ML20137M098

Prefiled Outline of Testimony of G Edwards Supporting Intervenor Contention That DNBR Limit of 1.17 for Optimized Fuel Assembly in Transitional Mix Core Will Reduce Safety Margin.Certificate of Svc Encl.Related Correspondence

ML20137M098
Person / Time
Site:	Turkey Point
Issue date:	12/10/1985
From:	Geoffrey Edwards CENTER FOR NUCLEAR RESPONSIBILITY
To:
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ML20137M088	List: ML20137M081 ML20137M098
References
OLA, NUDOCS 8512030614
Download: ML20137M098 (5)

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l OUTLINE OF TESTIMONY BY GORDON EDWARDS Before the Board. December 10. 1YUS The intervenor contends that the adoption of the proposed DNBR limit of 1.17 for the OFA fuel in the transitional mixed core in Units 3 and 4 will result in a signiticant reduction in the safety margin ot the reactors. The contention is that the probab111tv of DNB will increase and the confidence level will decrease. and that neither the licensee nor the statt have oroven that the 95/95 criterion will be met. I agree with this conten-tion on the following technical grounds.

1. Since both the WRB-1 correlation and the Licensee's own plant-specific safety analysis proceed trom the assumotion et a homogenous core, the applicability of a DNBR of 1.17 to the UFA fuel in a transitional mixed core is highly Questionable. It would seem prudent not to countenance the use of a DNBH of 1.17 for the OFA tuel in Units 3 and 4 at least until the transitional period is past and the core is truly homogeneous.

2. Moreover, the proposed DNBR limit of 1.17 does not compensate for the three uncertainties identitled in the statf's SER (at 4): uncertainties related to rod bow, increased nydraulic resistance associated with the mixed core, and ouestions related to the applicability of the WRB-1 correlation to the 16xib UFH fuel assembly. Although the licensee has argued that the calculated DNBH ot 1.34 allows tor these uncertainties. tne proposed DNBR limit of 1.17 does not. It is the UNUM limit wnicn is being challenged by the Intervenor, not the calculated UNBH.

Neither the licensee nor the staff have succeeded in proving that the proposed DN.yd limit of 1.17 will meet the 95/9b criterion.

3. If it cannot be demonstrated that tne proposed 1.17 DNBH l limit willymeet the 95/95 standard, the amendments will cause a l significadt'roduction in the margin of safety for the operation of Units.3 and 4. The licensee seeks to use the 1.17 DNBH as a design limit and may, in future, use it as the calculated DNBH.

Under 10 C.F.R. 50.91, a proposed amendment involves a signi-ficant hazard if it entails a significant relaxation of the criteria used to establish safety limits. Therefore, there is every indication that the acceptance of an unproven DNBH limit of 1.17 will result in a significant hazard since it will allow e

Units 3 and 4 to operate outside of the Standard Review Plan's I 95/95 standard, increasing the chances that the fuel could overheat and release fission products into the primary coolant.

Moreover, since the acceptance of a lower DNBR limit will allow the fuel to run at a hotter temperature, the releasable fraction t of iodine 131'in the gap between the fuel and the fuel sheath l will be greater than would otherwise be the case.

8512030614 851125 PDR ADOCK 05000250 PDR

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4. The adoption of a DNBR of 1.17 for the UFA fuel in the transitional core is unwarranted unless detailed studies and )

tests are carried out, proceeding trom the assumption at a mixed core, and confirming that a DNBR of 1.17 is indeed appropriate under such circumstances. The assignment at numerical penalties to compensate for the inadequacies and uncertaintles that exist in extrapolating from homogeneous cores to non-homogeneous cores gives only a crude linear approximation to the real situation, which is non-linear. Such crude linear approximations based on guesswork, should not be used to justity a relaxation of the safety margin in the operation of Units 3 and 4 I

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1 EXHIBIT A Professional Qualifications and Experience of

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Gordon D. J. Edwards 1

i My name is Gordon D. J. Edwards and my home address is 1300 Raimbault, Ville St. Laurent, Quebec, Canada, H4L 4R9. I am a professor of Mathematics and Science at Vanier College in Montreal, and I am also President of the Canadian Coalition for Nuclear Responsibility (Inc).

I graduated from the University of Toronto with a Bachelor of Science degree in Mathematics, Physics and Chemistry (gold medal in mathema-tics and physics) in June, 1961. As a Woodrow Wilson Fellow, I graduated from the University of Chicago with a Master of Science in Mathematics in June, 1962, and with a Master of Arts in English Language and Literature in June, 1964. After teaching university-i level mathematics at the University of Western Ontario for several years, I graduated from Queen's University (k i ngston , Ontario) with a Doctor of Philosophy degree in mathematics it. June 1972. I conducted post-doctoral research in the Economics of Ocean Fisheries at the University of British Columbia in 1972-1973, and was the Assistant Director of a nation-wide study of the Mathematical Sciences in Canada for the Science Council of Canada in 1973-1974.

As an applied mathematician, I have been keenly interested in the strengths and weaknesses of mathematical modelling as it is applied to real-life problems. In 1977, I was a consultant to the Cluff Lake

< Board of Inquiry into Uranium Mining in Saskatchewan, where I cross-examined technical experts on such subjects as health effects of 1

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radiation, radioactive waste disposal, and reactor safety. In 1977-l 1978, I was a consultant to the Ontario Royal Commission on Electric I

Power Planning, where I cross-examined experts in reactor safety from Ontario Hydro (the utility), Atomic Energy of Canada Limited (a research and development organization), and the Atomic Energy Control i Board (the regulatory agency) over a period of several months. In 1979-1980, I was a consultant to the Select Committee on Ontario Hydro Affairs (a Committee of the Ontario Legislature) during a thirteen-week investigation into reactor safety following the Three Mile Island accident. I have also acted as a consultant on nuclear-related matters to such bodies as the Canadian Broadcasting Corporation, the National Film Board, the Science Council of Canada, the United Steelworkers of America, and several Canadian governmental bodies.

I have published several articles on nuclear power in Canada, with special reference to reactor safety and economics; in particular,

" Cost Disadvantages of Expanding the Nuclear Power Industry" (Canadian Business Review, Spring 1982) and " Canada's Nuclear Dilemma" (Journal of Business Administration, Vol.13 1982). I have also prepared numerous unpublished reports involv J technical critiques of various safety analyses for various client i

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UNITED STATES OF AMERICA 00 METE' NUCLEAR REGULATORY COMMISSION MC BEFORE THE ATOMIC SAFETY AND LICENSINGR904BOgg P2 :30-L=r In the Matter of ) Docket Nos. 50-E50;OLA i"W

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50-2 51 USAd,,l(>-

. FLORIDA POWER AND LIGHT COMPANY )

) ASLBP NO. 84-496-03 LA Turkey. Point Units 3 and 4 ) (Vessel Flux Reduction)

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CERTIFICATE OF SERVICE I hereby certify that copies of an " Outline of Testimony by Gordon Edwards", have been served on the following parties by deposit in the United States Mail, first class, postage prepaid,

-on the date shown below:

Dr. Robert M. Lazo Harold F. Reis, Esquire Atomic Safety and Licensing Board Newman and Holtzinger, P.C.

U.S. Nuclear Regulatory Commission 1615 L. Street NW Washington, D.C. 20555 Washington, D.C. 20036 Dr. Emmeth A. Luebke Norman A. Coll, Esquire Atomic Safety and Licensing Board Steel, Hector & Davis U.S. Nuclear Regulatory Commission 4000 SE Financial Center Washington, D.C. 20555 Miami, Fl. 33131-2398 Dr. Richard F. Cole Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section A U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Martin H. Hodder

• 1131 NF 86 Street Mitzi A. Young Esquire Miami, F1. 33138 Office of Executive Legal Director (305) 751-8706 U.S. Nuclear Regulatory Commission Attorney for the Center Washington, D.C. 20555 for Nuclear Responsibility and Joette Lorion Dated: November 25, 1985

• signed in his absence by Joette Lorion