ML20079N201

Amended Petition of Ctr for Nuclear Responsibility,Inc to Intervene,Initially Filed on 831104

ML20079N201
Person / Time
Site:	Turkey Point
Issue date:	01/25/1984
From:	Hodder M CENTER FOR NUCLEAR RESPONSIBILITY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20079N203	List: ML20079N201 ML20079N218
References
84-496-03-LA, 84-496-3-LA, ISSUANCES-OLA, NUDOCS 8401300126
Download: ML20079N201 (9)

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VMITED STATES Of AMERICA

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l NUCLEAh REGULATORY CON 4!SSION

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THE ATOMIC SAFETY AND LICENSING BOARD j

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Sofcre Administrative Judges:

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', i Dr. Robert M. Lago, Chairman h

q Dr. Richard F. Colo 4

Dr. Emmeth A. Ludbka

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In the Matter cf

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Docket Nos. 50-250-01A l

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50-251-OLA i

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't FLORIDA POWER AND LIGHT COMFANY

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ASLBP No. 84-496-03 LA j

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(Turkey Point Plant'

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January 25, 1984 JJ Unit Nos. 3 and 4)

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AMENDED PETITION TO INTERVENE xd li In an Order dated December 20, 1983, the Ator ic Safety and

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Licansing hard c.; ("ASLB*j issued an Order Scheduling Prehearinq y

r Ceaference. In that Order, the Board required pursuant to 10 CTR l

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. 714 (b), that any amendments or supplements to'the petition to intervene by petitioner intervenors be filed by January 25, 1984.

i The Petitiorters, Center for Nuclear Responsibility, Inc. and Joette Lorion, submit this, their amendment and supplement to their Petiticn to Intervene filed initially in this matter on I

- Idovember-4,^1983 rwhich is also incorporated by reference herein.

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Pursuant to 10 CFR 2.716, the petitioners wish to amend ar.d 4

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clarify this Petition to Intervene by asking that the Board

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consolidate the subject matter of the July 20, 1983,' Federal

. g.,j hegister Notice (48 FR 33080) with the subject matter of the a, h, n

C October 7, 1983, Federal Register Notice (4d FR 45I62).

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Petitioners recognise that a petition to intervene on the i

could be considered untimely, but

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July 20th notice (48 FR 33000)

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Petitioners point out that this is not so'because the two notices a

treet identical subject matter, and the first notice of July 20, 1983,'wes misleading to members of the public in that it i

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fairly present the consequences of the proposed changes to the

. fuel core design for Turkey Point units 3 and 4.

The amendments requested in the July 20, 1983, Federal Register Notice (48 FR 32480) involved a planned fuel design modification l

l to Turkey Point Unite 3 and 4, which would replace the Westinghouse

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'S 15x15 low parasitic (14PR) fueled cores with Westinghouse 15x15 t, -y optimized fuel assembly (OTA) core with Wet Annular Burnable

e Absorber (WABA) Rods. Although the Federal Register Notice stated y

4 that there would be a change in the Technical Specifications affecting increase 13. shutdown and control rod ' drop time, use of

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hwnable poison rols, an6 changes in hot channel factors and other

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power distribution factors, the July 20th notice (48 FR 33080) did

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not give numerical vrlues associated with these changes. It also

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stated that tne " core safety limits and associated setpoints in the N

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. i; ls,5 current: Techt.ical Specifications are app 1 feeble...and the p{s.at will 1?

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.1 1-e be operated within the' previously approved margins and limits.*

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s separate amen h nt request to modify the fv1.*

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core design which isas noticed in the Federal Register ca Octobdr 7 -

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Tathnical specifications for Turkey Point Units.3 and 4 would N

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[ iesult in a,* reduction in the safety margin resulting from the

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~ /in rease in tih f4H and F4 limits,", and for the first time, nimeerical

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values were assigned to the fuc1 core design modifications. (6tFR v.,

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} 45862, october 7, 1983.) It was on this unendment request that the l [,,

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' Center for Wn': lear Responsibility,,Inc.- did Jostte Lorion filed a 3

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- ', timely petition for leave to intervenei which contained comuments

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sud concerns relative to both the July 20th and October "th set of I

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smendment requests concerning'the i el core design changes to Turkey

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Point Waits 3 and 4.

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1 Di.a to theitausual carcuinstances" relating to the piecemeal d

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, i noticing of taesd, feel core design changes to Turkey Point Units 3

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and 4, Ms. Ioridh and t% Center for Nuclear Responsibility, Inc.

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feel that the orb. # fair mahntr for t'Ae Board to consider the issues 4

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'surrounc'ing the fwl core design chaJge to TJrkey Point is to r

s et.:: rider the chrnges in their sotiret.y. This; Ms. Lorion and the

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7 Center ask that the poard consolidate the July 20, 1983, and'

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October 7,1923, saendment requests, so that a hearing can take

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i place on all aspects of the fuel core design changes and the Q

t, 1./ Safety Evaluation of the off'.ce of Nuclear Rasetor Regulation related to

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- 'l License Amendments No. DPR 31 and DPR 61. TFL Co. Turkey Feint Units Nos. 3 4

and 4. Docket nos. 3b 'JM be 50-251. December 9.1983. Section 8. pg.17.

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implications that these changes abh have for public health and 4

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Ms. Lorion and the Center for Nuclear Responsibility, Inc.

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J-believe that both the Board and the public will benefit by looking l'

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' Petitioner, Joette Lorion, states that she is a member of L

the Center for Nuclear Responsibility, Inc. and that individually d

and as a member of the Center for Nuclear Responsibility, she and the Conter each have interests that may be affected by the operation k

. of the Turkey Point Nuclear Plant.

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The Center for Nuclear Responsibility, Inc. (* Center") states that among its members who reside, work, and recreate within 25 miles

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of the Turkey Point Nuclear Power Plants are Joette Lorion, 7269 b

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j SW 54 Avenue, Miami, 71., Lauren Arreaza, 3931 Crawford Ave.,

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q Coconut Grove, F1., Beverly Courtright, 25230 SW 129 Place, r

g a Homsstead, F1., J. Marry Rothwell, 83 Mt 11 Street, Homestead, Fl.

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party intervenor in the captioned proceeding.

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I Sf'PPLDtENTAL AND AMENDED CONTENTIONS L

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The Center for Nucleas Responsibility, Inc. and Joette Lorion

.hereby amend and supplement and refine their pr=vaously stated list j

of contentions as, follows:

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4 (a) The petitioners contend that the amendments requested involve t

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a significant hasard consideration, because they will result in an l

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i increase in the authorised core peaking factors, an increase in the

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core pc,.ier deasity and an increase in the operating temperature of

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the fuel. There can he no lawful issuance of the ~ proposed license Q

amenJments before the holding of a formal hearing before the Atomic

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' safety and'!.icensing Board (A51.3). 2 4g (b) Whether the entirely new computer model used by the utility, for calculating'reflood portions of accidents meets the Commissien's y

ECCS Acceptance Criteria: specifically, whether a 2.24 reduction in

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re-flood rate is misleading because for a small decrease in re-flood r

Y rate, there results a large increase 'in. fuel temperature. Re-flood

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rates are critical if below 1 or 2 inches per minute.

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(c) Petitioners have been informed and believe a:ner.dment would f

increase the rod drop time from 1.0 to 2.4 seconds (a 33% increase y -j h

jl in rod drop time). That increase would significantly and adversely i;

reduce the safety margin and create the possibility or probability of a new or different kind of accident or an accident whose occurance A

or consequances hava not been analysed or which may increase the i,E probability of an accident previously analyzed.

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y that Commission's tentative conclusion that safety limits "are met" f

is not supported'hy any evidence.

(d) The proposed decrease in the departure in the nucleate p

boiling ratio (DNBR) would significantly and adversely affect the i

A margin of safety for the operation of the reactors. The restriction l

of the DNBR safety limit is intended to prevent overheating of the i

ei fi fuel and posJible cladding perforation, which would result in the l

release of fission products from the fuel. If the minimum allowable l

4-DBNR is reduced from 1.3 to 1.7 as proposed, this would authorize f

operation of 'the fuel much closer to the upper bou.dary of the

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yg nucleate boiling regime. Thus, the safsty margin will be signifi-h~

cantly reduced. Operation above the boundary of the nucleate boiling l

j regime could result in excessive cladding temperatures because of h.

the departure from the nucleate boiling (DNBl and the resultant sharp reduction in heat transfer coeffacient. Thus, the preposed amendment f,

2./ The Commission Issuance of Operating License Amendments Nos.' 92. 93. 98, and "I

99 for the Turkey Po'nt Nuclear Power Plants Units nos. 3 and 4. constitutes

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final administrative action. mooting administrative consideration of the jq contention that a prior hearing was requires before issuance of the ansndments.

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will both significantly reduce the safety margin and significantly

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increase the probability of serious consequeaces from an accident

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to) The increased fuel core temperatures would reduce safety 9$

l margins and would result in unacceptable swelling or bowing of A~

fuel tods. During an accident, fuel rod swelling due to higher temperatures impedes emergency cooling water flow and increases

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this could result in a significant increase in the possibility and/or

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consequescos of an accident.

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• P if) m The National Environmental Policy Act-of 1969 ("NEPA*)

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imposes the requirement of an Environmental Impact statement

("EIE*) for this proposed major federal action.

(g) A NEPA cost-benefit analysis would probably establish

%'3 that the preferred solutica to the problem of pressurized thermal shock (PTS) and the impaired reactor pressure vessels could be better achieved by premature decossissioning or by derating the

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reactors' power levels.

A full hearing is necessary 'to determine what, if any percent t f doration would achieve safe levels of operation.

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th). Whether the determination of the Wclear regulatory Commission in the final environmental impact statement for the U

J 4 Turkey point Nuclear Plants, issued in July 1972, that accidents 6

beyond the design basis of the plants (then Class 9)

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. pursuant to proposed Annex A to Appendix D,10 CFR 50,.36 Federal Register 22951, December,1,1971, have 's probability of occurance so low that their environmental risk,is proportionately low and that.

[Aj they need not be consideired in the Final Environnertal Statement - '

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reactor pressure vessel embrittlement being presently experienced by the Turkey. Point Nuclear Power Plants.

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Petithners have challenged the final gency *ction in the 3570, Center for NucleatUnited States District Court for the District of Colue'ota. In Case No. 83-

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Responsibility. Inc. and Joette Lorton v. U.S.

Nuclear Regulatory Commise8on and Florida Power & Light Company, complaint i11ed November 29, 1983.

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f (1). That the FPL company be required to meet the requirements S

of WRC Report No. NUREC - 66091Assynetric Blowdown toads on PWR f)

Primary Systems, Unresolved Safety Issue A-2) and submit a plant 5

specific analysis to evaluate fuel assembly structural adequacy e

9 and the design adequacy of reactor vessel supports and other

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h structures to withstand the loads when assynetric loss of coo. ant accident forces are taken into account. This is especially important because the new OTA and existing 14 PAR fuel assemblies f'

have slightly different T..

structural propertaes and this mixed tonfiguration should be analyses for structural adequacy before i

p the amendment is issued.

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(j)-That the reduction in guide thimble rod control cluster (RCC) rodlet clearance will have ah adverse effect on the extent of I

guide tube wear and consequently, the structural integrity of the e.

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15 x 15 ora will not be maintained with respect to the load it k

carrying capability of the guide thimble tubes and "scrrJnability" e

will be jeopardize 1.

This could lead to the inability of the t

I reactor to shutdown and increase the possibality of an accident other h

than those accidents previously evaluated or analyzed. Ti.is increase in rAsk that accidents, such as an anticipated transient without

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might occur should require that FPL pwrform a PRA of the increased risk of asch kccidents occuring at Turkey point 3 and 4.

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(kl Whether hydraulic compatability exists between the ora and l

LOPAR assemblies and whether the hydraulle flow conditions due to crossflow between fuel assemblies will adversely aficet lift forces, g

pressure drops,' cross flow and fuel vibrations, and fuel rod clad wear.

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(1) That the use of the 31rcaloy grid will increase the ar.ount f(;;

of Zircaloy that can react chemically with water or steam and impede the acceptance criteria of ECCS in 10 CTR $0.46.

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[gj tal That the demonstration experience with 17 a 17 OTA 3

oontaining Intcaloy grids does not provide evidence of the i

aatisfactory operation of the 15 a 15 OFA 31;caloy grids and l

that a plant specific analysis tak'.ng into account the deteriorated r

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condition of the Turkey point pressure vessel should be performed before the new fuel core design is implemented.

.j inlThat as indicated'in the Standard Review Plan Section i

4.2.1.1. D.

3., a post irradiation fuel surveillance program

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should be established at Turkey Point to detset anornolles in the k

fuel.

A similar program should be implemented for the WABA rods.

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to) That inservice inspection program be implemented to soonitor the deterioration in the pressure vessels in Turkey Point Units 3 and 4.

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the new fuel core design coupled with the eighteen

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(PI That month fuel cycle recently adopted by TPL will, and r

has caused, an 1

increase in radioactive iodine and a higher coolant activity at j

i Turkey Point as a result of fuel failure and that this increased c

I activity in the primary system and four fold increase in radioaodine

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poses a threat to the health and safety of nuclear workers during k

refuel 11Tg and maintenance of Turkey Point and is not in comp 11ence with the requirements of.10 crp Part 20, 50, 51, and 100.

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That the increase in radiciodine and higher coolant activity poses a danger in the form of of fsite releases that will not be in i

compliance with 10 CTR Parts 20, 50, 51, 100, NEPA, Or the PWPCA 4

and will pose a danger to the health and safety of the public and the I

4 Biscayne say environment.

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i That the 'new eighteen month fuel cycle at Turkey Point

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tr) in light of the impaired condition of the pressure vessels and 4

1 increased heat peak factors poses a danger of fuel 'cilure and i

that Turkey Point 3 and 4 should be ' returned to their traditional twelve amonth ref uelling cycle.

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' Respectfully Submitted,

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, Martin N. Modder ai 1133 NE 86 Street

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Center for Nuclear Responsibility and Joette 1erion W

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e Dated: January 25, 1984 l

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. 4, r.espectfully submitted,

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Martin M. Modder 1131 NE 86 at;eet r

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Telephone (305) 751-8706 Attorney for the Center for Nuclear Responsibility and Joette 14racn

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• i Dated: January 25, 1984 l

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