ML20140C858

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

ML20140C858
Person / Time
Site:	Turkey Point
Issue date:	01/22/1986
From:	Carr R BECHTEL GROUP, INC., FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML20140C819	List: ML20140C815 ML20140C823 ML20140C831 ML20140C844 ML20140C858 ML20140C866 ML20140C878 ML20140D130 ML20140D137 ML20140D155 ML20140D181 ML20140D224 ML20140D233 ML20140D253
References
OLA-2, NUDOCS 8601290011
Download: ML20140C858 (10)

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s7 h hf;E UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION (( > < z .'3?v', -

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARDf/ .

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In the Matter of ) Docket Nos. 50-250-OLA-2

) 50-251-OLA-2 FLORIDA POWER AND LIGHT COMPANY )

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(Turkey Point Nuclear Generating ) (Spent Fuel Pool Expansion)

Units 3 & 4) )

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AFFIDAVIT OF REBECCA K. CARR ON CONTENTION NO. 4

1. My name is Rebecca K. Carr. I am employed by Bechtel Power Corporation, Eastern Power Division, as an engineer in the Operating Services nuclear licensing group. As part of my previous duties as Group Leader within the Radiation Analysis Group of the Nuclear Engineering Staff, I supervised radiological evaluations performed in support of the expansion of spent fuel storage capacity at Turkey Point Units 3 and 4. A summary of my professional qualifications and experience is attached as Exhibit A and is incorporated herein by reference.

2. The purpose of my affidavit is to address Contention 4.

Contention 4 and the bases for the Contention are as follows:

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CONTENTION 4 That FPL has not provided a site specif~ic radiological analysis of a spent fuel boiling event thao! proves that offsite dose limits and personal exposure limits will not be exceeded in allowing the pool to boil with makeup water from only seismic Category 1 sources.

Bases for Contention FPL used calculation [ sic] performed for the Limerick plant to prove that they would not exceed radiological limits in a spent fuel pool boiling accident. FPL should not be allowed to extrapolate Limerick's study for their own, because there are many differences between the two plants which could be critical. For example, the saturation noble gas and iodine inventories could be greater for the Turkey Point plant as a result of fuel failure and increased enrichment; more than 1% of the fuel rods may be defective at Turkey Point because of the asme [ sic] fuel failure; and the gap activity of noble gases, such as krypton 85, and fission products such as radioactive iodine may also be greater for Turkey Point.

This affidavit demonstrates that the assumptions regarding saturation noble gas and iodine inventories, the percent fuel failure, and the gap activity used in the Turkey Point analysis of spent fuel pool boiling are appropriate, and that the doses calculated as a result of this analysis are acceptable.

3. Before addressing the contention and its bases, it is important to establish the overall basis of the Turkey Point spent fuel pool boiling analysis. In response to a question from the Nuclear llegulatory Commission (NRC) Staff, an analysis specific to Turkey Point was performed to confirm that pertinent dose limits would not be exceeded by allowing the spent fuel pools to bcil. 1/ As discussed further in the paragraphs below, 1/ Letter from J. W. Williams, (FPL) to Steven A. Varga (NRC),

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this analysis utilized assumptions and parameters that are either specific to Turkey Point or are generically applicable to pressurized water reactors (PWRs). To facilitate the Staff review of the analysis and to further establish the acceptability of the method and various assumptions used in the Turkey Point analysis, FPL's response to the Staff's question correctly stated that the analysis was " consistent with the methodology and

! assumptions utilized in a similar pool boiling calculation performed for the Limerick plant ... [that] was reviewed by NRC and found acceptable." (The Turkey Point calculation is also consistent with pool boiling analyses performed for other nuclear plants, not just Limerick's.) This was not to say that the pool boiling analysis for Turkey Point was the same as Limerick's, since it clearly was not. The assumptions used in the Turkey Point analysis were not the same in every case as that used in

, the Limerick analysis, and the Limerick analysis was not extra-polated to Turkey Point. The reference to Limerick's analysis i simply provided the NRC Staff a reference point for the method-I ology used for the Turkey Point calculation, since no specific guidance for performance of this type of analysis has been

! provided by the Staff (in the form of Standard Review Plan sections, Regulatory Guides, etc.). Only assumptions considered applicable to Turkey Point were used in the Turkey Point analy-sis.

I L-84-264, October 5, 1984, at 9-11.

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4. The saturation noble gas and iodine inventories used in the Turkey Point analysis were based on a power level of 2300 MWt with an initial enrichment of 4.5 w/o U-235 and a discharge burnup of 50,000 mwd /MTU. An initial enrichment of 4.5 w/o and a discharge burnup of 50,000 mwd /MTU are design basis values for I

the new high-density storage racks for Turkey Point. 2300 MWt is the steady state reactor thermal output design power level per Turkey Point Technical Specification 1.13. (The maximum licensed reactor thermal output is 2200 Mwt). With 72 metric tons uranium (MTU) in a full core of 157 assemblies, 50,000 mwd /MTU corres-ponds to approximately 52 months of full power operation, which is consistent with Turkey Point's 18 months fuel cycle (including refueling outages). By comparison, Limerick used source terms from TID-14844, " Calculation of Distance Factors for Power and Test Reactor Sites" (1962), 2/ corresponding to 3440 MWt and an i operating time of 54 months. Thus, the saturation noble gas and iodine inventories used in the Turkey Point analysis were based upon Turkey Point plant-specific data, and were not the same as or extrapolated from the inventories used in the Limerick analysis.

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2/ Final Safety Analysis Report, Limerick Generating Station, Units 1 and 2, Volume 10, Section 9.1.3.6 (hereinafter Limerick FSAR) i

5. The failed-fuel value of 1 percent used in the Turkey Point analysis is based on iodine concentrations measured in the reactor coolant at PWRs with zircaloy-clad fuel. 3/ 4/ The 1 percent assumption is conservative because it is approximately a factor of 10 higher than what has been measured for PWRs.

Furthermore, actual measurements at Turkey Point have shown that far less than 1 percent of the fuel has failed. 5/ The 1 percent figure is also consistent with the existing Turkey Point licensing basis, where the activity associated with 1 percent failed-fuel is used in Section 11 of the updated FSAR 6/ as the basis for the shielding and sizing of components such as demineralizers and gas decay tanks. Most plants, including Limerick, 7/ use a failed-fuel fraction of 1 percent or less.

Thus, although the Turkey Point analysis used an assumption of 1 3/ " Calculation of Releases of Radioactive Materials in Gaseous and Liquid Effluents from Pressurized Water Reactors (PWR-GALE Code)," NUREG-0017, April 1976, Table 2-10.

4/ " Source Terms Data for Westinghouse Pressurized Water Reactors," WCAP-8253, July 1975, pp. 4-12 to 4-14, Tables 4-13-A-1, 4-13-A-2, and 4-14.

5/ In 1983, FPL requested and received an amendment to its

' Turkey Point licenses regarding technical specification requirements for maximum reactor coolant activity. This request was made in response to relatively high levels of activity in the coolant during Cycle 8 for Unit 3.

Examination of the fuel from Unit 3 Cycle 8 revealed that about 0.1% of the fuel rods had failed (12g., had experienced pin hole leaks).

6/ Updated Final Safety Analysis Report, Turkey Point Units 3 and 4, Docket Nos. 50-250 and 50-251, Section 11.1.3.

7/ Limerick FSAR.

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percent failed fuel that was also used at Limerick, this assump-tion has been shown to be generally applicable to PWRs and is conservative based upon actual Turkey Point data.

6. For the Turkey Point analysis, the activity in the gap of the fuel rods (12g., space between fuel cladding and fuel pellet) was assumed to be 10 percent of the total noble gases except Krypton-85, 30 percent of Krypton-85, and 10 percent of the total lodines contained in the fuel rods. The Limerick analysis also assumed a gap activity of 10% for lodines to calculate thyroid doses. 8/ The figures used in the Turkey Point analysis are the same as those specified in NRC Regulatory Guide 1.25, 9/ paragraph C.1.d, and are widely accepted within the nuclear industry as conservative. Thus, although the Turkey Point and the Limerick analyses both used the same assumptions I

regarding gap activity, these assumptions are the same as those specified in Regulatory Guide 1.25 and are conservative for application to Turkey Point.

7. The results of.the Turkey Point analysis indicated worst case site boundary 2-hour doses o. 0.28 rem to the thyroid 4 and 0.00018 rem to the whole body. Worst case 30-day doses at the low population zone were 0.56 Rem to the thyroid and 0.00018 8/ Limerick FSAR.

9/ Safety Guide 25, " Assumptions Used for Evaluating the

, Potential Radiological Consequences of a Fuel Handling Accident in the Fuel Handling and Storage Facility for Boiling and Pressurized Water Reactors" (March 23, 1972).

rem to the whole body. These doses are a small fraction 10/ of the 10 CFR Part 100 guideline values of 300 rem to the thyroid and 25 rem to the whole body. That is, the doses are less than 30 rem (10% of 300) to the thyroid and less than 2.5 rem (10% of

, 25) to the whole body.

8. The following conclusions can be drawn concerning the Turkey Point spent fuel pool boiling analysis:

a) A site-specific analysis was performed which utilized conservative assumptions and parameters specific to Turkey Point or generically applicable to PWRs.

b) Although the general methodology used for the Turkey Point pool boiling analysis was consistent with the methodology used in the Limerick pool boiling analysis, the Limerick analysis and results were not extrapolated to the Turkey Point calculation.

c) The offsite doses calculated for the Turkey Point pool boiling event are a small fraction of the 10 CFR Part 100 guidelines.

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10/ "Small fraction" is defined as less than 10% of the Part 100 guidelines.

. O FURTHER AFFIANT SAYETH NOT The foregoing is true and correct to the best of my knowledge, information and belief.

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Re6ecca K. Cdrr STATE OF MARYLAND )

COUNTY OF MONTGOMERY)

Subscribed and sworn to before me this Mb day o , 1986. My commission expires:

NOTARY PUBLIC b.

My Commission Expires July 1,1986 O

EXHIBIT A STATEMENT OF PROFESSIONAL QUALIFICATIONS OF REBECCA K. CARR POSITION Project Licensing Engineer, Bechtel Power Corporation EDUCATION BS, Nuclear Engineering, Pennsylvania State University, 1980

SUMMARY

OF EXPERIENCE WITH BECHTEL:

Project licensing engineer, 1984-Present Staff group leader, shielding, 1983-1984 Staff engineer, radiation analysis, 1980-1983 EXPERIENCE WITH BECHTEL Ms. Carr is currently serving as licensing engineer with the Operating Services Group. This group provides engineering services to utilities with operating nuclear power plants, including the North Anna Power Station, Surry Power Station, and Millstone Nuclear Power Station. Her responsibilities include safety reviews of design changes to ensure com-pliance with NRC requirements, FSAR criteria, and plant technical specifications. Ms. Carr is also involved with licensing the steam generator replacement at Indian Point Station Unit 3, the independent spent fuel storage instal-lation at Surry Power Station, and the spent fuel pool reracking at Turkey Point Plant.

Prior to this, Ms. Carr served as an engineer in the nuclear licensing group for the two-unit Grand Gulf Nuclear Station (Mark III). She was responsible for coordinating imple-mentation of regulatory requirements, safety reviews and staff analyses for the operating Unit 1. While supporting the Unit 2 design effort, she was the lead engineer for the computer based licensing commitment tracking system.

Previously, Ms. Carr served as group leader - radiation analysis, on the Nuclear Engineering Department staff. In this capacity, she was responsible for shielding and dose analyses in support of both BWR and PWR projects in the construction and operating phases. Plants included the Grand Gulf Nuclear Station, Edwin I. Hatch Nuclear Plant, Wolf Creek Generating Station, Callaway Plant, Joseph M.

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Farley Nuclear Plant, Turkey Point Plant, and Calvert Cliffs Nuclear Power Plant. Work included operating and accident doses, equipment qualification (radiation), spent fuel pool reracking, low level waste processing and storage, and steam generator replacement.

As a staff engineer, Ms. Carr was involved in the analysis of airborne radiation releases and doses within plants and in the environment resulting from normal operation and postulated accidents. This included control rooms and emergency facilities. She also performed shielding analy-ses, including neutron streaming, and fulfilled a licensing assignment at the Three Mile Island jobsite. In addition, Ms. Carr participated in several audits of design and analysis work done by projects.

PROFESSIONAL MEMBERSHIPS American Nuclear Society and Society of Women Engineers

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