ML20039E111

Motion to Reopen Record Re ECCS Model Deficiencies.Board Notification 81-49 Indicates Discovery of Info of Matters of Serious Safety Significance & Warrants Reopening of Record. Certificate of Svc Encl

ML20039E111
Person / Time
Site:	Black Fox
Issue date:	12/29/1981
From:	Farris J CITIZENS ACTION FOR SAFE ENERGY, FELDMAN, HALL, FRANDEN, REED & WOODWARD
To:	Atomic Safety and Licensing Board Panel
References
TASK-AS, TASK-BN-81-49 BN--81-49, BN-81-49, ISSUANCES-CP, NUDOCS 8201060540
Download: ML20039E111 (6)

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THE ATOMIC SAFETY AND LICENSING BOARD __.-;J'.'.-

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In the Matter of the Application of )

Public Service Company of Oklahoma, )

Associated Electric Cooperative, Inc. )

and )

Western Farmers Electric Cooperative- ) Docket'Nos.

) STN 50-556CP (Black Fox Units 1 and 2) ) STN 50-557CP INTERVENORS' MOTION TO REOPEN THE RECORD WITH RESPECT TO ECCS MODELS DEFICIENCIES On December 17, 1981, following the prehearing conference in Tulsa, Oklahoma, the Board denied Intervenors' proposed Contention 3 (ECCS Model Deficiencies) without prejudice to Inte rvenors ' right, within 15 days, to resubmit this Contention showing a nexus between the deficiencies identified in NUREG-0630 and the proposed Three-Mile Island Licensing requirements.

Although Intervenors believe that virtually any new development with respect to the potential inadequacy of the emergency core cooling system has Three-Mile Island implications, Intervenors concede that there is no particular proposed rule relating to Three-Mile Island which would specifically constitute a nexus between the ECCS Model Deficiencies and such requirements.

However, Intervenors submit that Board notification (BN-81-49) indicates the discovery of information of matters of serious safety significance and warrants a reopening of the record to Qh Y\

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address these concerns in the context of the Black Fox Units.

Intervenors are mindful-of the scheduling order entered

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by the Board herein on October 14, 1981, and.specifically Item A. thereof, which required Motions to Reopen the ' Record 6

to be filed by November 5,1981. However, Intervenors respect-fully submit that BN-81-49 was not made available to Intervenors.

until after the prehearing conference Ani December 16 and 17,1981.

It is submitted that this new information, coupled with the Model Deficiencies identified in NUREG-0630, prima facie establish a matter of " substantial safety significance and

- would satisfy the test of Vermont Yankee and justify a reopening of the record in this regard.

Specifically, while the notification has been designated as applicable to BWR 4 and 5 Reactors, and Black' Fox is a BWR/6,

- language on.page 2 of the December 3 Mattson to Eisenhut. Memo-randum states:

There is also some possibility that the new data contradict conclusions from the 360*

air-water rests in the U.S. for a BWR/6 i configuration.

I' This Statement, coupled with the ECCS Model Deficiencies

! reported in NUREG-0630, give cause for concern that the Staff has not fully evaluated the ' possibility of significant de-ficiencies relevant to the Black Fox Units. Inte rvenor ' there-fore-respectfully requests'that the Board frame a question for consideration in the hearing as follows:

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What is the basis for the belief that the ECCS model- deficiencies reported in NUREG-0630 and the core spray maldistribution data reported from a recent test in Japan do not represent a potential serious deficiency relevant to Black Fox safety analyses?

Intervenor would be satisfied if the Board put forward this question and if testimony and the opportunity for cross-examination would be afforded. If the Board does not wish to advance such a Question, Intervenor would then propose that this issue be reopened, with the following words proposed:

Intervenor contends that the Applicant has not demonstrated compliance with the requirements of 10 CFR 50.46 and associated Appendix K.

Specifically, the accuracy of the core cooling models used for predicting performance follow-ing postulated loss-of-coolant accidents is suspect due to the model deficiencies identified in NUREG-0630. In addition, recent data concern-ing tests performed in Japan as described in Board Notification BN-81-49 has not been fully evaluated to determine the potential impact on the effectiveness of the ECCS intended for use at the Black Fox plant.

Accordingly, Intervenors respectfully move the Board to reopen the record with respect to the ECCS Model Deficiencies under either alternative suggested herein.

FELDMAN, '

L FRANDEN & WOODARD By  ; M 6 eph R. Farris 81 nterprise Building T a, OK 74103 ATTORNEYS FOR INTERVENORS

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Docket No. 50-322 ,

MEMORANDUM FOR: The Atomic Safety and Licensing Board for the Shoreham Nuclear Power Station.

FROM: Robert L. Tedesco, Assistant Director for Licensing Division of Licensing

SUBJECT:

BOARD NOTIFICATION - JAPANESE CORE SPRAY DISTRIBUTION TESTS ON A SIMULATOR BWR/S CONFIGURATION (BN-81-49 )

By memorandum dated December 3,1981, the Division of Systems Integration, in the Office of Nuclear Reactor Regulation indicated that the staff has been informed by the ACRS that Japanese core spray distribution tests of a simulated BWR/5 configuration showed that central bundles received low core spray flow due to maldistribution. This information relates to BWR/4 and -

BWR/5 reactor types.

Since this constitutes new information which relates to contentions raised in this proceding, it is being forwarded for the Board's information.

Robert L. Tedesco, Assistant Director for Licensing Division of Licensing

Enclosure:

DSI/NRR Memo dated 12/03/81 cc: See next page ,

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' OCCHETED DISTRIBUTION OF BOARD NOTIFICATION (RECENT SEISMIC ACTIVITY - LOW POWER OPERATIONS,SHOREHAM)

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Atomic S'afety and Licensing Eoard Panel Dr. Ro'bert C. axe ((aEn $ M ~

Mr. Myer Bender Atomic Safety and Licensing. Dr. Max W. Carbon Appeal Board Panel Docketing and Service Section Mr. Jesse C. Ebersole Mr. Harold Etherington Edward M. Barrett, Esq. Dr. William Kerr Jeffrey L. Futter,'Esq. Dr. Harold W. Lewis Ralph Shapiro Esq. Dr. J. Car' son Mark Howard L. Blau, Esq.

Mr. William M. Mathis

• W. Taylor Reveley III, Esq. Dr. Dade W. Moeller Jeffrey Cohen, Esq. Dr. David Okrent Stehpen B. Latham, Esq. Dr. Milton S. Plesset Energy Research Group, Inc. Mr. Jeremiah J. Ray Joel Blau, Esq. Dr. Paul G. Shewmon David H. Gilmartin, Esq. Dr. Chester P. Siess

• Mr. Jeff Smith Mr. David A. Ward MHB Technical Associates ~

1 Honorable Peter Cohalan Ezra I. Bialik, Esq. j t

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crm or sr:.m MEMORANDUM FOR: Darrell G. Eisenhut, Director Division of Licensing IM.!/M.W FROM: Roger J. Mattson, Director Division of Systems Integration

SUBJECT:

BOARD NOTIFICATION - BWR CORE SPRAY DISTRIBUTION CONCERNS

1. Item for Notification The staff has been informed by the ACRS that Japanese spray distribution tests of a simulated BWR/5 configuration have shown'that central

• bundles . receive low core spray flow due to maldistribution. We have

~a lso discussed the Japanese tests with the General Electric Company.

The Japanese tests were conducted for utilities which have kept the data ?roprietary and very little specific information is available 0 in the U. S. The test data obtained was for tests in steam of a 60 sector of a full scale BWRg core. The results were very similar to those obtained from 30 sector tests in steam in BWR/6 and BWR/4 (similar to BWR/5) configurations under the joint NRC/EPRI/GE Refill /Reflood program in Lynn, Massachusetts in 1979-80. The BWR/6 test results are discussed in staff SERs. .

0 The Lynn data are believed to be atypical of a BWR 360 configu- N ration. This conclusion is based on known gesign atypicalities, on data from air-water tests of a BWR/6 360 configuration and data '

from tests with other variously sized sectors which have shown that BWR/6 spray overlaps in the center of the core causing high flow to .

central bundles. This overlap does not occur in a sector test since thenozzlesfromtheoppositesectorwhichwould_providetheove5-lapping flow are not available. We would expect the Japanese 60 sector test to suffer; the same deficiency. ,

l We understand that the Japanese. core spray test program for the BWR/5 configuration consists of the following: -

(1) single header o BWR/5 reactors)peration in all tests (two are available in all 0

(2) 60 sector tests in steam i 0

(3) 360 tests in steam with onl to inadequate steam supply) y every sixth nozzle operating (due

.(4) 360 tests in air .

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.Darrell G. Eisenhut DEC 3 1981 Althougg no specific data are available, we have also been told that the 360 tests by the Japanese with 5/6 of the spray nozzles blocked 0

gave similar results to the 60 sector tests. This could be in-y terpreted to infer that our previous conclusions concerning the Fi atypicality of low central bundle flow are incorrect or. al_ not I applicable to the BWR/4 or 5 configurations.

This data is important to us'and we are asking our Office of International Programs to actively seek it from the Japanese govern-ment.

Since credit is taken for core spray heat transfer consistent with an assumption of a minimum spray flow to all bundles in the General Electric ECCS Evaluation Models, this infonnation may be of interest to licensing boards.

2. Relevancy and Materiality '

The Japanese tests are designed to simulate a BWR/5. Because of similarity have betweenfor implications BWR/4 BWR/4.and BWR/5 designs, the new data also may ,

the new data contradict conc!usions from 360Thereisalsogomepossibilitythat' U. S. for a BWR/6 configuration. air-water tests in the I The test results relate to the validity of core spray cooling assumptions employed in the Appendix K LOCA Evaluation Model for ,

licensed BWRs. l

3. t Sionificance of Test Information f

The Japanese data are not tSe first to show low flow to some sections

_ of BWR cores.  :

Thus, as dest.ribed above the staff has previously

( considered the effect of low core spray, flow to individual channels -

on calculated peak clad temperature (PCT). In our evaluation of .

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NED0-20566 Amendment 3, " General Electric Company Analytical Model for Loss-of-Coolant Analysis in Accordance with 10 CFR 50 Appendix K -

Effect of Steam Environment on Core Spray Distribution," it was concluded that minimum spray flow to any channel following a LOCA g would not be less than half of the design flow that was demonstrated g to be available by tests and calculations. g The tests and calculations E did rate. not include steam effects on_ nozzle spray patterns and flow Besed on measurements of minimum bundle s' pray flow for each  ?

BWR size and type for one sparger only, in air, the minimum flow for $

BWR/2 through BWR/S designs was calculated to be 1.3 times the flow ' [

necessary to remove decay heat by vaporization (reference flow). '

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Thus, the steam effects on spray l distribution would not result in .

1 lessspray both than spargers 0.65 times the minimum reference flow (or 1.3 times- with operating).

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BWR FLECHT data (Ref.1) show -

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EC 3M Darrell G. Eisenhut little degradation in heat transfer for flow as low as 0.38 times the reference flow, or approximately one gpm. As far as we have begn told, the minimum flow cbserved for any bundle in the Japanese

• 4 60 sector tests was one gpm. The heat transfer coefficients in '

GE's ECCS Evaluation Model are-based on the FLECHT data, and a minimum bundle flow of one gpm would justify the2hegt transfer .

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coefficient for core spray cooling (1.5 Btu /hr-ft - F) used in that Model.

To demonstrate conservatisms in the ECCS Evaluation Model and in response to questions raised by the NRC staff, the effect of reducing the core spray cooling to zero (i.e., no credit for core spray.

- cooling) has been evaluated by the General Electric Company for one BWR/3 and one BWR/5. For the reactors evaluated, it was found

' that the peak clad temperature limit in 10 CFR Part 50.46 of. 2200F was not exceeded even if credit was not taken for core spray cooling.  ;

It was further shown that a core spray maldistribution can result in

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4 lower peak clad temperature if the spray flow is assumed to flow down peripheral channels so as to increase the bottom reflood rate.

These results, however, are not necessarily valid for all BWRs since

• they are dependent on plant s'pecific reflood rates and on the available margin to the peak clad temperature limit (2200F) in previous calculations.

The staff concludes that the new information from the Japanese tests ~

does not pose a safety concern for operating reactors for the -

following reasons:

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(a) Only preliminary and incomplete data are available from the Japanese tests and it is impossible to draw final conclusions from them at this time. ,

(b) Core spray flow maldistributions resulting in flows on the order of one gpm per bundle (apparently consistent with those

• obtained in the Japanese # sector tests) would remain con-sistent 'With the core spray cooling assumptions employed in the present ECCS Evaluation Model of GE.

(c) Evaluation of one BWR/3 and one BWR/5 plant have shown that at least some plants can meet the LOCA core cooling criteria without-taking credit for any spray cooling, although this may -

not be true for all plants.

The staff intends'to pursue this. matter by attempting to obtain access to details of the Japanese tests via our international information exchange programs. In addition,'the General Electric .

Company has been asked to brief the ACRS subconnittee on ECCS concerning its awareness and interpretation of the ' Japanese data. .

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,- 1 Darrell G. Eisenhut - 4- DEC 3 198[

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4. Relation to Projects-The Japanese tests relate to BWR/4 and BWR/5 reactor types. It is recomended that appropriate boards be notified of the existence of the data and of staff s plans to try.to obtain the data for evaluation of their effect on the GE ECCS Evaluation Model.

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Roger . d;tson, Director Division Systems Integration

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, DEC 3 1981 Reference

1. APED-5529 " Core Spray.and Core Flooding Heat Transfer Effectiveness in a Full-Scale Boiling Water Reactor Bundle," June 1979, F. A. Schraub <

and J. E. Leonard. -

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'BEFORE THE ATOMIC SAFETY AND LICENSING BOARDiCE CF SECEETA~

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-In the Matter of the Application of )

Public Service Company of Oklahoma, )

Associated' Electric Cooperative, Inc. )

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M'~ Western Farmers Electric. Cooperative ) Docket Nos.

i ) STN 50-556CP (Black Fox Units ~ 1 and 2) . ) STN 50-557CP

, , , CERTIFICATE OF SERVICE

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. Action; for 'Sdfe Energy (C.A.S.E.), certify that copies of l,d

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"Intervenors' Motion to Reopen the Record.with Respect to ECCS-Models

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' have h en served on the persons shown on the attached list s' 2 b~y United States Mail, p'ostage prepaid, this 744'r day of

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e-Sheldon J. Wolfe, Esq. Andrew T. Daltone Esq.

Atomic Safety and ' Licensing Attorney at Law Board Panel 1437 South Main Street United States Nuclear Room 302 Regulatory Commission Tulsa, Oklahoma.74119 Washington, D.C. 20555 Mrs. Ilene Younghein Mr. Frederick J. Shon 3900 Cashion Place Atomic Safety and Licensing Oklahoma City, OK 73112 Board Panel United States Nuclear Mrs. Carrie Dickerson' Regulatory Commission Citizens Action for Washington, D.C. 20555 Safe Eneroy P. O. Box 924 Dr.. Paul W. Purdom Claremore, Oklahoma 74017 Director, Environmental Studies Group Joseph Gallo, Esq.

Drexel University Martha E. Gibbs 32nd and Chestnut Streets Frederick C. Williams Philadelphia, PA 19104 Isham, Lincoln & Beale 1120 Connecticut Ave.,N.W.

Docketing and Service Section Washington, D.C. 20036 Office of the Secretary of the Commission Michael I. Miller United States Nuclear Phillip P. Steptoe Regulatory Commission Isham, Lincoln & Beale Washington, D. C. 20555 One First National Plaza, (20 copies) Suite 4200 Atomic Safety and Licensing Board Panel Mr. Maynard Human United States Nuclear General Manager Regulatory Commission Western Farmers Electric Washington, D. C. 20555 Cooperative P. O. Box 429 Atomic Safety and Licensing Anadarko, Oklahoma 73005 Appeal Board Panel United States Nuclear Mr. Gerald F. Diddle Regulatory Commission Associated Electric Washington, D. C. 20555 Cooperative, Inc.

P. O. Box 754 Mr. Clyde Wisner Springfield, Missouri 65801 NRC Region 4 Public Affairs Officer Mr. Lawrence Burrell 611 Ryan Plaza Drive Rt. 1, Box 197 Suite 1000 Fairview, Oklahoma 73737 Arlington, Texas 76011 Dr. M. J. Robinson Black & Veatch P. O. Box 8405 Kansas City, Mo. 64114

e' Dr. John Zink Public Service Company of Oklahoma P. O. Box 201 Tulsa,-Oklahoma 74102 Mr. T. N. Ewing Public Service Company of Oklahoma P.-O. Box 201 Tulsa, Oklahoma 74102 Hon. Michael Bardrick Assistant Attorney General

-State of Oklahoma State Capitol Building Oklahoma City, Oklahoma 73105 f

Mr. Gregory Minor MHB Technical Associates 1723 Hamiton Ave.

Suite K San Jose, CA 95125 Samuel J. Chilk i Secretary of the Commission United States Nuclear  :

I Regulatory Commission Washington, D.C. 20555 2

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