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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
_ ;
- r ,
. UNITED STATES OF AMERICA
. NUCLEAR REGULATORY. COMMISSION-i BEFORE TIIE ATOMIC SAFETY AND LICENSING: BOARD 1-l y 'In the Matter of ) .
j
) Docket Nos. 50-250 OLA-2 1 1 FLORIDA POWER & LIGHT COMPANY ) 50-251 OLA-2 i )
l- (Turkey Point Plant, Units 3 and 4) ) (SFP Expansion) '
F i
j, AFFIDAVIT OF BERNARD TUROVLIN ON CONTENTION 6 1
I, Bernard Turovlin, being duly sworn, state as follows:
- 1. I an employed by the U.S. Nuclear Regulatory Commission as a ' , ,
i Material Engineer in the Engineering Branch of the Office of Nuclear Reactor-j Regulation. Prior to November 24, 1985, I .was a Chemical Engineer in the f Chemical and Corrosion Technology Section, Chemical Engineering Branch, I
Division of Engineering. A copy of my professional qualifications is attached.
. t
- 2. The purpose of my affidavit is to. address . Contention 6, with f' respect to any potential for loss of material integrity 'due to the increased i
j fuel storage capacity and the longer term storage of some fuel elements. With l
regard to Contention 6, I have read " Licensee's . Motion for Summary i
l Disposition of Intervenors' Contentions" and " Licensee's Statement of Material
! Facts as to Which There Is No Genuine Issue T6 Be Heard With Respect to
} Intervenors' Contentions," dated January 23,-1986. The material facts stated i
j in relation to Contention 6 are correct and I concur.in the conclusions '
{ reached in .the supporting affidavits. Contention 6 and the bases for the.
contentions state as follows:
2 I
i k 8602240043 i PDR ADOCM
- - -e. -
I o
i-j* .
o.
Contention 6 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 ' radio-I activity, as a result of increased capacity and long term storago, in the spent fuel pool.
.i 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 radiation 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.
(c) deterioration of concrete pool structure as a result of exposure to increased heat over extended periods of time.
, 3. The materials that can be affected by increased . storage capacity and extended time in storage of fuel elements are the fuel pin (or rod) cladding, fuel element materials other than cladding, storage rack materials, storage pool liner, and storage pool concrete structure.
- 4. Redesign of the spent fuel pool racks increases only the storage capacity of the pool and not the frequency or the amount of newly discharged fuel to be placed in the pool during each fuel reload cycle. The rerack i
design does not change the radioactivity of the newly discharged fuel placed in the storage pool. Before the current amendments authorizing the increased storage capacity of the Turkey Point spent fuel pools of 1404 cells, the authorized storage capacity of Units 3 and 4 was 636 elements. Each unit had a usable storage capacity of only 621 and 614 fuel elements, respectively,
r due to piping and other futerference. Based upon the estimated number of fuel elements to be discharged in future refuelings, the storage capacity would not have been exceeded until after the Cycle 13 refueling in December 1989 and December 1988 for Units 3 and 4, respectively. The oldest discharged elements, which in other circumstances would have been sent away for reprocessing will, in 1988 for Unit 4 and 1989 for Unit 3, be i stored in the expanded capacity. These first reload discharged elements will i
have by then aged in the pool for at least 13.5 years and the radiation and thermal output from these elements will have decreased to minor levels. This rerack allows the storage of an additional 780 elements all of which will have been in residence in the storage pool for at least 13.5 years.
- 5. Fuel elements stored over 13.5 years contribute little to the heat load of the spent fuel storage pool. These elements cause an increase in maximum pool temperature of approximately 1 to 2 degrees when newly discharged fuel is added to the pool. As these old elements continue to age, they contribute less and less to the heat load of the pool. The heat load contribution of all the aged elements during the last 10 refuelings (calculated by Westinghouse) only raises the maximum pool temperature after refueling to 143cF and decreases thereafter. This maximum pool temperature is within NRC guidelines.
- 6. As calculated by Westinghouse, the materials in the spent fuel pool 13 can be expected to be exposed to a maximum neutron fluence of 4.8 x 10 0
neutrons /cm and 1.9 x 10 rads of gamma radiation. Of the materials in the spent fuel pool, only the first discharged elements can be expected to receive this amount of radiation. The pool liner and pool concrete structure i
- i s..
_4-
-2.
I while in place in the pool for the entire ' storage period will have the radiation -
- i. attenuated by distance from the radiation sources (the aged elements) and the
- j. shielding afforded by the water. The fuel element racks which are new will i
have the shortest residence in the pool of ' all .the materials. except newly i
discharged fuel. 1 l 7. The new ~ spent fuel storage racks are constructed of Type 304 1
j stainless steel as the load carrying structure and use sheets'of Boraflex (held.
i i in place by.a thin-walled stainless steel wrapper) on the outer surface of the
} storage cells and between the cells as a neutron absorbing material. Type i l 304 stainless steel is also used in fuel element hardware and the pool liner.
Other metallic materials in the storage pool are Inconel and Zircaloy parts of !
l the fuel element assemblies. The pool structure is concrete composed of ASTM C-150 type II cement and aggregate meeting the requirements of ASTM i
j C33 and reinforcing bars of ASTM A-15 steel.
l 8. Stainless steel clad fuel elements have been stored in PWR ~ spent i fuel pools more than 18 years. This represents the maximum exposure any i
j stainless steel can accumulate in a spent fuel pool since the steel is directly
- against the fuel as the cladding material. Destructive and visual examination i
of this material produced no evidence of significant degradation of the
, stainless steel. Zirealoy-clad rods were examined after nearly 21 years of
{ water storage. A comparison of cladding properties with those measured 20 I
].
years earlier on rods from the same fuel assembly showed that no detectable f changes had occurred in corrosion film thickness , cladding mechanical ;
properties and fission gas release. Zircaloy-clad fuel elements which had i
i been charged into Canada's NPD reactor in 1962 are continuing to operate i
satisfactorily (i.e., with no apparent degradation) after 22 years of exposure to far greater radiation than any element in the Turkey Point spent fuel pools will .reccive during residence in the pools. W.J. Bailey, N.B . Johnson , Jr.
et al . , Surveillance of Spent Fuel in Wet Storage. NP-3765 October 1984 Electric Power Research Institute.
- 9. Irradiated fuel has been discharged into water pools since the first irradiated fuel was discharged from the Oak Ridge X-10 reactor into its pool in November 1943. Spent commercial fuel is presently stored in water-filled concrete pools that are lined with stainless steel. Some of these pools have been in use for more than 25 years. During this extended storage time there has not been any evidence of the degradation of the concrete structure of any of the spent fuel pools. In addition to the excellent performance of the concrete in the spent fuel pools, the dismantling of many concrete structures i
used as shielding, has not produced any evidence of degradation due to radiation heating or radiation.
- 10. In granting the previous rerack amendments for Turkey Point, the Staff approved the use of concrete -- as well as stainless steel in the pool liner, rack lattice structure and fuel storage cells -- until the end of the life of the plant. The NRC issued a Safety Evaluation (SE), dated November 21, 1984, which addressed the materials compatibility and corrosion degradation 1 aspects of the current spent fuel pool modifications (i .e . , reracking) and
' concluded that the Licensee complies with General Design Criteria 61 and 62 of 10 CFR Part 50, Appendix A. This conclusion was supported by finding that the environmental compatibility and stability of the materials used in the expanded spent fuel pools is adequate based on test data and actual
d i .
9 A
experience in operating reactors and that Licensee has adopted an acceptable pool materials surveillance program. The only materials used in the s
modifications that had not been previously approved were the' Boraflex nuclear absorber strips. Boraflex, has undergone extensive testing to study the effects of gamma irradiation in various environments and to verify its
! l l structural integrity and suitability as a neutron absorbing material. The tests show that Boraflex maintains its neutron attenuation capabilities after i
- being subjected to gamma radiation. Tests also show that Doraflex is
- - unaffected by the pool water environment and will not be degraded by j corrosion. To provide added assurance that no unexpected corrosion or I degradation of the integrity of the racks, the Licensee committed to conduct a f long term materials surveillance program. The Staff reviewed the Licensee's material surveillance program and found that the program provided reasonable assurance that the Boraflex material will be monitored so that the Boraflex will perform its function for the life of the _ plant. SE Section 2.2.
- 11. Because materials degradation in the spent fuel pool, either from i
- i radiation effects or corrosion is a long term effect, (C. Czajkowski, J.R.
j Weeks, and S.R. Protter. " Corrosion of Structural and Poison Material in
, Spent Fuel Storage Pools ," CORROSION /81, Paper 163, Toronto , Ontario, j Canada, April 6-10, 1981. National Association of Corrosion Engineers), the Staff's position regarding spent fuel modification requires that pool modifications include a long term material surveillance program. Since 1978 all i spent fuel pool modifications that have included the use of poison material to 7
control criticality have been required to have a material surveillance program or its equivalent. "OT Position for Review and Acceptance of Spent Fuel i
i J
_7_
Storage and Handling Applications," dated April 14, 1978. Many of the pools have used stainless steel and Boraflex. While the materials in these surveillance programs are not identical (i.e., not processed at the same time) they are similar to the extent that degradation information can be used to evaluate the behavior of the Turkey Point material. Experience with these leading ongoing surveillance programs has provided many hours of spent fuel pool exposure without significant degradation of the materials.
- 12. Experience world wide with stored fuel has shown (Technical Report Series No. 218: " Storage of Water Reactor Spent Fuel in Water Pools -
Survey of World Experience," International Atomic Energy Agency, Vienna, Austria , 1982) and the Commission concluded in its " Waste Confidence Decision," dated August 22, 1984 (49 Fed. Reg. 3458, August 31,1984), that spent fuel can be stored safely--either at reactor sites or at independent installations--for up to 30 years beyond the expiration of reactor operating licenses without significant degradation.
- 13. As noted in the recent International Atomic Energy Agency world survey cited above, the 40 years of positive experience with wet storage illustrates that it is a fully-developed technology with no associated major technological problems . Spent fuel storage pools are operated without significant risk to the public or the plant personnel. There is substantial technical basis for allowing spent fuel to remain in wet storage for several decades. There continues to ha no evidence that Zircaloy-clad fuel degrades significantly during wet storage -- this includes: continuous storage of fuel elements for as many as 25 years and irradiation of fuel in reactors for as long as 22 years. Cladding defects have had little impact during wet i
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<3 storage. Experience to date with handling operations at spent fuel storage i
pools indicates that failed fuel rods can be accommodated e Very few fuel o e assemblies have suffered major mechanical danIage as aer'sult of handling operations at spent fuel storage pools, s r
- 14. In summary, the materials in the spent fuel pools will not degrade significantly because of the increased pool storage capacity or the storage of elements longer than 13.5 years. The stainless steel storage racks which are
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yew will not be degraded because of increased radiation by agad fuel elements. The contribution of radiation to the adjacent structure decreases Y w as the elements age. The Staff evaluated the use of stainless steels in ,
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storage racks in approving the prior. Turkey Point' rerack amendments and concluded that the stainless steel racks could be used to the end of life of the plant. Many experiments have shown that stainless, as well as the Inconel and Zircaloy in the aged fuel elements, can be exposed to many orders of magnitude of radiation greater than can be reasonably expected at thie rack structure without significant degradation. In addition, there is no evidence of degradation due to rbdiation or heat of storage pool liners or concrete structure in spent fuel pools world wide. While the Staff guidelines suggest a maximum pool water temperature of 1400 F after normal discharge, any of the materials in the pool can .be exposed to much hi'gher temperatures 1
(145o F to 1800 F) for extended periods without detectable degradation. -
Accordingly, the Staff ha$ adeouately considered and analyzed degradation in materials integrity resulting from increased generation of heat an$ f, radioactivity, as a result of the increased capacity and the extended storage time of aged fuel elements in the Turkey Point spent fuel pools.
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The foregoing and the attached statement .of professional . qualifications are true and correct to the best of my knowledge and belief, h d.
Bernard Turo~vlin Suscribed and sworn to before me this Li, day of February,1986 k(??)
Notary Public k
My commission expires: y///76 1
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,9 PROFESSIONAL QUALIFICATIONS BERNARD 'rUROVLIN >
PROFESSIONAL ENGINEER - CALIFORNIA #9180 MAY 1949 I am employed by the U.S. Nuclear Regulatory Commission as a Materials Engineer in the Engineer Branch Office of Nuclear Reactor Regulation.
Prior to November 24, 1985, I was a Corrosion Engineer in the Chemical Engineering Branch of the Office . of Nuclear Reactor Regulation. I am responsible for safety review and evaluation of the degradation of materials used in the construction and operation of nuclear power plants. ,
I received a Bachelor of Science degree from the University of Illinois in 1941.
I have been associated with nuclear energy development and construction as an engineer or metallurgist since 1942. I have been employed in these capacities by the f.fetallurgical Laboratory of the University of Chicago, the Los Alamos Laboratory, the Brookhaven National Laboratory, Combus-tion Engineering Inc., General Atomic, General Dynamics /Convair, and the U.S. Army Nuclear Power Group. I have spent a minimum of 4 years at each location.
I have been responsible for the development of basic fabrication techniques, non-destructive examination, and failure analysis. I have done engineering design and component testing for various components used in the nuclear energy field.
I have more than 15 patents for various components and techniques used in the above field, i
I have published more than a dozen papere related to this field. '