ML20238A236
| ML20238A236 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/31/1987 |
| From: | Gouldy R, Kilp G FLORIDA POWER & LIGHT CO., WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | |
| Shared Package | |
| ML20237L743 | List: |
| References | |
| OLA-2, NUDOCS 8709090202 | |
| Download: ML20238A236 (49) | |
Text
{{#Wiki_filter:e . h UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION E 2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3 i 4 In the Matter of ) Docket Nos. 50-250-OLA-2 5 ) 50-251-OLA-2 FLORIDA POWER & LIGHT COMPANY ) 6 (Turkey Point Nuclear Generating ) (Spent Fuel Pool Expansion) Station, Units 3 & 4) ) 7 8 Testimony of Dr. Gerald R. Kilp and Russell Gouldy on Contention Number 6 9 10 01: Dr. Kilp, please state your name and address. 11 A1: (Kilp) My name is Gerald R. Kilp. I am an 12 Advisory Engineer in the Engineering Department of 13 the Nuclear Fuel Division of the Westinghouse 14 Electric Corporation. My business address is 15 Westinghouse Electric Corporation, Monroeville 16 Mall Off e Building, P.O. Box 3912, Pittsburgh, 17 Pennsylvania, 15230. 18 02: Please describe your professional qualifications 19 and experience. 20 A2: (Kilp) A summary of my professional qualifica-21 tions and experience is attached hereto as Exhibit 22 A, which is incorporated herein by reference. 23 03: Mr. Gouldy, please state your name and address. 24 25 26 27 llR09090202 070331 g ADOCK 05000250 PDR 28
. 1 l
1 A3: (Gouldy) My name is Russell Gouldy. I am a senior I l 2 engineer in the Nuclear Licensing Department of 3 Florida Power & Light Company (FPL). My business , 4 address is 700 Universe Boulevard, Juno Beach, 5 Florida 33408. 6 04: Please describe your professional qualifications 7 and experience. 8 A4: (Gouldy). A summary of my professional qualifi-9 cations and experience is attached hereto as 10 Exhibit B, which is incorporated herein by , i 11 reference. 12 05: What is the purpose of your testimony? 13 A5: (Both) The purpose of our testimony is to address 14 Contention 6. Contention 6 and the bases for 15 Contention 6 are as follows: 16 Contention 6 17 The Licensee and Staff have not 18 adequately considered or analyzed materials deterioration or failure in 19 materials integrity resulting from the increased generation of heat and radio-20 activity, as a result of increased capacity and long-term storage, in the 21 spent fuel pool. 22 l Bases for Contention l 23 The spent fuel facility at Turkey Point was 24 originally designed to store a lesser amount of Zuel for a short period of time. Some of j 25 the problems that have not been analyzed < properly are: l 26 j 27 i 28 l i l l ____J
; 4 l~ an ) - ' deterioration.o'f fuel. cladding as a I' result of increased l exposure and-2 decay heat and' radiation levels during extended ~ periods of pool 3 storage.
4 (b) . loss of materials integrity of storage rack and pool liner as a ' 5 result of' exposure to. higher' levels of. radiation over longer periods. 6 (c) deter.ioration of concrete pool 7 structure-as a result of exposure to increased heat over extended periods 8- of time. 9 In particular, the purpose of our testimony 10' is to address the materials integrity of the fuel 11- assemblies and spect fuel storage racks 11n the 12 spent; fuel pool environment. The Testimony of l 13 William C. Hopkins on Contention Number 6 and the u 1 14 Testimony of Eugene W. Thomas on Contention Number ! i 15 .6 discuss.the materials integrity-of the spent 16 fuel pool liner and spent fuel pool concrete 17 structure, and the Testimony of William A. Boyd.on 18 Contention Number 6 discusses the effects of 19 postulated gaps in the Boraflex plates on the-k-20 effective of the Turkey Point spent fuel pools. i 1 21 06: What particular topics does your testimony 22 address? 23 A6: (Both) Our testimony addressing Contention 6 1?4 covers fiVe topics. First, the type of materials,
'25 and the radiation and heat loads, present an the 26' Turkey Point spent fuel pools are identified.
27 Second, the materials integrity of the fuel 28
.1
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, 1- ' assemblies is discussed. Third, the materials
,2 integrity of the stainless steel in the spent' fuel
- 3. storage racks is discussed. . Fourth, the materials-l 4s integrity of the Boraflex in the spent fuel'
!S. storage racks is discussed. Finally, the leakage 6' -detection system for the spent' fuel pools is 7 discussed.
8 4 MATERIALS AND RADIATION LEVELS 9 IN THE SPENT FUEL POOLS
,10 07: What types of materials are present in the Turkey 11 Point spent fuel pools?
'12' A7: (Both) The Turkey Point spent fuel pools consist
.13 of a concrete pool structure with Type 304 1 14 stainless steel pool liner. The fuel assemblies
- 15. are comprised of Type 304 stainless steel, 16 Inconel, and Zircaloy. The new spent fuel storage l 17' racks are also constructed of Type 304 stainless 18 steel and utilize Boraflex, a neutron absorbing i i
19 raterial. The Boraflex is not intended to provide J 20 any structural support. 21 Q8: What heat loads will be present in the Turkey 22 Point spent fuel pools?
- 23. A8: (Both) As discussed at pages 43-52 of the 24 Licensing Board's Memorandum and Order of March 25 25, 1987, the temperatures in the spent fuel pool l
'26- could approach boiling during a loss of cooling 27 accident. The temperature for normal conditions l
)
28
i ^?' lA 4-f, i .- 1' is:not_ expected to exceed 143 F and.willLusually 2' be less. This temperature' represents only a 3 s2ight increase'over the 127 F. maximum temperature 4L which.was predicted to occur under normal condi-1 5 tions prior to the spent fuel' pool expansion. :] 6' 09:- What types of radiation will be present in the 7 Turkey Point spent fuel pools?' 8 A9: (Kilp) Four types of radiation (alpha, beta,. 9' gamma and neutron) will be present in varying 10 degrees in the spent fuel pool. For the types of
.11 material in the spent fuel pool (concrete, 12 stainless steel, Inconel, and Zircaloy) alpha and
- 13. aeta radiation are not a concern because they do 14 -not have an ability to penetrate these materials-15 deeply enough to appre'ciably affect their 16 structural integrity. Calculations were performed 17 to determine the cumulative gamma and neutron
-18 exposures of materials present in the Turkey Point 19 spent fuel pool for forty years. The results of 20 these calculations indicate that the cumulative 21 gamma dose would be 1.9 x 10 10 rads and the-22 cumulative neutron fluence would be 4.8 x 10 13 2
m 23 n/cm . These numbers were conservatively calcu-24 lated, assuming an infinite array of storage l' 25. cells, each containing a spent fuel assembly with ! 26 an average burnup of 36,000 Mega'.catt-days per 27 28 1 l.-
i
)
1 metric ton of uranium (mwd /MTU). This radiation 3 2 level is not appreciably higher than would have l 3 existed absent the spent fuel pool expansion. I 4 Q10: Interveners state that the burnup of fuel 5 assemblies in the Turkey Point spent fuel pool may j 1 6 reach as high as 55,000 mwd /MTU. Please identify I 7 the maximum expected burn up for the spent fuel to b be stored at Turkey Point, and explain why a 9 burnup of 36,000 mwd /MTU was used in your 10 calculation of radiation levels in the spent fuel 11 pool. 12 A10: (Gouldy) To date, the average burnup of each of 13 the core offloads of Turkey Point has not exceeded 14 36,000 mwd /MTU. For example, as shown on Table 1, 15 the average burnup of.the individual core offloads 16 at Turkey Point Unit 3 has ranged between 17 approximately 15,000 and 32,000 mwd /MTU, and the 18 average of all of the offloads is less than 29,000 19 mwd /MTU. Consequently, 36,000 mwd /MTU was an 20 appropriate burnup to use in calculating a forty-21 year dose in the Turkey Point spent fuel pools. 22 FPL is considering whether to increase its 23 fuel burnup beginning 'rith Cycle 12 in 1988. As a 24 result, average burnup may be as high as 42,000 to 25 45,000 mwd /MTU for some core offloads in the 26 future (with a naximum burnup per assembly of less 27 28
')
_3-2' i 7-y, t ' f 4
'l than:50,000 mwd /MTU). FPL has no' plans to
'l I
4 t> 2' increase:the; average burnup of.its fuel beyond q J
'3 -45,000' mwd /MTU. j 4-i
, '5 i i
-6 i I
7 .\ 8 9' i 10. 11 121
- -13 ,
14-15 i 16-17-18' ; 19 20 21 22 23 24 r .. 25 1 I '> 26 27 28
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;b 1 ' ,- '1-Table'l I 1
2 Averace Burnuo of Cora Offloads at'Turkev Point Unit 3 j Cycle-3 Averaae'Burnuo-(mwd /MTU) 4 -1 14,701 1 2 .25,541: 3, -{ 5' 29,320 {
, 4 28,603 l
' .6 5- 31,539 6 .31,736
)
4
.7 7 31,330 -l 8 32,420 8 9 29,984 q 10 31',451 4 9 11 29,925 Total .28,631 -<
10 i The burnup of an individual asa %oly within a core offload ] 11 . may'.be higher'or lower than the. average burnup of the core 1) 12- )
. offload. Burnups of individual aesemblies stored in the- j 13 Unit.3. spent fuel pool range from a; low of approximately q 14 7,000 mwd /MTU to a high of approximately 40,000 mwd /MTU.
15- i Only 37 of the 545 assemblies stored in the Unit 3-spent g 16 i fuel pool through Cycle 11 have burnups in excess of 36,000' {
.17 .
l mwd /MTU.
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20 - 21 1 22 23 , .24 l 1 25-ll .26 k 4 J 27L
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l' Oll: What impact would use'of a burnup of 55,000 k 2 mwd /MTU rather than 36,000 mwd /MTU have had on / 3 your calculated radiation levels in the Turkey 4 Point spent fuel pools? 5 All: (Kilp) The impact of increasing the burnup from ; i 6 36,000. mwd /MTU to 55,000 mwd /MTU depends upon the ; 7 length of storage of the fuel. For a one-year 8 storage period, the accumulated gamma exposure l 9 would be about 30% higher for fuel with a burnup 10 of 55,000 mwd /MTU than for fuel with a burnup of 11 36,000 mwd /MTU. For a forty-year storage period, 12 the accumulated gamma exposure would be about 50% 13 higher for fuel with a burnup of 55,000 mwd /MTU 14 than for fuel with a burnup of 36,000 mwd /MTU. 15 Thus, for an infinite array of storage ce]ls, each ; 16 containing a spent fuel assembly with an average 17 burnup of 55,000 mwd /MTU, the accumulated gamma 18 dose would be about 2.9 x 10 10 rads for a forty-19 year storage period. 20 Increasing the burnup from 36,000 mwd /MTU to . 21 55,000 mwd /MTU also has an impact on the cumula-22 tive neutron fluence. The cumulative neutron 23 fluence from fuel with a burnup of 55,000 MWa/MTU 24 is'about 3 to 3.5 times larger than from fuel with
~ 25 a burnup of 36,000 MTd/MTU, for any storage period 26 of forty years or less. Thus, for an infinite 27 array of storage cells, each containing a spent 28 I
N ._AA_-...- --
. 1 fuel assembly with an average burnup of 55,000 j l
2 mwd /MTU, the cumulative neutron fluence would be R 3 about 1.7 r. 10 14 n/cm 2 for a forty-year storage 4 period. ; 5 It should be noted that these calculated 6 radiation levels are conservative. Even if it is 7 assumed that FPL was planning to store fuel with a 8 burnup of 55,000 mwd /MTU, the radiation levels 9 would be lower than calculated because (1) the 10 existing stored fuel is of a relatively low
'll burnup, thereby essuring that the average burnup 12 of the fuel in the spent fuel pool would be well-13 below 55,000 mwd /MTU, and (2) the 55,.000 MW6/MTU 14 fuel would not be scored for the licensed lifetime 15 of Turkey Point as assumed in the calculation 16 since Turkey Point has already operated for 15 17 years.
18 MATERIALS INTEGRITY OF THE 19 FUEL AJEEMBLIES 20 Q12: What levels of radiation are the fuel assemblies 21 and the cladding of the fuel rods designed to 22 withstand? 23 A12: (Kilp) The fuel assemblies, including the 24 cladding of the fuel rods, ara designed to with-2S stand the very high radiation levels present in a 26 reactor. IbL neutron fluence levels that the fuel 27 assemblies, including the Zircaloy cladding, are 28
1 subjected to during storage in a spent fuel pool 2 are orders of magnitude lower than those which the 3 assemblies and cladding experience when exposed in 4 a reactor during full power operation. As a 5 result, the total neutron fluence exposure of the : 6 cladding is approximately 10 22 neutrons /cm 2 while 7 in the reactor, compared to about 5 x 10 13 8 2 neutrons /cm during a forty-year exposure in the 9 spent fuel pool (assuming storage of fuel with 10 burnup of 36,000 mwd /MTU). This difference is 11 approximately 8 orders of magnitude. Putting it 12 another way, the added neutron exposure after 13 forty years in the spent fuel pool is equivalent 14 to approximately one second in a reactor at full 15 power. Thus, the neutron radiation levels in the 16 spent fuel pool will have an insignificant impact 17 on the integrity of the fuel assemblies and the 18 fuel cladding. 19 Neutrons are the cause of virtually all the 20 irradiation induced changes in Zircaloy, Inconel, 21 and the stainless steel used for the fuel 22 assemblies. These materials are essentially 23 unaffected by the alpha, beta, and gamma radia-24 tion, which comprise the major fraction of the 25 radiation in the spent fuel pool. In particular, 26 although gamma radiation is a penetrating ; 27 radiation, its primary effect on these materials 28
1 is heating and not structural damage at the levels 2 of radiation expected in the Turkey Point spent 3 fuel pool. 4 Q13: Were the fuel assemblies designed to withstand the { 5 temperatures and heat loads expected in the Turkey 6 Point spent fuel pools? 7 A13: (Kilp) Yes. The fuel assemblies, including the 8 fuel cladding, were designed to withstand the 9 temperatures and heat loads present during 10 operation in the reactor, which are far more
.11 severe than those present in the spent fuel pool.
12 The zirconium used in the Zircaloy cladding is j 13 considered immune to stress corrosion cracking in 14 water environments like the spent fuel pool. 15 Corrosion and hydriding are the only realistic l 1 16 threats to fuel rod cladding integrity during ) i 17 storage in the pool. These can be shown to be of 18 no concern by considering the corrosion properties 19 of the Zircaloys used for modern light water I 20 reactor (LWR) fuel cladding. At 500U F, and at the 21 much higher heat fluxes in the reactor, the 22 corrosion rate of Zircaloy is approximately l l 23 1/100,000 inches per year. At this rate, it would 24 take over 100 years to corrode 1/1000 inches of 25 cladding (compared to at least 20/1000 inches of 26 Zircaloy wall thickness remaining when a fuel ' I 27 assembly is removed from the reactor for storage 28
- 13 -
i a
, lL .in;thelpool).
This' amount of corrosion would have j ,
-2 an insignificantrimpact upon-the structural: i 1
0 32 ' integrity oflthe fuel cladding. Withithe'much
- 4. -lower. temperatures actually' expected for the' spent o L5" fuel
- pool, theicorrosion rate would be substan--
y 6, tially lower. Thus, corrosion is'not expected to
-7 have any' appreciable impact upon the structural 8' integrity of the Zircaloy cladding. Hydriding,
' 9, 'which at'very high' levels canLlead to r ;10 '
embrittlement of the cladding, is a direct.
- 11. funct. ion of cladding corrosion in a water 12 ' environment. Since'the corrosion' rate is L13 ' virtually nil, hydriding in the spentLfuel pool r14 . will be nil also.
15 Similar conclusions can be applied to the 16 other fuel assembly components (stainless steel 17' and Inconel) which mechanically support the fuel j
'18 rods. All of.these materials have-been ahown by i
- 19. test and enperience to be virtually immune to 20 corrasion at spent fuel pool temperatures. For 21 example, it has been estimated that the corrosion 22/ of Type 304 stainless steel will not exceed 23 6/10,000 inches for one hundred years in an 24 oxygenated borated water environment similar to 25 that in the Turkey Point spent fuel pool.
26 Corrosion rates for Inconel are at least as low as
'27 those for stainless steel. Additionally, since 28
. <* 1 stainless steel, Inconel and Zircaloy all form 2 protective oxide films, no significant galvanic 3 attack is expected among these materials.
4 014: What has been the industry experience with storage 5 of spent fuel? 1 6 A14: (Kilp) The most convincing evidence that fuel 7 assemblies do not deteriorate in spent fuel pool 8 comes from actual experience. Visual observations 9 and radiation monitoring of pool water were 10 documented in a comprehensive review of light 11 water reactor behavior during pool storage by A. 12 B. Johnson (" Behavior of Spent Nuclear Fuel in 13 Water Storage," BNWL 2256, September, 1977). This I 14 report demonstrates that spent fuel has been 15 stored safely for mora than two decades. 16 Johnson's paper also reports on the results of a 17 number of hot cell examinations on fuel stored for 18 more than ten years which show no measurable 19 changes due to corrosion or hydriding and no loss 20 of fuel integrity. More recent examinations of 21 Zircaloy clad spent fuel stored in w:ter pools 22 have included numcrous examinations of fuel stored 23 from four co seven years; examinations (including 24 visual, metallurgical, and non-destructive 25 examinations) of fuel stored between 8 and 16 26 years; and an examination which provided metallur-27 igical data on fuel stored for nearly 21 years. 28
- i h
f,'
. l ~In all of these cases, there have been no reports-
- 2 that Zircaloy clad fuel' degrades significantly' 3 L i L '3 durino wet storage. -
4 Q15:1 Do yo'1 hat, any' conclusion regarding the ability 5 to store spent fuel at Turkey Point without 6 degradation? I
~ .7 ' A15: (Kilp) Yes. For all'of th'e above reasons, I 8 c'nclude.that Zircaloy clad fuel and the fuel 9' assemblies can safely be stored-well in excess of
.. i 10 forty years in the Turkey Point spent fuel. pool
'll without appreciable deterioration.
12 Ol6:. If you had assumed a burnup of 55,000 mwd /MTU, 13 what impact, if any, would this. assumption have . 14 had on your conclusions regarding the material 15 integrity of the stored spent fuel assemblies? !
\
16 A16: (Kilp). Non'e. As I previously discussed, storage 17 of spent fuel with a burnup of 55,000 mwd /MTU
-18 rather than 36,000 mwd /MTU would result in a 19 relatively.small increase in the radiation levels 20 in the Turkey Point spent fuel pools. These 21 increased radiation levels are inconsequential i 22 compared to the radiation levels to which the fuel l
23 is exposed in the reactor. Additionally, the l 24 materials in the fuel assemblies (Zircaloy, 25- Incorel and Type 304 stainless steel) can with- i 1 26 stand levels of radiation which are orders of , 27- magnitude above the levels they will experience in 28 _ _ _ _ - _ _ . _ -. __m
. 1 the Turkey Point spent fuel pools. Thus, the
~ 2 increase in radiation levels resulting from 3 storage of spent fuel with 55,000 mwd /MTU burnup 4 would not have any appreciable effect on the 5 integri'y of the fuel assembly materials. 6 017: Is a spett fuel assembly with a burnup of 55,000 1 l 7 mwd /F"U more susceptible to deterioration during i 8 storage in a spent fuel pool than an assembly with 4 9 a burnup of 36,000 mwd /MTU? 10 A17: (Both) No. In designing fuel assemblies, the 11 expected levels of burnup are taken into account, 12 and higher burnup fuel is designed to meet the 13 same performance criteria as fuel designed for 14 lowei burnups. Furthermore, since storage 15 conditions for high burnup fuel are insignificant 16 compared to operating conditions, storage results 17 in a negligible additional impact on the fuel. 18 Fuel with a burnup of about 55,000 mwd /MTU has 19 been stored at Zion since 1982 without any 20 reported incidents. Examination of stored fuel 21 with burnups as high as 41,000 mwd /MTU have not 22 found any significant material degradation. 23 Furthermore, fuel has been left in reactors for 24 over 22 years (at Canadian NPD) and 17 years (at 25 Shippingsport) and continued to operate satis-26 27 28
, 1 factorily. LThus, water' storage of fuel with high 2 'burnups will have very little or no effect on the 3' materials integrity of the fuel assembly.
4 Q18: Does Turkey Point'have a materials surveillance
, -5 program for the spent fuel stored in the spent 6 . fuel pools?
7 A18: (Both) No, based upon our_ previous answers, such 8 a program is not warranted. However, there are 9 two different radiation monitors which would 10 identify increased radiation levels in the spent 11 fuel pools which would occur if radioactivity were 12 released into the pools as a result of a pin hole
- 13 ' leak of-the cladding of a spent fuel rod. These 14 monitors are the area radiation monitor on the 15 ' wall in each spent fuel pool area'and the radia-16 tion' monitor located in the spent fuel pool 17 exhaust vent. If these monitors detect a 18 significant increase in radiation levels, 19 operating procedures require FPL to perform a 20 radiation survey of the entire spent fuel pool 21 area and, if warranted based upon the results of I 22 the survey, to determine whether there has been 23 any increase in the radioactivity in the spent l 24 fuel pool water. For the following reasons, this I
25 system is sufficient for monitoring the integrity 1 26 of the spent fuel assemblies: ! 27 28
.1 , J # 1 o Spent fuel assembly failure is not expected 2 given the relatively low level ># of radiation l 3 and' heat in the spent fuel pool, the ability 4 of the fuel assembly to withstand radiation 5 and heat, as well as the. industry experience j 6 with storage of spent fuel.
7 o If deterioration of the spent fuel assembly 8 materials were to occur for some unforeseen 9~ reason, it would first manifest itself in i 10 localized failure (e.o., a pin hole leak in 11 the fuel cladding of one or more fuel rods), 12 and the deterioration would not result in a 13 catastrophic failure of the spent fuel 14 assemblies. This' type of localized failure 15 could allow a discharge of radioactive 16 material into the spent fuel pool, which 17 'would be detected by the radiation monitoring 18 systems. Thus, these systems would provide 19 FPL with warning of the fuel failures and 20 enable it to consider the need for any action
.21 with respect to the remaining spent fuel 22 assemblies.
23 o Even if it is unrealistically assumed that 24 all spent fuel assemblies were to fail 25 simultaneously as a result of material 26 degradation, the resulting doses would be 27 well-within the guidelines of Part 100. As 28 l L ______ _ _ _ _ _
s 1 discussed at pages 6 and 7 the Licensing 2 Board's Memorandum and Order of March 25, 3 1987, offsite doses resulting from a breach 4 of all spent fuel assemblies would be 27 rem i 5 to the thyroid and less than 1 rem to the 6 whole body. 7 Q19: In its Memorandum and Order of March 25, 1987, the 8 Licensing Board quotes from an article by A.B. 9 Johnson, Jr. regarding storage of spent fuel. 10 Does this article recommend that individual 11 nuclear plants establish a surveillance program 12 for spent fuel? 13 A19: (Both) No. Johnson concludes that "there is 14 minimal reason to expect that the corrosion-15 resistant fuel bundle materials would degrade in 16 the relatively benign storage environments over 17 the expected storage period." Nevertheless, 18 Johnson recommends that " selected destructive 19 exams of spent fuel having a previous exam 20 history" and " periodic visual and non-destructive 21 surveillance" of spent fuel be performed for spent 22 fuel stored for 20 to 100 years "to determine BF 23 whether any slow degradation mechanisms are 24 operative." However, Johnson also states that "a 25 major initial effort does not appear to be 26 27 28 ..
3y 6
- 2 0 -- 1 R
. I warranted" and that he was only advocating an
'2 exploratory surveillance program of limited scope.
3 ? 4 In context, it is apparent that Johnson was 5 recommending that the industry perform selective V i
- 6 examinations of different types of spent fuel 7- stored for more than twenty years, not that each
[ Q 8 nuclear plant establish such a program. In fact, 9 in another article (Nuclear Technoloov, " Spent 10-. Fuel Storage Experience", Vol. 43, pages 165-173 11 (Mid-April 1979)) Johnson explicitly states that e , 12 unless an industry program identifies unexpected 13 degradation, "it currently does not seem justified ( 14 to require detailed fuel examinations of every < 15 pool operator". 16 MATERIAL INTEGRITY OF THE STAINLESS STEEL 17 IN THE STORAGE RACKS 18' Q20: Will.the stainless steel in the storage racks be f 19 able to withstand the temperature and radiation 20 levels in the Turkey Point spent fuel pools? 21 A20: (Kilp) Yes. As I have noted, stainless steel has 22 been shown by test and experience to be virtually 23 immune to corrosion at spent fuel pool .::pera-24 tures. Temperature levels which the spent fuel 25- pool storage racks will encounter would not result 26 in rack material deterioration. Similarly, the 27- neutron radiation levels in the spent fuel pool 28
._______J
- 3. .
1- are orders of magnitude below those levels ; 2 sufficient to produce any appreciable impact upon 3 the structural integrity of stainless steel. 4 Q21: Do you have any conclusion regarding the materials
, .5 integrity of the stainless steel in the storage 6 racks for Turkey Point?
7 A21: (Kilp) Yes. For all of the above rearons, I 8 conclude that the stainless steel in the Turkey 9 Point storage racks can be used in the spent fuel 10 -pools for well in excess of forty years without 11 appreciable deterioration. 12 Q22: If you had assumed a burnup of 55,000 mwd /MTU, 13 what effect, if any, would this assumption have 14 had on your conclusions regarding the material 15 integrity of the stainless steel in the spent fuel 16 racks? 17 A22: (Kilp) None. As I previously discussed, storage 18 of spent fuel with a burnup of 55,000 mwd /MTU 19 rather than 36,000 mwd /MTU would result in a
.20 relatively small increase in the radiation levels 21 in the Turkey Point spent fuel pools. The Type i
22 304 stainless steel of which the storage racks are 23 composed can withstand radiation levels which are 24 orders of magnitude higher than they will f 25 experience in the Turkey Point spent fuel pools. 26 Consequently, the increase in the radiation levels f: . 27
' 28-l
\
OL- - - - l
. r ,
1 resulting from storage of spent fuel with 55,000 o 2 mwd /MTU burnup would not have any appreciable ' 3 effect on the integrity of spent fuel racks. 4 023: Does FPL have a materials surveillance program for 5- the stainless steel used in the spent fuel storage . l 6 racks? ' 7 A23: (Both) No. Such a program is unnecessary for the 8 following reasons: 1 9 o Storing an increased number of fuel j 10 assemblies in the Turkey Point spent fuel 11 pool will result in a relatively small j 12 increase in the total radiation levels, 13 temperature and heat loads in the spent fuel 14 Pools. 15 o The type of stainless steel used in the spent 16 fuel racks has a demonstrated ability to 17 withstand the effects of radiation and heat 18 for long periods of time beyond what would be l 19 expected in the Turkey Point spent fuel pool. 20 o The total integrated exposure of the 21 stainless steel in the Turkey Point spent 22 fuel racks will be orders of magnitude below 23 the dose necessary to cause any appreciable 24 impact. Therefore, there is an extremely 25 large margin of safety in the racks. 26 27 28
. 1 o Licensees typically do not have surveillance 2 programs for the materials i" their spent 3 fuel storage racks, except for the poison 4 materials. To our knowledge, no licensee has 5 such a surveillance program for other than 6 poison material.
7 MATERIALS INTEGRITY OF THE 8 BORAFLEX IN THE STORAGE RACKS 9 024: Will the Boraf.I:*x in the storage racks be able to 10 withstand the temperature and radiation levels in 11 the Turkey Point spent fuel pools? l 12 A24: (Both) Yes. The neutron absorbing material, 13 Boraflex, used in the Turkey Point spent fuel rack 14 construction, is manufactured by Brand Industrial 15 Services, Inc. Boraflex is made by uniformly 16 dispersing fine particles of boron carbide in a 17 homogenous, stable matrix of a methylated 18 polysiloxane elastomer (polymer). 19 Boraflex has undergone extensive testing to 20 evaluate its ability to withstand the effects of 21 gamma and neutron irradiation in various environ-22 ments and to verify its structural integrity and 23 suitability as a neutron absorbing material. In 24 tests performed at the University of Michigan, 25 Boraflex was exposed to 1.03 x 10 11 rads of gamma 26 20 radiation and a total neutron fluence of 10 27 neutrons /cm in borated water. These tests 28
1- indicate that Boraflex maintains its neutron 2 attenuation capabilities after being subjected to
.3 an environment of borated water and these 4 radiation doses.
'5 Long term borated water soak tests at high '
6 temperatures were also conducted. In these later 7 tests, Boraflex maintained its functional
- 8. performance characteristics and showed no evidence 9 of swelling or loss of ability to maintain a 10 uniform distribution of boron carbide.
11 During irradiation of the Boraflex, small 12 amounts of non-radioactive gasses (N , 0 , CO, CO 2 2 2 13 and low molecular weight hydrocarbons) may be 14 generated, plus a small amount of He from 15 neutron / boron reactions. Slits in the stainless 16 steel wrapper that houses the Boraflex in the 17 storage cell walls allow a small amount of water 18 to enter and gas to escape from the Boraflex. 19 -Q25: Is there any information regarding the performance 20 of Boraflex in spent fuel pools at other plants?
-21 A25: (Both) Yes. Boraflex has been used in the spent 22 fuel racks for several plants, including Quad
'23 Cities for at least three years, Point Beach for 24 at least five years, and Prairie Island for at 25 least one year. With the exception of the 26 27 28
l
) ' i 1 Boraflex used at these three plants, we are not j l
2 aware of any other reports of any experience with { i 3 Boraflex. ) l 4 Q26: Please describe the experience with the Boraflex 5 used at Point Beach. j i 6 A26: (Both) As discussed in its report to the NRC l 7 dated February 11, 1987, Point Beach removed and 8 examined two of its full-length (152 inches long) 9 Boraflex poison inserts used in its spent fuel 10 racks (one of which had an accumulated gamma dose 11 of approximately 10 10 rads) and several of its 2" ) 12 x 2" Boraflex surveillance capsules (which had a 13 range of accumulated gamma dose of about 1.10 x 10 14 10 to 1.6 x 10 10 rads). The full-length 15 Boraflex poison inserts had good integrity with no 16 cracking or degradation (approximately 1-2% of the 17 surface area, located along the edges of the 18 insert, had some gray discoloration which yielded 19 a powder when rubbed). In contrast, the surveil-20 lance capsules experienced thinning and degrada-21 tion and had a gray powder on the surface of the 22 capsules. However, tests showed that the capsules 23 also retained almost all of their neutron 24 attenuation properties. Point Beach concluded 25 that the degradation of the capsules appeared to 26 be attributable to permeation of water in the 27 Boraflex, which occurred at the edges of the 28
1 Boraflex beginning with exposures of about 1 x 10 2- 10 r&ds gamma.- Point Beach also concluded that
.3 the full-length inserts were less susceptible to 4 overall degradation than the surveillance capsules 5 because the full-length inserts had a lesser 6 amount of area near the edge in proportion to the 7- overall area of the insert-. ,
8 Q27: Please describe the experience with the Boraflex .; i 9 used at Prairie Island? l 10 A27: (Both) Prairie Island removed two large Boraflex 11 surveillance coupons (B"x12") encapsulated in 12 stainless steel, which had been in the spent fuel 13 pool for 6 and 12 months, respectively. The 4 14 coupons were subject to various examinations, 15 including visual inspections, dimensional 16- measurements, and hardness tests. The.six-month 17 sample had an appearance similar to the as-11 8 . manufactured Boraflex, and the twelve-month sample-19 had some discoloration similar to the Point Beach { 20 full-length Boraflex panels. Additionally, there 21 were slight changes (less than 5%) in the hardness 22 and density of the twelve-month sample relative to 23 the six-month sample. 24 Q28: Please describe the experience with the Boraflex i 25 used at Quad Cities, 26 27 28
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I l' A28: (Both). Unlike the Boraflex poison panels used at 2 Point Beach, the panels at' Quad Cities are 3 sandwiched between two rack cell walls. As ) l 4 discussed in its report to the NRC on May 5, 1987, 5 Quad Cities performed an in-place examination of ! l 6 its Boraflex poison panels by moving a device 7 composed of a' neutron source and neutron detu; tors 8 along the length of the panels to detect any gaps-9' or. breaks in the Boraflex poison panels (gaps in ; 10 the Boraflex result in locally higher neutron . 11 backscatter radiation levels which can be 12 identified by the neutron detector). Less than a i 13 third of the examined Quad Cities Boraflex poison i 14 panels (which had an accumulated exposure of about ! 15 1 x 10 9 rads) were found to have gaps or breaks. 16 These gaps occurred at random locations in the 17 upper 2/3 of the panels. The gaps were 1.35 18 inches long on the average and the maximum gap was 19 4 inches in length (which occurred in only one 20 panel). Some panels had more than one gap, 21 resulting in an average cumulative gap size of 1.5 22 inches and a maximum cumulative gap of 4 inches. j 23 Quad Cities concluded that these gaps were caused 24 by stresses induced from shrinkage of the panels 25 which had been glued into the racks. Quad Cities 26 recalculated the neutron multiplication factor for 27 its spent fuel pools accounting for the existence 28
1 V-
,. 1; of these gaps. Quad Cities concluded that theLk-2- effective of the-spent fuel pools was still within 3 . applicable limits. ;
i
.4 Q29: Are-there any other sources of information 5 regarding the performance of Boraflex in addition 6 to those you have already described?
7 A29: (Both) Yes. The manufacturer of Boraflex has 8 commissioned the University of Michigan to perform 9 additional tests on Boraflex. Although these 10 tests will not be completed for several more 11 months, interim data from these tests are 12 available. These data indicate that Boraflex 13 shrinks about 0.75% with gamma exposures up to 14 5x10 8 Rads, that the shrinkage increases to about 15 2% at 5x10 9 Rads,.and that the shrinkage remains 16 at about 2% for exposures of 1x10 10 Rads. These l 17 data are consistent with the experience at Quad 18 Cities, where cumulative gap sizes per poison 19 panel were generally less than 2% of the length of l 20 the Boraflex panels and where the maximum cumula-21 tive gap sizes were less than 3% of the 1er.gth of 22 the Boraflex panels. 23 030: What is the cause of the shrinkage of the 24 Boraflex? , 25 A30: (Both) The major constituent of Boraflex is a 26 polymer. When such polymers are exposed to
'27 radiation, the radiation breaks the atomic bonds 28 i
C* , '4 :- 29 - t
. ]' 5
" Vl' in'the polymer and.the atoms tend-to crosslink 2 with' atoms in adjacent polymeric chains. As y 3 crosslinking occurs, the chains in the polymer are
.4L pulled clocer together and the material. undergoes 15 shrinkage. Calculations indicate that' cross-6 linking of all units will be complete (and the
'7 shrinkage will'stop) at about 10 10 Rads. These 8 calculations are consistent with the interim test 9- results at the University of Michigan, which 10 showed no additional shrinkage of Boraflex with 1 11 exposures beyoad 5x10 9 Rads.
12 Q31: Would you please summarize the. industry data 13~ .regarding the performance of Boraflex? 14 A31: (Both) Testing by the University of Michigan and' 15 , ,
. examinations at Quad Cities. indicate that exposure
, of Boraflex to gamma radiation may result in some 17 shrinkage up to approximately 2% of the-length of 18 the Boraflex. Additionally, qualification tests 19 and inspections of the Boraflex at Point Beach 20 indicate that the edges of the Boraflex panels may
'21 experience some discoloration with exposure to
- 22. gamma radiation but that the Boraflex will retain 23 its neutron attenuation properties.
24' 'Q32: , Does FPL have a materials surveillance program for 25 , the Boraflex in the Turkey Point spent fuel 26 ' storage racks? 271 28
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f.s i: y 11 'A32: (Gouldy) Yes. Within: the Unit - 3 spent fuel pool, 2' series of not less than 24! jacketed Boraflex 3 . coupons, of the'same composition, produced by the 4 same method, and' certified under the same criteria 5 as.the full-length Boraflex panels,.are' suspended 6 around the periphery of Region I or Region II rack 7 modules. The pool contains four such series of 8' poison coupons, two of which'are suspended'around 9- Region I racks and two of which are suspended
- 10. .around. Region II racks. The coupons are located 11 'around the pool so that they receive a representa-12 tive exposure'to gamma radiation. The same 13 surveillance program'will be used for Unit 4. FPL
.14 will perform an initial' surveillance of the 15 coupons after five years of exposure in the pool 16 environment. This surveillance will involve 17 removal of several specimens from the pool and 18' will include visual examination and other tests.
- 19. Based on the results of this initial surveillance, 20 and industry experience with BoreClex, further 21 curveillances will be scheduled.
22 The surveillance program will evaluate the 23 physical and nuclear characteristics of both the 24 Region I and Region II coupons. The evaluation of 25 the physical characteristics will include the l 26 following: examinations of the stainless steel 27 jacket for the coupons to determine whether the
~28 l
. s. J . 1 ' jacket material is smooth or exhibits any. visible 2 damage; examinations of the Boraflex sample to 3 determine whether the Boraflex material is smooth j 4 or exhibits'any visible changes (such as changes
]
i 5 in color, pitting, or cracking); measurements of 6 the weights and volume of the Boraflex and R 7 calculation of its density; and measurement of the 8 hardness of the Borafle7. The evaluation of the 9 nuclear characteristics will include the follow-10 ing: taking a neutron radiograph of the specimen 11 to determine the uniformity of boron distribution; 12 and performance of attenuation measurements of the 13 specimen to determine the Boron-10 loading. ! 14 In addition to the coupon surveillance 15 progrem, FPL will perform " Blackness Testing" to 16 detect whether there are any spatial distribution ; 17 anomalies (such as gaps) in the Boraflex panels in , 18 the new Turkey Point spent fuel racks. Blackness 19 Testing involves the use of a fast neutron source 20 and thermal neutron detectors. The thermal ; 21 neutron detectors are connected to chart recorders 22 which will record the level of thermal neutrons 23 received. There will be a low number of thermal 24 neutrons detected if the boron carbide is present 25 in the Boraflex material. However, if gaps or 26 voids are present in the Boraflex, there will be 27 an increase in the number of thermal neutrons 28
1 which will be detected and recorded by the chart 2 recorders. The Blackness Testing technique was 3 utilized successfully at Quad Cities to determine 4 the existence of gaps in their spent fuel racks. i 5 FPL performed baseline Blackness Testing in 6 early August of 1987 for several storage cells in I 7 both Region I and Region II of the new storage 8 racks including some that have received the 9 highest cumulative exposure to date in Turkey l 10 Point Unit 3. FPL will retest these cells within 11 three years (in conjunction with the five year 12 surveillance period for the Boraflex surveillance 13 coupons). The need for further retests will be 14 based upon FPL's results and Electric Power 15 Research Institute (EPRI) and industry data. 16 FPL's surveillance program and Blackness 17 Testing will be sufficient to detect any changes 18 in the neutron attenuation properties of the 19 Boraflex and any changes in the physical distri-20 bution of the Boraflex. As a result, the 21 surveillance and testing will assure that the 22 Boraflex in the Turkey Point spent fuel racks will 23 be acceptable for continued use. 24 In addition to FPL's surveillance program and 25 Blackness Testing, FPL will also continue to 26 monitor industry developments related to Boraflex. 27 For example, EPRI and several utilities have 28
i 1 joined together to collect and evaluate data 2 regarding the performance of Boraflex. This data 3 includes data from utility surveillance programs, ; 4 qualification tests, and additional tests 5 commissioned by the manufacturer of Boraflex. FPL 6 has participated and will continue to participate ; 7 in this effort. 8 033: What were the results of the Blackness Testing 9 performed at Turkey Point in early August, 19877 10 A33: (Gouldy) FPL performed Blackness Testing to i 11 determine whether there were any gaps in the 12 Boraflex panels in eighteen storage cells of the 13 new racks in Turkey Point Unit 3. Ten of the 14 tested cells (containing a total of 22 full-length 15 Boraflex panels) were in Region 2 of the spent l 1 16 fuel pool and eight of the cells (containing a 1 17 total of 32 full-length Boraflex panels) were in ] ( 18 Region 1 of the spent fuel pool. These cells were j 19 selected randomly from among those cells which had 1 20 the highest burnup fuel stored for the longest l 21 period of time (approximately 2 1/2 years). No l' 22 indications of gaps, voids, or other spatial 23 distribution anomalies were found in any of the 54 1 24 Boraflex panels for any of the tested storage I 25 cells. 26 27 l 28 l % -_-_m__
-:34 -
1 034: If degradation of Boraflex were to occur
'2 unexpectedly'at Turkey Point, would it endanger 3 the health and safety of the public? i 4 LA34: (Both) No. If degradation of the Boraflex were 5 to occur unexpectedly at Turkey Point, there would 6 be no impact on the public health and safety. As i 7 explained in the Licensing Board's Memorandum and 8 Order of March 25, 1987, at page 58, the boron in 9 the Turkey Point spent fuel pool water would keep 10 the pools within their k-effective limits even if 11 it is' assumed that the spent fuel storage racks do 12 not contain any Boraflex.
13 Additionally, Westinghouse has performed a i 14 sensitivity analysis to determine the impact of 15 postulated gaps on the k-effective of the Turkey 16 Point spent fuel pools, assuming the absence of 17 any boron in the pool water. As discussed in the 18 Testimony of William A. Boyd on Contention Number 19 6, the Turkey Point spent fuel pools would remain 20 within their 0.95 k-effective (Keff) limit under 21 the following postulated conditions: 22 o With storage of 4.1% enriched fuel 23 (which is the maximum enrichment 24 planned for operation of the Turkey 25 Point reactors prior to the next 26 surveillance and testing of the 27 Boraflex in approximately three 28 l ] E . _ _ _ J
, - 1 years), the stored fuel would 2 remain within its k-effective 3 limits with 3.5 inch gaps in the
-4 center of each Boraflex par:el (3.5 ;
5 inches is equivalent to 2.5% of the 6 length of the Boraflex panels). 7 o With storage of 4.5% enriched fuel ! 8 (which is the technical specifica- : 11 9 tion limit for storage of fuel in i 10 the Turkey Point spent fuel pools), -! 11 the stored fuel would remain within 12 its k-effective limits with 2.0
.13 inch gaps in the center of each l 14 Boraflex panel or with 3.75' inch
-15 gaps in the center of half of the 16 Boraflex panels (3.75 inches is 17 equivalent to 2.75% of the length 18 of the Boraflex panels).
i 19 Based upon the data from Quad Cities, each of j 20 these postulated cases is extremely conservative. 21 and unrealistic because (1) less than one-third of 22 the Boraflex panels examined at Quad Cities had 23 gaps, (2) for the panels at Quad Cities that had 24 gaps, the average cumulative gap size was only 1.5 ) l 25 inches, and (3) the gaps were randomly distributed l 26 along the Boraflex panels and were not all located 27 at the center of the panels. 4 28
F ' 1
.o
. 1' Additionally, each of these postulated cases j l
2 is extremely conservative based upon the actual 1
'3 conditions at Turkey Point. In particular:
I 4 o The enrichment.of the new fuel currently used i 5' at Turkey Point ranges from 3.4% to 3.6%. 6 Under FPL's fuel management program and the 1 7 current limits on reactor, operations, FPL ! 8 will only be able to increase the maximum ;
.9 Turkey Point fuel enrichment in small 10 increments (approximately 0.2%) each cycle.
11 Therefore, at the time of the next Blackness j 4 12 Testing and surveillance of the Boraflex in ' 13 approximately three years, the maximum fuel 14 enrichment at Turkey Point will not be 15 greater than 4.1%. 16 o Spent fuel has been stored in the new storage j 17 racks at Turkey Point Unit 3 for-approxi-18 mately two years. For. storage of spent fuel 19 with a burnup of 36,000 mwd /MTU, the one-year 1 9 20 exposure was calculated to be 7.8 x 10 Rads
'21 gamma. As we discussed previously, the 22 shrinkage of Boraflex should essentially be
-23 complete at exposures of approximately this 24 magnitude. Therefore, if the Boraflex at 25 Turkey Point currently has not develrped any ,
26 gaps, we would not expect any gaps of any , 27 significant size to develop in the future. 28
1 1L 035i If FPL's surveillance program were to identify any 2 degradation of the Boraflex in the Turkey Point 3 spent fuel' storage racks, are there any actions 4 which FPL could take to assure the continued safe 5 storage of fuel at Turkey Point. 6 A35: (Both) Yes. There are several possible options 7 which would assure-the continued safe storage of i 8 fuel. These include: ! 9' l. The degraded Boraflex could be evaluated 10 to determine whether the degradation and any 11 expected future degradation would adversely affect 12 FPL's ability to satisfy the .95 K,ff limit for 13 the Turkey Point spent fuel pools.- If the pools 14 could still satisfy this limit, no further action 15 would be necessary. 16 2.- Administrative controls could be imposed 1
.7 on the placement of new fuel assemblies around ,
18 storage cell locations that have degraded 19 Boraflex. The sensitivity analysis performed for 20 Turkey Point Units 3 and 4 assumes that only new 21 fuel with 4.5 w/o enrichment is stored in the 22 spent fuel pool. By limiting the amount and 23 location of the storage of new fuel assemblies and 24 by inserting spent fuel between the new fuel, FPL 25 could reduce the K to less than or equal to eff 26 .95. l 27 28 i
1 3. A poison material similar to a control 2 rod or burnable poison could be added to any new 5 3 fuel assembly to be placed in a storage cell with 4 degraded Boraflex. This would reduce the K eff to 5 less than or equal to the .95 limit. 6 4. Poison panels could be added into the
\
7 space between the fuel assembly and the cell wall 8 to assure a K of less than or equal to .95. eff 9 5. FPL has taken no credit for the 1950 ppm 10 boron concentration in the spent fuel pool water. 11 This boron concentration alone assures a K eff f 12 less than .90. In order to take credit for this 13 boron, FPL could establish various administrative 14 controls to provide a high level of confidence 15 that the spent fuel pool water will remain 16 borated. These controls could include isolating 17 pure water sources and routine sampling of the 18 boron concentration. 19 6. The storage cells with the degraded 20 Beraflex could be blocked off to prevent loading 21 of any fuel assembly into the cell. 22 7. The storage racks with the degraded 23 Boraflex could be coated with boron with a 1 24 sufficient density to assure a K of less than eff 25 or equal to .95. 26 8. The storage racks which contain degraded 27 Boraflex could be replaced. 28
1
, 1 Q36: Do you expect gaps similar to those at Quad Cities 2 to form in the Boraflex panels at Turkey Point 1
3 Unit 3? l l 4 A36: (Both) No. The renilts of the Blackness Test at ! ( 5 Turkey Point Unit 3 indicate that the Boraflex l 6 panels do not have gaps. Furthermore, we do not 7 expect such gaps to develop in the future due to 8 the differences in the design and manufacturing 9 process between the Quad Cities and Turkey Point 10 racks. 11 The Turkey Point rack design and fabrication 12 process differs significantly from Quad cities. 13 At Turkey Point, the Boraflex is held to the 14 stainless steel cell wall by enclosing it in a 15 wrapper panel. During fabrication, a cut-to-16 length sheet of Boraflex was attached to one 17 wrapper panel with adhesive applied in short 18 lengths (up to 2 1/2" long) at a maximum of 16 19 places (8 per side) along the Boraflex. The 20 wrapper was then inverted and spot welded to the 21 cell wall. The purpose of the adhesive was to 22 provide temporary support during the spot welding 23 process and not for long-term support or 24 adherence. The wrapper provides an enclosure 25 which protects the Boraflex from the flow of 26 water, and maintains it in a space in which there 27 is a several mil clearance between the Boraflex 28
1 1 1 and the rack cell wall. The arrangement is very I l 2 similar to that used in the original Boraflex l 3 qualification testing. In contrast, the Quad 4 Cities fabrication process used a sealant applied 5 along the entire axial length of the Boraflex to 6 attach it to the side of the rack. This element 7 and the other side of the rack wall were then 8 placed in a fixture for subsequent welding. 9 Apparently, this process did not allow for the 10 predicted shrinkage of the Boraflex and as such 11 gaps developed. 12 Overall, the design and fabrication process 13 at Turkey Point is more similar to the design and 14 fabrication process used for the Point Beach 15 storage racks than for the Quad Cities racks. The 16 Boraflex plates at Point Beach were not restrained 17 from shrinking inside the racks, and these plates 18 did not develop any gaps. Consequently, we do not 19 expect gaps of any significant size or extent to 20 develop at Turkey Point. 21 037: Would you please summarize your testimony with ) 22 respect to Boraflex? 23 A37: (Both) We have the following conclusions: i 24 25 l 26 27 28 L_ __ _ _ .
M i 1 o -Boraflex has'been demonstrated-in qualifica-2 tion tests to be acceptable for-use up to l 3' '1011 rads gamma. This dose is well in excess 4- of the. dose. expected during a forty-year 5 storage period at Turkey Point. 6 o The Boraflex panels in use at Quad Cities has 7 experienced shrinkage and cracking at-10 9 8 Rads gamma, and the Boraflex surveillance-
-9 capsules (though not the Boraflex plates) in 10 use at Point Beach have experienced some 11 degradation at 1 x 10 10 Rads gamma. However, 12 the Boraflex in use at Point Beach and Quad
.13 Cities is capable of performing its intended 14 safety function despite the degradation.
15 o FPL has a capsule surveillance program for i l 16- the Boraflex in the Turkey Point spent fuel 17 pools and will perform an in place examina- l 18 tion of the Boraflex panels in the Unit 3 19 storage racks. These programs are adequate ; 20 to determine whether the Boraflex at Turkey 21 Point is experiencing the types of degrada-22 tion which have developed at Point Beach and J 23 Quad Cities. 24 o No gaps were found in the Boraflex for the 25 new storage racks at Turkey Point Unit 3 as a 26 result of the Blackness Testing conducted in 27 August 1987. Furthermore, unlike the 28
1 Boraflex at Quad Cities,.the Boraflex at - 2 Turkey Point is not expected to develop any 3 gaps due to difference in the design and 4 manufacturing of the Turkey Point and Quad
]
5 Cities storage racks. 6 o If degradation of the Boraflex were to occur 7 unexpectedly in the Turkey Point spent fuel 8 pools, the spent fuel would remain within its 9 k-effective limits. 10 In summary, based upon industry and Turkey Point-11 specific data, we believe that the Boraflex at 12 Turkey Point is capable of performing its safety 13 function. FPL's. surveillance and testing program 14 will be sufficient to confirm the continued 15 ' acceptability of the Boraflex. Any significant 16' degradation would be-detected by the surveillance 17 and testing program, and there are several options , 18 which would assure the continued safe storage of 19 the fuel. 20 038: If you had assumed a burnup of 55,000 mwd /MTU, 21 what effect, if any would this assumption have had 22 on your conclusions regarding the material l 23 integrity of the Boraflex in the spent fuel racks? 24 A38: (Kilp) None. As I previously discussed, storage L 25 of spent fuel with a burnup of 55,000 mwd /MTU l l 26 rather than 36,000 mwd /MTU would result in a l 27 relatively small increase in the radiation levels 28
, , , _ _ , __, ____ --- _.m_ - - - - - _ _ _ . - - - - - - - - - - - - - _ _ _ _ _ _ - . - _ _ _ . - - - - - . , . _ _ . . . - - - - -- - - . , . _ . - - - - . _ . , . - - - - - - - - ,
O 3 i 1 in the Turkey Point-spent fuel pools. The ! 2 Boraflex in the storage racks'can withstand 3 radiation levels far higher than they will 4 experience in the Turkey Point spent fuel pools. J 5 Consequently, the increase in the radiation levels 6 resulting from storage of spent fuel with 55,000 7 mwd /MTU burnup would not have any appreciable 8 effect on the integrity of spent fuel racks. f 9 SPENT FUEL POOL LEAKAGE 10- DETECTION SYSTEM 11' Q39: Does Turkey Point have a materials surveillance I 12 program for-its spent pool liners? 13 A39: '(Gouldy) No. However, the Turkey Point. spent 14 . fuel pools do have a leakage detection and 15 collection system, which includes a monitoring 16 trench behind the' liner. If the liner were to 17 deteriorate and develop a leak, the leakage would 18 be collected in the monitoring trench and would be 19 retained there until plant personnel open valves 20 in the system to direct the leakage to a waste 21 disposal system. Current procedures require a 22 daily check of the leakage collection and 23 detection system to determine whether there has 24 been any leakage from the spent fuel pools.
'25 26 27 28
, 1
SUMMARY
2 040: Would you please summarize your testimony? 3 A40: (Both) The spent fuel assemblies, including the 4 fuel cladding, are designed to withstand the 5' radiation and heat loads in the reactor. These 6 conditions are far more severe than those present 7 in the spent fuel pool. Tests and experience have 8 shown that no significant deterioration of the 9 materials used in cladding and assemblies occurs 10 in a spent fuel pool environment. Therefore, the 11 fuel cladding and assemblies are expected to 12 maintain their structural integrity during storage 13 in the Turkey Point spent fuel pool. Similarly, 14 the materials in the spent fuel storage racks are 15 expected to maintain their integrity while in the 16 Turkey Point spent fuel pool. Therefore, other 17 than the surveillance program for the Boraflex in 18 the spent fuel racks, no monitoring or surveil-19 lance program is required for the spent fuel 20 assemblies or the spent fuel racks. 21 ' 22 23 24 25 26 27 28 L_________. _.
1 EXHIBIT A 3 2 STATEMENT OF PROFESSIONAL QUALIFICATION OF GERALD R. KILP 3 4 My name is Gerald R. Kilp. My business address is 5 Westinghouse Electric Corporation, P.O. 3912, Pittsburgh, 6 Pennsylvania, 15230. I am an Advisory Engineer for the 7 Product Engineering Section of the Westinghouse Nuclear Fuel 8 Division, Westinghouse Electric Corporation. I have served l - - - - 9 in this function since November, 1983. In this capacity, I 10 am responsible for selected Materials Development programs
- 11 and act as an advisor on materials performance questions for 12 the Westinghouse Nuclear Fuel Division.
13 I graduated from Missouri Valley College, 14 Marshall, Missouri, in 1952 with a Bachelor of Science 15 degree in Chemistry. In 1957, I received a Doctorate of ' 16 Physical Metallurgy from Iowa State College (since renamed 17 to Iowa State University). 18 From 1952 to 1957, I was a Graduate Assistant at 19 the Ames Laboratory for Atomic Research, an AEC supported 20 laboratory at Iowa State College. During this period, I
- 21 worked on binary phase diagrams and evaluated methods for 22 protection of uranium metal from corrosion. ,
23 From December, 1957 to May, 1962, I was a Senior 24 Engineer and, later a Fellow Engineer, at the Westinghouse 25 Atomic Power Department where I worked on thermoelectric and 26 thermionic materials for application in nuclear reactors. 27 28
1 In May, 1962 and until September, 1968, I acted as 2 supervisor and later Manager of Fuel Evaluation on the NERVA 3 Reactor Project at the Westinghouse Astronuclear Laboratory 4 at Large, Pennsylvania. In September, 1968 and until May, 5 1972, I served as the Engineering Manager of the 6 Astronuclear Fuel Facility at Cheswick, Pennsylvania. In 7 this capacity, I was responsible for process development for 8 fabrication of NERVA reactor fuel as well as reactor fuel 9 performance evaluation. 10 In May, 1972, I transferred to the Westinghouse 11 Nuclear Fuel Division of Westinghouse Nuclear Energy 12 Systems, in Monroeville, Pennsylvania. From then to May, 13 1980, I served as the Manager of Materials Design. This 14 group had the basic responsibility for materials research 15 and development, and approval of materials for use in 16 Westinghouse pressurized water reactors. The duties further 17 included determination of the necessary and sufficient 18 requirements for reactor coolant and pool storage 19 chemistries needed to assure satisfactory performance under 20 all warranted conditions. All reactor and out-reactor { 21 corrosion testing evaluations were done under the cognizance 1 22 of this group. 23 From May, 1980, and until November, 1983, I worked l 24 at the Westinghouse Advanced Energy Systems Division where I 25 served as the Manager of Materials Interactions until
- 26 November of 1983. These activities were primarily concerned ;
f ! 27 28 l
, o 1 with addressing materials selection and evaluation for 2 application in long term storage of light water reactor fuel 3 in underground and above ground facilities.
4 Since 1979 I have also been a member of the 5 American Society for Testing and Materials (ASTM) C26 6 Committee on the Nuclear Fuel Cycle. At the present time I 7 am the Chairman of Sub-committee C26.02 (Fuel and Fertile 8 Materials Specifications) and serve on C26.03 (Neutron 9 Absorber Materials Specifications). 10 11 12 13 14 15 16 17 18 19 20 21 22 23 1 24 l 25 l 27 28
- y. 2
, 1 Exhibit B 2 PROFES9IONAL-QUALIFICATIONS AND EXPERIENCE OF RUSSELL GOULDY 3 4 Education: 5 Courses in High Energy & Nuclear Physics, University of 3 Tennessee, Knoxville, 1970-72 O ] BS in Nuclear Engineering, University of Tennessee, i 7 Knoxville, June 1978 8 EQrk Experience: 9' 1979 - Present Florida Power & Licht Company -- 10 Mr. Gouldy has been a Nuclear Licensing Engineer since January 11 1985 with responsibility for providing operating reviews and 12 assistance in maintaining Turkey Point's Operating License. 13 Additionally, he is FPL's repre-sentative to the EPRI committee 14 which is assessing the performance of Boraflex in spent fuel pools. 15 From December 1979 to June 1983, Mr. Gouldy was a Shift Technical 16 Advisor and Senior Reactor Operator for the Turkey Pcint Plant. In 17 this position, he was responsible. for advising the shift supervisor 18 on matters of safety, including response and analysis of plant 19 transients. From June 1983 to January 1985, Mr. Gouldy was a 20 Plant Engineer in the Reactor Engineering Department at Turkey 21 Point with responsibility for reactor physics, refueling 21 Operations, and design and installation of the safety 23 assessment system computers. 24 1978-1979 Alabama Power Comoany -- Mr. Gouldy was a Technical Engineer at the 25 J.M. Farley Nuclear Plant. In this position, he was responsible for 26 systems testing and plant start-up assistance. 27 28
9
. 1 1977-1978 Tennessee Vallev Authority -- Mr.
Gouldy was a Technical Writer in 2 the Engineering Design. Division. In this position he developed 3 computer programs for materials handling for TVA's nuclear 4 projects. 5 1975-1977 Continental Tool and Enaineerino -- Mr. Gouldy was a Draftsman and-6 Designer of pneumatic tools. 7 Licenses: 8 Professional Engineer - Florida #31965 (1982-Present) Senior Reactor Operator - NRC SOP #4284 (1982-1986) 9 Certified General Contractor - Florida #CGC 41804 Certified Structural Inspector - Florida #608 10 11 12 13 14 15 16 17' 18 19 20 21 22 23 24 25 26 27 28}}