ML20094J065

Motion for Summary Dispositon of Intervenor Contention B.No Genuine Issue of Matl Fact Exists & Util Entitled to Favorable Decision.Related Correspondence

ML20094J065
Person / Time
Site:	Turkey Point
Issue date:	08/10/1984
From:	Bauser M FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20094J050	List: ML20094J042 ML20094J065 ML20094J088 ML20094J123 ML20094J194 ML20094J226 ML20094J260 ML20094J281
References
84-496-03-LA, 84-496-3-LA, LA, OLA-1, NUDOCS 8408140220
Download: ML20094J065 (5)

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'o DOCKETED U%RC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'84 ASO 13 N1:48 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD GrFICf FF SRH F GC d t. ]';, /. il t ,

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In the Matter of ) Docket Nos. 50-250 OLA-1

) 50-251 OLA-1 FLORIDA POWER AND LIGHT COMPANY )

) ASLBP No. 84-496-03 LA (Turkey Point Nuclear Generating )

Units 3 & 4) )

)

LICENSEE'S MOTION FOR

SUMMARY

DISPOSITION OF INTERVENORS' CONTENTION (b)

Florida Power & Light Company ("FPL" or " Licensee")

moves, pursuant to 10 C.F.R. S 2.749, for summary disposition of Petitioners' Contention (b). For the reasons set forth herein, it is Licensee's position that there is no genuine issue as to any fact material to Contention (b), and that FPL is entitled to a decision in its favor en the Contention as a matter of law. This motion is supported by the (1) Affidavit of Mark J. Parvin, attached hereto; (2) Licensee's Statement of Material Facts as to which There Is No Genuine Issue To Be Heard with respect to Intervenors' Contention (b), dated August 10, 1984; and h8f0 0

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. t (3) Licensee's Memorandum of Law in Support of Motions for Summary Disposition of Intervenors' Contentions (b) and (d),

dated August 10, 1984.

I. BACKGROUND Intervenors' Contention (b) was admitted by the Licensing Board Prehearing Conference Order, dated May 16, 1984. There-after, on May 29, 1984, Licensee propounded interrogatories to Intervenors. These were answered, in accordance with a July 3, 1984 Board Order granting an unopposed motion for extension of time, in Intervenors' Response to Interrogatories Propounded by Florida Power & Light Company, dated July 10, 1984 ("Intervenors' Response to Interrogatories"). There are no outstanding discovery requests and Intervenors' Contention (b) is ripe for summary disposition.

II. DISCUSSION Intervenors' Contention (b) reads as follows:

Whether the entirely new computer model used by the utility, for calcu-lating reflood portions of accidents meets the Commission's ECCS Acceptance criteria: specifically, whether a 2.2%

reduction in re-flood rate is misleading because for a small decrease in re-flood rate, there results a large increase in fuel temperature. Re-flood rates are critical if below 1 or 2 inches per minute (sict read second (see 10 C.F.R. Part 50, Appendix K, 5 I.D.5)].

Amended Petition to Intervene, p. 5, Jan. 25, 1984. In essence, the contention questions whether or not "a 2.2%

reduction in re-flood rate" has been properly accounted for

9 5 in analysis by means of the Westinghouse Emergency Core Cooling System ("ECCS") evaluation model utilizing the new "BART-Ali computer code for the Best Estimate Analysis of Reflood Transients" (BART computer code). See also Inter-venors' Response to Interrogatories, p. 3 (answers b-9 and b-10).

Section 50.46 of Nuclear Regulatory Commission regulations requires that an ECCS analysis be per*ormed with an acceptable evaluation model, and result in a calculated maximum fuel element cladding temperature not greater than 2200* F.

Pursuant to that requirement, ECCS analysis has been performed for the Turkey Point units with an evaluation model utilising the BART computer code, which has been found acceptable and approved by the NRC. See attached Affidavit of Mark J. Parvin, 11 3, 4 and 9 ("Parvin Af fidavit") . ECCS evaluation model analysis utilizing the BART code results in a calculated fuel rod peak clad temperature (" PCT") of 1972* F for a homogeneous core of either low-parasitic ("LOPAR") fuel or optimized fuel assembly ("OFA") fuel. Itowever, in the current period of transition, when mixed cores of LOPAR and ora fuel are utilized at Turkey Point, the analysis results are slightly effected by the fact that the hydraulic resis-tance of OFA fuel is 4.5% higher than that for LOPAR fuel.

This causes steam flow velocity past the core midplane of the OFA fuel during reflood to be reduced by about 2.2% for the mixed core transition period, and only that period.

This, in turn, results in approximately 10' F increase in

o ,

PCT over the calculated 1972* F PCT for a homogeneous core, which is well within the 2200* F criterion of 10 C.P.R.

S 50.46. Parvin Affidavit, 15.

The BART computer code utilized in the evaluation model to perform calculations for Turkey Point did not include the BART grid spacer rowet model, thuu, introducing an additional conservatism. Due to increased flow turbulence, the presence of fuel rod grid apacers in fuel bundles generally increases the local heat transfer in the vicinity of the spacers. The BART grid rewet model, which is now undergoing NRC review, is an improved version of the BART code and accounts for increased heat transfer due to the spacer grids. Parvin Affidavit, t 6.

Further, it is important not to confuse the "2.2% reduc-tion in reflood rato" referred to in Contention (b), and dia-cuosed in documentation portaining to Amendments 99 and 93 to Turkey Point operating licenses DPR-31 and DPR-41, respectively, with core flooding rates during reflood. The 2.2% reduction rofors only to reflood hot assembly steam flow velocity.

Thus, the Intervenors' concern for the apparent sensitivity of fuel rod temperature to reflood core water flooding rates below one inch per second, due to NRC requirements estab-lished in section I.D.5 of Appendix K to 10 CFR Part 50, is not relevant. parvin Affidavit, 1 7.

At the request of the NRC Staff, an analysis was also performed using the previously approved, unmodified version of the 1981 Westinghouse ECCS evaluation model, utilizing

, the Westinghouse Full Length Emergency Cooling Heat Transfer (FLECHT) correlation and not BART. This analysis indicated a PCT of 2130 F for a homogeneous core and worst case LOCA.

Adding 10* F for the transition, mixed core also results in a PCT of less than the 2200 F limit imposed by 10 CFR 50.46.

Parvin Affidavit, 1 8.

. In sum, required LOCA analyses, utilizing approved NRC evaluation models and properly taking into account reduced reflood flow rates in the OFA regions of the core, have been performed for Turkey Point yielding results consistent with applicable NRC criteria. Parvin Affidavit, 1 9.

III. CONCLUSION Based upon the foregoing; the attached Affidavit of Mark J. Parvin; Licensee's Statement of Material Facts as to which There Is No Genuine Issue To Be Feard with respect to Intervenors' Contention (b); and Licensee's Memorandum of Law in Support of Motions for Summary Disposition of Inter-venors' Contentions (b) and (d), there is no genuine issue as to any material fact and this motion for summary disposition l

should be granted and Intervenors' Contention (b) should.be decided in Licensee's favor.

l Respectfully submitted, n",

Harold F. Reis

Michael A. Bauser Steven P. Frantz Of Counsel

Newman & Holtzinger, P.C.

Norman A. Coll 1025 Connecticut Avenue, N.W.

Steel, Hector & Davis Washington, D.C. 20036 4000 Southeast Financial Center (202) 862-8400 l Miami, FL 33131-2398 l (305) 577-2800 1

l Dated: August 10, 1984