ML20198E435

Affidavit of J Lorion Re Contention (D).Change in DNBR Limit from 1.3 to 1.17 Reduces Margin of Safety.Board Should Conduct Hearing Previously Ordered to Investigate Margin of Safety

ML20198E435
Person / Time
Site:	Turkey Point
Issue date:	11/06/1985
From:	Lorion J CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J.
To:
Shared Package
ML20198E427	List: ML20198E424 ML20198E431 ML20198E435 ML20198E444
References
OLA, NUDOCS 8511140026
Download: ML20198E435 (6)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of -) Docket Nos. 50-250 OLA-1.

) 50-251 OLA-1 FLORIDA POWER AND LIGHT COMPANY ) (Vessel Flux Reduction)

)

Turkey Point Nuclear )

Units 3 and 4 )

)

AFFIDAVIT OF JOETTE LORION REGARDING CONTENTION (d)

I, Joette Lorion being duly sworn, state as follows:

1. I am r esearch Director of the Center for Nuclear Responsibility Inc. , a non-profit nuclear information and resource center. I have been researching, writing, and involved in litigation on nuclear safety issues since 1978. Although I am not.a nuclear scientist, I have acquired broad knowledge of safety issues surrounding the Turkey Point nuclear power _ plant.

I feel that the information I have to offer relates to important elements of this proceeding. It is in this vain that I offer it to the Board for their consideration. I have personal knowledge of the matters stated here, and I believe them to be true and correct. I also incorporate, by reference, all the statements made by Dr. Gordon Edwards in his affidavit on November 6, 1985, and include them with my own in support of Intervenors' Contention (d).

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(2)

2. In an Atomic Safety and Licensing Board Order dated August 16, 1985, the Board admitted Intervenors' Contention (d) and presented three issues of material fact that were to be resolved at a hearing.

3. The first issue of material fact raised by the Board is:

Whether the DNBR of 1.17 which the amendments impose on the OFA fuel in Units 3 and 4 compensates for the three uncertainties outlined by the Staff in its December 23, 1983 SE on the amendments at 4.

The answer to this question is no: No.

4. Both the Licensee and Staff agree with Intervenors that the 1.17 DNBR fuel design limit allowed by the amendments does not allow for the uncertainties associated with rod bow, the hydraulics 6f the mixed core, or the application on the WRB-1 correlation. Appearing to sense that allowing for these uncertainties could mean that the 1.17 limit might not meet the 95/95 standard of the Standard Review Plan, both the Staff and FPL go to great lengths to show this Board that the calculated DNBR limit of 1.34 does meet the standard. Yet, it is not the 1.34 standard that Intervenors are arguing with.

Intervenors are questioning the safety of the 1.17 design limit that this amendment will allow and that may someday be used for the calculated DNBR.for a full OFA core Neither Staff nor the Licensee have anywhere proven that the 1.17 limit after compensating for the uncertainties for rod bow at 5.5%, mixed fuel core at 3%, and 2% penalty for

(3) application of the WRB-1 correlation to the 15 x 15 OFA core will meet the 95/95 standard. In fact, the 1.17 standard may not even meet Turkey Point's Technical Specif2 cations at B2 -

1-2, which states:

The restrictions of the Core Thermal Hydraulic Safety Limits assure that an muount of DNBR margin greater than or equal to the above penalties (5.5% for rod bow) is retained to offset the rod bow DNBR penalty.

It would also seem necessary to compensate for the 2%

pmudty for 15 x 15 OFA fuel, since no tests have ever been performed on a 15 x 15 assembley and the CHF for such an assembley is still unknown.

Thus, even though the mixed fuel core penalty of 3%

will be removed when Turkey Point has a full OFA core, there is still an uncertaintly of 7.5% that has not been compensated for in the 1.17 DNBR design limit.

4. The second issue of material fact raised by the Board is:

Whether, if the DNBR of 1.17 does not compensate for those uncertainties, the SRP's 95/95 standard or a comparable one, is somehow satisfied.

The answer to this question is: No.

5. If the 1.17 DNBR design limit does not compensate for the above ancertainties,and because the 1.17 limit constitutes the 95/95 bounding value for experimental data (indicating there is no room for uncertainties), it follows that a DNBR desigi value of 1.17 does not provide the 95% confidence

(4) prescribed by the NRC Staff in the Standard Review Plan in NUREG-0800, Section 4.4. The 1.17 would also violate the Bases for Safety Limit, Reactor Core, Turkey Point Technical Specification B2. 1-1, which states:

The DNB design basis in as follows: there must be at least a 95 percent probability with 95% confidence that the miniumum DNBR of the limiting rod during Condition I and II events is greater than or equal to the DNBR limit of the DNBR correlation being u sed . The correlation DNBR limit is established based on the entire applicable experimental data set such that there is a 95 percent probability with 95% confidence that DNB will not occur when the minimum DNBR is at the DNBR limit.

It is clear that in seeking this amendment, the Licensee seeks to use the 1.17 DNBR as the design limit and may one day use it as the calculated DNBR. Yet, it is also clear that if the uncertainties outlined in the Staff SER are compensated for, the 1.17 DNBR will not meet the 95/95 standard. The fact that the 1.17 DNBR limit will not meet the 95/95 standard, and since this is the limit the amendnent seeks to impose, places this license amendment request in the "significant hazards" category and indicates that the Staff's No Significant Hazards Consideration Determination of Amendments 99 and 93 was wrong, because the amendments both decreased the margin of safety and caused the Turkey Point nuclear plants not be in accordance with their own technical specifications and the Standard Review Plan's 95/

95 standard. (48 FR 14870 (4/16/83), the Sholly Amendment).

Einally, Intervenor would surmise that since a comparable standard has not been mentioned by the licensee or Staff, that

~

( 5) they are relying on the approved 95/95 standard for these amendments. The DNBR limit of 1.17 does not satisfy this standard.

6. The third issue of material fact raised by the Board is:

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

The answer to this question is: Yes.

7. It appears that this is the type of question that should have been answered at hearing before the subject license amendments were issued. There is every indication that a DNBR limit of 1.17 will cause a significant reduction in the safety margin of the Turkey Point reactors because it will cause these reactors, if one compensates for the above un-certainties,to operate outside of the 95/95 standard prescribed in the Standard Review Plan. Thus, the probability that DNB will take place increases and the confidence level that it will not decreases since the Turkey Point reactors will be operating outside of a proven standard.

To borrow from the Board, "usually, the closer one drives to the edge of the road, the more likely one is to go off the road. However, the behavior of the prudent driver depends on how clear he can see the edge of the road."

It is clear from both the Staff's and FPL's affidavits that they have not yet calculated just how close operating at the 1.17 DNBR limit is to the edge of the road. It would also seem that

( 6) since they have not compensated for uncertainties in their 1.17 DNBR limit, that they are driving close to the edge of the road without knowing how much of a margin of cafety they have before running off the road. This is not only imprudent, on the narrow mountain road of nuclear safety, it is dangerous to the health and safety of the South Florida community.

Because the change in DNBR limit from 1.3 to 1.17 reduces the margin of safety for the Turkey Point reactors, this Board should conduct the hearing that they ordered, so that the true margin of safety can be known. The Licensee and Staff I must not be allowed to continue on this hazardous course.

Especially in light of the fact that a recent Board Notification (BN-85-081), dated August 27, 1985, indicates that the Turkey Point nuclear reactors may not have the required redundant safety systems to protect against DNB in case of a dropped rod or rod bank accident.

Further deponent sayeth not:

Joette Lorion Subscri@ d and sworn before me this h7R day of November, 1985.

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