ML20135H886

Statement of Matl Facts as to Which There Is No Genuine Issue.Certificate of Svc Encl

ML20135H886
Person / Time
Site:	Turkey Point
Issue date:	09/20/1985
From:	Bauser M AFFILIATION NOT ASSIGNED, FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20135H878	List: ML20135H877 ML20135H879 ML20135H883 ML20135H886
References
84-496-03-LA, 84-496-3-LA, OLA, NUDOCS 8509240350
Download: ML20135H886 (5)

Text

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UNITED STATES OF AMERICA 00LKETED NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 85 S0) 23 A11 :08 GFFCE Gr SECRtiA.

) 00CnET=NG A SE RV!U.

In the Matter of #""

) Docket Nos. 50-250 OLA-1

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

)

(Turkey Point Nuclear )

Generating Units 3 & 4) ) ASLBP No. 84-496-03 LA

) (Vessel Flux Reduction)

LICENSEE'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD WITH RESPECT TO INTERVENORS' CONTENTION (d)

Pursuant to requirements of 10 C.F.R. 5 2.749(a) and con-sistent with the Licensing Board's August 16, 1985 Order denying -- on a limited, narrow basis--- Florida Power & Light Company's (Licensee's) earlier motion for summary disposition of Contention (d), Licensee offers the following statement of material facts as to which there is no genuine issue to be heard in support.of " Licensee's Motion for Summary Disposition l

of Intervenor's Contention (d)," dated September 20, 1985.

A. As to Whether the DNBR of 1.17 which the amend-ments impose on the OFA fuel in Units 3 and 4 compensates for the three uncertainties outlined by the Staff in its December 23, 1983 SER on the amendments, at 4, the answer is: No.

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G

( (1) The DNBR acceptance limit of 1.17 for the WRB-1 correlation constitutes the 95/95 bounding value for experi-mental data. The 1.17 DNBR acceptance limit provides the 95/95 confidence prescribed by the NRC Staff in its Standard e

Review Plan, and applies to all Westinghouse plants using OFA fuel. Dzenis Affidavit, p. 2 (Sept. 10, 1985).

(2) The 1.17 DNBR acceptance limit does not. compensate for the three Turkey Point plant specific calculational uncer- '

tainties referred to in the Board's question; i.e.: rod bow, 4

mixed Low-Parasitic LOPAR/OFA fuel core, and 15x15 OFA array fuel. However, such uncertainties are considered in the Turkey Point plant specific analysis of anticipated operational occurrences. The results are then compared to the 1.17 DNBR limit to determine acceptability. Id.

2 B. As to Whether, if the DNBR of 1.17 does not 4

compensate for those uncertainties, the SRP's 95/95 standard, or a com-parable one, is somehow satisfied, i

the answer is: Yes.

l (1) The SRP's 95/95 confidence (or standard) is satisfied by assuring that minimum DNBR's calculated for al.1 normal and anticipated operational occurrences are greater than the 1.17 DNBR acceptance limit, after accounting for the uncertainties referred to above. In the case of the particular amendments under consideration in the captioned proceeding (Amendment No. 99 to the Turkey Point 3 license, and Amendment i

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. - ~ _ _ . . - . . -. . . - , . .

} No.~93 to the Turkey Point 4 license), the safety analysis minimum DNBR is 1.34 using the WRB-1 correlation. (See SER on Amendments at 4.) The 1.34 safety analysis minimum DNBR --

j which is calculated from Turkey Point plant specific reactor parameters -- is 12.7% higher than the allowable DNBR limit of 1.17 derived- from the WRB-1 correlation.

1.34-1.17

= 12.7%

. 1.34 i

l The three uncertainties referred to above, however, total only 1

i 10.5%.

5.5% (for rod bow) 3.0% (for mixed LOPAR/OFA fuel core) 2.0% (maximum, for 15x15 OFA array fuel) i 10.5%

! Since 12.7% 33 greater than 10.5%, there is sufficient margin in the 1.34 3afety analysis minimum DNBR, above the 1.17 allowable DNBR limit, to compensate for uncertainties associated with rod bow, the mixed LOPAR/OFA fuel core, and 15x15 OFA

! array fuel. Dzenis Affidavit, p. 3 (Sept. 10, 1985).

(2) Application of uncertainties.to results obtained

! from credictive analysis, rather than to design basis limits, l is common in the engineering field, and is the approach that

] has been used for all Westinghouse safety analyses for Turkey Point, independent of fuel design or critical heat flux corre-i lations. Id.

, C. As to 5

Whether, if that standard is not being satisfied, the reduction in the margin of safety has been significant, i

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I

[ the standard is, as discussed above, in fact being satisfied.

Dzenis Affidavit, p. 4 (Sept. 10, 1985).

Respectfully submitted, Of Counsel:

R_^1^ad.RM 2- w Harold F. Reis Michael A. Bauser Norman A. Coll Steven P. Frantz Steel, Hector & Davis Newman & Holtzinger, P.C.

4000 Southeast Financial Center 1615 L Street, N.W.

Miami, FL 33131-2398 Washington, D.C. 20036 (305) 577-2800 (202) 955-6600 Dated: September 20, 1985

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-P D0'.X E TED USMC UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION '85 EP 23 A11 :08 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD. 0.-

cent ,. A n <

00ChETiNG A SEPvia BRANCH

)

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 ) (Vessel Flux Reduction)

Units 3 & 4) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of (1) Licensee's Motion for Summary Disposition of Intervenors' Contention (d); and (2)

Licensee's Statement of Material Facts as to which There Is No Genuine Issue To Be Heard with respect to Intervenors' Conten-tion (d), both dated September 20, 1985, were served on the following by deposit in the United States mail, first class, postage prepaid and properly addressed, on the date shown below.

Dr. Robert M. Lazo,' Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Emmeth A. Leubke Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Richard F. Cole Atomic Safety and' Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

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't F Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief,. Docketing and Service Section (originals plus two copies)

Mitzi A. Young, Esq.

Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. ~20555 Norman A. Coll, Esq.

Steel, Hector & Davis 4000 Southeast Financial Center Miami, FL 33131-2398 Martin H. Hodder, Esq.

1131 N.E. 86th Street Miami, FL 33138 Dated this 20th day of September 1985.

ALUB- ~

Michael A. Bauser Newman & Holtzinger, P.C.

1615 L Street, N.W.

Washington, D.C. 20036 Telephone: (202) 955-6669