ML20081J739

Suppl to 830930 Petition of Jf Doherty for Leave to Intervene & Request for Hearing on Licensee Request for License Amend Permitting Single Loop Operation.Certificate of Svc Encl

ML20081J739
Person / Time
Site:	Pilgrim
Issue date:	11/03/1983
From:	Doherty J DOHERTY, J.F.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OLA, NUDOCS 8311090099
Download: ML20081J739 (5)

Text

.

1 a Novambar3,1983 l U$1TED STATES OF AMERICA 00CKETED NUCLEAR REGULATORY COMMISSION UMU BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Qg -

In the Matter of: }

)

Boston Edison Company ) 0FFlncp3ccy,r,j-[

00CXETrus g, scp.,,

(Pilgrim Nuclear Power Station, Docket No. 50-293 -OLA MANCH Unit 1) )

)

JOHN F. DOHERTY'S SUPPLEMENT.TO HIS PETITION FOR LEAVE TO INTERVENE On September 30, 1983, this Petitioner filed a " Request for a Hearing end Petition for Leave to Intervene" in response to the Applicant's (Licensee) request for an amendment to its operating license to permit eingle loop operation. The Licensee responded on0ctober 17, 1983, and the Staff on October 20, 1983. The Licensee also requested the Chair of the ASLB Panel appoint an ASLB for this Amendment, but urged denial of the Petition for lack of standing. The Staff, in its response supported the Petition, stating this Petitioner did have standing under the Commission's case law, but that this Petitioner must supplement his Petition with Con-tentions, pursuant to 10 CFR 2.714(a)(2).

Hence, this Supplement is filed pursuant to 10 CFR 2.714(a)(2).

Contentions

1. Licensee's technical specifications for operation with single loop in operation should include limits on the core plate pressure drop. Such l

j a limit would permit better regulation of core flow, leading to less variable l

within core coolant flow yielding more even cross-core power. The appli-l cation for a 50% power operation during single loop operation of the l

Cooper Nuclear Station (50-298) as noticed in the Federal Register of Sep-l tember 15,1983 (pg. 41537) sets such limits.

l l

2. If granted the right to operate "in excess of 70% rated power with on re-circulation pump out of service", the Licensee would have the first operating license right in Commission regulation not controlled by a stated power rating. The amendment has no time limit. The Board should require Licensee to 0311090099 831103 DR ADOCK 05000293 eda 9 93

2-

! operate at a stated power rating during single loop operation, which if exceeded would require shutdown, because: ,

A. Instrument drift or other malfunction may give false readings in the Average Power Range Monitors such that the plant operates above the power it is assumed operating; B. The Minimum Critical Power Ration (MCPR) for single loop operation for this plant is 1.08, which is 0.16 lower than for BWR 5, and BWR 6, reactors. Because of set-point drift in the APRMs and operator errors in reading these monitors, inadvertent operation at MCPR less than 1.07 is possible, and represents a hazard to the public safety because of i' fuel melting; C. The public is entitled to know through the Federal Register definite operating characteristics of the plant. The amendment says operation with one loop out of service at more than 458.5 MWe is allowed so long as APRM flux SCRAM trip and rod block settings are " appropriate" , Average Planar Linear Heat Generation Rate (APLHGR) are suitable and MCPR is higher than (presumably) two loop operation. By its language the proposed amendment is unclear, and does not put the public on notice as to what it proposes and how it may effect the public's Interests; D. At least one other plant, Cooper Nuclear Station (50-298), in its notice

- of amendment did so state a proposed power rating. ( 48 Fed. Reg 41,537, Sept. 15, I983).

3. As a condition of the license, the idle recirculation loop must be fully inoper-able, not merely out of service, because the danger of inadvertant start-up is present. Inadvertent start-up with the other recirculation pump running and producing in excesss of 70% rated power for the reactor would result in an overpower transient, exceeding the technical specifications for the plant for two recirculation loop operation, leading to fuel damage.

4. In event of a Loss of Coolant Accident (LOCA) due to recirculation line break in the operating loop, the operators of the plant would loose the option of supplying water to the core through the recirculation system if ECCS system failure or unavailability were to occur with the event.

5. The Licensee was recently ordered (September 2,1983) to shutdown by the Director of the Office of Nuclear Reactor Regulation because of suspected intergran-ular stress corrosion cracking (IGSCC) in the recirculation system piping, Residual Heat Removal System, Core Spray System and Reactor Cleanup System.

(48 Fed. Reg. 40,035, Sept. 2, 1983) The Applicant should be required to e e b -e di ,e.. mm e4

- - - , .- - - - , - - , ,.,y =-- 9.py,,,ym ~. - _ . _ _ _ - - - - - . p7nw-., . . - -,_r,, ,,g-g, 4 ,. ,,.-r-,- m.,, .,

show that bringing the plant to safe shutdown is is more easily achieved following a large pipe break in the single operating loop of the recir-culation system with the reactor operating in excess of 70% of rated power than if there is the same large pipe break with two operating loops and the BWR at 100% (655 MWE) power.

7. In the event of a stuck open relief valve which results in considerable water loss from the reactor, natural circulation, which is used to maintain cooling, will be less available, should the water loss accident occur

]

when a single recirculation loop is out of service. Applicant should be

required to show how it can make up for the loss of ability to turn to natural circulation cooling in event of loss of water accidents such as the stuck open relief valve event, or a main steam line break.

I

8. Operation of the Pilrrrim I with single loop oneration un-necessarily increases the effects of a pumo seizure event.

In this event, coolant wculd heat up and reduced flow vould cause steam blanketinr before core heat outout i could decline causing fuel rod crumble and melting. The danger differs in two loop operation, where the remaining pump in operation would urevent steam' blanketing. The basis for this Contention is in Accident Hazards of Atomic Power Plants, by Richard Webb, U. Massachusetts Press., 1976.,

p. 32.

9. Single loop operation, in excess of 70% power, in event of a fast transient (for example, turbine trip) is more hazardous i

than two loop operation, because single loop operation will p aggrivate the strong variability seen in axial flow rate within a BWR fuel channel, causing the critical power ratio j

(CPR) to become too low and leading to fuel heat up with -

j consecuent departure from nucleate boiling. Oneration with single loop urcvides a non-uniform flow in the fuel channels which aggrivate the observed variability. That there is strong variability seen axially in flow rate in.BWR fuel channels is based on an article: " Critical Power Ratio in BWR Transient Analyses," in the Transactions of the American Nuclear Society, 33, Hov. 1979, p. 476-7.

,-  % .,,, e-. ---.-- , .~w -.---e 3. . . , - , , - , - . - - - , , -w,w-,.-.,w,,.,-.,-- w. e-,~, -r<e,p-, . , - . . -, c c- - -------. - - . - .p,.-

10. Operation in excess of 70% power with single loop operation will re-quire reduced oper.ating temperature. In the event of a pressure transient with an Anticipated Transient without SCRAM (AIWS) the  !

reactor pressure vessel will be in a less ductile state when it encoun-ters the increased pressure and hence more open to fracture. Appli-

-cant should be required to show that here is suffficient margin in the reactor pressurve vessel to maintain integrity under pres-sure transient conditions (turbine trip, turbine trip without ,

bypass, steam line valve closure) and failure to SCRAM to avoid reactor pressure vessel fracture.

11. Single loop operation at in excess of 70% power is hazardous to this Petitioner's safety interest because reduced flow will cause  !

recovery from a loss of feedwater heater transient to be of longer duration than with two loop operation. A loss of feed water heater transient may last long enough with two loop operation for pellet-clad interaction failure to occur, so with single loop operation, this ,

prospect increases in magnitude. A basis for this contention is '

provided in the. contents .of a document which this Petitioner' fs under f

a Prot.ective Order not to reveal. This Petitioner requests -

instructions from the Board in how protected information may be used $

as the basis for a Contention.

E

~

k Respectfully Submitted,

& l:-

ohn F. Doherty 9 Petitioner, pro se i

=.

m

,9 O

e - - - , - - - --m--- e -

DOLKETED UNITED STATES OF AMERICA Mc NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFF1CE OF SECRt!A -

In the Matter of .

DOCKETygtpyd.r Boston Edison Company Docket No. 50-293

)l (Pilgrim Nuclear Power Station Unit 1) ))

CERTIFICATE OF SERVICE I certify that cocies of " JOHN F. DOHERTY'S SUPPLEMEIT TO 5 HIS PETITION FOR LEAVE TO INTERVENE" werp served via -

First Class U. S. Postal Service, this3tS of November, 1983, from Boston, Massachusetts. .

{

Thomas Dignan, Esq.

Ropes & Gray Docketing and Service Section 225 Franklin. Street Office of the Secretary E Boston, MA 02110 U.S. Nuclear Regulatory Commission f Washington, DC 20555 .

~

Atomic Safety arid Licensing Appeal [

Board Panel i U.S. Nuclear Regulatory Comission I B. PaulSafety

' Atomic Cotcer, and Jr.

Licens,ingChairman Board Washington, DC 20555  ?

Panel i U.S. Nuclear Regulatory Commission Elaine Chan , Esc. '  !

Washington, DC 20555 Staff Cohn'sel E U. S. Nuclear Regulatory Comm. I Dr. Oscar H. Paris Washington D. C. 20555 [

!

• Atomic Sa'ety and Licensing Board U. S. Nuclear Regulatory Commission [

Washington D. C. 20555 i Gustave A. Linenberger, Jr.

Atomic Safety and Licensing Board P. B. Nuclear Regulatory Commission -~

Washington D. C. 20555 3 Respectfully, fh John F. Doh ty

, ,