applicable Stds & Criteria.Certificate of Svc Encl ML20140C6231986-01-17017 January 1986 Affidavit of SE Turner Re Contention 3 Concerning Increased Fuel Enrichment.Certificate of Svc Encl ML20198E4311985-11-0606 November 1985 Affidavit of G Edwards Re Intervenor Contention (D).Dnbr of 1.17 for Optimized Fuel Assembly Fuel in Transitional Mixed Core Unwarranted Unless Detailed Studies Done.Adoption of Lower DNBR Value Would Allow Operation at Hotter Temp ML20198E4351985-11-0606 November 1985 Affidavit of J Lorion Re Contention (D).Change in DNBR Limit from 1.3 to 1.17 Reduces Margin of Safety.Board Should Conduct Hearing Previously Ordered to Investigate Margin of Safety ML20133J2511985-10-15015 October 1985 Affidavit of Yi-Hsiung Hsii Addressing Contention (D) Re Three Issues Stated in ASLB 850816 Order Denying Licensee Motion for Summary Disposition ML20135H8831985-09-20020 September 1985 Affidavit of EA Dzenis Re Vessel Flux Reduction at Facilities ML20096F3971984-09-0404 September 1984 Affidavit of J Lorion Refuting Contentions (B) & (D) That There Is No Genuine Issue of Matl Fact to Be Heard ML20096F4291984-09-0404 September 1984 Affidavit of Gd Edwards Refuting Licensee Contentions (B) & (D) That There Is No Genuine Issue of Matl Fact to Be Heard. Prof Qualifications & Certificate of Svc Encl ML20094J2261984-08-0808 August 1984 Affidavit of EA Dzenis in Support of Licensee 840810 Motion for Summary Disposition of Intervenor Contention (D). Realted Correspondence ML20094J0881984-08-0303 August 1984 Affidavit of Mj Parvin in Support of Applicant 840810 Motion for Summary Dispositon of Intervenor Contention (B).Related Correspondence ML20087F6211984-03-0909 March 1984 Affidavit of DC Poteralski on Petitioners 840303 Brief Re Conflict Posed by Legal Requirement of Timeliness & Equitable Considerations.Util 830720 Amends Not Part of Pressurized Thermal Shock Program.W/Certificate of Svc ML17341A4301981-08-0505 August 1981 Affidavit Responding to ASLB 810728 Order Re Void Found in Area Adjoining & Beneath Equipment Hatch.No Breach of Structural Integrity of Unit 3 Containment Pressure Boundary Occurred ML17341A3241981-07-10010 July 1981 Affidavit Re Intervenor Oncavage 810627 Application for Stay of Final Order ML17341A3251981-07-10010 July 1981 Affidavit Re Intervenor Oncavage 810627 Application for Stay of Final Order ML18008A0181981-06-27027 June 1981 Affidavit Re Lack of Adequate Precautions in Storing Wastes Resulting from Steam Generator Repair.Prof Qualifications Encl ML17341A2461981-06-12012 June 1981 Affidavit Addressing ASLB 810528 Memorandum & Order Re Filing of Detailed Info on Low Level Solid Waste Resulting from Repairs.Prof Qualifications & Certificate of Svc Encl ML17340B2761981-05-12012 May 1981 Affidavit Supporting Contention 1 on Alternatives to Repairing Facility Steam Generators.Conservation Potential from Several Approaches Could Cut Energy Consumption by 50-70%.Prof Qualifications Encl ML17341A2871981-05-11011 May 1981 Affidavit Re Probability & Result of Hurricane Damage to Containers in Which Low Specific Activity Waste Resulting from Steam Generator Repair Would Be Stored.Prof Qualifications Encl ML17340B2781981-05-11011 May 1981 Affidavit Supporting Contention 4B.Integrity of Loosely Stacked Drums of Low Level Radwaste Cannot Be Assured During Passage of Major Hurricane.Prof Qualifications Encl 1997-06-13
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEAR3F0999-05, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines1999-09-14014 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines L-99-201, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments1999-09-0707 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments ML20206H4441999-05-0303 May 1999 Comment Opposing Proposed Rules 10CFR170 & 10CFR171 Re Rev of Fy 1999 Fee Schedules ML20205J0461999-04-0101 April 1999 Comment Supporting Proposed Draft Std Review Plan on Foreign Ownership,Control & Domination.Util Supports Approach Set Forth in SRP Toward Reviewing Whether Applicant for NRC License Owned by Foreign Corp.Endorses NEI Comments ML20205B3771999-03-16016 March 1999 Comment Opposing PRM 50-64 Re Liability of Joint Owners of Npps.Util Endorses Comments of NEI & Urges Commission to Deny Petition for Rulemaking ML17355A2511999-03-0909 March 1999 Comment Supporting Amend to Policy & Procedure for NRC Enforcement Actions Re Treatment of Severity Level IV Violations at Power Reactors.Util Also Endorses Comments of NEI on Revs L-98-306, Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP1998-12-10010 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP L-98-272, Comment on Draft Reg Guide DG-4005, Preparation of Suppl Environ Repts for Applications to Renew Nuclear Power Plant Operating Licenses1998-10-28028 October 1998 Comment on Draft Reg Guide DG-4005, Preparation of Suppl Environ Repts for Applications to Renew Nuclear Power Plant Operating Licenses L-98-252, Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule1998-10-0606 October 1998 Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule L-98-248, Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement1998-10-0505 October 1998 Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement ML17354A8741998-03-27027 March 1998 Comment Opposing Proposed Generic Communication,Lab Testing of nuclear-grade Activated Charcoal (M97978) ML17354B1061998-02-26026 February 1998 Submits Listed Requests for NRC EA Per 10CFR2.206 to Modify OLs for All FPL NPPs Until Licensee Can Demonstrate Open Communication Channels Exist Between NRC & Licensee.Also Requests EA to Address Alleged Discriminatory Practices ML20217M0751997-08-13013 August 1997 Licensee Response to Supplemental 10CFR2.206 Petitions Filed by Tj Saporito & National Litigation Consultants.Petition Provides No Basis for Extraordinary Relief Requested. Petition Should Be Denied.W/Certificate of Svc ML20217J4321997-08-0707 August 1997 Memorandum & Order.* Grants Staff Petition for Review & Reverses Presiding Officer Decision Requiring Staff to Issue Tetrick SRO License.Order Disapproved by Commissioner Diaz. W/Certificate of Svc.Served on 970807 ML20148P8461997-06-25025 June 1997 Memorandum & Order (Determination of Remand Question).* Concludes That Presiding Officer Reaffirms Determination That Response of Rl Tetrick to Question 63 of Exam to Be SRO Was Incorrect.W/Certificate of Svc.Served on 970626 ML17354A5521997-06-18018 June 1997 Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems. ML20141F5441997-06-13013 June 1997 NRC Staff Response to Presiding Officer Memorandum & Order (Questions Relevant to Remand).* Staff Submits That Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam Should Be Denied ML20141F5711997-06-13013 June 1997 Supplemental Affidavit of B Hughes & Ta Peebles.* Affidavit Re Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam.W/Certificate of Svc ML17354A5181997-05-27027 May 1997 Licensee Response to 10CFR2.206 Petition Filed by Tj Saporito & National Litigation Consultants.Petition Should Be Denied,Based on Listed Info.W/Certificate of Svc ML20148G6531997-05-27027 May 1997 Notice.* Forwards Documents Received & Read by Author from Rl Tetrick on 970317 W/O Being Served as Required Under Procedural Rules.W/Certificate of Svc.Served on 970527 ML20148G7071997-05-27027 May 1997 Memorandum & Order (Questions Relevant to Remand).* Rl Tetrick May Respond to Questions W/Filing Served Pursuant to Procedural Regulations W/Notarized Statement to Be Received by 970617.Certificate of Svc Encl.Served on 970527 ML20148G7501997-05-20020 May 1997 Memorandum & Order CLI-97-05.* Staff May Withhold Issuance of SRO License to Rl Tetrick Pending Further Order of Commission.W/Certificate of Svc.Served on 970520 ML17354A5631997-05-17017 May 1997 Second Suppl to 970423 Petition Requesting Enforcement Against Listed Util Employees by Imposing Civil Penalties, Restricting Employees from Licensed Activities & Revoking Unescorted Access ML20141C7331997-05-16016 May 1997 Order Extending Until 970616,time within Which Commission May Rule on NRC Staff 970416 Petition for Review of Presiding Officer Initial Decision.W/Certificate of Svc. Served on 970516 ML17354A5611997-05-11011 May 1997 Suppl to 970423 Petition Requesting Enforcement Action Against Util Former Executive Vice President,Site Vice President & Maint Superintendent by Imposing Civil Monetary Penalty ML20138J2331997-05-0202 May 1997 Affidavit.* Affidavit of B Hughes Re Denial of Application for SRO License for Rl Tetrick.W/Certificate of Svc ML20138J2271997-05-0202 May 1997 NRC Staff Response to Questions Posed in Commission Order of 970425.* Staff Respectfully Submits That Commission Should Undertake Review of Presiding Officer Decisions in Proceedings LBP-97-2 & LBP-97-6 ML20138J2241997-05-0202 May 1997 Line (Providing Omitted Citation).* Informs That Submitted Citation Inadvertently Omitted from Response to Questions Posed in Commission Order of 970425.W/Certificate of Svc ML20138J2401997-04-25025 April 1997 Scheduling Order.* Staff Instructed to File W/Commission,By COB 970502,response to Tetrick Argument Re Question 63 & Discussion of Legal Significance of Consistent Staff Practices.W/Certificate of Svc.Served on 970425 ML17354A5651997-04-23023 April 1997 Requests That NRC Take EA to Modify,Suspend or Revoke FPL Operating Licenses for All Four Nuclear Reactors Until Licensee Can Sufficiently Demonstrate to NRC & Public That Employees Encouraged to Freely Raise Safety Concerns ML20137X5921997-04-16016 April 1997 NRC Staff Petition for Commission Review of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Undertake Review of Presiding Officer Decisions in Proceeding.W/Certificate of Svc ML20137X5511997-04-11011 April 1997 NRC Request for Issuance of Order Staying Effectiveness of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Stay Effectiveness of Decision in Subj Proceeding.W/Certificate of Svc ML20137R3531997-03-27027 March 1997 Correct Copy of Memorandum & Order (Denial of Reconsideration,Stay).* Denies NRC Staff Motion for Reconsideration.W/Certificate of Svc.Served on 970327 ML20137F5551997-03-25025 March 1997 NRC Staff Response to Memorandum & Order of 970321.* Presiding Officer Should Grant Staff 970310 Motion for Reconsideration.W/Certificate of Svc ML20137F8251997-03-21021 March 1997 Memorandum & Order (Grant of Housekeeping Stay).* Orders That Effect of Initial Decision Postponed Until Close of Business on 970326.W/Certificate of Svc.Served on 970321 ML20137F5081997-03-17017 March 1997 NRC Staff Motion for Issuance of Stay.* Requests That Presiding Officer Deny NRC Staff Request for Issuance of Stay in Matter of Issuance of SRO License ML20137F5371997-03-17017 March 1997 NRC Staff Motion for Reconsideration in Matter of Rl Tetrick.* Requests That Presiding Officer Deny NRC Staff Request for Reconsideration ML20136F2981997-03-12012 March 1997 Memorandum & Order (Grant of Housekeeping Stay).* Informs That Initial Decision Issued by Presiding Officer on 970228 Postponed Until 970321 & Rl Tetrick May File Response by 970318.W/Certificate of Svc.Served on 970312 ML20136F2351997-03-10010 March 1997 NRC Staff Motion for Reconsideration Introduction.* Requests That Presiding Officer Reconsider Determination That Tetrick Passed Written Exam & Find,Instead,That Tetrick Failed Written Exam ML20136F3411997-03-10010 March 1997 NRC Staff Request for Issuance of Order Staying Effectiveness of Presiding Officers Initial Decision LBP-97-2.* Staff Submits That Presiding Officer Should Stay Effectiveness of Initial Decision.W/Certificate of Svc ML20136F2721997-03-0606 March 1997 Supplemental Affidavit of B Hughes.* Supports Staff Motion for Reconsideration of Presiding Officer Initial Decision of 970228.W/Certificate of Svc ML20138Q0191997-02-28028 February 1997 Initial Decision.* Concludes That Rl Tetrick Had Passing Score of 80% & Should Be Granted License as Sro. W/Certificate of Svc.Served on 970228 ML20134A6551997-01-23023 January 1997 Written Presentation of NRC Staff.* Staff Concludes That SE Turk Failed Written Exam & Did Not Establish Sufficient Cause to Change Grading of Answers to Listed Questions. Denial of Application for SRO License Should Be Sustained ML20134A6661997-01-23023 January 1997 Affidavit of B Hughes & Ta Peebles Re Denial of Application for SRO License.W/Certificate of Svc.Served on 970124 ML20129J5681996-10-23023 October 1996 Memorandum & Order (Error).* Informs of Incorrect Caption Identified in Order .W/Certificate of Svc.Served on 961023 ML20129D4981996-10-21021 October 1996 Memorandum & Order (Grant of Request for Hearing Scheduling).* Requests for Hearing Hereby Granted. W/Certificate of Svc.Served on 961021 ML20129D6681996-10-18018 October 1996 NRC Staff Answer to Rl Tetrick Request for Hearing.* Staff Does Not Oppose Request & Will Be Prepared to Submit Hearing File.W/Certificate of Svc & Notice of Appearance ML20129D4401996-10-0909 October 1996 Designating of Presiding Officer.* Pb Bloch Designated to Serve as Presiding Officer to Conduct Informal Adjudicatory Hearing in Proceeding of Rl Tetrick Re Denial of SRO License.W/Certificate of Svc.Served on 961010 ML17353A6311996-01-19019 January 1996 Decision & Remand Order Re FPL Discrimination Against RR Diaz-Robainas.FPL Ordered to Offer Reinstatement to RR Diaz-Robainas W/Comparable Pay & Benefits,To Pay Him Back Pay W/Interest & to Pay His Costs & Expenses Re Complaint ML17353A2471995-06-27027 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style. 1999-09-07
[Table view] |
Text
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UNITED STATES OF AMERICA
[b l*ey [X NUCLEAR REGULATORY COMMISSION \'6 . ' q- M l} BEFORE THE ATOMIC SAFETY AND LICENSING
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In the Matter of ) Docket Nos. 50-250-OLA-2
) 50-251-OLA-2 FLORIDA POWER AND LIGHT COMPANY )
' Turkey Point Nuclear Generating ) (Spent Fuel Pool Expansion)
Units 3 & 4) )
)
AFFIDAVIT OF DR. GERALD R. KILP ON CONTENTION NO. 6
- 1. My name is Gerald R. Kilp. I am an Advisory Engineer in the Engineering Department of the Nuclear Fuel Division of the Westinghouse Electric Corporation. My business address is Westinghouse Electric Corporation, Monroeville Mall Office Building, P. O. Box 3912, Pittsburgh, PA. 15230. A summary of my professional qualifications and experience is attached hereto as Exhibit A, which is incor-porated herein by reference.
- 2. The purpose of my affidavit is to address Contention 6. Contention 6 and the bases for the Contention state as follows:
8601290194 060123 PDR ADOCK 05000250 g PDR s
Contention 6 The Licensee and Staff have not adequately consi-dered or analyzed materials deterioration or failure in materials integrity resulting from the increased generation and heat and radioactivity, as a result of increased capacity and long term storage, in the spent fuel pool.
Bases for Contention 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:
(a) deterioration of fuel cladding as a result of increased exposure and decay heat and radia-tion levels during extended periods of pool storage.
(b) loss of materials integrity of storage rack and pool liner as a result of exposure to higher levels of radiation over longer periods.
i (c) deterioration of concrete pool structure as a result of exposure to increased heat over extended periods of time.
, In particular, the purpose of my affidavit is to address the materials integrity of the fuel assemblies and spent fuel storage racks in the spent fuel pool environment. The Affidavit of Rebecca K. Carr on Contention No. 6 and the Affidavit of Eugene W. Thomas on Contention No. 6 discuss the materials integrity of the spent fuel pool liner and spent fuel pool concrete structure. The Affidavit of Daniel C.
Patton on Contention Nos. 6 and 8 discusses the heat loads present in the Turkey Point spent fuel pools.
't
- 3. The remainder of this affidavit is divided into three principal parts. The first part identifies the type of materials present in the spent fuel pools and identifies the radiation and heat loads present in the spent fuel pools.
The second part discusses the materials integrity of the fuel cladding, and the third part discusses the materials inte-grity of the spent fuel storage racks.
I. Types of Materials and Radiation and Heat Loads Present in the Turkey Point Soent Fuel Pools
- 4. The Turkey Point spent fuel pools consist of a concrete pool structure with Type 304 stainless steel pool liner. The new spent fuel storage racks are also constructed of Type 304 stainless steel and utilize Boraflex, a neutron absorbing material. The fuel assemblies are comprised of Type 304 stainless steel, Inconel, and Zircaloy.
i 5.
As discussed in the Affidavit of Daniel C.
i Patton on Contention Nos. 6 and 8, the temperatures in the spent fuel pool could approach boiling during a loss of cooling accident. The temperature for normal conditions is not expected to exceed 143 F and will usually be less.
- 6. Four types of radiation (alpha, beta, gamma, and neutron) will be present in varying degrees in the spent fuel pool. For the types of material in the spent fuel pool (concrete, stainless steel, Inconel, and Zircaloy), alpha and beta radiation are not a concern because they do not have an ability to penetrate materials deeply enough to appreciably
- - . . . ._-_. ~
affect their structural integrity. Calculations were performed to determine the cumulative gamma and neutron exposures of materials present in the Turkey Point spent fuel pool for forty years. The results of these calculations indicate that the cumulative gamma dose would be 1.9 x 10 10 Rads and the cumulative neutron fluence would be 4.8 x 10 13 2
n/cm . These numbers were conservatively calculated, assuming an infinite array of storage cells each containing a spent fuel assembly.
II. Fuel Claddina Materials Intearity
- 7. The fuel assemblies and the cladding of the fuel rods are designed to withstand the very high radiation levels present in a reactor. The neutron fluence levels that 4
the fuel assemblies and the Zircaloy cladding are subjected to during storage in a spent fuel pool are orders of magni-tude lower than those which the assemblies and cladding experience when exposed in a reactor during full pcwer 5
operation. As a result, the total neutron fluence exposure 22 2 of the cladding is approximately 10 neutrons /cm while in 13 2 the reactor, compared to about 5 x 10 neutrons /cm during a 40 year exposure in the spent fuel pool. This difference is approximately 8 orders of magnitude. Putting it another way, the added neutron exposure after 40 years in the spent fuel pool is equivalent to approximately 1 second in a reactor at
full power. Thus, 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.
- 8. Neutrons are the cause of virtually all of the irradiation induced changes in Zircaloy, Inconel, and the stainless steel used for the fuel assemblies. These mate-rials are essentially unaffected by the alpha, beta, and gamma radiation, which comprise the overwhelming fraction of the radiation in the spent fuel pool. In particular, although gamma radiation is a penetrating radiation, its primary effect in these materials is heating and not struc-tural damage at the levels of radiation expected in the Turkey Point spent fuel pool.
- 9. The fuel assemblies and fuel cladding are al,so l
designed to withstand the temperatures and heat loads present during operation in the reactor, which are far more severe than those present in the spent fuel pool. Since the zirconium used in the Zircaloy cladding is considered immune to stress-corrosion cracking in water environments like the spent fuel pool (Ref. 1), corrosion and hydriding are the only realistic threats to fuel rod cladding integrity during storage in the pool. These can be shown to be of no concern i by considering the corrosion properties of the Zircaloys used for modern light water reactor (LWR) fuel cladding.
- 10. At 50O degrees Fahrenheit, and at the much higher heat fluxes in the reactor, the corrosion rate of Zircaloy is approximately 1/100,000 inches per year (based upon corrosion rate equations given in References 2 and 3).
At this rate it would take over 100 years to corrode 1/1000 of an inch of cladding (compared to at least 20/1000 inch of Zircaloy wall thickness remaining when a fuel assembly is removed from the reactor for storage in the pool). This amount of corrosion would have an insignificant impact upon the structural integrity of the fuel cladding. Furthermore, at the much lower temperatures actually predicted for the spent fuel pool, the expected corrosion rate would be substantially lower. Therefore, corrosion is not expected to have any appreciable impact on the structural integrity of the Zircaloy cladding.
- 11. 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 as established above, hydriding in the spent fuel pit will be nil also.
- 12. Similar reasoning can be applied to the other fuel assembly components (stainless steels and Inconel) which mechanically support the fuel rods. All of these materials have been shown by test and experience to be virtuelly immune to corrosion at spent fuel pool temperatures. For example, J. R. Weeks has shown (Ref. 4) that the corrosion of Type 304 I
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stainless steel will not exceed 6/10,000 inches for 100 years in an oxygenated borated water environment similar to that in the spent fuel pool. Corrosion rates for Inconel are at least as low as those for stainless steel. Additionally, since stainless steel, Inconel, and Zircaloy all form protective oxide films, no signif:. cant galvanic attack is expected among these materials.
- 13. The most convincing evidence that fuel assemblies do not deteriorate in the spent fuel pool comes from actual experience. Visual observations and radiation monitoring of pool water documented in a comprehensive review of light later reactor fuel behavior during pool storage by A. B. Johnson (Ref. 5), demonstrate that spent fuel has been stored safely for more than three decades. Johnson's paper also reports on the results of a number of hot cell examina-tions on fuel stored for more than ten years which show no measurable changes due to corrosion or hydriding and no loss l
of fuel integrity.
- 14. For- all of the above reasons, I therefore conclude that Zircaloy clad fuel and the fuel assemblies can be safely stored well in excess of 40 years in the Turkey Point Spent Fuel Pool.
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III. Fuel Storace Rack Materials Inteority
- 15. The spent fuel storage racks are constructed of Type 304 stainless steel, which provides structural support, and Boraflex, a neutron absorbing material. As I have acted, stainless steel has been shown by test and experience to be virtually immune to corrosion at spent fuel pool temperatures. Similarly, the neutron radiation levels in the spent fuel pool are orders of magnitude below those levels sufficient to produce any appreciable impact upon the structural integrity of stainless steel.
1G. The neutron absorbing material, Boraflex, used in the Turkey Point spent fuel rack construction is manufac-tured by Brand Industrial Services, Inc. Boraflex is a silicone-based polymer containing fine particles of boron carbide in a homogeneous, stable matrix.
- 17. Boraflex has undergone extensive testing to evaluate its ability to withstand the effects of gamma and neutron irradiation in various environments and to verify its structural integrity and suitability as a neutron absorbing material. (Ref. 6). In tests performed at the University of Michigan, Boraflex was exposed to 1.03 x 10 11 Rads of gamma radiation and a total neutron fluence of 1020 neutrons /cm 2 in borated water. (Ref. 7). These tests indicate that Boraflex maintains its neutron attenuation capabilities after being subjected to an environment of borated water and radiation
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13 2 and doses substantially exceeding the 4.8 x 10 neutrons /cm 10 Rads of gamma radiation anticipated for 40 year 1.9 x 10 fuel storage at Turkey Point.
- 18. Long-term borated water soak tests at high i
temperatures were also conducted. (Ref. 8). Boraflex maintained its functional performance characteristics and .
showed no evidence of swelling or loss of ability to maintain a uniform distribution of boron carbide. During irradiation of the Boraflex, small amounts of non-radioactive gas (N2 , 02 and CO 2
) may be generated, plus a small amount of He from neutron / boron reactions. Holes provided in the stainless 4
steel wrapper, that attaches the Boraflex to the storage cell walls, allow water to enter and gas to escape from the Boraflex. The actual tests verify that Boraflex maintains long-term material stability and mechanical integrity and that it can be safety utilized as a poison material for neutron absorption in spent fuel storage racks.
- 19. Based on the material properties of Type 304 i stainless steel and the rigorous testing of the Boraflex neutron absorber material, I am confident that the spent fuel racks will maintain their material integrity under the conditions expected in the spent fuel pools for Turkey Point.
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IV. Conclusion i
- 20. The spent fuel assemblies and fuel cladding are designed to withstand the radiation and heat loads in the reactor. These conditions are far more severe than those present in the spent fuel pool. Tests and experience have shown that no significant deterioration of the materials used in cladding and assemblies occurs in a spent fuel pool environment. Therefore, the fuel cladding and assemblies are l
expected to maintain their structural integrity during storage in the Turkey Point spent fuel pool. Similarly, the materials in the spent fuel storage racks are expected to maintain their integrity while in the Turkey Point spent fuel pool.
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FURTHER AFFIANT SAYETH NOT The foregoing is true and correct to the best of my knowledge, information and belief.
d .
Gerald R. Kilp "
STATE OF PENNSYLVANIA )
COUNTY OF ALLEGHENY )
Subscribed and sworn to before me this 70 day of , 1986. My commission expires /#/d/87
/ r h ft
- A NOTARY PUBIfIC LORRAINE M. PlfLiCA. N07EI PUBlic MONR3EVILLE BORD. ALLEGt:IfiY COUr TY MY COMMISSION EXPIRES CEC 14,1987 Member. Pennsylvania Association of Notanes
r HEEEEENCES
- 1. Douglas, D. L., "The Metallurgy of Zirconium," Fublished by the International Atomic Znergy Agency, Vienna, 1971 Supplement, page 363.
t
- 2. Dalgaard, S. B., "Long Term Corrosion and Hydriding of Zircaloy 4 in Commercial Pressurized Reactors with Forced Convective Heat Transfer", presented at the Electrochemical Society, Inc., May 2-7, 1976, Page 1.
- 3. Garzarolli, F., Jorde, D., Manzel, R., Parry, P. W. and Smerd, P. G., " Review of PWR Fuel Rod Waterside Corro-sion Behavior," EPRI NP-1472, August 1980, Section 2.0.
- 4. Weeks, J. R., " Corrosion of Materials in Spent Fuel Storage Pools," BNL-NUREG-23021, July 1977.
- 5. Johnson, A. B., " Behavior of Spent Nuclear Fuel in Water Storage," BNWL 2256, September, 1977.
- 6. Anderson, J. S., "Boraflex Neutron Shielding Material --
Product Performance Data," Brand Industries, Inc.,
L Report 748-30-2 (August 1981).
l o
- 7. Anderson, J. S .' , " Irradiation Study of Boraflex Neutron Shielding Materials," Brand Industries, Inc., Report 748-10-1 (August 1981).
- 8. Anderson, J. S., "A Final Report on the Effects of High Temperature Borated Water Exposure on BISCO Boraflex Neutron Absorbing Materials," Brand Industries, Inc.,
Report 748-21-1 (August 1978).
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EXHIBIT A ,
STATEMENT OF PROFESSIONAL QUALIFICATION OF GERALD R. KILP I
My name is Gerald R. Kilp. My business address is Westinghouse Electric Corporation, P.O. 3912, Pittsburgh,
- Pennsylvania, 15230. I am an Advisory Engineer for the Product Engineering Section of the Westinghouse Nuclear Fuel Division, Westinghouse Electric Corporation. I have served in this function since November, 1983. In this capacity, I am responsible for selected Materials Development programs and act as a general advisor on materials performance questions for the Westinghouse Nuclear Fuel Division.
I graduated from Missouri Valley College, Marshall, Missouri, in 1952 with a Bachelor of Science degree in Chemistry. In 1957, I received a Doctorate of Physical Metallurgy from Iowa State College (since renamed to Iowa 1
State University).
From 1952 to 1957, I was a Graduate Assistant at the Ames Laboratory for Atomic Research, an AEC supported laboratory at Iowa State College. During this period, I j worked on binary phase diagrams and evaluated methods for protection of uranium metal from water corrosion.
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From December, 1957 to May, 1962, I was a Senior Engineer and, later a Fellow Engineer, at the Westinghouse Atomic Power Department where I worked on thermoelectric and thermionic materials for application in nuclear reactors.
In May, 1962 and until September, 1968, I acted as supervisor and later Manager of Fuel Evaluation on the NERVA Reactor Project at the Westinghouse Astronuclear Laboratory at Large, Pennsylvania. In September, 1968 and until May, 1972, I served as the Engineering Manager of the Astronuclear Fuel Facility at Cheswick, Pennsylvania. In this capacity, I was responsible for process development for fabrication of NERVA reactor fuel as well as reactor fuel performance evaluation.
In May, 1972, I transferred to the Westinghouse Nuclear Fuel Division of Westinghouse Nuclear Energy Systems, in Monroeville, Pennsylvania. From then to May, 1980, I served as the Manager of Materials Design. This group had the basic responsibility for materials R&D, and approval of materials for use in Westinghouse Pressurized Water reactors.
The duties further included determination of the necessary and sufficient requirements for reactor coolant and pool storage chemistries needed to ascure satisfactory performance under all warranted conditions. All reactor and out-reactor corrosion testing evaluations were done under the cognizance of this group.
t From May, 1980, and until November, 1983, I worked at the Westinghouse Advanced Energy Systems Division where I served as the Manager of Materials Interactions until November of 1983. These activities were primarily concerned with addressing materiale selection and evaluation for application in long term storage of light water reactor fuel in underground and above ground facilities.
Since 1979 I have also been a member of the American Society for Testing and Materials (ASTM) C26 Committee on the Nuclear Fuel Cycle. At the present time I am the Chairman of Sub-committee C26.02 (Fuel and Fertile Materials Specifications) and serve on C26.03 (Neutron Absorber Materials Specifications).
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