ML19225B554
| ML19225B554 | |
| Person / Time | |
|---|---|
| Site: | Atlantic Nuclear Power Plant  |
| Issue date: | 06/01/1979 |
| From: | Cowan B, Daugherty T, Kendrick J ECKERT, SEAMANS, CHERIN & MELLOTT |
| To: | |
| Shared Package | |
| ML19225B553 | List: |
| References | |
| NUDOCS 7907250428 | |
| Download: ML19225B554 (199) | |
Text
-
Cffshore Power Systems June 1, 1979 Sheldon J. Wolfe, Esquire, Chairman Ata' tic Safety aM Licensing Board U. S. Nuclear Regulatory Commission W..shington, D. C.
20555 Dr. David R. Schink, Member Atanic Safety aM Licensing Scard Derartment of Oceanography Texas A & '4 University College Station, Texas 77840 Mr. Lester Kornblith, Jr., Member Atemic Safety and Licensing Board U. S. Nuclear Regulatory Ccrmissicn Washington, D. C.
20555 Re: Cffshore Powar Systems, Docket No. S'IN 50-437 Mr. Chairman aM Me-bers of the Board:
Offshore Power Systems hereby files the attached
" Applicant's Procosed Partial Firdings of Fact in the Form of a Proposed Initial Decision" in accor4"' * " th the Board's Order dated May 2, 1979.
Service on be parties is docunented by a Certificate of Ser/ ice which is bouM as the last three pages of the attached volune.
Respectfully submitted, f & f. 0 0'd "
Bart.cn ". Cowan
/
JQ 772, 'W' #
Thomas M. Daugherty
/Gchn R. Kenrick Counsel for Acclicant
@ ['
Cffshore Power Systems bCA
- 6c-Is.1[.harties per Certificate of Serzice 2007250'412
CNITED STATES Cc AMERICA NUCLEAR REGULA'ICRY CCPMISSICN BEFC.E THE ATCMIC SAF?!Y AND LICD;SI!E BOARD In the Matter of
)
)
CFFSHORE K74ER SYSTEMS
)
Dociet No. S3 50-437
)
(Manufacturing License for Floating
)
Nuclear Powr Plants)
)
APPLICANf'S PROPCSED PARTIAL FINDI';GS OF FACT IN THE CORM CF A PPOPCSED INITIAL CECISICN CF CCUNSEL:
Barton 2. Cowan, Esq.
Thomas M. Daugherty, Esq.
Vincent W. Cupbell, Esq.
John R. Kenrick, Esq.
Offshore Powr Systems Counsel for Apolicant Offshore Power Systems June 1, 1979 003
~[
TABLE OF CCNIENTS Page I.
PRELIMI"RY STATD!E'72 AND DESCRIPTICN CF THE RECORD 1
A.
Introduction 1
B.
Ad:nissions and Withdrawals of Parties 4
C.
Discovery, Hearings and Motions for Su=ary Disposition 9
D.
Ir.terlccutory Acceals from Board Rulings 13 II.
FI'iDI'X35 CF FAC"' - HEALTH AND SAFETI 17 A.
General 17 B.
Description of the FNP aM Site Envelope 19 C.
Safety Evaluation of the FNP 26 D.
Researcn and Develognent 27 E.
Feasonable Assurance 28 F.
Techni-1 Qualifications of Applicant 28 G.
Financial Cualifications of Apolicant 29 H.
Canncn Defense ard Security 29 III. Findings of Fact - Compliance with the National En/ironmental Policy Act (NEPA), Sections 102 (2) (C) and (D), and 10 CFR Part 50, Apoendix D (Now 10 CFR Part 51), and Apterdix M 30 IV.
Findings of Fact Ee: Contentions Ainitted as Issues in Controversy, Board Questions, and Other Matters 33 A.
Contentien I
- Emergency Power 34 B.
Ccntention II
- Underwater Electrical Transmission Lines 39 C.
Contention III
- Marine Environment 41 D.
Centention IV
- Central Control Rocm 55 E.
Contention 7
- Transoortation 60 F.
Contentien VI
- Site Erielcpe Data 69 4
L'
- 1
?
fn JG
_1_
TABLE OF CCNTENTS (CCNT'D)
Page G.
Contention VII
- Rcdiological Lmcact on Swi.mers and Boaters 34 H.
Contention VIII
- Aircraft 90 I.
Contention IX
- Ship Collision 97 J.
Contntion X
- Ice Contair: ent 106 K.
Contention XI
- Turbine-Generator Matters 111 L.
Contention XII
- Effect on Biota 152 M.
Contention XIII
- Discharge Cutfall 153 N.
Contention XIV
- Food Chain 156 0.
Contention XV
- Dredging 157 P.
Contention XVI
- Impact on Pesort Economics 160 R.
Contention XVIII - Net Energy Yielt' Cost-Benefit Dalance 174 S.
Contention XIX
- Special Energy Paquiren ents 180 T.
Contention XX
- Heat Pumps ard Secondary ar.i Tertiary Recovery of Oil 184 Appendix A A-1 Accendix B B-1 h$$
005~
-ii-
CNITED STATES CF AMERICA NUCLEAR FIGUIA'ICRY CC 01ISSICN BEFORE THE A'ICMIC SAFE"? AND LICENSDiG BCARD In the Matter of
)
)
CFFSHOEE FU4ER SYSTEMS
)
Docket No. SIN 50-437
)
(Manufacturing License for Floating
)
Nuclear Powr Plants)
)
APPLICANT'S PPCPOSED PARrIAL FD!DDiGS OF FACT DI THE FORM OF A PFCPCSED DIITIAL CECISICN I.
PRELDiINARY STATEME:TP AND DESCRIPTICN OF THE F2CCRD A.
DTrPCDUCTICN 1.
This proceeding involves the Application filed by Offshore Pcwer Systems (Apolicant) for a license authorizing the manufacture of eight standardized floating nuclear plants (FNPs) at its manufacturing facility located on Blount Island in Jacksonville, Florida. Offshore Power Systens (CPS) is an unincorporated joint venture of Westinghouse Electric Corporation (West;.gnouse) and Westinghouse International Power Systems Company, Inc.
(WIPSCO),
Westin7 house having a 99% interest and WIPSCO having a 11 interest (Final Erwironmental Statement, Part II, September, 1976, NUREG-00.16 (FES II), Vol. 1, p. 1-1).
2.
'Ite nip will be a totally integrated gewer station mounted en a floating platform. The manufacture and assembly of the n!Ps will be done en a production line basis at the Blount Island facility.
454 90
3.
'Ite instant Application for a manufacturing license was subnitted to the Atcraic Energy Comission ( AEC)1 on January 22, 1973.
It was docketed by de Ccrc:nission en July 5, 1973. This Application was the first ene accepted by the Ccmission for licensing pursuant to the provisions of Appendix M to 10 CFR Part 50 pertaining to the manufacturino license option of design standardication.
4.
'frder Appendix M,
an application for a manufacturing license must meet cll of the requirements of 10 CFR Sections 50.34 (a) (1)-(9) and 50.34a(a) and (b), except that any required information er analyses relatirg to site matters shall be predicated on postulated site parameters which shall be smcified in the application.
Fur der-more, under Appendix M, an applicant for a manufacturing license must suunit with the application an environmental report as regaired of apolicants for constructicn permits, provided, however, that such envircnmental report shall b, directed at the manufacture of reactors at de manufacturing site and, in general terms, at the construction and cperation of reactors at hypothetical sites having characteristics that fall within the postulated site parameters.
'As of January 1,
1975, de Nuclear Regulatory Ccmmission (NRC) assened all the licensing respcnsibilities of the AEC under the Atcmic Energy Act of 1954, as amerded.
A-
' D.if 0of.
v M
M
5.
The instant Apolication, as docketed by the Commission, was accompanied by a Plant Design Report (PCR) aM an Environment _1 Report (ER). Cn various occasions since original docketing the PCR has been amended and the ER has been supplemented.
The Application, de PCR as amended, and the ER as supolemented have been admitted into evidence.
Appendix A hereto lists by exhibit nu:2ers the title, date and transcript ximission page of the Application, the PCR, Se ER arxi the ER supolements.
6.
Re NRC Regulatory Staff (Staff) performed a review of the Apolication.
As a result of this review and its own independent study, de Staff prepared a Safety Evaluation Report (SER) and two Supolements thereto. This Report ard the Supplements have been ad-mitted into evidence. Se Staff also precared as part of its review a multi-part Final Enviromental 3tsteent (FES) which has been admitted into evidence. Aopendix A hereto lists 2e title, publication number, date, and transcript admissicn page of the SER, its Supplements, and de FES.
7.
Pursuant to de Atcra;_c Energy Act of 1954_, as amended (AEA), de National Envirc = ental Polic'i Act of 1969, as amended
! EPA), and be regulations of de AEC, de AEC published en Ceceminer 10, 1973, a Notice of Receipt of Application for M nufacturing License arxl Availability of Apolicant's Environmental Reports (Notice of Receipt) and a Notice of Hearing on Application for Manufacturing AS4 Og
License (Notice of Hearing) (38 Fed. Reg. 34008). The Notice of Re-ceipt advised that the Apolication had been docketed under cne option of the Ccanission's recently announced standardization policy for nuclear gewer plants and muld be governed by the regulations set forth in Acpendix M,10 CFR Part 50. The Notice of Hearing set forth the requirements to be satisfied prior to de issuance of the re-quested manufacturirg license. O.e Notice of Hearing also apcointed this Atomic Safety and Licensing Board (Scard) to conduct the hearing ard provided that any person whose interest might be affected by the proceeding could file, by January 9, 1974, a patition for leave to interiene with respect to de issuance of the requested manufacturing license. By March 2S, 1978 all of de Board's initial members had been replaced arri the Boart.
u reconstituted to consist of its present members.
B.
ACMISSICNS AND WITSI.<AWAL5 CE PARTIES 8.
Petitions for aave to interiene were filed by the following persons or entities:
(a)
Kenneth B.
Nalton on cehalf of the City of Brigantine (Brijantine), New Jersey (subsequently, petitions for leave to intervene on behalf of de City of Brigantine were filed by Messrs. Gectge W.
'ard and Walter H.
Bew on March 27 and 28, 1974; however, these latter two cetitions were withdrawn in April, 1974);
hh (b)
Natural Resources Defense Council, Inc. (NRDC), an environmental organization with a nationwide membership; (c)
Atlantic County Citizens Council on Environment (ACCCE), a New Jersey environmental organization; (d)
Board of Chosen Freeholders of Atlantic County, New J :sey (Atlantic County), the governing body of Atlantic County, New Jersey; (e)
Bruce Doueck; (f)
Environmental Law Society of the University of Miami School of Law, Inc. (however, the Environmental Law Society withdrew its p tition in February, 1974).
9.
In February, 1974, the State of New Jersey filed a petition to participate as an interested State pursuant to 10 CFR S-tion 2.715 (c).
10.
Apelicant and Staff filed answers to the petitions for leave to intervene filed by tne aforementioned persons or entities.
Ite Board heard argunent regarding the petitions at prehearing con-ferences held on February 11, April 9 and April 30, 1974, and ulti-mately admitted NRDC and Atlantic County as intervening parties in its First Prehearing Conference Crder dated April 15, 1974 and Brigantine t
and ACCCE as intervening parties in its Second Prehearing Conference Order dated May 21, 1974. In addition, in its First Prehearing Con-ference Order the Board (a) denied the Doueck petition for leave to intervene for failure to set forth conte" 'ons with the particularity required by 10 CFR Section 2.714 (a), and (b) permitted the State of New Jersey to participate in the proceeding Wrsuant to 10 CFR Section 2.715 (c).
11.
In its First and Secord Prehearing Conference Crders the Board admitted certain contentions propunded by Brigantine, NRDC, Atlantic County and ICCCE as issues in controversy. The Board subse-quently admitted other contentions as issues in controversy. Appendix B hereto lists the contentions admitted by the Board. In addition, Apoendix B lists certain other matters which were the subj ect of incuiry in this proceeding.' The Scard's findings of fact with regard to the cententions and certain other matters which were the subject of inquiry are set for+t in Section IV. of this Initial Decision.
Since several of the admitted contentions in this proceeding per-tained to the same sucject matter, they were censolidated by topic for consideration at hearing. Appendix B reflects this censolidation and utilizes the Ranan nuneral numbering sequence and subject matter designations enployed by the Apolicant in its various mtions to establish schedule.
$ff
+
12.
By letter dated March 25, 1975, Kenneth B. Nalton filed a motion with the Board recuesting the right to participate as an individual intervenor in this proceeding rather than as a representa-tive of Brigantine. In our Memorardum ard Order dated May 8,1975, the Board granted Mr. Walton's recuest for individual intervention status aM encouraged Brigantine to secure counsel to represent its interest.
Subsequently, Brigantine did secure representation of counsel.
13.
In August, 1975, Atlantic County filed a motion to ameM and expand its contentions.
In October,1975 Brigantine also filed a motion to amerd and expaM its contentions. Applicant and Staff filed answers to these motions ard this Board heard argunent thereon at a prehearing conference held on December 2, 1975. In our Fourth Pre-hearing Ccnference Order dated Ceceder 29, 1975, the Board ainitted certain of Brigantine's proposed amended and expanded contentions as issues in controversy. 'Ite Board in this Crder denied all Atlantic County prorcsed amended and expanded contentions as either having been included within the original wrding of previously adntted Atlantic County contentions or as fnling to set forth a procer contention under applicable Crnission regulations. The Brigantine amended ard exp -ded contentions which were admitted as issues iri contrcversy are listed in Appendix B hereto.
14.
Cn 'oveder 19, 1976, NRDC filed a motion to amend and expard its contenticrs.
Also on November 19, 1976, counsel for ACCCE fil=d a joint motion en behalf of ACCCE and Atlantic County to amend Ih1 0;3 and expand their contentions.
Applicant and Staff filed answers to these mutions ard the Board heard argument thereon on May 20, 1977.
- 15. On June 24, 1977, Brigantine filed a Notice of WitN drawal as a party to this proceeding.
Said withdrawal was approved by Board Order dated July 27, 1977.
16.
Tais Stard, in its August 1,1977 Memorandt:n and Crder Re:
Motions to Amend and F.xpand Contentions, admitted one proposed ACCCE/ Atlantic County contention as an issue in controversy.
Addi-tionally, in this Order the Board stated that in view of the with-drawal of Brigantine as a party, the Board would treat the one Brigantine proposed amended ard expanded contention which it admitted as an issue in controversy at the May 20, 1977 argument as an issue retained by the Board. Finally, in this Crder the Board requested Applicant and Staff to cresent evidence on a Board question pertaining to consideration of the utilization of heat pumes and of secordary and tertiary recovery frcm oil wells a the environmental assessnent under taken in connection with the Application.
The ACCCE/ Atlantic County contention, the Board issue and the Board question are listed in Apcendix B hereto.
17.
On June 15, 1976, Mr. Ernst J. Effenberger (Efferberger) ma te a limited appearance statement before the Board concerning turbine-generator matters (Tr. 999-1010). The Board requested Acplicant and Staff to address the matters raised by Effenberger.
<l 0.i]
_s_
Subsecuently the Board authorized withdrawal of the limited acpearance statement and Effenberger testified on turbine-generator matters as a witness for ACCCE.
18.
In August, 1978 NRDC filed a motion to amerd its con-tenticn. That motien was d'enied by Crder dated ;eptember 11,1978 and a motion to reconsider that Crder was denied by Crder dated November 9, 1978. For additional discussion of this matter, see paragrapn 33, infra.
19.
In April,1977, Apolicant filed a motion for recensider-ation of that portion of this Board's May 21, 1974 Second Prehearing Conference Crder which had admitted an ACCCE contention partaining to breakwater stability as an issue in controversy. By Crder dated April 20, 1977, the Board granted Appli ant's motion and ruled that the ACCCE breakwater stability contention was site related rd hence imprcper as a contention in this manufacturing license proceeding.
Accordingly, this contention was dismissed.
C.
DISCOVERY, EEARINGS AND MCTrICNS FCR SC4 MARY DISPOSITION 20.
In its Second Prehearing Ccnference Order the Ecard coened discovery on all issues in controversy.
A;mlicant, Staff ard all intervencrs engaged in some disccvery thereafter, the majority of such discovery being conducted en an informal basis.
454
'0?
-/,
-g_
21.
A Notice of Evidentiary Hearing was issued by the Board en Marca 11, 1976. The Notic7 of Hearing stated that hearings would be held in Jacksonville, Florida, en March 23 and 24, 1976, for the pur-pose of consideration of the Staff's Final Environmental Statebent, Part I (FES I) together with de Applicant's Environment?1 Report, Part I,
as supplemented (ER I). S.ese documents considered the envircr:r, ental impact of manufacturing activities to be corducted at de Applicant's Blount Islard facility. The Notice of Hearing also stated dat limited appearance statements v suld he received at this Jacksonville hearing session. Finally, the A tice of Hearing advised dat a public hearing session would he held in Atlantic City, New Jer sey, en March 29, 1976, for the purg se of receiving limited app 2arance statements.
22.
Evidentiary hearing sessions were held in Jacksonville on March 23-24, 1976.
At the March 23, 1976 hearing, Applicant's witnasses authenticated and de Board admitted into evidence, the ER I.
In additicn at de March 23, 1976 hearing, Staff witnesses authenticated, and the Scard ainitted into evidence, the FES I.4 3Exhibits CPS-4 through CPS-10. ?.e witnesses who authenticated these exhibits were Dr. John A.
Nutant and Messrs. 2.cmas A. Mantia ard Harlan L.
Bowman. (Professional Cualifications Mmitted and incor-potated into the record at Tr. 609.)
4FES was admitted into evidence at Tr. 642 ard incorporated into the record follcwing 2. 637.
Messrs. Fred J. Clark, Jr. and Ecy 'tma were the sponsoring witnesses. (Professional cualifications aimitted ard incorocrated into the record at Tr. 637.)
A e-tog
23.
Limited apmarance statements wre taken by the Board at hearing sessions held in Jacksonville, Florida, on March 2.$-24, 1976.
Hearing sessions were convened in Atlantic City, New Jersey, on March 29-30, 1976, ani limited apmarance statements were received at those sessions.
Limited atoearance statements also.ere taken at a hearing session held in Bethesda, Maryland on June 15, 1976.
24.
On May 11, 1976, de Board convened a special prehearing conference to consider the scheduling of hearing sessions, the status of discovery in the proceeding and other matters. At de special prehearing conference the Board heard argument regarding NRDC's opcesition to de establishment of a hearing schedule in acccrdance with a stipulation Concerning Hearing Schedule and Related Matters (Stipulation) dated March 8,1976 which had been entered into by all parties to de proceeding with the exception of !BDC.
25.
Follcwing de May 11, 1976 special prehearing cen-ference, de Board issued its Fifth Prehearing Conference Order dated May 17, 1976.
In dat Crder de Board rejected the NEDC argtment that evidentiary hearirgs could not begin until de full final environ-ental statement had been p2blished.
In det Crder de Board also ordered the resumption of hearings on June 15, 1976.
The Board furder stated in its Crder dat all Se conditions, limitations and qualifications in the Stipulation muld be adhered to and that the schedule derein would be followd as closely as was reasonably practicable.
/
Y c[
J (11
/ 1
26.
Pursuant to puolished notice, evidentiary hearings on radiolog ical health and safety matters were held in Bethesda, Maryland, en June 15-18, 1976, in Washington, D.C., on July 6-9, 1976, in Silver Spring, Maryland, on July 26-27, 1976, and in Bethesda, Maryland on July 28-30, 1976, September 20-24, 1976, Septe.mter 28-23, 1976, November 3-4, 1976, December 8-10, 1976, December 16-17, 1976, February 2S-March 4, 1977, May 9-13, 1977, May 16-17, 1977. In addi-tion to de hearings on FES I held on March 23-24, 1976, hearings on environmental issues relating to generic siting of FNPs were held in Bethesda, Maryland on May 17-20, 1977, July 10-13,1978, and April 4, 1979.
27.
Cn February 16, 1979, taDC filed a motion seeking sum-mary disposition with regard to its sole contention in this proceed-ing. Sis contention alleges that the Final Environmental Statement prepared by the Staff in connection with its review of the instant Application violates the recuirements of NEPA in that it is not a programatic impact statenent.
lue Applicant's answer to the !aDC motion and the Apolicant's cross-motion for summary disposition was filed on March 8,1979.
2e Staff's response to the tmDC motion was filed March 13, 1979. Se NRDC reply to Applicant and Staff responses and its opposition to Applicant's cross-motion was filed en April 16, 1979.
gt,
'b Ojy D.
INTERIDCUICRY APPEALS FRCM BCARD RULIt'GS 28.
Applicant on March 17, 1977 filed a motion to establish schedule requesting, inter alia, a scheduling of hearings in May,1977 to consider certain environmental contentiens which had been admitted as issues in controversy.
All previous hearing sessions devoted to consideration of admitted contentions had addressed radiological health and safety issues.
Cn March 29, 1977, Brigantine #iled a response in partial oppsition to Applicant's motion to establish schedule in which Brigantine oppsed the scheduling of any hearings on previously Mmitted environmental contentions, claiming that ct:ch scheduling contravened the provisions of the Stipulation.
By Crder dated April 12, 1977, the Board scheduled hearings on certain pending environmental contentions for the May, 1977 hearing sessions.
Cn April 20, 1977, the Staff filed a motion to modify the scheduled May, 1977 hearing sessions.
Brigantine again raised the Stipulation ob-jection in an answer to the Staff motion dated April 26, 1977.
Cn April 26, 1977, the Board issued an Crder scheduling May,1977 hearing sessions on one Mmitted environmental contention of Atlantic County pertaining to resort econcraics.
Cn April 28, 1977, Atlantic County filed a motion for reconsideration of the Board's April 26, 1977 Crder scheduling May,1977 hearing sessions en the resort econcraics environ-mental contention.
Atlantic County's motion for reconsideration and Brigantine's objection to envircr= ental contention hearings were rejected by the Board at the May 9, 1977 hearing (Tr. 5505-5509).
ACCCE made an oral motion for reconsideratica of the May 9, 1977 A r-4Dh.
018' ruling at the hearing session of May 10, 1977 which was rejected by the Boare that day (Tr. 5643-5654). On May 19, 1977, Brigantine filed with tne Atanic Safety and Licensing Appeal Boa-d (Appeal Board) a pleading entitled "Apolication for Review of Hearing Board Ruling and for Stay of Further Hearings on Atlantic County Contention No. 1 (Resort Economics) ".
In that p)eading Brigantine sought to have the Appeal Board review the determination of this Board that hearings could proceed with regard to consideration of Atlantic County's resort econanics contention at the May,1977 hearing sessions.
The Appeal Board issued a Mamorandtr. and Order dated May 20, 1977 in which it denied Brigantine's application for review on the ground that it was interlocutory and not acpealable as a matter of right, and on the further ground that the Appeal Board saw no occasion to irricke its discretionary cuthority to undertake review of the matter.
29.
On February 2,1978, Applicant fi'ed a Motion for Relief in which it sought an order from this Board directing the Staff to file the AddenStra to rart II of the Final Environmental Statement, Part II (FES II) not later than February 16, 1978, and to publish the Final Environmental Statement, Part III (FES III), not later than March 10, 1978.
In its Motion for Relief, Applicant also sought declaratory relief in the nature of a directive frc;. this Board to the Staff not to include within FES III an analysis of the environmental effects of an accident more severe in consequences than those within the design basis (the " Class 9 accident" issue).
This Board in its Order dated February 23, 1978, denied Applicant's Motion for Relief.
454 O!$
Apolicant on March 18, 19.8, filed a motion for recone ration of that Order. By Order dated March 30, 1978, the Board denied Appli-cant's motion for reconsideration. In tnis Order the Board did direct the Staff to publish FES III on or before April 24, 1978, and to publish the Final AddeMum to FES II on or before June 6,1978.
30.
On April 7,1978, the Staff peti c " ne Apmal Board to direct certification of that portion of the Board's March 30, 1978, Order which required the Staff to publish the Final Addendum to FES II by June 16, 1978, aM the FES III by April 24, 1978.
On April 17, 1978, Apolicant filed with the Apoeal Board a pleadinc entitled
" Applicant's Oppsition to NPC staff Petition for Order Directing Certification and Applicant's Cross-Petition".
In this pleading, Acplicant cp sed Appeal Board certification of the Staff acpeal regarding me authority of this Board on schedule matters but cross-petitioned seeking an order of the Appeal Board directing certifica-tion of the Class 9 accident issue.
31.
Bf Order dated April 19, 1978, the Appeal Board granted both the cetition of the Staff for certification of the issue pertaining to licensing board authority on schedule mattgrs and the petition of the Acplicant for certification of the Class 9 accident issue. After briefing, the certified gaestions were argt>::d before the Accaal Board on May 25, 1978, and the Appeal Board issued its decision en August 21, 1978, ( AUS-489 ), 8 NRC 194 (1978).
In that decision the Appeal Board refusen to grant the declaratory relief sought by the A c-4 ) <l 0.20 Acplicant with regard to the Class 9 issue.
The Appeal Board also held that a licensing board may direct the Staff to publish its en-vironmental documents by soecific dates if it, after affording the parties an opoortunity to be heard on the matter, firds that no further delay is justified.
However, in this proceeding the Appeal Board ruled that this Board's Order of March 30, 1978, setting a date for the filing of FES III ard the FES II Addendum had not rested on such a finding and thus that prtion of the March 30, 1978, Order was not allowed to stand.
On Septe-1x.r 1,
1978, Applicant moved for reconsideration of that prtion of ALAB-489 relating to the Class 9 accident issue aM, in the alternative, regaested the Appeal Board to certify that issue to the Ccranission for its determination.
'Ihe Appeal Board in ALAB-500 issued September 29,1978, 8 NRC 212 (1978),
denied Applicant's motion for reconsideration but exercised its authority to certify the Class 9 accident issue to the Comission.
32.
By Order dated December 8, 1978, the Ccrnmission issued an Order accepting review of the question certified by the Acpal Board in AIAB-500.
Briefs by certain of the parties to this pro-ceeding as well as oy amicus curiae parties have been filed with the Comission.
33.
On August 9, 1978, NRDC. filed a motion seeking Board permission to amerd its sole contention in this proceeding.
Following receipt of pleadings filed by Apolicant and the Staff ocposing the NRDC motion, this Board, by Order dated Septed>er ll,1978, denied the A 'd
!J
/)< /
(1)
The Applicant has described the propoced design of, aM the site parameters postulated for, the reactors, including, but not limited to, the principal architectural aM engineering criteria for the design, and has identified the major features or ccrnponents incorporated therein for the pro *ection of the health and safety of the public; (2)
Sech father technical or design information as may be reqaired to complete the Applicant's design report and which can reasonably be left for later consideration,
.ill be supplied in a su;.plener.t to the design report; (3) Safety features or ccxnconents, if any, which require research ard develegnent have been dec-criNd by the Applicant and the Applicant has dentified, aM there will be ccMucted a research and development program reasonably designed to resolve any safety questions associated with such features or ccrnponents; ard (4)
On the basis of the foregoing, there is reasonable assurance bat (i) such safety questions will be satisfactorily resolved before any of the propased nuclear power reactors are removed from
[h the manufacturing site and (ii) taking into con-sideration the site criteria contained in 10 CFR Part 100, the proposed reactors can be constructed aM operated at sites having characteristics that fall within the site parameters postulated for the design of the reactors without undue risk to the health aM safety of the p1blic.
(b) htether the Arplicant is technically qualified to design and manufacture the proposed nuclear power reactors; (c) hhether the Applicant is financially qualified to design and manufacture the proposed reactors; and (d) khether the issuance of a license for manufacture of the reactors will be inimical to the common defense and security or to the health and safety of the giblic.
B.
DESCRIPTION OF THE FNP AND SITE ENVELOPE 35.
The basic shape of the FNP platform will be approxi-mately square with overall dimensions of 400 by 378 feet.
The plant systems and structures, in general, will be arranged on top of the basic platform structure. Within the platform structure, there will be 44-foot-deep bulkheads which extend the full length of the platform in 454 ogg.
p2rpandicular directions. These bulkheads will form the basic support structure for the hull bottan, sides, and main deck. (PDR, Section 1.2.l; SER, Section 1.4). For convenience, the description of the FNP is divided into seven basic areas discussed below. The nuclear steam supply system and the site envelope are discussed separately below.
Safeguards Area 36.
Four trains of engineering safeguards systems will be provided.
Each will be located in a comaartment separate from the obers and each will have its own diesel generator.
We eyipnent in each train will be arranced in similar vertical configurations to maximize the separation beu*en trains.
In order to ensure avail-ability of equipnent vital to safe shutdow1 in the event of the sinking emergency, taree of the four cafeguard trains of equipnent will be located in three separated water',nt canpartments. (PDR, Sections 1.2.2.4 and d.3.1; SER, Section 1.4.1).
Containment Area 37.
Be containment will house the reactor and reactor coolant system. The contairrnent system for the FNP will consist of a containment vessel and a shield building. Se containment vessel will be a free-standing,..elded steel cylindrical str ucture. A concrete shield building will enclose the containment and will provide an annulus within which any leakage fran the containment following an 454 g,',/ '
accident will be collected prior to fil tration and release to the environment.
The containment fluid systems for d.e FNP include contaiment spray systes, contaiment isolation systems,, an annulus filtration system and a combustible gas control system. Tne contain-ment will utilire an ice condenser. (PDR, sections 1.2.3, 6.2 ar.d 6.4.2; SER, Sections 1.4.2 ard 6.2).
Auxiliary Area 38.
The auxiliary area will house the spent fuel pit and radwaste treatment systems. Spent fuel transfer equipnent is designed such that the spent fuel pit will not be endangered by an accider?
involving the drop of a spent fuel cask.
Each FNP will have radwaste systems to provide for controlled handling and treatment of liquid, gaseous aM solid wastes. We liquid waste treatment systen will process wastes from equipment and floor drains, decontamination operations, laboratory wastes and lauMry and chower wastes. We gaseous waste treatment system will provide holdup capacity to allow decay of short lived noble gases stripped from the primary coolant and treat:nent of ventilation exhausts through high efficiency particulate air aM charcoal filters. The solid waste treatment system will provide for the solidification, packaging and storage of radioacti"e wastes generated during FNP operation prior to shipnent offsite to a licensed facility for burial. (PDR, Sections 1.2.2.2, 11.2, 11. 3 and 11.5; SER, Sections 1.4.3 and 11.1).
ArJ ff
?
Control Area 39.
'Ihe control room will be located in the con rol area.
"he control rocra will be surrounded by rMiolcgical shielding and will be provided with a ventilation system incorporating dual air intakes aM the carability of filtered recirculation. (PDR, Sections 1.2.2.5 and 6.5; SER, Sections 1.4.4 and 6.4).
Turbine-Generator Area 40.
Ihe turbine generator area hauses the steam and p3wer conversion systen. The steam aM p3wer conversion system for the FNP will be of conventional design, similar to those of previously approved pressurized water reactor plants but with certain features provided to accomodate platform ::cvements, su:n as a spring-mcunted turbine foundation ard vacuum-balanced cordenser. 7he system will be designed to remove heat energy from the reactor coolant by four steam generators aM convert it to electrical energy by the steam driven turbine-generator unit. 'Ibe condenser will transfer unusab'e heat in the cycle to the condenser cooli:vg water. The entire syrrem will 'oe designed #cc the maximum expected energy from the nuclear stera sugly system.
(PDR, Sections 1.2.2.6 and 3.7.2.1.1.8, Chapter 10; S':R, Sections 1.4.3 and 10.1).
Power Transmission Area 41.
The power transtission area will house the main and auxiliary transformars as well as various switchyard equipment.
N,7 v9
(
~g,z-
Terminal facilities on the ENP for plant-to-shore 345 KV transmission circuits also will be provided. (PDR, Sections 1.2.2.7 and 2.10.1; SER, Sections 1.4.6 and 8.2).
Administration and Service Area 42.
The adninisetation aM service area will contain the hotel, administrative and health @ysics facilities. (PDR, Section 1.2.2.3; SER, Section 1.4.7).
Nuclear Steam Supply System 43.
The Westimbouse RESAR-3 (Consolidated Version) nuclear steam supply system without loop stop valves will be the nuclear steam supply eystem for the FNP. The propose initial power for the RIP is 3411 megawatts, thermal.
. nuclear steam supply system consists of a pressurized water reactar, a four-loop reactor coolant ustem, and associated support systems. We reactor core will contain 193 fuel assemblies, each contain'.ng 264 fuel rods (17 x 17 array) of slightly enriched uranium encapsulated in Zircaloy tubes. Upper and lower reactor internals will provide supcort, location, orientation, and guidance for the fuel assemblies and their control rods as well as definirg a f1w path for the reactor coolant. (PDR, Section 1.2.3, Chapter 4; SER, Sectits 1.5 and 4.1).
44.
Se reactor coolant system will consist of four essen-tially identical loops of piping, reactor coolant pumps, and steam generators. Peactor coolant will circulate through the core, where it
$s'fy 029 will be heated; it will then go to the steam generatoc, where the heated coolant will transmit heat to the feedwater, thus producing steam.
We coolant pressure will be controlled by a pressurizer and ancillary equipnent attached to one loop. (PDR, Section 5.1; SER, Section 1.5).
45.
Four auxiliary support systems will parform several functions necessary for reactor and reactor coolant system operation.
Be chemica] cM volume control system will maintair. water inventory in the reactor coolant system and will provide Zlow tc the seal system of the reactor coolant pumps; it will also control the coolant che.w istry, incitding boron concentration ard the purity of the reactor coolant. Be boron recycle system will process effluent from the reactcr coolant systen ard chemical and voltne control s' stem to remove particulate matter, fission products, activation products, and to reconcentrate bcric acid. This processing will minimize plant discaarges by enabling the boric acid solution and reactor grade water to be recycled. The safety injection system will function as part of the emergency core cooling system. Other plant systems performing as part of the emergency core cooling syste. will be the residual heat removal system and the upper head injection system. We safety in-jection system and the upmr head injection system will supply highly concentrated torated water to the reactor coolant system in the event of a loss-of-coolant accident, or a steam line rupture. These systems will use pressurized accumulators for rapid response, and high, intermt liate, ard low head pt:rping systens for continuous injection
)#
@g ard long-term recirculation cooling. The residual heat removal system will remove heat frcn the reactor core during rormal plant cooldown aM refuelirs ard will provide low head injection ard recirculation as part of the safety injection system. (PDR, Sections 6.3 ard 9.3; SER, Section 1.5).
46.
Many features of the design of tht ENP are similar to those apprcried previously for land based nuclear power plants now under construction or in operation, especially the McGuire Nuclear Station Units 1 and 2 (Docket Nos. 50-369 and 50-370), and the Catawba Nuclear Station Units 1 ard 2 (Docket Nos. 50-413 ard 50-414). (SER, Section 1.5).
Site Envelope 47.
In accordance with 10 CFR Part 50, Appendix M,
the Acolicant has develo;rd site envelope parameters which will assure that the FNP is not subjected at an operating site to conditions for which it has not been designed. Further, in accordance with Appendix M,
a detailed review will be male of each individual site during construction permit proceedings to ascertain that the site falls within the site err / elope parameters. (PDR, Chapter 2; SER, Section 1.6). A contention concerning the appropriateness of the site envelope parameters was raised by Brigantine in this proceeding. The Board's Findings of fact regarding this contention are set forth in Section IV. F, infra.
024 Y
C.
SAFETY EVALUATION OF THE FNP 48.
Be Applicant in its PDR has described the proposed design of, and site parameters postulated for, the FNPs, incltding,
but not limited to, the principal architectural aM engineering criteria for the design, aM has identified the major features or ccrnpnents incorporated therein for the protection of the health aM safety of the public. Further technical or design information, as may be regaired to complete Applicant's design reprt and which can reasonably be left for later consideration, will be supplied in an ameninent to the design report.
he PDR also describes the gaality assurance to be applied to the design, fabrication, construction, and testing of the facility. (PDR, cassim).
49.
Be Staff parformed a technical review and evaluation of the data subnitted by Applicant in the license Application and in the PDR. As a result of this review and its own indeperdent studies, the Staff prepared the SER and its Supplements.
The SER analyzes and 5Exhibit OPS-21, admitted into evidence at Tr. 1031.
The witnesses who authenticated the PDR were Dr. Dee H. Walker ard Messrs. P. Blair Haga and Robert A.
Bruce. (Professional gaalifications ainitted aM incorporated into the record at Tr.1024.)
6SER and SER Supplement No. I were ainitted and incorporated into the record at Tr. 1043. Be witness sponsoring the testimony was Mr.
Ralph A. Bir kel. (Professional qJalifiCations admitted and incorpor-ated into the record at Tr.
1038.)
SER Supplenent No. 2 was published on October 8, 1976.
kC1 039 evaltutes the following topics among others: postulated site paran-eters, including seimology, geology, hydrolog, and meteorology; the design, fabrication, construction, testing, and expected performance of the FNP's structures, systems, and cm.pnents important to safety; the response of the facility to various anticipated operating trans-lents and to a broa3 spectrtra of postulated accidents inclu3ing design basis accidents; plans for conducting plant operations, the steps to be taken for iMustrial security, as well as the financial and tech-nical cualifications of the Applicant (SER, cassim).
50.
In sum, we have examined Applicant's manuf acturing license Apolication, the PDR, and the Staff's SER as supplemented and find that appropriate site parameters have been postulated. We further find that the R;P is designed adecuately to take into account the p stulated site parameters, including meteorological, hydrological, and geological conditions. Additionally, we find that there are a reasonable ntrrber of sites along the East and Gulf coasts that meet the FNP site enveloce parameters. (Tr. 1489; SER, Section 1.6).
D.
RESFAR3 AND DEVELOP E T
- 51. Apolicant has described in the PDR safety features or comoonents which recuire research and developnent. (PDR, Section 1.5).
Applicant's R&D programs, which are essentially developnental in nature, are aimed at verifying certain aspects of the RIP design. The objectives and schedules for completion are summariced in the PDR.
454 U s, n
-2,1-
52.
'Ihe Board fiMs that Applicant has identified safety features or canponents which require research aM developnent and that Applicant will conduct a research aM developnent program reasonably designed to resolve any safety qJestions associated with such features or compJnents.
E.
REASONABLE ASSURMEE
- 53. On the basis of the foregoing, the Board fiMs that there is reasonable assurance that (i) any safety gaestions associated with safety features or components which require research aM de-velognent will be satisfactorily resolved before any of the FNPs are removed fran the manufacturing site and (ii) taking into consideration the site criteria contained in 10 CFR Part 100, the FNPs can be constructed aM operated at sites having characteristics that fall within the site parameters postulated for the design of the ENPs without uMue risk to the health and safety of the public.
F.
'IECHNICM., CUALIFICATIONS OF APPLICNE 54.
The PDR sets forth the Applicant's technical gaalifica-tions. (PDR, Section 13.1). 'Ihe Staff, in the SER, determined that the Applicant is technically cualified. (SER, Section 22.0). The Apoli-cant's technical gaalifications were not contested in this proceeding.
Against this backgrouM aM in light of our own review of the record, '
the Board finds that the Applicant is technically qualified to design and manufacture the EUPs.
G.
FINANCIAL CUALIFICATIONS OF APPLICAhi
- 55. Se Application sets forth the Applicant's financial qualifications. Incitded in the Application is data irdicating that the relevant costs for manufacture of the FNPs can be financed in the ordinary course of Applicant's business (Application, Section 6 cassim). After reviewim the Applicant's data and subjecting that information to an independent check, the Staff concitded that the Applicant is financially qualified (SER Supp. No.
1, Section 1).
Neither the Aplicant's nor the Staff's financial determinations were cc tested during this proceeding. Against this background ard in light of our own review of the record, the Board finds that the Applicant is financially qualified to design and manufacture the FNPs.
H.
s DN KU DEFENSE AtO SECURI'IY 56.
The activities to be cordt.cted urder the manufacturing license applied for will be within.he jurisdiction of the Uniteo States (PDR, Sec*. ion 1.1.1).
57.
Applicant is not owned, dominated, or controlled by an alien, a foreign corporation, or a foreign govermient. The activities to be conducted do not involve any res;;icted data, but Applicant has 033 agreed to safeguard any such data which might become involved in accordance with the require nents of 1C CFR Part 50.
No nuclear fuel will be secured or supplie.d in connection with the activities to performed pursuant to this license.
For these reasons, and in the absence from the record of any evidence to the contrary, we find that the activities to be performed will not be inimical to the cmmon defense and security.
III. FINDItK;S OF FACT - COMPLIANCE WITH 'HE NATIONAL CUIROfNENTAL POLICY ACT (NEPA), SECTIONS 102 (2) (C) AND (D),
AND 10 CFR PAR" 50, APPDDIX D (tKJW 10 CFR PART 51), AND APPENDIX M 58.
The Board is required by the Notice of Hearing issued in this proceeding on December 10, 1973 to:
(a) determine whether the requirements of 102 (2) (C) and (D) of NEPA,10 CFR Part 50, Appendix D (now 10 CFR Part 51), and 10 CFR Part 50, Appendix M,
have been cm. plied with in this proceeding; (b) independently consider the final balance among confliccing factors contained in the record of the proceeding with a view to determining the appropiiate action to be tar.en; and 454 ps (c) determine whether the manufacturing license should be issued, denied, or appropriately conditioned to protect environmental values.
Sf. Applicant sutraitted, in accordance with 10 CFR Part 50, Appendix D (row Part 51), and Appendix M a series of Environmental Reports in support of its Application. Applicant's Environmental Rep 3r t, Part I (ER I), as supplemented, considered the environmental impact of manufacturing activities to be conducted at the Blount Islam facility. Applicant's Environmentra deport, Part II (ER II),
together with Appendices and Supplements, evaluated err /ironmental considerations associated with offshore, estuarine and riverine siting of FNPs.
- 60. The Staff grformed a review aM evaluation of the information sutraittcd by the Applicant in its ER. In addition, it p2rformed an independent ualysis and environmental evaluao an and prepared an Err /irorrnental Statenent in various parts. The Staff's Final Environmental Statement, Part I (FES I), dated October 1975, considered the err /ironmental impact of the manufacturing activities to be conducted at the Blount Island facility. In September 1976, the 7Exhibits OPS-57 through 64. See Appendix A for a listing of the title, date and transcript admission page of these exhibits. The witnesses who sponsored these exhibits were Dr. John A. Nutant and Ms. Cynthia C. Spencer. (Professional Qualifications admitted at Tr.
609 and 6184 respectively.)
gn
' O
Staff published Final Err /ironmental Statement, Part II (FES II) relating to its environmental assessment of the siting of FNPs at various hypothetical locations.8 In February 1977, after receipt of cx;nents on FES II from the Council on Environmental Quality, the Staff decided to publish an Addendum to FES II to address those comments. 'Ibe Final Addendum to FES II was published by the Staff in June 1978.Q' 61.
While FES II was being prepared the Staff undertook a generic consideration of the comparative risks and consequences between ENPs and lan3-based nuclear plants concerning a pstulated accidental release of radioactive material through the liquid pathway.
Consideration of the liquid pathway analysis was incitded in Part III to the Final Err /ironmental Statement (FES III) which was published in December, 1973.10 8FES II was attitted into evidence and incorprated into the record at Tr. 3626. Mr. Fred J.
Clark, Jr. was the sponsoring witness.
(Professional Qualifications ainitted at Tr. 637.)
o'The Final Adderdum to FES II was adnitted into evidence and incor-porated into the record at Tr. 7014.
Messrs. Clifford A. Haupt and Roy 3. Tana were the sponscrim witnesses. (Professional qualifica-tiens a nitted ard incorprated into the record at Tr. 7014 ard 637 respectively.)
10FES III was ainitted into evidence by stipulation on April 4, 1979, as Staff Exhibit 3 (Tr. 7264).
The Staff's Licuid Pathway Generic Sttdy (NUREG 0440) was also ainitted into evidence by stipulation on April 4,1979 as Staff Exhibit 4 (Tr. 7764).
Also on April 4, 1979 the Applicant's Liquid Pathway Generic Study, Topical Report No.
22A60, was adnitted into evidence by stipulation as OPS Exhibit 65 (Tr. 7266).
ll 03f 62.
Be ccrnplete Final Environmental Statement (FES) des-cribes the major systens of the FNP, its manufacturing process, the environmental effects of plant operation at hypothetical sites having characteristics that fall within the postulated site parameters, and postulated design basis accidents. Le FES also contains an ar.alysis of alternatives to the FNP.
In addition, the FES contains a cost-benefit analysis which considers and balances the environmental effects of the FNP and the alternatives available for reducing or avoiding Mverse environmental effects, against the environmental, econanic, technical, and other benefits of the facility. De FES concitdes that the manufacturing license, rubject to certain con-ditions for the protection of the environment, should be issued. We Staff review has also been supplemented by its evidentiary presenta-tions at the hearing. These are discussed in Section IV., infra.
IV.
FINDINGS OF FACT RE. COtEEhTIONS ADMIITED AS ISSUES IN CONTROVERSY, BOARD QUESTIONS, AND CHEER MA'1TERS
- 63. We Board, in accordance with the Notice of Hearing, has decided the issues in controversy among the parties as set forth in thisSection IV of the Initial Decision.
454 0367 A.
CONTENTION I - EMERGENCY POWER Brigan'inc mended Contention 3:
"'Ihere are insufficient experience and data with respect to '_ne functioning of the high witage electrical cables which Applicant proposes to be buried in the seabed to transmit electricity fran the shore to the facility and the undersea electr ' cal cable that Applicant proposes for connection to t'w facility to provide adequate confidence that a reliable s.,2rce of emergency power will be avail-able for safe operation of the facility."11 64.
On this contention, both Applicant and Staff presented evidence incltdig both written and oral testimony.12 None of the intervenors presented witnesses, testimony, or other information.
Hearirg sessions with regard to the contention were held on June 15 and 16, 1976, and the testimony apoears at Transcript pages 1044-1157, 1160-1324 respectively.13 11Admitted as interpreted by Board Order dated December 29, 1974, p.4.
lThe Applicant's written testimony, Exhibit No. OPS-22 entitled
" Applicant's 'Dastimony Regarding I.
Energency Power," was admitted at Tr. 1052 (6/15/76). The witnesses sconsoring this testimony were Messrs. John W. Wanless, Raymond J.
- Cooney, P.
Blair Haga and Dr.
Dee H. Walker.
(Professional Qualifications admitted at Tr.1049, 1047, 1024 respectively).
The Staff's written testimony entitled
" Supplemental Testimony on Behalf of NIC Staff in Res;cnse to Brigantine Amended contention 3" was admitted at Tr. 1163 (6/15/76).
The Staff witness sponsoring this
'estimony was Mr. Faust Rosa c
(Professional Qualification aimitted at Tr.1161).
13Applicant and Staff witnesses were examined by counsel for City of Brigantine, Atlantic County Citizens Council on Environment, Atlantic County Board of Chosen Freeholders, State of New Jersey, KC Staff and the Board.
454 03g'
- 65. Le transmission circuits for emergency power are not within the scope of the FNP design.
For FNP's that utilize underwater cable for these transmission circuits the only significant difference between the FNP offsite energency power aM that of land-based plants is the use of buried subnarine cables with flexible connections at the plant erd to accomodate the motion of the FNP. (Staff's Testimony, Page 2'.
- 66. At present there are two types of high voltage cables with proven experience installed both undergrourd ard urderwater.
Bese types of cable are known as pipe-type and self-contained type.
(Applicant's Testimony, Page 2) 67.
For nest 1C circuits, a pipe-type cable consists of three conductors.
Each corductor is insulated with layers of oil impregnated paper tape. Le three conductors are installed in a pipe, which is then filled with oil.
A protective polyethlene coating is applied to the outside of the pipe. (Tr. 1299).
68.
Self-contained cable consists of a hollow conductor surrounced witn. Layers ot oil impregnated paper tape insulation. Out-side of the paper tape is a layer of lead ard surrounding the lead is a polyethylene jacket.
Inside the hollow corductor is the oil used in conjunction with the paper tape for the total insulation systen. % hen cabler of this type are laid on the bottom unburied, an additional armor is usually apolied over the polyethlene jacket for mechanical protection. (Tr. 1300).
03(0
' /
e
69.
The adegaacy of the oil-impregnated paper tape insula-tion system for 345 kV cables was verified by an extensive utility industry testing program at Cornell University from 1957 to 1963 (Tr.
1050). A similar utility-sponsored program in the early 1970's verified the use of the same insulation system for 500 kV cables.
Both test programs established that experience data for cables operating at 138 kV aM 230 kV is applicaF
., cables operating at 345 kV. (Applicant's Testimony, Pages 2 and 3).
70.
Both pipe-t pe and self-contained cable systems are designed to empletely protect the insulated conductors frm moisture.
Therefore the same cable is used Loth underground aM underwater.
(Aoplicant's Testimony, Page 3).
- 71. The environment experienced by a cable installed underground when cmpared with the enviroment experienced by an identical cable installed underwater is sufficiently similar that no difference in failure rate would be expected. (Tr.1182).
72.
A tabulation in Applicant's Testimony of several significant high voltage cable installations in various parts of the world illustrates that cables utilizing voltages un to 575 kV are being designed and installed including sulnarine cables up to 26 miles in length.
(Applicant's Testimony, Pages 4, 6 and 7).
454 gyg 73.
A develognent program for the flexible cable connection for the offsite pwer circuits of the FNP has establishe( that a staMard self-contained 345 kV cable with an aluninun sheath is feasible ard can withstaM platform motion (PDR, Section 2.10.1.5; see also Staff Testimony, Page 5).
74.
At each end of a high voltage oil cable installation there is an oil reservoir with an oil pressurization system ard oil pressure 11 arm. An oil pressure alarm provides a warning that the cable insulation system is deteriorating. Such oil pressure alarms are normally provided on high voltage oil cable installations. (Tr.1216 -
1117).
75.
A Megger test is used to test underwater aM underground cable for deterioration of the protective polyethlene coating.
This test is in use on underground and underwater cables and is capable of detecting pinholes. (Tr. 1301 - 1302).
76.
he general location of a hole in the outer plyethlene coating of an cil/ paper cable can be found by applying a potential to the pipe or lead sheath. We route of the cable is traversed by boat with probes innersed several inches in seawater beneath the bottczn of the boat. A signal is detected where current leavec the pip = through the hole in the sheath. (Tr. 1301, 1312).
A'54 04l 77.
An Edison Electric Institute survey of forced outages of underground transnission circuits, based on a 5-year average for 1,000 miles of cable, reported an outage rate of 0.00068 outages per mile per year.
This average annual rate is about 1/5 the outage rate for overhead line aM deronstrates the reliability of underground power transmission.
(PDR Section 8.2.1).
78.
Le regulatory regairements for emergency electric power are containec in General Design Criterion 17 which requires that both an on-site electric pwer system and an off-site electric p3wer system, each redundant in itself, be provided to permit functioning of structures, systems and campnents important to safety. We on-site source of emergency p3wer for the FNP consists of four diesel gener-ator sets. (Tr.1155). Se plant design is such that on-site power for essential safety systems is adequate even for the case of ccrnplete loss of all external pwer.
(Applicant's Testimony, Pages 1 and 2).
79.
The Board firds that sufficient experience aM data exist to assure adecuate confidence that high voltage underwater cable can provide ecuivalent reliability to overhead transmission lines for emergency offsite p wer.
80.
he Board concitries that an off-site emergency power system for an FNP which utlizies high voltage underwater cable can be designed to meet the requirements of General Design Criterion 17.
454 04$
B.
COtEE!EION II - UNDEFETE.R ELECTRICAL TRAMSMISSION LINES ACCCE Contention 4b:
"Ihe Board interprets Contention numbered 4 (b) as assert-ing that the Applicant has not given adequate considera-tion to prevention of hazards which could be caused by defects in underwater electrical transnission lines. As interpreted, this Contention is hereby admitted as an issue in controversy."14
- 81. On this Contention both Applicant and Staff presented evidence including both written and oral testimony.15 None of the intervenors presented witnesses, testimony or other infor: ration. A hearing mssion regarding this Contention was held on September 29, 1976 a.xl the testimony appears at Transcript pages 3785-3800.16
- 82. The Applicant and Staff considered possible hazards to people from electric shock, chemical effect of the cable insulation anS sudden rupture of the cable. (Applicant's testimony, page 1; Staff's Testimony, page 2.)
14Admitted as interpreted by Board Order dated May 21, 1974, p. 7.
The Applicant's written testimony, Exhibit No. OPS-33 entitled "Apolicant's Testimony Regarding II. Underwater Electrical Trans-mission Lines" was atitted at Tr. 3787 (9/29/76). The witnesses spanscring this testimony were Messrs. Jota W. Wanless, Raymond J.
Cooney, P. Blair Haga an Dr. Dee H. Walker. (Professional Qualifica-tions a nitted at Tr. 1049, 1047, 1024, respectively.) The Staff's written testimony entitled "Supolemental Testimony of NRC Staff in Response to ACCCE Contention 4 (b)" was admitted at Tr. 3792 (9/29/76). The Staff witness sponsoring this testimony was Mr. Faust Rosa (Professional Qualifications admitted at Tr.1161).
Both Applicant and Staff witnesses were examined by the Board.
o'l 0
83.
No shock hazard can exist with the cable metallic housirg intact. Under normal operating conditions, c. person can touch the metallic Musing of the cable while the cable is energized and receive no harmful effects. (Applicant's Testimony, pages 1 and 3).
84.
If the cable metallic houang were d.T. aged expsing the conductor, the cable would be deenergized within a s 'all fraction of a second. During this snall fraction of a second, mot t current would flow to this housire and only a very snall amount woult return to the source through the earth or sea. (Applicant's Testimony, page 2) 85.
Regarding chemical effect of the cable insulation, no hazard has been identified. Cable insulation materials are non-toxic.
(Applicant's Testimony, pages 3 and 4).
86.
'Ihe likelihood of sudden rupture of a cable occuring due to salt water caning in contact with an energized conductor is extremely low dm to the details of cable construction and the rapid cable deenergitation which would result from loss of oil pressure, or from very low levels of current leaking throtgh the insulation.
(Applicant's Testimony, page 3.)
87.
In response to a Board question, the Applicant advised that it was not aware of any history of ships, boats, or swinners suffering as a result of contactino high voltage underwater cables.
(Transcript, p. 3789.)
45'1 04ff 88.
In 903 mile years of operation of 34.i kilovolt under-water cable, there were no failures experienced along the cable length. (Tr. 3797.)
89.
We Staff reviewed the design of underwater / underground transnission cables respecting hazard resulting frcxn defect induced cable failures and concitried that the hazards to the general public are negligible. (Staff's Testimony, page 1.)
90.
'Ihe Board finds that adequate consideration has been given to the pssible hazards that could be caused by defects in underwater cable and concludes that, with available design features, underwater ables and their associated protective systems offer protection against such hazards.
C.
CJtEDEION III - REINE CNIRONMCC ACCCE Contention 2:
"'Ihe Board interprets ACCCE contention nu:nbered 2 as asserting that the Applicant has not given adequate consideration to the effects of corrosion resulting in adverse changes in mechanical properties due to the effects of both a salt water environment and radio-activity. This contention further asserts that there should be a monitoring system to detect corrosion and other salt water effects. As so interpreted, this c tention is hereby cdmitted as an issue in controversy."y 17Admitted as interpreted by Board Order dated May 21, 1974, pp. 4, 5.
g-
Brigantine Amended Contention 6:
"Bere are substantial uncertainties as to the behavior of the reactor and essential safety systens in the marine environ:nent."
(Brigantine Proposed Amended Contention 6 frcan Motion by Intervenor City of Brigantine to Amend and Expand its Contentions, dated October 21, 1975.) "Brigan-tine's prop:) sed amended contention 6, as interpreted by the Applicant and agreed to by Brigantine and the Staff, is ADMI'ITED, ad it is understood aM agreed that the phrase, ' reactor and essential safety systems' is con-strued to refer solely to Class I safety systems and
' substantial uncertainties' refers to particular unique effects on Class 1 safety systens fran the floating plat-form and marine environment."18
- 91. On these contentions both the Applicant and Staff presented evidence, incitding material contained in the Plant Design Report (PDR), the Safety Evaluation Report (SERJ, as supplemented, and written and ot al testimony.19 None of the intervenors presented 18Admitted as interpreted by Board Order dated December 29, 1975, p.5.
19The Applicant's written testimony, Exhibit No. OPS-23, entitled
" Applicant's Testimony Regarding III. Marine Environment" was ad:nitted at Tr.1715. We witnesses sponsoring this testimony were Messrs. Joseit B.
McArdrew, Clinton Dotson, Raymond J.
- Cooney, Robert A. Bruce, P.
Blair Haga and Dr. D. H. Walker (Professional Qualifications ainitted at Tr. 1713,1712,1047, and 1024, respec-tively.)
The Staff's testimony, consisting of five separate docunents each entitled " Supplemental Testimony of the NRC Staff in Resconse to Brigantine Amended Contention 6 and ACCCE Contention 2" was ditted at Tr. 1956.
'Ihe witnesses sponsoring this testimony were Mr. Faust Rosa, M".
Richard J. Kiessel, Mr. Herbert F. Crnrad, Mr. Lauren J.
Connery, and CDR. John Deck III, United States Coast Guard (USCG). The testimony sponsored by CDR. Deck was writnen by LCDR William E. Remley, USCG and LT. 'Ihomas E. Thompson, USCG. CDR.
Deck adopted this testimony as his own at Tr. 1955.
With the exception of CDR. Deck's written testimony, the Staff testimony follows Tr. 1956. CDR. Deck's written testimony follows Tr. 2028.
The Professional Qualifications of Messrs. Rosa, Kiessel, Conrad, Connery, ard CDR. Deck were admitted at Tr. 1161 and 1946, re-smetively.
dr.
T J //
witnesses, testimony or other information. Hearing sessior.s with re-gard to this contention were held on July 6, 7, and 8,1976, and the testimony appears at Transcript pages 17061799,1800-1957, and 1958-2145, respectively.20 Protection of Interior Equipnent 92.
The FNP ventilation systems are designed to prevent the entry of marine air into interior spaces with the exception of the Fuel Buildirs (see paragraph 97 below). Ventilation systes supply air through demisters and filters which remove salt mist aM salt partic-les, respectively. (Applicant's Testimony, p.
1; Staff's Testimony, Rosa, p. 4) Interior spaces are maintained at a pressure slightly higher than the outside environment thus preventing in-leakage of the marine atmosphere (Tr. 1777-1779).
93.
Marine demisters which are capable of removing all fog and mist fran ventilation systs intake air will be utilized on the P;P (Tr. 1980 ).
20Applicant witnesses were examined by counsel for the City of Brigantine, (Br igantine), Atlantic County Citizens Council on Environment (ACCCE), Atlantic County Board of Chosen Freeholders (Atlantic County), State of New Jersey, NRC Staff and the Board.
Staff witnesses were examined by Counsel for Brigantine, ACCCE, Atlantic County, State of New Jersey, Acplicant, ard the Board.
h5) 04f]
94.
Salt particle removal filters to be supplied for FWP ventilation systens serving areas housing ecuipnent impartant to safety will have an efficiency of 99.7 percent for the removal of salt particles larger than tw micrcns (Staff's Testimony, Rosa, p. 3; Tr.
1954, Tr. 1988). These salt particle removal filters meet U.S. Navy Specifications for salt renoval in reactor cm.partment ventilation systems (Tr. 1979, Tr. 1991).
95.
Relative humidity within the FNP will be controlled to a maximtrn of 80 percent (Tr.1913). The Applicant and Staff agree that under this cordition any salt deposition which might occur wuld be dry salt (Tr. 1913) sich is non-corrosive (Staff's Testimony, Rosa, page 4).
96.
The deleterious effect of any salt deposition on protection equipment is a long-term process (Tr. 1976) and plant operation could continue in the marine environment for over a year without airborne salt removal (Tr. 1996). However, to provide an additional degree of protection the Applicant will provide a specif-ication for acquisition by the owner of the necessary equipnent periodically to measure cumulative salt deposition (if any) (Appll-cant's Testimony., pages 1 and 2). Although the specific method (s) have not been selected, several possibilities exist, each of wtiich is considered feasible by both the Applicant and the Staff (Tr.1909, et
$n ta 048.
seq.; Tr. 2136, et seq.). The purpose of 'such monitoring is to detect any potentially significant salt deposition before an equipment problem could develop (Tr.1976).
97.
Die fuel buildir.g is maintained at a slightly negative pressure with resoect to the marine atmosphere to prevent the leakage of radioactivity to th? surrounding atmosphere (Tr. 1839, et seq.).
Ecuipnent located in the fuel building important to safety will be qualified for operation in the marine atmosphere (Applicant's Testi-many, p.1; Tr.1871-1873).
- 98. Ventilation systems are provided with instrumentation to monitor systs flow rate, pressure drop across filters and demisters and differential pressure between the ventilated space and the atmosphere outside the plant (Tr. 1779-1780). These monitoring systems provide diverse indication of ventilation system perfor:rance and also provide on-line assurance that marine air is not entering ventilated areas (Tr. 1780, "t.
1904).
Continued instrunentation accuracy will be assured by periodic maintenance performed by the owner (Tr. 1781-1782).
99.
Intrusion of marine air into interior spaces housing ecuipnent important to safety will be prevented during plant tow by operation of the ventilaltion systems. Other.r2ces will either i:>3 ventilated or closed off to prevent intrusion of mar.ine air. Power for ventilation systems will be provided during tow by the emergency
$$ 't 0g}
diesel generators. (Tr. 1758, Tr. 1771-1773). In the event of diesel generator failure during tow, it is expected that the load would be transferred to another diesel generator within approximately thirty minutes (Tr.1884).
Protection of Raw Water Systems 100. The Auxiliary Raw Water (A W) and Essential Raw Water (E W) systems are the only safety-related systems which are exposed to raw (basin) water.
The materials used in these systens were selected for their proven corrosion resistance and streng th.
(Applicant's Testimony, page 2).
Joints between dissimilar metals, such as the carbon steel trim tank-tosystem piping (PDR, p. 9.2-43a), will t:e pro-tected by a coal-tar epoxy coating (Staff's Testimony, Connery, page 4). 'Ihe AW and EFW systems do not come into contact with reactor coolant an3 are not exposed to neutron radiation (Staff's Testimony, Connery, page 3).
Protection of the Platform Hull 101. Protection of the RIP hull from corrosion is described in detail in Offshore Power Systems Report AD-7100-14A85, " NIP Platform Hull Drydocking Equivalency" (Applicant's Testimony, page 2).
The Applicant has divided the exterior of the platform hull into three corrosion control zones:
the atmospheric zone, the splash zone and
}
Off the innersed (or subterged) zone (Staff's Testimony, Remley and Thompson, page 2; Tr.1858-1859).
102. Le atmospheric zone is subject to corrosion by minute salt particles carried by the wind.
(Staf f's Testimony, Remley and Thompson, page 2). Wetting in the atmospheric zone occurs mainly from rain, dew aM occasionally, spray (Tr.1742).
103. te atmospheric zone will be protected frcra corrosion by a coating systen consisting of alkyl silicate inorganic zine aM vinyl copolymer (Staff Testimony, Remley and tempson, page 2).
Protective fenders at the service dock will provide protection against possible damage to the coating from service craf t (Tr. 1918).
Coating systems such as that prop 3 sed for the atmospheric zone have trzen in service since World War II (Tr. 1743).
104. te splash zone is that area of the platform hull which is continuously wetted with aerated water (Staff's Testimony, Remley and Thompson, cage 3).
We Applicant has defined the splash zone area as extending frcm two feet below the waterline to four feet above the waterline based on expected wave action in the basin and investigation of charts of corrosion rates for pilings protected at the waterline (Tr. 1738-1739).
$a4 r
MS.
105.
Be splash zone will be protected from corrosion by a coating of modified amine-cured epoxy resin filled with inert sil-icates (Staff's Testimony, Paley and Thompson, page 3). Se Applicart has specified a coating thickness of three-sixteenths of an inch based on the costing manufacturer's recommendation (Tr. 1790-1791).
Additionally, that part of the splash one beneath the waterline will be protected from corrosion by the cae mdic protection system (Tr.
1807).
106. Coatings of the type proposed for use in the splash zone have been in service for approximately seven years ard lifetine predictions are therefore based on limited experience to date as well as general knowledge of the coating chemistry and characteristics (Tr.
1740, 2069-2070). It is reasonable to expect that complete recoating of the solash zone will not be necessary during plant life (Tr.1740).
107. Se Applicant has considered repair or replacement of splash :one coatire in OPS Document Number NA-1220-14A80, " Floating Nuclear Plant Platform Hull Corrective Maintenance Plan." Access to areas of defective coating can be obtained by triming the pla".t up to 1 degree and through the use of cofferdams where necessary (Staff's Testimony, Remley and Thmpson, page 4).
The Applicant states that the frequency and extent of splash zone coating maintenance will deperd largely on the degree of mechanical damage caused by service vessels and flotsam (Tr.18G3). We Apolicant estimates that no more 454 q
than 5 percent of the splash zone coating area will reqaire repair on an annual basis (Tr.1803, et seq.).
108. The immersed zone will be protected from corrosion by an impressed current cathodic protection system. Corrosion protection is achieved by shifting the rormal corrosion ;otential of the platform hull until it is equal to or more negative than 0.t' volts with respect to a standard copper-copper sul tate reference electrode.
At i
this potential, the corrosion rate of carbon steel in seawater has been shown to be reduced to a negligible value. (SER, p. 59).
109.
Each owner will be responsible for providing a suitable cathodic protection system at the operating site (SER, p.
60).
Included in the Site Err / elope are functional requirements for the on-site cathodic protection system (SER, Supp.
2, page 6).
The Applicant will provide platform cathodic protection during plant manufacture while the platform is afloat in the slipway (SER, page 59).
110.
During tow from the manuf acturing facility to the owner's site, impressed current cathodic protection will not be provided. The Applicant estimates that the duration of tow will be no more than a few weeks ard further estimates that, considering addi-tional time out of service for maintenance, the platform hull will be without cathodic protection for a total of less than one year during the forty year life of the plant. (Tr. 1732-1733).
454 053,
111. The impressed current cathodic protection system will incorporate autanatic control of the rectifier units by hull-mounted reference electrodes (SER, Supp. 2, page 8).
"he system is therefore self-correcting in that the reference electrodes are used to adjust automatically rectifier current output to eccpensate for variations fra" the desired hull potential (Tr. 2026-2027). At monthly intervals during plant life, the cathodic protection rectifier units will be inspected ard the voltage ard current output of each rectifier will be recorded (Tr.1719).
112.
Impressed current cathodic protection in seawater has been in use at least since 1029. The most extensive experience with these systems probably is with the U.
S.
Navy reserve fleet where numerous ships have been maintained in excess of twenty years at a reduced corrosion rate.
(Staff's Testimony, Remley and Thompson, page
- 7). The basic difference between the fresh water reserve fleet system and systems used in the ocean is related to the resistivity of the water.
The current requirements in the ocean are higher than for fresh water, which has greater resistivity.
(Tr. 1876-1877).
113.
In addition to protective coatings ard the impressed current cathodic protection system, the hull plating thickness has been increased by 0.20 inches beyord that required for platform strength and thickness.
This increment is based on a time-averaged corrosion rate for steel in seawater of 0.005 inches per year over the forty year life of the plant. This corrosion rate would be expected 45'1 053/
were no means of corrosion control provided. (PDR, page 3.12-46; Tr.
1733, et. seq.). The assuned annual corrosion rate of 0.005 inches per year does not inclide non-uniform corrosion in the form of pitting; however, pitting penetration in carbon steel relative to total corrosion diminishes to a minor fraction af ter long times such as the forty year life of the FdP.
Proper selection of wlding alloys will p rvent pitting problems in the region of welded joints. (PDR, pages 3.12-46, 47; Tr. 1899-1900).
114. The Applicant has provided in OPS Ibcunant No. NA-1220-14A79, " Floating Nuclear Plant Platform Surveillance Plan," a program for periodic inspection of the platform hull.
In order to assure the continuing effectiveness of corrosion prevention systems the U.S.
Coast Guard (USCG) will corduct in-service inspections at four year intervals, or more frequently if deemed necessary by the local L3CG Officer in Charge of Marine Inspection. (Staff' ; Testimony, Rmley and Thanpson, pages 3, 6 and 7). USCG inspectiers are required by law (Tr.
2024) and satisf actory resolution of any deficiencies found is required for continued plant operation (Tr. 2100-2101). The Applicant has considered underwater wld repairs of the platform hull and has concluded that such repair is feasible using existing techniques (PDR, pages 3.12-55, et seq.).
~
454 0"g.
Salt Water - Radiation Synergism 115. With respect to the effects of radiation upon the mechanical properties of metals, experiments have shown that only neutrons have any effect (Staff's 1bstimony, Conr ad, page 2,
Tr.
116. The reactor vessel and its internals are the only FNP components that are subj ect to significant neutron irradiation (Applicant's Testiwny, page 2; Staff's Testimony, Conrad, page 3; Tr.
1950-1951). The reactor vessel is lo:ated within containment ard is expased neither to salt water nar to a salt atmosphere (Applicant's Testimony, page 2).
117. Applicant's investigat. ions indicate that radiation 3evels would have to increase by 8 to 10 orders of magnittde in those areas expased to salt water benze there would even be any patential for synergistic ( ffects (Tr. 1846). No normal or accident condition has bet.n identified which would produce this level of radiation exposure (Tr. 1945-1847).
118. Components of the nuclear steam supply system and associated safety systm.s will receive inservice inspection under the provisions of Section XI of the Americt Society of Mechanical Engineers Boiler and Pressure Vessel Code (Staff's Testimony, Conrad, page 3).
$5d 05g
Plant Motion in the Marine Environment 119. 'Ihe as-moored accelerations a.,d angular displacements for wnich the FNP is designed are stated in the Site Envelope (Table 2.1-1) of the PDR. 'Ihe Comission will require the plant owner to demonstrate that these motions will not be exceeded at the propsed site. (Staff's Testimony, Kiessel, pages 2-4).
120. The Applicant presented analyses of several types of cangnents for motions in excess of the stated design basis limits.
The calculated equivalent static accelerations are less than the accelerations for which these companents otherwise n be designed to satisfy seisnic requirements. (PDR, Appendix B,
pages B.9.2-5, 6;
Applicant's Testimony, p. 3).
121.
It is an acceptable procedure to design FNP systems, canponents and canoonent supports for loads resulting fran wind and wave excitation on the basis of rigid body analyses, appropriate fatigue factors ard the specified Site E:welope parameters. (Staff's Testimony, Kiessel, pages 2-4; Tr. 2130, et seq.; SER, page 47).
Conclusions 122. 'Ihe Board finds that the Applicant has given adegaate consideration to the effects of corrosion due to a salt water environ-ment which could result in adverse changes in mechanical properties.
454 057 The Board further finds that the design of the FNP provides Megaate protection against corrosion such that plant operation within the marine environment will not pse undue risk to public health and safety.
123. The Board finds that the design of the ENP, in combina-tion with required inservice surveillance, provides adequate monitor-ing to detect corrosion and other salt water effects and further finds that no additional such monitoring systems are required to detect corrosion and other sa'.t water effects.
124. The Board finds that the Applicant has given adequate consideration to the combined effects of salt water and radioactivity on the mechanical properties of materials. The Board further concludes that there exists reasonable assurance that the combined presence of radiation of the type aM intensity necessary to affect the mechanical properties of materials and either salt water or salt air, will not occur in the FNP.
The Board firds that the pstulated synergistic action of salt water and radiation cannot occur in the ENP and therefore such synergisn does not impose an undue risk to public health and safety.
125. The Board finds that the Site Envelope limits on plant motion in the marine err /iror:nent are reasonable as regards both plant siting and equignent design.
454 95g 126. 'Ibe Board finds on the basis of the foregoing that there are no substantial uncertainties as to the behavior of the reactor and essential safety systems in the marine environment.
D.
CONTENTION IV - CENTPAL CONTROL POOM ACCCE Contention 9:
" Applicant has not given Mequate consideration to failure or malfunction of control operation.e because the location of the structure housing the central control operations is in a relatively unprotected position, exposing this struc-ture to severe meteological (sic) conditions and damage or destruction by fire, industrial sabotage, terrorists acts, flying debris or collisions." Further, "the design of the central control operation structure is inadequate to pro-tect it frcm the hazards mentioned above." 1 127. On this contention, Nth Applicant and Staff presented evidence incitriing material contained in the Plant Design Report (PDR), the Safety Evaluation heport as supplemented (SER) aM written and oral testimony. 2 None of the intervencrs presented witnesses, testimony or other information.
Hearing sessions with regard to this contention wre held on July 9, 26, 27, 28, 29 aM 30,1976, and the 21Admitted as interpreted by Board Order dated May 24, 1974, p. 10.
22The Applicant's written testimony, Exhibit No. OPS-24 entitled
" Applicant's 'Ibstimony regarding IV.
Central Control Rocn" was admitted at Tr. 2164. 'Ihe witnesses sponsoring this testimony were Dr. Dee Walker and Messrs. Raymond J.
- Cooney, P.
Blair Haga and Richard S.
Orr (Professional Qualifications admitted at Tr. 1024, 1047, 1024, and 1329 respectively). Mr. Charles King was Mded to the panel for the in-camera sessions (Professional Qualifications admitted at Tr. R-5). The Staf f's written testimony entitled
" Supplemental Testimony on behalf of NRC Staff in response to ACCCE Contention 9" by Falk Cantor, Kenneth G. Murphy and Ray F.
- Priebe, 454 059 testimony appears generally at Transcript pages 2163-2869 and R1 -
R168. ')3 128. Tne control roan is located on the starboard side of the platform. It is serrounded on three sides by reinforced concrete walls of either one or two foot thickness and on the exterior side by a 1 1/8 inch thick steel plate wall.24 The roof structure consists of a two foot thick reinforced concrete slab. We floor of the control roan consists of metal deck and concrete approximately 3 inches thick. We control room is located approximately 66 feet above the basin water level. (Applicant's Testimony, page 1; Staff's Testimony, page 1; PDR Section 6. 5. 3.1. 2. )
(Footnote 22 Continued) which follows Tr. 2536, was ainitted at Tr. 2536. NRC staff wit-nesses sponsoring this testimony were Messrs. Murphy and Priebe together with Drs. John A. O'Brien and Jacques B.
J.
Read (Pro-fessional Qualifications of Messrs. Murphy, and Priebe and Drs.
O'Brien and Read were Mmitted at Tr. 2534). Messrs. Phillip Mathews and Charles Long were added to the panel at Tr. 2798 (Professional Qualifications were Mmitted at Tr. 2803) 23Apolicant witnesses were examined by counsel for Atlantic County Citizens Council on Environment (ACCCE), City of Brigantine (Brigantine), Atlantic County Board of Chosen Freeholders (Atlantic County), State of New Jersey, NRC Staff and the Board.
Staff witnesses were examined by counsel for ACCCE, Brigantine, State of New Jersey, Aoplicant and by the Board.
The Applicant's written testimony stated that the exterior wall of the control room was 3/4 inch thick steel plate. We thickness of the steel plate was subsequently changed to 1 1/8 inch. The 1 1/8 inch thickness is provided for radiation shielding. ( Applicant's Testimony, Page 3, and PDR Section 12.1.2.5).
454 p-WVen 129. Se location of the control rom in relation to the other structures, systems, and equipnent on the FNP ard in relation to the exposure of the control room to the environment is comparable to the location of control roms on land-based nuclear plants which have been licensed by the CcInmission (Staf f's Testimony, Page 2, and Tr.
2382 and 2567).
130. he primary criteria used in locating the control rom were to minimize the length of low level signal cables and to place the control room at an elevation above the maximum water level assumed for the postulated sinking energency (Tr. 2384 and 2516 and PDR Section 15.61.
131. Be control room is a structure important to plant safety and is designed to meet the design criteria ard standards established for safety related structures. It is designed to withstand severe meteorolcgical corditions (Applicant's Testinony, page 2:
Staff's Testimony, page 2).
132. Le control room is designed to withstand the spectrum of missiles asstxned to be generated by the desic,n basis tornado.25 o A test performed for the Applicant subsequent to the hearings on this contention resulted in penetration of a 3/4 inch steel plate by r.ne of the specified tornado missiles (letter of November 18, 1976 frcxn T. M. Daugherty to the Board). As irdicated in Paragraph 2 and footnote 3, suora, the exterior control room wall is now 1 1/8 inch thick. Tha final design of the exterior control roczn wall will withstand all specified tornado missiles (Tr. 5243).
4
%r.4
()u~e r -
These missiles are trore energetic ard therefore more ptentially damaging than any other missiles or flying debris which could be pstulated to occur as the result of other severe meteorological phencznena or p tential accidents (Staff's Testimony, page 4; PDR Sections 3.5.3 and 3.5.7; SER Section 3.5.2).
133. The control roan is designed to withstand the crash of a passenger carrying helicopter (PDR Section 3.5.5, SER Section 3.5 ard Tr. 2237). Potential collisions with the FNP are additionally dis-cussed in the Findings of Fact on Ship Collision and Aircraft, infra.
134. The plant design provides the capability for effecting and maintaining a safe shutdown condition from outside the control room in the unlikely event that conditions necessitate evacuation of the control room (Staff's Testimony, Page 6).
135. The control roan is protected against floating fires external to the plant by its location which is well abcrie the basin water level (Staff's Testimony, Page 3). The site err / elope requires that an owner provide site features which will prevent an oil spill outside the site structure fran approaching within 100 feet of the plant (PDR Table 2.1-1, SER Table 1.2 (Revised), and Staff's Testi-mony, Page 3.) The FNP external fire protection systen is designed to control and/or extinguish floating fires within 100 feet of the plant.
In addition, for those sites at which the risk frcra ra'diant heat flux from exposure fires more than 100 feet frcxn the plant is significant, OQ a falling water film system is provided as an option to prctect the exterior walls of the plant, including the control room. (PDR Section 9.5.1.2, SER Section 9.5.1, and Staff's Testimony, Page 3.)
The control roan ventilation system is designed to protect the control r T. operators fran the effects of smoke and other combustion products (Staff's Testimony, Page 3, and PDR Section 9.4.1).
136. Se design of the FNP will enable an cwner to meet the irdustrial security requirenents of 10 CFR 73 and Regulatory Guide 1.17 (Protection of Nuclear Powr Plants against Industrial Sabotage).
(Applicant's Testimony, Page 3).
137. The inherent structural characteristics of the FNP result in a well protected, blast and penetration resistant structure, and provide a facility at which intentional dange would be extremely difficult. Furthermore, the location of the control roan, three floors above the boardingplatform and approximately 66 feet above the basin water level, substantially reduces the susceptibility of the control room to credible external threats from a potential adversary. (Staff's Testimony, Page 1 and 5).
138. he owner of each ENP will be required to provide a ccraprehensive security program for the protection of the plant against external threats. Be principal elements of such a program will include physical protection features to prevent or deter surreptitious entry, administrative measures to control access, a trained security
)
062 force for plant surveillance, and a response capability by armed guards supplenented by arrangements with offsite law enforcement authorities. (Staff's Testimony, Page 6).
139. The Board conclaSes that the design aM location of the central control room is adequate to protect the cen*Jal control operation from hazards due to meteorological conditions, fire, industrial sabotage, terrorist acts, flying debris or collisicas.
E.
CONrfNTION V - TRANSPORTATION ACCCE Contention 5:
"The Applicant has not given a5 equate attention to provis-ions for preventing accidents in the handling aM *Jans-portation of radioactive materials to and from the ocean site in the following areas:
a.
Provisions to prevent damage to platforms, mooring systens, reactor buildings ard breakwater in event of barge collision and passible resultant flying debris, all re-sulting frcra rapid onset of severe, unforeseen, extreme meteorological conditions.
b.
Provisions to safeguard reactor plant and platform in event of fire aboard a nuclear fuel-transporting barge while barge is within breakwater, entering or leavir g breakwater, or in close pec:.imity to the offshore plant.
c.
Provisions to deal with a collision of a vessel with a barge or breakwater resulting in dispersal of hazardous cargo on or around the breakwater or on the floating plant."26 26A nitted as interpreted by Board Order dated May 21, 1974, p. 7.
45s Y g6t]
Atlantic County Contention 3:
"Intervenor contests the adequacy of procedures for safe transfer of spent fuel and radioactive waste fran the floating nuclear plant to the ship, to account for the peculiar characteristics of floating nuclear power plants."'7 Walton Contention:
" Adequate consideration has not been given by the Applicant to accidents, that could occur during transportation of ra-dioactive materials between the facility and the shore."
140. These three related contentions were considered by the Board together. On these contentions, both Applicant and Staff presented evidence, including material contained in the Plant Design Report (PDR), the Final Environmental Statement (FES), as supple-mented, the Safety Evaluation Report (SER), written and oral testi-mony, and an affidavit. None of the intervenors presented witnesses, testimony, or other information.29 The Hearing sessions with regard to 27Admitted as interpreted by Board Order dated April 15, 1974,pp.9,10.
28Admitted as interpreted by Board Order dated May 21, 1974, pc.2,3.
20'The Applicant's written testimony, Exhibit No. OPS-34, entitled
" Applicant's Testimony Regarding V. Transportation," was admitted at Tr. 3864. 'Ihe witnesses sponsoring this testimony were Dr. Dee Walker, Mr.
P.
Blair Haga, ard Miss Mary Ann Capo (Professional Qualifications ainitted at Tr. 1024,1024, and 3831, respectively).
The Staff's written testimony entitled " Supplemental Testimony of NRC Staff in Response to the Pertin int Portion of ACCCE Contention 5, Atlantic County Contention 3 ard Brigantine Original Contention and Walton Contention" by Joselt R. Levine, John A. O'Brien, Edward B.
Tomlinson and Robert F. Barker, was admitted at Tr. 3915 (Pro-fessional Qualifications of Mr. Irvine, Dr. O'Brien, and Messrs.
Tanlinson anS Barker were admitted at Tr. 1476, 2534, and 3911, respectively). Apolicant's Exhibit No. OPS-104, entitled " Affidavit of Dee H. Walker," containing information requested by the Board at Tr. 3900, was filed on March 29, 1977.
d[
these contentions were held on November 3 and 4,
1976, and the testimony appears at Transcript pages 3866 - 3905, 3916 - 3929, 3933 -
3989.30 141. A crane will be provided for the Floating Nuclear Plant (FNP) to transfer a spent fuel cask frcIn the plant to a barge (or other form of transportation) along side the plant (Applicant's Testimony, page 2). The cask handling crane is designed for loads in excess of 200 tons (the largest spent fuel shipping cask proposed for licensing under 10 CFR 71 is only 125 tons) (Applicant's Testimony, page 2). Se MiP cask handling crane will be designed to ANSI B30.6 standard (Staff's Testimony, Page 12 arx3 Tr. 3961). The cask handling crane can be designed for the WP to meet criteria for the health and safety of the public (Tr. 3958).
142.
It is the responsibility of the utility owner to perform the radioactive material transfer operations (Applicant's Testimony, page 2). Se method for transporting nuclear fuels will be incitx3ed in the utility owner's application for an operating license (Staf f's Testimony, page 9).
30Applicant witnesses wre examined by Mr. Walton, by counsel for Atlantic County Citizens Council on Environment (ACCCE), and by the Board. Se Staff witnesses were examined by Mr. Walton, by counsel for ACCCE, by counsel for the State of New Jersey, and by the Board.
gN Ll ta 064 V
Shipping Container Design 143. he specific shipping package and the shipping method to be employed in transporting radioactive material fran the Floating Nuclear Plant are the responsibility of the utility owner. Design and testing requirenents for radioactive material shipping packages and requirements governing their transport have been issued by the Nuclear Regulatory Ccmnission (10 CFR 71), by the Depart:nent of T*
portation (14 CFR 103, 46 CFR 146, and 49 CFR parts 170-189), and by the U.S.
Postal Service (Postal Service Manual, Section 124). These regulations require that radioactive materials, incltxSing spent fuel, be packaged for shipping in containers of special design. In the case of spent fuel, the cask must be designed and licensed in accordance with the requirements cf 10 CFR 71. Bis part of the regulations requires that the cask design be such that the contents of the container will not be released in the event of severe hypothetical accidents. (Applicant's Testimony, pages 2 and 3).
Postulated Accidents During Transfer 144. An accident involving transfer of spent fuel would result in more severe radiological consequences than an accident involving transfer of low-level waste containers. Rus, detr.il xl analyses of pstulated accidents durin; transfer were limited to those involving spent fuel casks. (Staff's Testimony, page 9; Applicant's Testimony, page 2.)
+
454 06f/
4 145. Six spent fuel cask drop scenarios during the transfer operation frm the RTP to a transport vessel (barge) are analyzed in the PDR Section 15.4.7 (Applicant's %stimony, page 3). Wese cask drop scenarios are the worst which can be developed using existing design parameters and 1xocedural controls (Staff's 'Ibstimony, page 10). The cases analyzed include a drop frce the maximum height to which the crane will lift the cask above the basin water surface into the maximum depth of water acceptable for a site (Applicant's Testi-mony, page 3). In these analyses no credit is taken for the safety features and conservattsm in the design of cask handling system canponents (Staff's Testimony, page 9). 'Ihe analyses in the PDR show that nor.e of the cases considered m uld lead to rupture of the shipping casx or release of any radioactivity (A@licant's Testimony, page 3).
146.
If a shipping cask should drop onto the ocean floor, the retrieval of the cask would be the responsibilty of the utility owner, including the postulated case of a cask rolling beneath the FNP (Tr.
3868). The device to retrieve the cask may consist of a portable barge-mounted crane (Tr. 3868). 'Ihe cask retrieval could be accom;>-
lished in a reasonable amount of time b2 fore appreciable corrosion could occur (Tr. 3869). Even if the radioactivity were released due to corrosion, it would be a very snall amount and would be below maximum permissible concentrations (Tr. 3877).
14n OGg Radiological Consequences of a Cask Rupture Accident 147. Although the analyses in the PDR show that a cask rupture will not occur, the radiological consequences of a cask rupture were analy::ed and reported in PDR Section 15.4.7 ( Applicant's Testimony, page 3). Dose analysis was performed for the released radioactivity which passes through the sea water, is vented to the atmosphere, arG carried away from the site by atmospheric conditions (Tr. 3881). The resulting hypothetical offsite dose (using conserva-tive meteorological conditions) would meet the dose criteria of 10 CFR 100; namely, 300 ren thyroid and 25 rem whole body ( Applicant's Testimony, page 3, and Staff's Testimony, page 11). 'Ihe isotopes considered in this dose analysis are iodine-131 and krypton-85 (Tr.
3885).
148.
Bounding calculations were also performed to estimate the concentrations downstream frcra a dropped and ruptured cask if the iodine--131 available in the void space of the fuel elements in the cask was released approximately 100 days af ter the fuel was removed from the reactor. 'Ihose calculations indicated that for a distance about five to eight.niles in the drift direction away fran the dropped cask the concentrations would be three orders of magnitude below Maximum Permissible Concentrations (Tr. 3873).
149.
In addition to the analysis required by Pagulatory Guide 1.25 and Regulatory Guide 4.2 for a postulated cask drop accident, the 454 06Q applicant calculated the dose to the maximally exposed individual as a function of distance from the cask drop location. Although 25 isotopes (fission products) were considered in the calculation, only Cs-137 arx3 Nb-95 contribute significantly to the dose. 'Ibe results of the analy-sis show that at a distance of 2 kilaneters fran the postulated cask drop the swi:nner is exposed over a two ye. c period to a whole body dose of only 1.5 mrem and a skin dose of only 3.5 mrem. (Applicant's Exhibit OPS-104; Tr. 3894.)
Explosion or Fire on a Fuel - Resupply Barge 150. The FNP has been designed to withstand damage fran flying debris resulting fran an explosion of a fuel-resupply barge without jeopardiziro plant safety functions (Staff Testimony, page 7).
The fire suppression system (s) on the FNP can adecuately cope with the diesel fuel barge fire (Staff's Testimony, page 8, and Tr. 2828). It can be concitried that the same fire suppression systems could easily cope with a fire on a nuclear fuel transporting barge and simultane-ously, the tug (Staff's Testimony, page 8).
Meteorological Conditions 151. With respect to stormy weather, the transportation of nuclear fuel or waste can be delayed or advanced a sufficient nunber of days to avoid storms. Also, the time at which the movement takes 454 07d place can be adj usted to avoid heavy traffic or corditions not suitable for safe movenent ( fog, low tide, etc.) (FES II, page 6-87.)
152. We desigt. of the EWP is such that the plant can withstand collisions or flying debris that might occur during the rapid onset of severe, unforeseen meteorological conditions while nuclear fuel is oeing handled or transported. The floating nuclear plant is designed to resist the effect of any of the following: (1) a 25 ton tornado borne boat i:rpactireg the plant at its water line with a velocity of 29.3 feet per secord and a kinetic energy of.67 million foot-pourds. This impact is in addition to the usual spectrum of tornado borne missiles and debris required by the Staff for land-based plants. We tornado borne boat of 25 tons is assuned to strike the platform while the tarnado wird and pressure drop are at their most severe ccxtbination, so that a super-position of loads occurs; (2) a 3500 ton service vessel striking the plant without tornMo effects; ard (3) a helicopter weighing 19,000 Irunds traveling at 30 miles per hour and having a kinetic energy of.57 million foot-pounds striking any critical part of the plant. (Staff Testimony, page 4.)
Conclusions 153. The Board firds that the Floating Nuclear Plant has been designed so that soent fuel can be safety transferred to a barge (or other form of transportation) alongside the plant.
4 14
()i 154. The Board finds that accidents in the transportation of spent nuclear fuel radioactive waste which could release radioactive materials from the cask or package and thereby produce radiological consequences have been thoroughly considered and adequately treated on a generic basis.
155. The Board finds that the FNP has been designed such that the plant can withstand collisions or flying debris that might occur during rapid onset of severe, unforeseen meteorological coMitions while nuclear fuel is being handled or transperted.
156. The Board fiMs that the analyses of fuel cask drop accidents show that the cask would not rupture, but even if it should rupture, the resulting calculated radiological consequences are well below the guidelines set forth in 10 CFR 100.
157. The Board finds that adequate consideration has been given to the prevention of accidents in the handling aM transporta-tion of radioactive materials to and from the ENP, and that adegaate consideration also has been given to accidents which could occur during such transportation. The Board further finds that such con-sideration adequately accounts for the characteristics of the FWP.
454 0%
F.
CONTENTION VI - SITE D NELOPE DATA Brigantine Amended Contention I:
"'Ihe pstulated site parameters (10 CFR Part 50, Appendix M,
para. 2) relating to climatic, meteorology, tidal, or other particular natural conditions have not been properly selected and jastified."31 158. On this contention both Applicant and Staff presented evidence, including material contained in the Plant Design Report (PDR), the Safety Evaluation Report (SER), as s palemented, and written ard oral testimony.32 None of the intervenors presented witnesses, testimony or other information.
Hearing sessions with regard to this contention were held on June 16,17 and 18,1976, and 31Admitted as interpreted by Board Order dated Decen >2r 29,1975, p.4.
32The Applicant's written testimony, Exhibit No. OPS-25, entitled
" Applicant's Testimony Regarding VI. Site Envelope Data", was admitted at Tr.
1331 (6/16M6). The witnesses synsoring this testimony were Dr. Dee Walker and Messrs. P. Blair Haga, Richard S.
Orr and Robert C. Beebe (Professional Qualifications admitted at Tr.
1024, 1024, 1329 and 1327 respectively).
The Staff's written testimony entitled "Supplenental Testimony on Behalf of IEC Staff in Response To Brigantine Amended Contention I" by Edward F.
- Hawkins, Gale P. Turi, Joseph R.
Levine, Earl H. Markee, Jr. ; and " Supple-mental 'Ibstimony On Behalf Of tac Staff In Response 'Ib Brigantine Amended Contention I" by Renner B. Hoffman, which follows Tr.1483, was a nitted at Tr. 1483 (6/17M6).
(Professional Qualifications of Messrs. Hawkins, Levine, Markee ard Hofmann and Ms. Turi were ainitted at Tr. 1476; on June 18, 1976 Mr. Lewis G.
Hulman sub-stituted for Staff witness Hawki.is.
Mr. Hulman's Professional Qualifications were a nitted at Tr.1520).
N J-
')
the testinony appears at Transcript pages 1326-1353, 1354-1510, and 1511-1701, respectively. 3 159. Paragraph 2 of Appendix M to 10 CFR Part 50 requires that the applicant for a manufacturing license provide an envelope of postulated site parameters. Paragra@ 5 of Appendix M to 10 CFR Part 50 authorizes the Ccmission to issue a license for one or more nuclear p3wer reactors to be operated at sites not identified in the license application if the Camtission finds that inter alia (1) "The applicant has described the proposed design of and the site parameters postulated for the reactor (s).... " 'Ibe criteria for the design of nuclear power plants for protection against natural @enomena are stated in Criterion 2 of Appendix A to 10 CFR Part 50 and Appendix A to 10 CFR, Part 100.
160. Applicant's envelope of postulated site parameters incitxling those pertaining to climatic, meteorological, tidal and other natural conditions associated with the marine enviornment (and combinations of these phenonena) are su:nnarized in the PDR at Table 2.1-1 and in the SER, Supplement No.
2, in Table 1.2 (Revised).
33Applicant witnesses were examined by counsel for City of Brigantine (Brigantine), Atlantic County Citizens Council on Environment (ACCCE), Atlantic County Board of Chosen Freeholders (Atlantic County), State of New Jersey, NRC Staff ard the Board.
Staff witnesses were examined by Counsel for Brigantine, ACCCE, Atlantic County, State of New Jersey and the Board.
llJC 49 0, '
Hurricane 161. Hurricane is a windstorm which produces surge (or drawdown) and wave activity. Hurricane winds create pressure loading on ENP structures, while wind and wave together create plant motion (Applicant's Testimony, pp. 2-3; PDR, Section 3.3.1).
Surge (or dradown) combine with astronomical tide to produce the still-water depth (Applicant's Testimony, p. 4). Hurricane is therefore an event of interest in each of the following site envelope parameters:
maximum water depth, minimum water depth, plant motion and wins speed (pressure loading) (PDR Table 2.1-1).
162. Le Applicant has specified two levels of hurricane intensity in the site envelope, the Hundred Year Storm (HYS) and the Probable Maximun Hurricane (PMH)
(PDR Table 2.1-1).
The HYS is defined by its recurrence interval or equivalently by a probability of occurrence pr year of 0.01 (Transcript, Page 1336).
Se PMH is a hypthetical hurricane havire a combination of characteristics which make it the most severe hurricane that can probably occur in the particular region involved. P'4H parameters have been developed by the Weather Bureau, now the National Oceanographic and Atmospheric Administration (NCAA) for the Atlantic and Gulf coastal regions from maximization of hurricane grameters based on historical data (SER, Section 2.2).
Og 163. 'Ihe Applicant irstulates the occurrence of a hurricane not exceeding HYS intensity subsequent to the postulated sinking emergency and while the plant remains in the sunken condition (PDR, Section 2.3.2).
The Staff concurs with the Applicant that this event canbination is adequately conservative (SER, Section 2.3.2).
Site water depth at mean low water (MLW), the reference cordition, must be such that the sum of MLW depth, astronomical tide, storm surge and wave height adjacent to the plant vital structures does not exceed 76 feet, the height above the bottom of the platform co which plant areas housing equipnent necessary for safe shutdown are designed to be waterticht.
(PDR Table 2.1-1; Transcript, Page 1333).
164. The HYS is the operating basis event with respect to wind pressure loading on plant structures and with respect to plant motions resultirs fran wiM and wave (Appli.: ant's Testimony, Page 2).
165. HYS wind speed was bounded originally by the Applicant at 130 moh for the Atlantic and Gulf Coasts.
This magnittx3e was increased subsequently to 160 m;h based on the reco::raendation of NOAA (SER Section 1.10, Acpendix C; SER Supo.
1, Section 1.10, PDR Table 2.1-1).
166.
Each owner will be required to evaluate surge reight for the HYS (SER, Section 2.3.2).
The Applicant expects that each owner will determine a site specific HfS wind speed because a lower magni-tude than the generic bound established by the Applicant would be
$tJ4 0?
expected (Applicant's Testimony, Page 3).
Plant motions resulting from the HYS will be evaluated by the owner through model testing (SER, Section 3.7.2).
167. 'Ibe Applicant pstulates the occurrence of a hurricane no more intense than the RE with the plant in the normal, floating condition (PDR Table 2.1-1).
Be Staff concurs with the Applicant that the PMH is an adequately conservative maximum hurricane (Staff's Testimony, Hawkins, et.al.,
Page 2; Tr. 1544 and 1661). 'Ihe Site Envelope requires that plant motions not result in platform contact with the basin floor during the passage of a PMH (PDR Table 2.1-1).
Thus the minimtn acceptable basin water depth at MLW is equal to the algebraic sum of plant draft, astronomical tide, hurricane surge (or drawdown) and maximum plant motion (downward corner displacement) produced by the PMH (PDR Table 2.1-1).
168. The PMH is one of the design basis events with respect to wind pressure loading on plant structures (see our discussion of Tornado, below) aM is the desigr. basis event with respect to plant motions resulting from wind and wave (Applicant's Testimony, Page 2; PDR Table 2.1-1).
45+1 cUlq 169. Be Applicant has based the m'P design on the maximum 34 wind spaed stated in HUR 7-97 for the Atlantic aM Gulf Coasts (PDR, Section 3.3.1.1). Se maximun ten-minute wind speed of 163 mph from HUR 7-97 is stated in the site envelope as an equivalent fastest mile wind speed of 204 mph (PDR Tables 2.1-1 and 3.3-2).
170. Each owner will be required to evaluate storm surge and drawdown for the PMH (Staff's Testimony, Hawkins, et.al., Page 3).
Each owner may determine a site-specific R4H wind speed because a lower magnitude than the generic bound established by the Applicant would be expected at most sites (Applicant's Testimony, Page 2). Plant motions resulting from the R4H will be evaluated by the owner through model testing (SER, Section 3.7.2).
Tornado 171. Tornado is a windstorm which produces direct loading on FNP structures resulting frcIn wind and pressure drop forces.
Those forces in turn produce plant motion (Applicant's Testimony, Page 5).
Tornado is therefore an event of interest in the following site envelope parameters: minimum besin water depth, plant motion aM wind speed (press =e loading) (PDR Table 2.1-1).
34 U.S. Department of Commerce, Environmental Services Administration, Weather Bureau (Now NOAA), Memorandum HUR 7 97, " Interim Report Meterological Characteristics of the Probable Maximum Hur ricane,
Atlantic and Gulf Coasts of the United States", May 7,1966. '
172. The Site Envelope requires that basin water depth be sufficient to prevent contact between the platform and the basin floor during the passage of the design basis tornado (PDR, Section 2.3.1).
The site err / elope requires that basin water depth at MLW be at least equal to the sum of plant draft plus the maximum downward motion produced by the design basis tornado (PDR Table 2.1-1).
173. The design basis tornado is one of the design basis events with respect to pressure loading on plant structures m3 is one of the design basis events for plant motions resu] ting from extreme winds (see our discussion of Hurricane, above) (Applicant's Testimony, Page 3; PDR Table 2.1-1).
174. The tornado cnaracteristics defined in Regulatory Guide 1.76 were used by the Applicant to design the FNP (PDR Section 3.3.2).
The basis for these tornado characteristics is discussed in detail in
" Technical Basis for Interim Regional Tornado Criteria", WASH-1300, May, 1974.
The Tornado characteristics used by the Applicant are boundire for all areas alonc the Atlantic and Gulf Coats (Staff's Testimony, Hawkins, et.al., Page 7 anS 8).
175. The principal parameters of the Applicant's design basis tornado are: rotational wind speed 290 m;h, maximum forward speed 70 mph and a pressure drop of 3 psi (PDR Table 2.1-1). These magnitudes represent conservative upper bounds.
(Staff's Testimony, Hawkins, et.al., Page 8).
454 Og 176. The tornado characteristics developed in WASH-1300 resulted mainly frce data collected over lard. The Applicant and the Staff agree that it is reasonable and conservative to extend data collected over land to the region of adjacent coastal waters for the purpose of predicting tornado characteristics (Tr. 1698-1699).
177. The owner will be required to analyze plant motions resulting from the design basis tornado and to demonstrate that neither platform contact with the basin floor nor acceleration and/or angular displacements in excess of site envelope limits occur.
No further evaluation of tornado intensity parameters is required of an owner unless the owner wishes to postulate a less severe design basis tornado for design of site features for the specific site (Applicant's Testimony, Page 5).
178. Waterspouts are small regions of intense rotational wirds which develop over water ard draw water into the rotating fluid.
Their potential effects upon an EWP are similar to those produced by tornaSo; however, the maximum wird force ard pressure drop are approximately 30% of those of the design basis tornado. 'Ibe Applicant and Staff agree that the large margin between waterspout and tornado forces assures that waterspout loadings will not be limiting fcr either plant design or siting (PDR, Section 2.7.5; PDR, Appendix 2D; SER, Section 2.8.1.1).
- llsq, t
ogg Tsunami 179. Tsunami are long period sea waves caused by underwater disturbances such as earthquake, volcanic eruption or lardslide (PDR, Section 2.3.1; SER, Section 2.8.4). As tsunami taves approach lard, bottan friction causes wave amplification, and a significant series of alternating surges and drawdowns may occur (Staff's Testimony, Hawkins, et.al., Page 3; PDR, Section 2.3.1). Tsunami is therefore an event of interest in the site envelope limitations for maximum and minimum basin water depth (PDR Table 2.1-1).
The Applicant has not incitded tsunami as an event for which plant accelerations and angular displacements are canpared to site envelope limits, because the response of the plant is ex gcted to be a gentle rise and fall analagous to the response to tidal fluctuations (PDR, Section 2.3.1).
180. 'Ihe Applicant postulated the occurrence of a tsunami coincident with the ten percent exceedance high spring tide subsequent to the hypothetical sinking energency and while the plant remains in the sunken cordition.
The sum of MLW depth plus astronanical tide plus tsunami surge twight plus wave height adjacent to the plant vital structures is required to be less than 76 feet, the maximtrn water depth for which systems necessary for safe shutdown are protected from flooding. (PDR Table 2.1-1).
OC1
-7_/-
181. '1he Applicant postulates the occurrence of a tsunami coincident with the ten percent exceedance low spring tide with the plant in the rormal, floating cordition. Basin water depth at MIW is required to be be equal to or greater than the sum (;f plant draft plus astronomical tide plus tsunami drawdown. Satisfaction of this limit assures that the platform will not contact the basin floor (PDR Table 2.1-1).
182. Global records of tsunami indicate that the Pacific is the most activ2 region while tsunami along the Atlantic and Gulf coasts have been both rare and of small magnitude.
It is expected that. the magnitude of tsunami wave heights would be less than hurri-cane-induced wave heights. (Staff's Testimony, Hawkins, et.al, Page 4; Applicant's Testimony, Page 3).
183.
Each owner will be recpired to estimate tsunami magni-tudes based on evaluation of potential initiating mechanims, both local and d.stant (SER, Section 2.8.4).
Astroncznical Tide 184. Site Envelope limits for both maximum and minimum water depth account for astroncmical tide as a component of still water level (PDR Table 2.1-1; Applicant's Testimony, Page 4). 'Ihe HYS, PMH and tsunami are each postulated to occur in coincidence with ten percent exceedance tide levels (PDR Table 2.1-1).
'1he ten percent
'Stf Com
-7S-
exceedance tide levels (high and low) are those predicted tidal maxima aM minima which are exceeded by only ten percent of the predicted monthly maxima and minima over a continuous 19 year period.
We Applicant postulated the occurrence of the design basis tornado at a water depth equal to or greater than MLW (PDR Table 2.1-1). MLW is the average water depth during low water corditions. Th7 design basis tornado event is not combined with the ten percent exceedance low tide because the combined probability is small. (Tr. 1340; PDR, Section 2.3.1, 2.13).
Earthquake 185.
Earthquakes required to be pstulated for the design of nuclear power plants are defined in 10 CFR Part 100, Appendix A, in term-of probability of occurrence ard macnitude.
Appendix A is supplemented by Regulatory Guide 1.60. ( Applicant's 'mstimony, Page
- 4).
186. 'Ihe Applicant postulated a safe shutdown earthquake (SSE) having maximum accelerations at the basin floor of 0.3g (hori-zontal) and 0.2g (vertical) (PDR Table 2.1-1).
'Ihe Applicant testi-fied and the Staff concurred that the postulated SSE acceleration will meet or exceed the requirements of 10 CFR, Part 100, Appendix A for most.ocations along the Atlantic and Gulf coasts (Applicant's Testimony, Page 4; Staff's Testimony, Hoffman, Page 5; SER, Page 33; PDR, Section 2.5.3).
h qy'
-7 9--
Opg
187. 'Ihe Site Envelope parameter limits for horizontal SSE acceleration are derived fran the maximum ground acceleration of 0.3g (Tr. 1442, 1462); the site envelope parameter limit for SSE vertical motion is the Regulatory Guirle 1.60 groun:1 response spectrum corres-parding to a maximum vertical ground acceleration of 0.2g (PDR Table 2.1-1; Section 2.5.2.2).
Seiche 188. Earthquakes, landslides and windstorm can produce standing wave oscillations of a large enclosed or semi-enclosed wa:er bcxly known as seiche.
Seiche will oe evaluated for the environmental phencmena specific to each site in order to assure that the maximum water level produced by each environmental @enomenen is used in site evaluation (Staff's Testimony, Hawkins, et. al., Page 7).
Precipitation 189. Precipitation produces struct ral loadings from the accumulation of water on plant roof surfaces.
The Site Envelope requires that the expected rainfall rate at ar. FNP site not exceed 13 inches per hour (PDR Table 2.1-1). The Applicant and Staff agree that the precipitation rate for all Atlantic and Git)f coastal locations is less than 13 inchet par hour (?qmlicant's Testimony, Page 5; Staff's Testimony, Hawkins, et.rl, Page 5).
The Staff's estimate of precip-itation rate at siteo along the Atlantic and Gulf coasts is based on
/ r-O
the Probable Mximun Precipitation (PMP) defined in Hydro-Meteoro-35 logical Report 33 of the U.S.
Department of Ccmnerce.
PMP is defined by the U.S. Department of Commerce (NCAA) as "the theoretic-ally greatest depth of precipitation for a given duration that is meteorologically possible over the applicable drainage area that would produce flows of which there is virtually no risk of being exceeded".
(Staff's Testimony, Hawkins, et.al, Page 5).
Minimtru Air Temperature 190. We platform hull is designed for a minimum service temperature (in air) of -15 F (PDR Sections 3.12.4.2, 3), although a lower service temeprature can be accomodated by using a different hull steel (PDR, Section 3.12.4.3). The Applicant has incitded in the Site Envelope the requirement that the minimum air temperature, at 0 to 5 meters above the basin surface, be no lower than -15 F (PDR, Table 2.1-1). Based on data reported in PDR Apperdix 2D, the Applicant concluded that sites exist alorg the Atlantic and Gulf coasts which will satisfy this limit (PDR Appendix 2D; Section 2.7.2). Be Staff concluded that the Applicant's original limit of -5 F was sufficient for all of the East and Gulf coasts except for the northern portions of the coast of Maine (SER, Section 2.8.1.1).
' 5U.S. Department of Coninerce, U.S. Weather Bureau (Now U.S. Weather Service, NTA), " Seasonal Variation of Probable Maximum Precipita-tion, United States East of 105th Meridian for Areas 10 to 1,000 Square Miles", Washirgton, D.C.,1956.
454 086 Maximum Water Temperature 191. Plant cooling water systems required for safe shutdown are designed to transfer their maximum heat load at a maximum heat sink temperature of 95 F (Applicant's %stimony, Page 6). We Site Envelope requires that basin water tm.perature not exceed 95 F (PDR Table 2.1-1).
Based on data reported in PDR Apperdix 2D (Section 2D.5), the Apolicant concluded that sites along both the Atlant c and Gulf coasts will satisfy this limit.
We Staff concluded, based on the Applicant's original limit of 85 F, that there are n:any areas along the Atlantic and Gulf coasts where maximtzn water temperature will not exceed 85 F (SER, Page 36).
Minimtra Water Temperature 192. Platform hull material toughness testing requirements are based on minimum service temperature (PDR, Page 3.12-27a).
We Applicant requires that the Nil-Ductility Transition Temperature (NDIT) of platform exterior plating be -30 F or lower. This tempera-ture (-30 F) results frcrn the basic requirement that the l'I7 T of platform exterior plating be approximately 60 F below the minimum service teperature of the bottom shell (PDR, Page 3.12-27f). The Site Envelope requires a minimtIn basin water temperature of 28.6 F (PDR Table 2.1-1). This temperature is the freezing point of sea water of average salinity and was the minimtzn water temperature measured during the trans-artic cruise of the ice breaker Manhattan (PDR, Pages 2.7-5, 454 036 2.7-6).
Slightly lower temperatures resulting frca locali::ed hign salinity would not be of any significance (Applicant's hstimony, Page
- 6).
Conclusion 193. There is adequate knowledge regarding climatic, meteoro-logical, tidal and other natural conditions at ocean and inshore locations at which "NP's could be sited.
(Tr 1382-83, 1503-04). The depth of knowledge regarding climatic, meteorological, tidal and other natural ccMitions at riverine, estuarine ard coastal locations is doct:nented in numerous Comission dockets incitding, inter alia, Calvert Cliffs, Pilgrim, Brunswick, St. Lucie, Turkey Point, Oyster Creek, Millstone, San Onofre and Surry.
194. The Site Err / elope parameters specified in PDR Table 2.1-1 and in SER, Supplement 2, Table 1.2 (Revised), conservatively account for all reasonably expectable environmental occurrences that could aSversely affect an FNP (Tr. 1381, 1453).
195. The Board has reviewed the envelope of sice parameters with regard to the climatic, meteorological, tidal and other natural corditions described in PDR Table 2.1-1 aM in SER, Supplenent No.
2 Table 1.2 (Revised).
Incitded in this review were the site parameters specifically discussed in these findings of fact as well as all other site parameters set forth in those tables. '1he Board conc 1tdes that the Applicant, in accordance with the provisions of 10CFR50, Appendix M, Paragraph 5 and 10CFR2.104 (b), has properly selected and justified the site parameters set forth in those tables (SER 1.6, 21.0; Appli-cant's Testimony, p. 1, Tr.
1397, 1435, 1489).
G.
CONTEN'rION VII - RADIOIDGICAL IMPACT CN SWIMMERS AND BOATERS ACCCE Contention 3d:
"Subprt 3d asserts that the Applicant has not given ade-quate consideration to the radiological impact on humans who may boat or swim in the vicinity of the floating nuclear plant. This contention is hereby admitted as an issue in controversy."36 196. On this contention, both Applicant and Staff presented evidence, including material contained in the Plant Design Paport (PDR), the Final Environment Statement (FES), as supplemented, and written and oral testimony.
None of the intervenors presented witnesses, testimony, or other information. The Hearing session with 36Admitted as interpreted by Board Order dated May 21, 1974, p. 6.
The Applicant's written testimony, Exhibit No. OPS-35, entitled
" Applicant's Testimony Regarding VII. Radiological Impact on Swicmers and Boaters", was admitted at Tr. 3333. The witnesses sponsoring this testimony were Dr. Dee Walker, Mr.
P. Blair Haga, and Miss Mary Ann Caco (Professional Qualifications admitted at Tr.
1024, 1024, and 3831, respectively). Tne Staff's written testimony entitled " Supplemental Testimony of NRC Staff in Respnse to ACCCE Contention 3 (d)" by Dr. Reginald L. Gotchy, which follows Tr. 3849, was admitted at Tr. 3848 (Professional Qualifications of Dr. Gotchy were admitted at Tr. 3847).
4 h]
regard to this contention was held on November 3,
1976, and the testimony appears at Transcript pages 3833-3857.38 197. Applicable parts of Title 10 of the Code of Federal Regulations (10 CFR 20, the Annex to Appendix I of 10 CFR 50, and 10 CFR 100) are the governing regulations relating to radiologica? impact on humans, incitding swimers and boaters. 'Ihe Floating Nuclear Plant (FNP) is designed to be in canpliance with those regulations. (Appli-cant's Testimony, page 1.)
198. The Staff prepared an independent assessment of the potential radiological impact on routine releases from the FNP on humans, including swimers and boaters, 11 the Final Environmental Statement, Part II, Section 11.3, page 11-7.
Normal Operation - MaximtIn Permissible Concentrations 199. The Maximum Permissible Concentrat'
.s of radioactivity in air and water above natural background fcr unrestricted use are defined in 10 CFR 20, Appendix B, Table II. The estimated yearly quantities of radioactive discharges from an FNP during normal oper-ation are given in Section 12.4 (comencing on page 12.4-1) of the 38Applicant witnesses were examined by counsel for Atlantic County Citizens Council on Environment (ACCCE) and by the Board. The Staff witness was examined by counsel for ACCCE and by the Board.
b
(;) u t C
Plant Design Report (PDR). 'Ihe average concentrations in air and surrouMing water resulting frcra these estimated yearly releases during normal plant operation are compared in PDR Section 12.4.3 (ccanencing on page 12.4-23) with the Maximum Permissible Concen-tration limits and are below the acceptable limits for all isotopes.
Normal Plant Operation - Airborne Dose 200. Estimates of the annual dose resulting from released airborne radioactivity are presented in PDR Section 12.4-4 (comencing on page 12.4-25) as a function of distance from the plant. In calcu-latirg the dose frcm airborne radioactivity over a pericxl of a year, conservative values for atmospheric disperson coMitions given in PDR Section 2.7.1 were used; thus, these doses represent conservative limit values for Atlantic Coast and Gulf Coast sites. 'Ihese da*a show that the dose guidelines for released airborne radioactivity set forth in the Annex to Appendix I (10 millirad gama and 20 millirad be'a for all reactors at a site) can be met for continuous occupancy for distances greater than about 200 meters from the plant. 'Ihe distance of 200 meters corresportis to the distance that is about as close as an individual might be able to approach a typical breakwater in a boat (Tr. 3841). Assuning an occupancy of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year at 200 meters, and using the annual doses in PDR Section 12.4.4 from airborne V
radioactivity, a swimer or boater would receive a doce of only 0.16 mfem mr year frcn this source frm an FNP. 9 Normal Plant Operation - Direct Dose 201. Estimates of the additional annual dose resulting frcra direct radiation are 7 resented in PDR Section '.2.4.4 as a function of distance fran the plant. Assuning an occupancy of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year at 200 meters from the plant, a swimer or boater would receive a dose of 0.082 mren per year frcra this source ei radiation frcn an FrG. The Annex to Appendix I of 10 CFR 50 does not require a consideration of the direct radiation frcm the plant (Tr. 3843). The direct dose is only a snall fraction of that resulting from natural background radiation, approximately 80 mrem pr year. (Applicant's Testimeny, page 2).
Normal Plant Operation - Dose Due to Liquid Releases 202.
Estimated annual doses to swim ers and boaters fran liquid releases are presented in PDR Section 2.8 as follows: an individual sperding 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year swiming in the mixing zone of the thermal plume and 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year boating in the mixing zone of 39Dose value of 0.36 mrem gr year in Applicant's Testimony (page 2) was revised in PDR Amend: rent 24 to the current value of 0.16 mrem per year in compliance with Regulatory Guide 1.112 (issued April, 1976), NUREG-0017 (issued April,1976), and Regulatory Guide 1.109 (published March,1976), and Revision 1 (issued October,1977).
ASA 09)
_g,_
-4 the thermal plume would receive a dose of 1.2 x 10 mrem per year and
-5 4.3 x 10 mrem per year, respectively, fran an FNP.4 These doses are only a small fraction of the dose for a subnerged individual due to background radiation, approximately 60 mren per year (Tr. 3855).
Doses for Postulated Accidents 203.
In addition to the calculation of doses due to routine releases from the plant, the Applicant is also required under 10 CFR 100 to calculate the doses due to postulated accidents which could result in release of a significant quar.tity of radioactive fission products. Activit.y release by isotope for each such postulated accident is set forth in PDR Sections 15.3 (commencing on page 15.3-lf) and 15.4 (camencing on page 15.4-10). Doses were calculated employing these activity releases and the conservative atmospheric dispersion conditions set forth in PDR Section 2.7.1. Plots of these doses as a function of distance from the release point on the plant are presented in PDR Sections 15.3 and 15.4. Evaluation of these dose plots demonstrates that an exclusion distance of 500 meters (0.3 miles) anS a low copulation boundary of 1200 meters (0.75 miles) is O
-5
-5 Dose values of 6.7 x 10 and 2.3 x 10 mrem per year in Appli-cant's Testimony (page 2) were revised in PDP'5 Amendment 24 to the current values of 1.2 x 10 ' and 4.3 x 10 respectively, in carpliance with Regulatory Guide 1.112 (issued April 1976),
NUREG-0017 (issued April, 1976), and Regulatory Guide 1.109 (pub-lished March,1976), and Revision 1 (issued Cetober,1977).
Stf 092.
adequate to meet the dose guidelines of 10 CFR 100 for sites along the Atlantic and Gulf Coasts. Be actual exclusion distance and low
, copulation bouMary are site specific aM will be calculated by each C&'ner. ( Applicant's Testimony, page 3.)
Conclusions 204. Se floating nuclear plant is designed to be in compli-ance with applicable parts of 10 CFR 20, the Annex to Appendix I of 10 CFR 50, and 10 CFR 100.
205. We Applicant's calculated doses to swim ers and boaters are not significant canpared to natural background radiation (Tr.
3844). We Staff concluded that the radiological impact (from ENP routine releases of radioactive effluents) on boaters ard swimners will be insignificant.
206. Be Board finds that adequate consideration has been given to the radiological impact on humans who may swim or boat in the vicinity of the ENP. Be Board further finds that routine releases of rMioactive effluents from the FNP will have no significant effect on humans who may boat and swim in the vicinity of the plant. Be Board also fin's that the calculated doses for postulated accidents comply with the requirements of 10 CFR 100 for sites along the Atlantic r.nd Gulf coasts.
S'Q OR$
H.
CONT!2n'ICU VIII - AIRCPJLW Brigantine Amenued Contention 4:
"The probability of aircraft crashing into the facility is understated, since the analysis is based on the frequency of commercial aviation flights without regard to the frequency of other kirds of flights, e.g.,
military and general aviation."41 Atlantic County Contergent 2:
"With the continuance of air traffic and increases to air traffic alory tne Atlantic sea coast, we believe that the proposed Floating Nuclear Plants located in said zone should be constructed to withstard the effects of a possi-ble collision with any existing size aircraf t that may fly over or in the vicinity of the site ard any reasonably foreseeable large size aircraft built during the lifespan of the proposed plants that may operate as above without damage 'to the reactor core such that dosages of harmful radiation in excess of required limits would occur.
Our basis for this belief is that:
a.
The crash probability is sufficiently high.
b.
The resultant damage to the proposed plants and attendant effects on radiological safety in the event of a collision is sufficiently great.
c.
The combination of the above irdicate that the plant should be so designed." 4~9 Pertinent Part of ACCCE Contention 6:
"The apolicant has not given zdequate consideration to possible accidents resulting from an intentiotal collision by an aircraft as part of industrial sabotage."43 41Mmitted as interpreted by Board Order dated Docember 29, 1975, p.4.
42Admitted as interpreted by Board Order dated April 15, 1975, p.9.
4 Admitted as interpreted by Board Order dated May 21, 1974, p.8.
dc, Jg OS$
207.
Both Applicant and Staff presented evidence concerning this contention, incitding material contained in the Plant Design Report (PDR), the Safety Evaluation Report (SER) ard written and oral testimony.44 None of the intervenors presented witnesses, testimony or other information.
Hearing sessions with regard to this contention were held on September 23, 24, 28, and 29, 1976, ard the testimony appears at Tr. pages 3413-3431, 3432-3504, 3505-3630, and 3631-3770.
208. Standard Review Plan 3.5.1.6, Aircraf t Hazards, and Regulatory Guide 1.70, Rev. 2 (NUREG-25/094 ), Standard Format and Content of Safety Analysis Recorts for Nuclear Power Plants, Section 2.2.3.1, set standards for aircraft crash probability with which an owner must ca: ply when siting a nuclear power plant (Staff's Testi-many, Page 2 and Applicant's Testimony, Page 1).
he PDR, Table 2.1-1, identifies plant-site interface recuirements.
Table 2.1-1 The Apolicant's written testimony, Exhibit No. OPS-26, entitled
" Applicant's Testimony Regarding VIII.
Aircraft, "was admitted at Tr.
3421.
Se witnesses sponsoring this testimony were Dr. Dee H.
Walker, Mr.
P. Blair Haga, Dr. Douglas i1. Shaffer, and Mr. J7hn F.
Hanst (Professional Qualifications admitted at Tr. 1024, 1024, 2881, and 3419 respectively).
The Staff's written testimony entitled "
Supplemental hstimony of NRC Staff in Response to Brigantine Amended Contention 4, Atlantic County Contention 2 ard the Pertinent Portion of ACCCE Contention 6,"
by Jacques B.
J.
Read, John A.
O'Brien, Ray F.
Priebe, was admitted at Tr. 3636.
Professional Qualifications of Dr.
- Read, Dr.
O'Brien, and Mr.
Priebe were admitted at Tr. 2534.
45Apolicant and Staff witnesses were examined by counsel for inter-venor Atlantic County Citizens Council on Environment (ACCCE) and the Board.
$h %
vicinity.
Be results of the Applicant's analysis demonstrate that although the threat of a military crash at this site is greater than that from connercial aviation, the cumulative threat from all aviation is of the order of 10- / year or less. (Applicant's Testimony, Page 3.)
215. Be Eh7, with substantial protection around its safety-related areas to satisfy NRC tornado missile protection requirements, is not vulnerable to the crash of small aircraft.
Be Applicant has calculated the thickness of steel or concrete required to prevent perforation of missiles resulting from a crash into the plant of aircraft weighing up to 12,500 pounds. In all cases structures protecting safety-related plant areas exceed the required thickness.
(Applicant's Testimony, Page 3.)
tG (C
216. Be probability of an aircraft crash into the FNP is de-termined by four factors, all first power tems cuch that none is more inflmntial than any of the others. These terms are: 1) nunber of overflights, 2) accident rate, 3) density function, and 4) effective plant area. (PDR, Appendix 23.) The Applicant treated these variables as discussed below.
217. Number of Overflights.
The number of overflights is determined by " peak day" statistics which represent the heaviest traffic of the year. Yearly rates are obtained by assuming ",mak day" b,t4 09 traffic every day of the year. (Tr. 3610.)
This term is therefore conservative.
218. Accident Rate.
We long term accident rate trend is downward (Tr. 3477).
Therefore, using the present rate is conserva-tive.
219. Density Function.
We denrity function is a mathema-tical statenent that the likelihood of a crash decreases as the distance from the airway increases.
We function used by the Appli-cant was formulated by fitting to a curve offset distances from airways at which serious crashes occurred in the years 1964-1967.
(PDR, Appendix 2B, Page 2B-11.)
As such, this function is neither conservative nor unconservative.
220. Effective Plant Area.
Analysis by the Applicant irdicated that the average shadow area is obtained by utilizing a 32 crash angle. The Apolicant used a 30 crash angle which tults in a slightly greater shadow area. (Tr. 3484.)
In additi' asions of plant features wre increast 3 account for en; s at on of i
aircraft (Tr. 3429). The resu2. ant is a conservatively calculated effective plant area.
221.
In addition to the conservatism built into the factors making tr,.s the probability calculation, another conservatism is the Apolicant's simplifying assumption that a crash into i-ha plant by an
?4P-J4 aircraft larger than 12,500 pounds is equatable to safety-related consequences. No credit is taken for the structural barriers incorpor-ated into the plant, especially the shield building, which the tac Staff has estimated could survive a collision of a 70,000 pound e-111B at approximately 100 miles per hour (Tr. 3574-3575, 3747.)
222. Present Nuclear Regulatory Cmmission regulations do not require inclusion of intentional crash as a design basis event (Staff Testimony, Page 7).
While acknowledging the possibility of threat of such a crash by a deranged individual, the Staff considers the execution of such a threat to be incredible (Tr. 3738).
Conclusions 223. The Board concitx3es that the FNP need not be designed to withstand the consequences of a large aircraft crash since siting restrictions limit the probability of such an event to the order of 10- or less.
224. Tne Board concludes that the FNP need not be designed to withstard the consequences of an intentional crash of an aircraf t as a part of industrial sabotage.
45"1 098,
225. The Board fiMs that the Applicant has given adequat.e consideration to cocinercial, military aM general aviation, and that the Applicant has demonstrated that potential rip sites exist along the East and Gulf Coasts where the probability of aircraf t crash is acceptably low. Evalustion of aircraft crash probability at a specific site is the responsibility of the plant owner.
I.
CNTEN'rION IX - SHIP COLLISION Brigantine Amended Contention 5:
"Tne probability of ship collisions is understated, since inadegaate consideration is given to potential changes in the pattern of ship traffic and the character of ships and their ra goes over the 40-year life of the facility."46 Pertinent Part of ICCCE Contention 6:
"... the Applic ant has not given adequate consideration to passible accident:. resulting from a collosion (sic) of the floatire plant with a ship...."47 226. On these contentions both Applicant and Staff presented evidence, incitriing material contained in the Plant Design Report (PDR), the Safety Evaluation Recort (SER), as supplemented, and 46Admitted as interpreted by Board Order dated Dece:nber 29, 1975,p.4.
47Admitted as interpreted by Board Order dated May 12, 1974,p.8.
k'R1 09]
written and oral testimony.48 None of the intervenors presented witnesses, testimony or other information.
Hearing sessions with regard to this contention were held on July 30, September 20, 21, 22, and 23, 1976, and the testimony appears at Tr. 2869-3412.49 i
227. Regulatory Guide 1.70 (NUREG-75/094), Section 2.2.3 and Standard Review Plans 2.2.1 and 2.2.2 require that transportation activities in the vicinity of proposed nuclear power plant sites :
3 evaltnted to determine if accidents that could result from these activities need to be design basis events for the plant.
Regulatory Guide 1.70, Section 2.2.3.1 and 5tandard Review Plan 2.2.3 indicate that potential accidents external to the nuclear plant should be considered design basis events if the probability of the _ccident
-7 exceeds on the order of 1 X 10 per year and if the consequences may affect the plant to the extent that the requirements of 10 CFR 100 could be exceeded. (Applicant's Testimony, pages 1 and 2). For an 48The Applicant's written testimony, Exhibit No. OPS-27, entitled
" Applicant's Testimony Regrdirg IX.
Ship Collision", was admitted at Tr. 2884. The witnesses sponsoring this tc.stimony were Drs. Dee H. Walker, Douglas H. Shaffer and Henry J. Stumpf, Capt.
Derek R.
King, Ms.
Hyla Napadensky and Mr.
P.
Blair Haga (Professional i
Qualifications admitted at Tr. 1024, 2881). The Staff's written testimony entitled " Supplemental Testimony of NRC Staff in Response to Brigantine Amended Ccatention 5 and the Pertinent Portion of ACCCE Contention 6" by Drs. Jacque B. J. Read and John A. O'Brien, which follows Tr.
3284 was admitted at Tr. 3284 (Professional Qualifications of Drs. Read and O'Brien were ainitted at Tr. 2534).
Applicant witnesses were examined by Counsel for City of Brigantine (Brigantine), Atlantic County Citicens Council on Environment (ACCCE),
tate of New Jersey, NIC Staff and the Board.
Staff witnesses were examined by Counsel for ACCCE, State of New Jersey, OPS, and the Board.
rJ4 by Applicant's consideration in detemining design basis eve;its, the Staff has identified several accident categories with the categories beim based upon the effect that a particular type of accident could have on the plant. The accident categories include explosions, fla re.able vapor clouds, toxic chenicals ard fires. (SER Supplement 2, Appendix C, Section 5).
228. The Applicant examined available data on shipping accidents ard then evaluated in more detail those accidents which presented a potential hazard tc the plant (Tr. 2895). Seven classes of shicping accidents were identified as presenting a potential hazard to the plant (PDR Appendix 2A). Of these accident classes, three were determined to be design basis events for which there are specific plant design features and/or site reqairements (Ship Collision With Plant; Tanker Collision With Breakwater: Fire; Service Ship Acci-dents). Two accident classes were determined to be of sufficiently low probability to be excluded fran the plant design basis (Ligaified Natural Gas (I1;G) Carrier Accident; Munitions Ship Explosions). The renainirs two accident classes were incitded within the plant design basis up to specific maximum design limits (Tanker Accident: Vapor-Air Explosion; Hazardous Chemical Carrier Accident: Toxic Vapor Cloud).
(Acclicant's Tbstimony, pages 2 and 4). Each of the accident classes is discussed infra.
ll4
. n t
/
Ship Collision With Plant 229. Site protective features (such as a breakwater) are required to prevent a large vessel frm, colliding with the plant (PDR Table 2.1-1). 'Ihe Apolicant has shown that protective barriers can be designed to prevent a ship collision with the plant. Applicant has also shown that a ship collision with the site protective structure, excluding cargo effects, will not result in unacceptable consequences with respect to 10 CFR 100. (PDR Section 2A.2.) Potential hazards arisirs frcm the cargo of a ship colliding with the site protective structure are discussed infra.
Tanker Collision With Breakwater: Fire 230. The site protective features are required to be such that they prevent a potential oil spill occurring outside the site structure frcn reaching a point closer than 100 feet frcra the plant (Apolicant's Testimony, page 3; SER Section 2.10.2). 'Ihe fire which could result frcm a collision of a tanker carrying flammable fuel, other than U;G (see paragraph 232), with the site protective structure may be a design basis event at sme sites. An adequate external fire protection system is provided for these cases. (PDR Section 9.5.1. 2.)
1 9
/ 03.
-100-
Service Ship Accidents 231. Potential accidents involvirg the FNP and service ships are of three types: direct collision with the plant by the service ship; fire resultirg frcn release of diesel fuel oil into the basin surrounding the ENP; explosion on the service ship. Vessels within the basin must be limited in size ard speed such that potential impact on the plant will be rc greater than that equivalent to a ship of 3150 lory tons at 13 knots. (PDR Section 2A.8.1; Applicant's Testimony page 3; SER Section 2.10.2). We agaeous film forming foam system is provided to extinguish a fire within 100 feet of the plant resulting from a spill of flannable liqaid. We applicant has evaluated the consegaences of an explosion of a fuel-air mixture in a supply barge tank and has determined that preventative actions are possible. We Staff cc:rurs. The owner will be reqaired to: (a) inert the fuel barge tanks during offloading, or (b) maintain sufficient separation between the plant ard fuel supply barge, or (c) limit the volume of irdividual tanks on the fuel supply barge. (PDR Section 2A.8.3.1; Applicant's Testimony, page 4; SER Supplement 1, Section 2.10.2).
Liquified Natural Gas (IN3) Carrier Accident 232. The Site Err / elope regaires that the probability of a munitions ship explosion, the consegaences of which could exceed the plant design basis, bo on the order of 1 X 10- per year or less (PDR Table 2.1-1; SER Supplement 2, Table 1.2 (Revised)). Se Applicant has 454
-101-
concluded and the Staff has concurred that sites can be found such that the probability of an accident involving an ING accident, the consequences of 5.tlich could exceed the plant design basis, be on the order of 1 X 10- per year or less (PDR Table 2.1-1; SER Supplement 2, Table 1.2 (Revised)). De Applicant has concluded and the Staff has corcurred that sites can be fouM such that the probability of an accident involving an ING carrier affecting the site is on the order of 1 X 10- per year or less. (PDR Section 2.4.6; Applicant's hsti-mny page 4; SER Section 2.10.2).
Munitions Ship Explosion 233. The Site Envelope reqaires that the probability of a munitions ship explosion, the consequences of which could exceed the plant design basis, be on the order of 1 X 10- per year or less, (PDR Table 2.1-1; SER Supplement 2, Table 1.2 (Revised)). W e Applicant has concluded and the Staff has concurred that for East Coast sites well removed from munitions terminals and for Gulf Coast sites the proba-bility that a munitions ship accident with mass detonation suffici-ently near the plant to affect it is negligibly low (PDR Section 2A.4; Tr. 3213-3220; SER Section 2.,10.2). Be owner will be required to demonstrate with an appropriate site specific model that the proba-bility of a munitions ship explosion affecting the plant to the extent that 10 CFR Part 100 dose guidelines could be exceeded is on the order of 1 X 10- per year or less (SER Section 2.10.2).
I$$
,iy
-102-
Tanker Accident: Vapor-air Erolosion 234. The FNP is designed to withstand explosions which pr& luce a reflected overpressure of no more than 2 psi on the plant's Category I structures (PDR Section 2.9.2). For a site to be suitable, the owner must demonstrate that the probability of an explosion producing reflected overpressure of greater than 2 psi is on the order of 1 X 10- per year or less. This can be done by showing that a site possesses protective features which provide adequate separation distance to insure that the plant design blast overpressure criteria will not be exceeded or that the probability of such an event is on
-7 the order of 1 X 10 per year or less. The Applicant has denonstrated a xi the Staff has concurred that sites can be fourxl where the prob-ability of an accident involving a petrolet:n carrier that results in a reflected blast overpressure greater than 2 psi at the Category I structures is on the order of 1 X 10~ per year or less (PDR Section 2A.5.5; SER Section 2.10.2).
Bazardous Chemical Carrier Accident: Toxic Vapor Cloud 235. A toxic vapor cloud formed as a result of an accident involving a hazardous chemical carrier is incitried in the plant design basis up to a soecified maximurn limit (Applicant's Testimony page 4).
For control room habitability, the plant design will acconmodate concentrations of toxic gases at the Control roan ventilation intakes as soecified in Table 2.9-1 of the PDR.
These limits were determined
-103-f
by the methods of Regulatory Guide 1.78, " Assumptions for the Evalua-tion of the Hazards of a Nuclear Power Plant Control Rocm during a Postulated Hazardous Chemical Release".
For a site to be suitable for a RIP the owner must show tnat the probability of an accident producing concentrations at the control room ventilation system intakes in excess of those scecified is on the order of 1 X 10~
per year or less.
(Applicant's Tbstimony page 5). The Applicant has demonstrated ard the Staff has concurred that sites can be fouM where the probability of an accident involving a hazardous chemical carrier is on the order of 1 X 10~
per year or less (PDR Appendix 2A; Acplicant's Testimony page 6; SER Section 2.10.1).
Future Ship Traffic, Character of Ships and Cargoes 236. The Acplicant has evaluated shipping trade flow and traffic patterns with emphasis on the shipping of various hazardous material cargoes (PDR Sect. 2A, 2A.4, 2A.6, 2A.7). Although these
- c. valuations are based on current and imediate past shippirs and hazardous cargo traffic, these results can be extended reasonably to the future. Ccntinuing econcnic pressures indicate that growth in the shipping trades (except for IliG) will be accommodated by fewer overall snips of larger size.
(Applicant's Testimony page 6; Tr. 2998, 2999, 3001, 3064, 3109, and 3210). In addition ships of increased draf t are less likely to be in shallow waters near an RIP site. Improvent ats in ship design and stricter safety regulations can also be expected to reduce accident probabilities. Therefore, future trends in shipping av
.tog
-104-
are expected to reduce the overall likelihood of an accident at zn FNP site (Applicant's Testimony page 6; Staff's Rstimony page 2; Tr.
3235, 3255, a-d 3315).
237.
Projections of MG traffic have been made on the basis of proposed MG projects (PDR Section 2A.6; Applicant's Testimony page 6; Tr. 2994, 2995 and 3001). A study of the routes of UG ships show that most ships approach the eastern seaboard frcm well out to sea and do rot traverse t'
mastline; consecuently they do not enter the general area of potential FNP sites. Although the present trend is for an increase in MG traffic from foreign prts there seems to be ro evidence to indicate a significant future increase in coastal WG traffic. (PDR Section 2A.6.2; Applicant's Testimony page 6; Tr. 3051, 3052, 3182 ard 3312).
Corclusion 238. The Board firds that the seven classes of shipping accidents discussed in the Plant Design Report Appendiy 2A encompass the potential ha::ards to the FNP from shipping.
239. The Board finds that the probability of ship collision has not been urderstated ard that adequate consideration has been given to ptential changes in the pattern of ship traffic and the character of ships ard their cargoes over the 40 year l_fe of the facility.
</
/07
-105-
240. The Board finds that adequate consideration has been given to possible accidents resulting frcra ship collisions with site structures and from serivce ship collisions with the plant itself.
241. The Board further finds that the ccrabination of FNP design features and site envelope regairements provides reasonable assurance that shippirg accidents will not present an uMue hazard to the health and safety of the public.
J.
CONTCCION X - ICE CONTAItMEIC ACCE Contention 7:
"The refrigerated ice containment structure system is in-novative and therefore should not be permitted without an adequate pre-licensing testing taking into account the effect of roll, pitch, and yaw present on a floating nuclear plant."50 242. On this contention trth Applicant and Staff presented evidence, including material contained in the Plant Design Peport (PDR), the Saf my Evaluation Report (SER), as supplemented, aM written aM oral testimony.51 None of the intervenors presented 50?dmitted as interpreted by Board Crder dated May 21, 1974, pp. 8,9.
The Applicant's written testimony, Exhibit !;o. OPS-42, " Applicant's Testi: Tony Regarding X.
Ice Condenser Containment", was ainitted at Transcript, page 6009 (5-13-77). The witnesses sponsoring this test-imony were Dr. Dee H. Walker and Messrs. P. Blair Haga, Richard S.
Orr, and John D. Sutherland (Professional Qualifications admittc<l gd4 t,,
Of
-106-
witnesses, testimony or other information. Hearing sessions with regard to this contention were held on May 13,16, and 17,1977, aM the testimony appears at Transcript pages 6002-6042, 6043-6117, and 6118-6150 and 6174-6226, respectively. 5
243. The ice condenser containment has been adopted in the design of nuclear plaats by the Indiana and Michigan Electric Co. (D.
C. Cook 1 & 2); Duke Power Co. (McGuire 1 & 2, Catawba 1 & 2); and the Tennessee Valley Authority (Sequoyah 1 &
2, Watts Bar 1 & 2). In addition, two units utili::ing ice condenser containment are under construction in Japah and two in Finland.
(Applicant's hstimony, Page 2: Staff's Testimony, Pages 1-2).
244. The design of the ice condenser containment system is based on an extensive ice cordenser developnent program which began in 1965.
Sis program consisted of ccxnprehensive system testing as well as full scale static and dynamic structural testing of ice condenser (Footnote 51 Cantinued) at Transcript, pages 1024, 1024, 1039, ard 6004). We Staff's written testimony entitled, " Supplemental Testimony of NRC Staff in Response to ACCCE Contention 7" by William C.
Milstead, Jr. was admitted at Transcript, page 6085 (5/16/77). (Mr. Milstead's Professional Qualifications were atnitted at Transcript, page 6083).
5'Arplicant witnesses were examined by counsel for Atlantic County Citi:: ens Council on Environment (ACCCE), State of New Jersey, NRC Staff and the Board.
Staff witnesses were examined by Counsel for ECCE, State of New Jersey, and the Board.
454 10ff
-107-
components. Structural behavior of ice condenser components was messured durire static ad dynamic testing and confirmed analytical predictions of their structural adequacy.
(Applicent's Testimony, Pages 1-2).
245.
Ice condenser heat absorption capability during design basis accident was verified by blowdown tests on a full scale ice condenser section at energy levels of up to 160 percent of those predicted. In these tests, 36 ft. long ice baskets were used instead of 48 ft. ice baskets which are used in the actual ice cordenser. mis reduced basket lergth provides a conservative irdication of the heat absorr. lion capability of the full length ice condenser section. (Tr.
6097-6098).
246.
In the full scale section tests, higher than predicted drain temperatures were observed. These high drain temperatures indicate that ice melt out is delayed in time and long term pressures are lower than predicted. (Tr. e177-6183).
247. Se first ice cordenser plant, D.
C.
Cook 1, achieved initial criticality in January, 1975, ard ccmmercial operation in August, 1975.
Bere had been no problems of safety significance associated with the ice condenser and through Decenber 31, 1976, D. C.
Cook 1 had generated cuer eleven billion kilowatt-hours of electricity with a plant availability of greater than 33 percent.
( Applicant's Testimony, Page 2; Tr. 6092).
248. Bere have been some normal " teething" problems with the ice condenser at D. C. Cook 1 including air handling units, refriger-ation system i:talances, air leaks and isolated incidents of ice buildup on the lower inlet doors. In only a single instance did this require a reduction of power, in this case a reduction to 20 percent of ;cwer to reclose lower inlet doors. (Tr. 6056-6057 and 6111-6112).
249. Be ice ccMenser for the ENP will have substantially the same gemetries, features, aM materials of construction as those for land based plants (Applicant's Testimony, Page 1).
250. The FNP ice condenser is exposed to tne same type of loading ccMitions as land based ice ccMensers. Additionally it is exposed to loads resulting frcm roll, pitch, and yaw which are transmitted to the ice condenser through plant structures. A load acting on an ice condenser ccuponent has an identical effect whether it is caused by roll, pitch, and yaw or by a seismic event. Maximum loads which may occur as a result of roll, pitch and yaw are sig-nificantly less than the loads for which adegaacy was demonstrated during the static and dynamic structural testing of ice condenser creponents. (Applicant's Testimony, Page 2) 251. Dynamic tests under simulated seismic loading s showed ice fallout frcn ice baskets to be less than the allowable limit of one Wrcent. As design basis wind and wave loadings on the FNP are about one-twentieth of the seismic loadings uspin the test, it is y
6
-109-
concluded that fallout during this condition will be also less then one percent. (Tr. 6023-6033).
252. Ib assure that the ice condenser installed on the ENP is able to perform its safety function, a monitoring prcgram will be per-formed througrout plant life.
This program will include weighing of ice baskets, visual inspection of doors and flow passages, testing of openirg forces on doors, monitoring of temperatures at various locations within the ice condenser, and checking the chemical com-psition of the ice.
There is also a monitoring system that provides indication that the door panels are al' properly closed. This is very similar to the program at D.
C.
Cook. (PCR, Pages 6.2-117a ( f) 6.2-11;c; Tr. 6055-6056).
253.
Ice may be replenished in the ice condenser by either adding water of the proper chemical com;rsition at a controlled rate and allowing it to freeze or by melting down the ice bed and com-pletely refi' ling with fresh flake ice. Tests h;ve shown that fresh flake ice fuses w. ':5in five weeks of filling to a level which provides adequate retention for high "g"
loadings. Jt is not necessary to partially melt the ice to ensure fusion. (Tr. 6047 and 69-6211).
254. The Board concludes that the ice condenser containment system, which is being used on a total of fourteen domestic and foreign lard based nuclear pwer plants, is not innovative for the EMP b.t4
/ l.2
-110-
ard that adecuate prelicensing testing has been performed which appropriately takes idto account the effect of roll, pitch, and yaw.
K. CONI'Em' ION XI - TURBINE-GENERATOR MATTERS 255.
On June 15, 1976, Mr. Ernst J.
Effenberger made a limited appearance statement before this Board concerning turbine-generator matters (Tr. 999-1010).
The Board requested the Applicant and Staff to address the matters raised by Mr. Effenberger (Tr.1011).
Both Aoplicant and Staff presented evidence on these matters, inclui-ing material contained in the Plant Design Report (PDR), the Safety Evaluation Report (SER), as supplemented, and written and oral testimony. 53 Intervenors Atlantic County Citizens Council on Environ-ment (ACCCE) aM Atlantic County Board of Chosen Freeholders (Atlantic County) presented written ard oral testimony.54 53The Applicant's written testixny, Exhibit OPS-38, entitled "Appli-cant's Testimony Regarding Turbine-Generator Matters," was admitted at Tr. 5095.
Ine witnesses sponsoring this testimony were Drs. Dee H. Walker and Douglas H. Shaffer aM Messrs.
P.
B.
Haga, John F.
Hanst, John D. Dickins.on, Harold C. Kersteen, and Francis S. Maszk (Professional Qualifications admitted at Tr. 1024, 2881, 3419, 5091, 5093, and 5094). The Staff's written testimony entitled " tac Staff Testimony in Response to Limited Appearance Statement of Ernst Effenberger," was ainitted at Tr.
5659, 5660.
The witnesses sponsoring this testimony were Drs. Kazimieras M.
Campe and John A.
O'Brien and Messrs. Ronald F. Naventi, Richard J. Kiessel, Stefan S.
Pawlicki and Ralpn A.
Birkel (Professional Qualifications admitted at Tr. 5658, 2534, 5658,1946, 5658, and 1038).
54The June 15, 1978 limited appearance statement of Mr. Ernst J.
Effenberger was withdrawn (Tr. 4016 ard 4033) and the written testimony of ACCCE, entitled "Co:mtents on the Safety Evaluation Report, NUREG-75/100 (9/30/75),
and Supplement, NUREG-0054 (3/16/76), by the Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission, Related to the Procosed Manufacturing 454
'S,
-131-
Hearing sessions with regard to the turbine-generator matters wre held on December 8, 9, 10, 16 and 17, 1976, February 28, March 1, 2, 3, and 4, May 9, 10, 11, 12, 13 and 17, 1977 and the testimony appears generally at Transcript pages 4004-6001 and 6151-6172.55 256. In response to the Board's request at Tr. 5940 and 6377-6378, the Applicant provided additional information with respect to the preliminary design of the turbine-generator spring mounted support ard vacuum balanced ccMenser and the effect of these two (Footnote 54 Cont'd) of Floating Nuclcar Power Plants, Offshore Powr Systems, Docket No.
Sri 50-437, Safety Evaluation of Mechanical Equignent, Coments by Ernst J. Effenberger, a Concerned U.S. Citizen," dated June 1976, was admitted into evidence at Tr. 4069. Mr. Effenberger, on behalf of ACCCE, read into the record at Tr. 4021-4026 additional direct testimony. (he Professional Qualifications of Mr. Effenberger were admitted at Tr. 4021.)
At_lantic County's written testimony entitled
" Testimony of Intervenor Atlantic County in Respect to Turbine-Gen-erator Design & Turbine Missiles," by Dr. George Luchak was admitted at Tr. 4343. (he Professional Qualifications of Dr. Luchak were ad-mitted at Tr. 4336.) Dr. Luchak testified that he was an expert in the areas of systens engineering, applied probability, reliability and cost effectiveness studies (Tr. 5046). Dr. Luchak testified that he is not an expert in the aceas of turbine design, turbine sup-prts, valve systems, fracture mechanics, materials, stress corros-ion, instrunentation and controls, bearing design, or the design of concrete structures; nor has Dr. Luchak ever designed a structure for dynamic loa 3s or missile impact (Tr. 4398-4412 and Tr. 4763, 4764). Atlantic County's written testimony entitled "'Ibstimony of Intervenor Atlantic County in Respect to Turbine-Generator Design &
Turbine Missiles" by Daryl F. Todd, Atlantic County Freeholder, was withdrawn and not offered into evidence (Tr. 5081, 5082).
55Applicant witnesses were examined by counsel for Atlantic County, State of New Jersey, ACCCE, NRC Staff, ard by the Board. Staff witnesses were examined by counsel for Atlantic County, State of New Jersey, ACCCE ard by the Board. ACCCE witness Mr. Effenberger was examined by counsel for Atlantic County, NRC Staff, State of New Jersey, Acolicant, and by the Board. Atlantic County witness, Dr.
Luchak, was exa-ined by counsel for State of New Jersey, ACCCE, City of Brigantine, NRC Staff, Applicant, ard by the Board.
1$ r$,
U llff
-112-
components en the probability of turbine missile generation.56 Also in response to the Board's recuest, and as further clarified in the Board Order of February 28, 1978, the Staff provided an evaluation of the effect of the preliminary design of the turbine-generator support and cordenser on the probability of turbine missile generation.57 257. The Staff subnitted on November 21, 1977, the " Affidavit of John A.
O'Brien," which provided two amendments to the oral testimony which Dr. O'Brien gave at the May 13, 1977, hearing session.
56On August 15, 1977, Applicant submitted three a"fidavits entitled
" Preliminary Design of the Floating Nuclear Plant Turbine-Generator Support and Discussion of the Effect of the Preliminary Design of the Turbine-Generator Support and Vacuum Balanced Condenser on the Probability of Missile Generation," " Preliminary Design (Propriet-ary) of the Floating Nuclear Plant Vacuum Balz.nced Cordenser," and
" Preliminary Design (Non-proprietary) of the Floating Nuclear Plant Vacuum Balanced Condenser," each by P. Blair Haga, Richard S. Orr,
and Dee H. Walker, and each dated August 12, 1978. 'Ihese affidavits are hereinafter referred to as " Applicant's Affidavit I,
II, or III," respectively. (Professional Qualifications of Richard S. Orr were admitted at Tr.1329). The Applicant had previously supplied to the Staff a brief description of the spring mounted ENP turbine supoort and an indication that a condenser was being designed to minimize the vacuum load on the sucporc. This information is contained in Applicant's Exhibit OPS-106, a letter (with attachment) from OPS to the NRC dated September 8,1976, admitted at Tr. 5641.
Exhibit OPS-106 also contains other informati i concerning the FNP turbine.
On March 10, 1978, the Staff submitted a document entitled
" Affidavit of Richard J. Kiessel," hereinafter referred to as the "Kiessel Affidavit."
</ ll$
-113-
258. We design and supply of the ENP turbine-generator is performed by the Westinghouse Electric Corporation, a supplier of turbine-generators to industry for over 75 years (Applicant's Testi-mony, Pace 2).
Turbine Rotor Deflection 259.
Mr. Effenberger made the following allegations relating to rotor stresses dm to platform deflection:
"A standard lard based T-G rotor is well over designed. The rotor stresses are in the range of 8 to 10 times the safety factor, because the bearing diameter usually dictates the other dimensions of the rotor. The manufacturer of the FNP turbine assumes a + 1/2 inch deflection allowance in the operation of the turoine rotors. This in turn will increase the bending stresses in the rotor to an extent where the safety factors in certain areas will be reduced to less than two, which will increase the probability of a rotor failure in the same ratio." (Effenberger's Testimony, Page
- 3).
"Reducitr7 the stress safety factors in the shaft from 8-10 down to below 2 is increasing the irssibility of a shaft failure ard a missile generation." (Effenberger's Testi-mony, Page 8).
260.
A Westingtruse criterion for rotor design, whether the rotor is for a land-based plant or an FNP, is that *he stress safety factor will be no less than 2. Based upon long Westinghouse experience with land-based plants and marine propulsion turbines, the stress safety factor of 2 or greater is good engineering practice. Analyses conducted demonstrate that the final design of the FNP turbine rotor fCs
![h
-114-
will mee c.
this criterion, even with turbine-generator foundation deflections of + 1/2 inch. ( Applicant's Testimony, Pages 3 and 4, Tr.
5429 and Applicant's Affidavit I,
Pages 45, 46, and 48.) The BT turbine-rotor meets this criterion, even without the benefit of the vacuum balanced condenser (Tr. 5430 and 5441). The analysis of the D7 turbine rotor cocservatively assumed the + 1/2 inch deflection was im psed on every revolution of the rotor,58 even though such a deflection is an extreme ccMition that will seldom occur, if at all (Tr. 5616, 5617, 5931 and 5932).
261. Westinghouse Steam Turbine Division analyses of rotors for land-based turbine generator units similar in design to that of the B7 show that, while there are locations where the ratio of 59 allowable to actual stress is in the range of 8 to 10, there are also locations where the ratio of allowable to actual stress is in the range of 2 to 3 ( Applicant's Testimony, Page 3,
and Applicant's Affidavit I, Pages 46 and 48). The stress safety factors for the B7 turbine rotor on a spring supoort aM with a vacuuit balanced condenser SQ*The terms " shaft" and " rotor" appear to have been used interchange-ably in several portions c' the transcript; accordingly, the ' trd makes no distinction betwee ie two terms.
The allowable stress is the eMurance strength of the material wnich is about 50% of the ultimate strength for the B7 rotor material (Tr. 5628 and 5629).
$'24
//$
-115-
are similar to the stress safety factors for a land-based turbine rotor on a typical reinforced concrete support and with a typical condenser (Apolicant's Affidavit I, Pages 46 and 48).
262. Utilization of a vacuum balanced condenser reduces the vacuum load and the deflection of the FNP rotor. Also, the FNP rotor will be aligned a that the turbine-generator foundation deflections, given in Section 10.2.4 of the PDR, will cause rotor deflections of equal magnitude in the upward and downward directions, thereby minimizing the effect of these deflections.
(Applicant's Testimony, Page 4, and Applicant's Affidavit I, Page 46).
263. The spring mounted turbine support se ves to attenuate local platform deflections, an a5 vantage for which no credit was taken in the analysis discussed in the preceeding Paragraph 261 (Applicant's Affidavit I, Pages 11 and 47).
Previous Experience With Rotor Deflections 264. Mr. Effenberger made the following allegations relating to previous experience with rotor deflections:
"There is no cr.parison between a land based T-G and a floating T-G. A land based unit is erected and operated on its natural ' sagging line. ' The slightest deviation from this line will cause an unrest of the rotor which will show un in excess vibration until the misalignnent is corrected.
Every M in the world operates that way. No other situa-tion is known." (Effenberger's Testimony, Page 2).
!ig
-116-
"As discussed earlier, the smooth operation of a turbir e shaft depeMs on an exact alignment of the whole turbine.
Any deviation, experience shows about 15 mils, will induce excessive vibration and therefore increase the possibility of a rotor failure." (Effenberger's Testimony, Page 6).
" Operating experience has shown all over the world that any deviation frcm the calculated ' sagging line' will cause excessive vibration. No turbine in the whole world is known to operate under any other condition." (Effenberger's Testirrony, Page 6).
" Bending the shaft during operation is against any experience in history and totally unproven." (Effenberger's Testimony, Page 7).
265. -In the following statement, Mr. Effenberger appears to contradict the above allegations:
" Going back to the proposed + 1/2 inch deflection of the turbine shaft, history has shown that it is possible to force a rotor to operate away from the natural ' sagging line'. This is strictly a stress problem in the rotor coucling and the shaft ends. Increasing the coupling size and the coupling bolts usually takes care of this condition. The specific bearing pressure will also increase, and this dictates a larger bearing. These changes create no problem since the operation under this arrangement is the same as in any other design. In other words, a turoine rotor can be designed to operate at any different ;oint or line as long as the rotor stresses are being taken care of." (Effenberger's Testimony, Page 6).
266. During cross examination by counsel for the State of New Jersey, Mr. Effenberger clarified his concern as being related to the movement (or flexing) of the rotor across the natural " sagging line'
$v
/;g
-117-
rather than the operation of the rotor at sm.e constant deviation from the " sagging line" (Tr. 4082 and 4083).
20.
Intervenor witness Dr. Luchak agreed with Mr. Effen-berger's comments on the beMing of the turbine shaf t during ooera-tion, changes in bearing pressures, and the effects of hull vibrations on rotor strain, all in the context of the high-tuned mount (Luchak's Testimony, Page 5, as interpreted at Tr. 4648 and 4649, aM Page 6, as modified at Tr. 4333).
As acknowledged by Dr. Luchak (at Tr. 4649),
the FNP turbine fouM ation is a low-tuned mount, not a high-tuned mount (PDR Section 3.7.2.1.1.8).
'Ihe Board notes that Dr. Luchak irriicated that he would wish to reconsider these opinions with respect to the proposed (low-tuned) FNP turbine foundation design (Tr. 4649).
The Board therefore fiMs the preceding opinions of Dr. Luchak are not relevant to the EUP design under consideration in this proceeding.
268.
It is nomal for turbine-generators to operate away from the natural " sagging line," including novement back and forth across the "saggirg line" (Applicant's Testimony, Page 5, Tr. 5195, 5443, and 5446). Such deflections do rot cause any problems unless they become excessive (Applicant's Testimony, Page 5). Based on previous experi-ence and analyses, the deflections of the FNP turbine-generator will not result in unacceptable vibration (Applicant's Testimony,Page 5).60 60Refer to the section on Bearing (Paragraphs 2f6 through 280, infra) for additional information respecting the effect of rotor deflection on bearing oil pressure and vibration.
<f
/e2C
-118-
Rotor Stresses and Plant M3 tion 269.
Mr. Effenberger made the following allegation relating to rotor stresses induced as a result of plant motion:
"The increase in disc stresses due to plant motions are 4 PEscussed, but what about rotor stresses? Since the plant
- motions are not kept away fra the turbine shaft, the rotor will go through its own cyclic stresses, plus all the plant motions.
"To illustrate the plant motions, a wave motion period of 20 secoMs is assumed.
O/er a forty year life spa, the rotor will exp3rience over 60 million additional stress cycles.
This fact is totally ignored."
(Effenberger's Testimony, Page 4',.
270. The effect of plant motion on rotor stresses is con-sidered in the analyses of the turbine-generator as discussed in PDR Section 10.2.4.
'Ihese stresses were incided in the Applicant's analyses discussed in the previous section on Turbine Rotor Deflec-tions. The Applicant's calculations show that platform motions contribute a maximum of about 17 percent of the total cyclic stress in the rotor, and at nest locations the percentage is much lower.
In these calculations, the Applicant conservatively assumed that the rotor is continuously exposed to the maximum plant motion rather than a range of lesser plant motions that muld actually be present. The Applicant also conservatively assumed that this maximum rcotion ctress level is apolied for each revolution of the rotor, whereas the actual stress m uld cycle less frequently as the plant noves through its motion cycle.
The net result of these assumptions is that more than
-119-
30 billion cycles of the maximum motion stress level are imposed on the rotor in the Applicant's analysis, compared to the 60 million cycles mentioned by Mr. Effenberger. ( Applicant's Testimony, Page 6).
Accordingly, the Board finds that the effects of plant motion on rotor stresses were not ignored, ard in fact the Applicant has conserva-tively considered such effects.
Rotor Stresses and Hull Vibrations 271.
Mr. Effenberger made the following allegation relating to rotor stresses and hull vibrations:
" Hull vibrations will add to rotor strains ard stresses ard increase rotor failures and therefore missile generations."
(Effenberger's Testimony, Page 8).
272. The design of the ENP provides for isolation between the turbine and the hull, as discussed in PDR Section 3.7.2.1.1.8. Accord-ingly, the effect of hull vibrations on rotor stress or strain levels and on the possibility of missile generation will be negligible.
(Applicant's Testimony, Page 7, ard Applicant's Affidavit I, Pages 16 through 19).
273. The Applicant has conducted analyses to determine the dynamic response of the tt'rbine-generator and support system to an unbalanced rotating mass. Analyses were performed for the turbine-generator on the FNP (spring mounted) support as well as for the sgeJ4
,/ '
-120-
turbine-generator on a typical reinforced concrete support. These analyses demonstrate that the dynamic resconse of the turbine-gener-ator is not adversely affected by the spring mounted supprt. There-fore, the dynamic behavior of the turbine suoport will not add to the probability of turbine missile generation.
(Applicant's Affidavit I, Pages 12 through 16 and 47).
Condenser Vacuum Load 274.
Mr. Effenberger made the following allegation relating to ccMenser vacuum loads:
":t is impx;ible to compensate life (sic) loads such as vacuum loads by selective alignment. In a conventional design the cordenser is fixed, the turbine is on the foundation ard between the turbine and condenser is a flexible expansion joint. 'Ihe full vacuum load is on the turbine. The only way to eliminate the vacuum load is to mount the condenser on springs and eliminate the expansion joint.
This arrangement works on a land based plant, not on a floating nuclear pwer plant, because there is no way to restrain the hanging condenser, which is also exposed to the platform motions." (Effenberger's Testimony, Page 7).
275. As stated previously, a vacuum balanced condenser will be utilized on the WP to reduce the vacuum load on the turbine-generator. The FNP design does not involve mounting the cordenser on scrings or eliminating the expansion joint. (It is noted that there has been wide use in the power industry of vacuum balanced condensers incitx3ing many which do not involve spring mounting or elimination of the excansion joint.) Thus, contrary to Mr. Effenberger's allegation, 1r
$ s g, I?g
-121-
it is possible to comoensate for vacuum load on the FNP turbine-generator.67^ (Apolicant's Testimony, Page 8, Applicant's Affidavit II, ard Tr. 5636).
Bearings 276.
Mr. Effenberger made the following allegations relating to tne FNP turbine rotor bearings:
" Changing the bearing pressure during oparation will induce vibration ard increase the passibility of a shaft failure and missile generation." (Effenberger's 'Ibstimony, Page 8).
"The journal bearings of a turbine rotor are very precise.
The weight of the rotor dictates the size of the bearing, the thickness of the oil film and the oil pressure. 'Ihe gap between the bearing and the shaft is filled with oil and well defined. If this gap is too large, the phenomena of an oil whip shows uo. If the gap is too snall, then the oil will be over-heated and the babbit in the bearing melts.
The limitations between these two conditions are very small.
"Any berding of a turbine shaft during operation will change the gap in the bearing, will change the bearing pressure and will cause all the corditions as discussed above." (Effenberger's Testimony, Pages 6 and 7).
61The Board notes that Mr.
Effenberger himself submitted to the Applicant in late 1975 an invention disclosure for a condenser joint
- o. sign that would reduce the vacuum load on the WP turbine-genera-tor, c:. Effenberger's proposed design did not involve elimination of the expansion joint or munting of the condet on springs. The design procased by Mr. Effenberger was not selected for use on the WP because other proposed designs were superior.
(Applicant's Testimony, Pages 7 and 8, Applicant's Affidavit II, Page 4, and Tr.
4091).
ITvY
/2$
-122-
277. As indicated in PDR Section 10.2.4, the WP turbine rotor bearing pressures have been evaluated under FNP loading con-ditions, aM the results indicate that the final design will meet the Westirghouse design criteria applicable to all turbine-generators.
Sach evaluations included consideration of potential for oil whip and bearing overload.
(Applicant's Testimony, Page 9).
278. Oil whip is a vibration of the rotor in a sleeve bearing that is caused by instability of the oil film.
It has been stdied intensively and is well understood.
Tne potential for oil whip is gwerned by combinations of such parameters as bearing pressure, rotational speed, oil viscosity, bearing clearance and system flexi-bility.
Analyses of the FNP bearings under the range of FNP bearing pressures indicate that oil whip will not occur.
Additionally, Westinghouse experience shows that oil whip is unheard of on 1800 RPM rotors such as that on the NP.
If oil whip were to occur, it would be cetected by the vibration sensors that will be on the FNP unit, and the unit could be safely shut down for corrective action without an increase in the probability of missile generation.
( Applicant's Testimony, Paga 9).
279.
Design criteria for determining the maximum pressures under whi-aearires can operate successfully have been established through experiments conducted by Westinghouse and others and through many years of oporating experience with We 7tinghouse turbines.
Analyses of the WP bearings under the expected range of FNP bearing
$CI
-123-
pressures indicate M au sufficient oil film will exist to carry the load.
The FNP will contain redundant temperature sensors that will show if a bearing is overloaded (and hence overheated) so that corrective action can be taken, thus preventing melting of the babbitt dm to excessive temperatures.
The temperature alarm point is 210 F and the established trip limit is 225 F, which is well below the melting rint of the bearing babbit (approximately 450 F). If the babbitt in a bearing were to melt, subsequent to the turbine being tripped, the resulting friction forces created between rotating and stationary parts would cause rapid deceleration of the turbine-generator from operating speed with no effect on the probability of missile generation. (Applicant's Testimony, Pages 9 and 10, and Tr.
5456).
280. Westinghouse field service experience has shown that land-based turbine designs similar to the FNP, which have met the above bearing design criteria, have not experienced " excessive vibrations". It is therefore concluded umt the FNP turbine-generator will not exparience, as a result of beming pressure induced vibra-tion, any greater potential for missile generation than a similar land-based turbine-generator.
(Applicant's Testimony, Page 10).
Shippingport Failure 281.
Mr. Effenberger made the following allegation relating to turbine-generator materials:
9,f ',
/n$
(
-124-
"The T-G manufacturer claims that no T-G failure in his design has occurred. I would like to point out that Shippingport, a nuclear power plant, failed at operating speed last year, not at design or destructive overspeed; it just fell apart after sixteen years of normal operation.
Obviously the integrity of the material is only good for a limited time, definitely not fer forty years as this FNP is planned to operate." (Effenberger's Testimony, Pages 4 and
- 5).
282.
In February, 1974, after 16 years service, the Shipping-port turbine of Duquesne Light Ccmparcr experienced a disc failure at the second LP disc. No missiles external to the turbine casing were generated by this incident. (Applicant's Testimony, Page 10). Other turbines with design features similar to the Shippingport turbine have been in ooeration for more than 40 years. (Applicant's Testimony, Page 11).
283. Metallurgical examination of the failed Shipping; ort disc revealed that the fracture originated at cracks in the corner of the keyway near the exhaust face of the disc. 'ihese cracks formed and slowly propagated during the 16 years of operation, and failure occurred when the cracks enlarged to critical flaw size. dixiern disc materials used for the FNP turbine exhibit more than twice the toughness of the material used for the Shipping; ort turbine. In addition, design changes which have occurred since about 1958 limit the stresses and the likelihood of crack formation.
(Applicant's Testimony, Page 11, and Staff's Testimony, Page 30). The Board therefore firds there is no reason to expect the rip turbine to 12f7
-125-
experience a " Shipping; ort-type" disc failure during its forty year design life.
Overspeed Protection Systems 284.
Mr. Effenberger made the following allegations relating to the overspeed protection systems for the FNP turbine-generator:
7 "Three overspeed protective systems are provided in this design, but all systems act finally on the same valve spindle, so no matter how many systens are installed for overspeed protection, if the one valve gets stuck then there is little protection and the reasoning for having three systems is not valid.
"The trip systems are part hydraulic and part mechanical.
Tnis means that the valves are spring loaded and the springs are kept open by hydraulic pressure.
On imoulse, the fluid is dumped and the springs are closing the valves.
Two systems have the same drain line and any bending or plug-up of this line will make the main steam valves inoperable."
(Effenberger's Testimony, Pages 3 and 4).
w "All three emergency trip systems depend finally on the reliability of a single valve as shown earlier.
Is this really enough?" (Effenberger's Testimony, Page 5).
"The overspeed protective trip systems are actity ai de same valve spindle and therefore not reducing the overspeed possibility.
Two of the three emergency trip systems have the same dump lines.
Any damage or plug-up of this line will increase the passibil.ity of an overspeed condition and therefore missile generaCon." (Effenberger's Testimony, Page 8).
$tJY
,l<'j
-126-
285. Be three overspeed protection systems for the ENP turbine are described in PDR Section 10.2.2.4, pages 10.2 - 6b, 6c, aM 6d.
'Ihe three systems are designated Electrical, Mechanical md SCOIS (Single Channel Overspeed Trip System).
In response to a Board request at Tr. 4181 and 4315, additional description of tne overspeed protection systems was provided in Applicant's Exhibit OPS-104 (aimitted at Tr. 5106) and in the testimony of Applicant's witness at Tr. 5107 - 5114.
286. The Staff has received a preliminary design of the ENP turbine overspeed protection system (Tr. 5892). 'Ihe improvements in the EMP cverspeed protection system (the double drain trip block and SCOTS) are not innovative, new or unusual (Tr. 5893 and 5898).
'Ibe SCOTS system has been previoucly utilized on lam-based nuclear plants (Tr. 5893 and 5894).
The overspeed protection system will conform to the requirements of IEEE-279, 1971.6*' Conformance with this standar',
specifically with the equignent qualification aM periodic testing requirements, should result in an enhanced reliability of the over-speed protection system.
(SER Section 7.6.1 and Tr. 5928 through 5931).
62Institute of Electrical aM Electronic Engineers StaMard 279, 1971,
" Criteria for Protection Systems for Nuclear Power Generating Stations" (Tr. 5929).
As noteo in SER Section 7.6.1, the Staff recuires that the oversoeed protection system conform to IEEE-279, 1971, except as follows:
454
!29
-127-
287. All three overspeed protection systems do not depend finally on the functioning of a single valve.
In accordance with standard American Erwer industry practice of many years standing, the FNP turbine will be furnished with redundant valve systems for the main steam piping (throttle and governor valves) and redundant valve systens for the reheat pipirr.: (reheat stop and interceptor valves).
In each steam flow path i: o the turbine there are two "alves in series to protect the turbine against overspeed. These valves are held open against a spring force by fluid pressure. Stainless steel tubes are used to carry the trip fluid. A loss of fluid pressure will cause the valve to close. Blockage of any one drain line will not prevent valve closure. (Applicant's Testimony, Page 12).
(Footnote 62 Cont'd)
"(a) Section 4.4 of IEEE Std 279-1971 (Equignent Qualifica-tion). The equipnent of the turbine overspeed protection system shall meet the environmental qualification requirements (including vibration) under all conditions of normal, abnormal, and accident conditions, but excitx3ing seismic gaalification.
(b) Section 4.17 (Manual Initiation). Manual initiation at the system level in the control room for the turbine oversceed protection system is not required.
However, industry practice which provides for a means for manual trip locally at the turbine struld be followed."
(SER Section 7.6.1).
With respect to item (a), the Staff reqaired "The turbine overspeed protection system should be designed and installed (equignent gaality, mounting, routing and
. supporting of associated circuitry and piping) such as to provide a high degree of assurance thst it will retain its functional capability during a:x3 after earthquake." (SER Section 7.6.1).
g4 c
130
-128-
233.
In response to a hypothetical question by Applicant's counsel, Mr. Effenberger agreed that, if there are three separate drains for the emergency trip fluid, if there is a separate line for the emergerry trip fluid fran each dump valve, and if there is a third fully independent auxiliary overspeed protection system known as SCOIS, he no longer would believe that two overspeed protection systems have the same drain line and any bending or plugging of any single line will make the main steam valves inoperable (Tr.
4197 through 4200).
'"he hypothetical question is shown to be based on factual information in the PDR Section 10.2.2.4 (Pages 10.2-6b, 6c, and 6d), Acplicant's Exhibit OPS-104 ard the oral testimony of the Applicant's witness at Tr. 5107 through 5114.
289.
During cross examination, Mr. Effenberger agreed that if cne valve f ails to function ard the other nineteen valves operate, there is still protection from turbine overspeed (Tr. 4210).
290.
The Board concludes that failure of any one valve or any ae trip fluid line will not prevent tripping of the turbine.
Plant Motion and Valves 291.
Mr. Effenberger made the following allegation relating to the effect of plant motion on the steam valves:
gx;,
r
.l!f
-129-
"It has not been irriestigated what t.he platform motion could do to a valve spindle clearance. We steam chest which houses the main steam valves is also exposed to the paltform (sic) rrotions." (Effenberger's Testimony, Page 5).
292.
Mr. Effenberger's statement acpears to imply that a reduction in main steam valve spindle clearance, due to the forces im;rsed on the main steam valves by plant motions, may prevent the main steam valves from closing. We main steam valves and steam chest have been analyzed aM found to be acceptable ror accelerations about ten times the valms of acceleration that may be experienced due to plant motion.
It is therefore concluded that platform motions will not prevent the main steam valves from closing. (Applicant's Testi-many, Page 13).
Valve Testing 293.
Mr. Effenberger marle the following allegations relating to valve testing:
" Turbine main steam valve stems build up deposits no matter how the feedwater is treated. Practice has shown that even valve testing is not practical because the schedule is never kept by the opn ator. Only those who have worked in and maintained a pwar plant know that. If every stuck valve would be reported by the utility industry, the in-surance rates would go un to the extent that we would have no pwer stations in operation." (Effenberger's Testimony, Page 4).
"Every valve testing makes it necessary to reduce the load of the turbine to the pint wLere the valve can be tauen out of service to close. Having twenty main steam valves and numerous non-return valves on a 1200 Mecawatt Unit, the j
0;t.
-130-
ti:ne element involved will be such that the unit will never get above 75 - 30% of tull load. This means that the utility owner will resist, and if necessary will cane up with his own schedule for valve testing. 'Ihis will further increase the probability of a valve failure and create a potential possibility for any overspeed cond ition. "
(Effenberger's Testimony, Page 5).
294. Valve failures cannot result in unacceptable overspeed excursions unless at least two valves in series in the same stean flow path into the turbine fail to close simultaneously unen there is a demand to close (see Paragraph 287, supra). Fr the reasons discussed in PDP. Section 3.5.4.4.2, it is unlikely that one valve, let alor.e two valves in series, will fail.
Design features such as spiral grooves in throttle and governor valve stems, backseating of the stems and substantial closing force are provided to minimize the possibility that valves will stick open.
(PDR Section 3.5.4.4.2, Applicant's Testimony, Page 14, and Staff's Testimony, Page 16). All-volatile treatment of the feedwater, which is provided in the WP design, will reduce the particulate content of the steam passing through the valves. 'Ihis particulate material is the cause of builduo on the valve stems ard possible sticking. (PDR Section 10.3.5 and Staff's Testi-many, Page 16).
295. 'Ihe Commission will require an owner of an WP to include in its Technical Specifications the valve testing and in-service inspection program outlined in PDR Section 10.2.6 (Staff 's Testimony, Page 13).
45-4 13
-131-
296. 'ite time required to test the FNP turbine valves amounts to a few minutes per valve, or approximately one hour per week for all turbine valves (Applicant's 'Destimony, Page 14, and Tr. 5116-5119).
Maximum load reduction during test of any valve occurs when testing governor valves and is approximately 10 percent of full loM when the turbine is operating at full power (Applicant's Testimony, Page 14).
It is not necessary to reduce load on the ESP turbine prior to testing the turbine valves (Tr. 5137). When testing is done at less than full load, the turbine control system acts automatically to maintain load at a constant level.
Interference with normal operation of the turbine is usually minimi::ed by scheduling valve tests at off peak hours and by staggerina the tests of the various groups of valves over a one week period (the period recommended between valve tests).
(Applicant's Testimony, Page 14).
297. Testing of conventional nonreturn valves in the extrac-tion pipes between the turbine ad feedwater heaters aM in the drain lines between the moisture separator-reheater aM feedwater heaters will not cause a significant load change (Applicant's Testimony, Page 15).
298.
Dr. Luchak testified that it is reasonable to assume turbine valve testing on the FNP will reduce the FNP capacity factor by five percent. (Luchak's Testimony, Page 10). Dr. Luchak's estimated reduction is based on his observation that such a reduction is within the standard deviation of capacity factors he observed on land-based 1 Cs
$oy
,I,U
-132-
plants and that such a reduction would, therefore, not be unusual (Tr.
4372 and 4373).
Dr. Luchak performed further calculations based on two issues of the Commission " green book"63 which additionally corriinced hi:n that a reduction in capacity factor of five percent is possible dm to valve testing on the ENP (Tr. 5028 through 5030 and Tr.
5034).
The Applicant reviewed the two issues of the Comission
" green book" to which Dr. Luchak referred at Tr. 5029 and 5030. 'Ibese two issues listed only tw Westinghouse turbines that have valves functionally the same as the ENP turbine, and only one of these two turbines had a valve test.
That one turbine has a restrictien which recuires that load be reduced to at least 75% during valve testing.
Since the FNP has no such restriction, the information on this one turbine is not applicable to the ENP. (Tr. 5597 and 5598).
299. Utili::ing Mr.
Effenberger's estimates of valve test times (which are about 6 times higher than the times stated by the Apolicant) ard Mr. Effenberger's estimate of power reduction (25% vs.
Apolicant's maximun of 10%), the Scaff calculated that wekly valve testing on the FNP migpt reduce the capacity factor by about one-half of one percent. (Tr. 5982, 5983, 5989, and 5990).
63" Operating Units Status Report, Licensed Operating Reactors, Data for Decisions," Nuclear Regulatory Commission, November and December, 1975.
$ ',r 5 4
-133-
300.
The Board finds that Dr. Luchak's estimate of capacity factor reduction due to valve testing on the RTP is not supported by the facts. The available information indicates that weekly valve testing on the rip will not have a significant impact on the plant load or capacity factor.
Turbine Missiles 301.
Mr. Effenberger made the following allegations relating to turbine missiles and applicable regulatory probability criteria:
"NRC, Bush Report 4/7-1973, Probability of T-G Missiles.
This report does collect data on a worldwide basis of T-G failures. Not a single floating TH3 is included, just information on lard based units. Therefore, this report is totally unacceptable for an evaluation."
(Effenberger's Testimony, Page 2).
"The conclusion in the Bush Report shows that a probable
-4 failure of a T-G is in the range of 10
. To be on the safe side, the NRC assumed a 10-failure rate on new land based nuclear power plants is sufficient to guarantee the safety of the p;blic. Ignoring the fact that the operation and envir-or:nantal corditions of a floating nuclear power plant is totally different from land based plants, this recuirement vas also imposed on the FNP. The FNP was and is evaluated as any other land based power plant and this is wrong and dangerous, because the probability of a T-G failure on the FNP ic greater than on a lard based plant." (Effenberger's Testimony, Pages 2 and 3).
" Missile generation -depends on the reliability of failsafe equignent, like an overspeed protective trip system, re-liability of valve system, rotor failures - material
/>'
-134-
integrity, disc failures - material integrity, valve testing, just to mention a few. The orientation of the T-G in a power plant should te decided considering all the above conditions."
(Effenberger's Testimony, Page 3).
"The h% in its wisdom decided in a last year's ruling to locate the main T-G rMial to the contair:nent in any future nuclear power plants.
The main reason was the probability of turbine missiles hitting the containment and all the short-comings discussed earlier.
The rest of the world has done this for many years, aM this makes sense.
A special ex-ception was made for Offshore Power Systems.
Why? Since the probabilities of turbine failures on a FNP are greater than on land based plants, it is an absolute necessity, for our protection, to relocate the most dangerous equignent and largest missile producer, so as to reduce the probacility of missiles." (Effenberger's Testimony, Pages 5 and 6).
"If the T-G should go on the destructive overspeed then the largest piece ejecting the turbine casing will have a kinetic energy of 32 million ft. lbs. There is nothing on the present ENP which could contain or stop these missiles which in turn would penetrate all the structures, the shield building, the containment and the recctor vessel itself and in addition would puncture the hull aM sinx the plant.
What happens then, I will leave to your imagination."
(Effenberger's Testimony, Page 1).
302. Based on the discussion in the preceding paragraphs, the Board finds that Mr. Effenberger's allegations regarding turbine rotor deflection, previous ex;erience with rotor deflections, rotor stresses anS plant motion, rotor stresses and hull vibrations, corrienser vacuum load, bearings, the Shipping port failure, overspeed protection systems, plant motion arrl valves, arvi valve testing are not supported by the evidence. 'Iherefore, there is no basis for expecting that the probability of a turbine-missile-producing event is significantly different for land-based nuclear plants and ENPs.
454 1367
-135-
303. The guideline employed by the Staff in determining whether a postulated event needs to be a design basis event (for which specific Mditional protection is provided) are those events for which a realistic estimate of the probability of occurrence is greater than the order of 10~ / year and which could lead to potential consequences in excess of 10 CFR Part 100 exposure guidelines. (See StaMard Review Plan 2.2.3). Stated another way, turbine missile protection is deemed to be adequate if the probability for unacceptable consegaences (consequences in excess of 10 CFR 100 ex;osure guidelines) is found to
-6 be of the order of 10 / year for conservative evr_luations, or of the
~I order of 10 / year for realistic evaluations. Rese criteria, utilized in determining whether or not an event needs to be considered a design basis event or whether protection is adegaate, are not dependent upon whether the plant is land-based or floating. (Applicant's Testimony, Pages 16 and 17, Staff's Testimony, Pages 2,10 and 11, and Tr. 5369 through 5872).
204. De ENP has an offset turbine orientation. In response to a Board request at Tr. 4314 and 4315, the Applicant provided in Exhibit OPS-103 an example of the barriers that intervene between the turbine and safety related equignent.
fpecifically, Exhibit OPS-103 64Apolicant's Exhibit OPS-103, atnitted at Tr. 5121, consists of three sheets entitled, respectively, " Identification of Section Cuts,"
" Simplified Drawing Showing Significant Structures Between the Turbine and the Reactor Vessel," and " Simplified Drawing Showing Significant Structures Between the Turbine and Safeguards Area No.
2."
Applicant's Exhibit OPS-102, marked for identification at Tr.
4813, was not offered into evidence because Exhibit OPS-103, Sheet 1, provided the sane information concerning the EUP turbine orienta-tion vis-a-vis the containment (Tr. 5122 through 5124).
142
-136-.
/ 3[
J
illustrates the material and material thicknesses for barriers that intervene between the turbine and the reactor vessel ard the turbine and Safeguards Area No.
2.
(Apolicant's Exhibit OPS-103 and Staff's Testimony, Page 1).
305. The Applicant evaluated design overspeed turbine missile. This evaluation assumed the probability of generation of a
-4 turbine missile at design overspeed is 1 X 10 per year, based on a review of the Bush report.
(PDR Section 3.5.4.3 ard Applicant's Testimony, Page 17). Materials, manufacturing techniqaes and in-spection techniques have all substantially improved relative to those associated with the turbines included in the data base for the Bush 66 report (PDR Section 3.5.4.3 and Applicant's 'Ibstimony, Page 18). As an example, the WP turbine must meet the design, material toughness, and quality assurance provisions of Standard Review Plan 10.2.3,
" Turbine Disk Integrity" (Staff's Testimony, Page 30).
The Board
-4 therefore concludes that the 10 per year value for the probability of turbine missile generation at design overspeed is conservatively high when applied to the FNP.
65Bush, S.
H., Probability of Damage to Nuclear Comp 3nents to Turbine Failure," Nuclear Safety, Vol.14, No. 3, May-June,1973.
66The data base in the Bush recort incltdes 70,000 turbine years of operation frcra turbines manufactured fran the early to mid 1900's to approximately 1970 (PDR Section 3.5.4.3 and Arplicant's Testimony, Page 18).
$m:
Ri
-137-
/
306. Considering both high and low trajectory design over-speed turbine missiles, the Applicant canputed the probability of a missile, once generated, striking an essential safety system *w be on the order of 10~
This gives an overall probabil ty (the product of
-4 10 and 10-3), at design overspeed, of genera.ing a missila wat strikes an essential safety system on the order of 10-per year. (PDR Section 3.5.4.3.3 and Applicant's Testimony, Pcge 17).
Desig.1 Overspeed Turbine Missile Evaluation 307. Be lower half of each low-pressure turbine on the m'P contains a 4-1/2 inch thick steel missile shield exterding the entire blMed length of the rotor (Applicant's Exhibit OPS-103, Sheets 2 ard 3, PCR Sections 3.5.4.3.4.2 and 10.2.2.5, ard PDR Figurc 10.2-1B). The Applicant concities, based on calculations using the Hagg-Sankey formula (Tr. 5602, 5270, PDR Sections
- 3. 5. 8. 2.1), that a design overspeed turbine missile cannot perforate the missile shield (Tr.
5128, 5702). The Staff's conclusion was based on application of the BRL formula to the turbine internals and casing. Be Staff later advised the Board by letter dated December 15,1973 that subsecuent tests, which do not exactly siir.ulate the real situation for the n'P, have led the Staff to conclude that their use ci the BRL formula is not supported by the limited data available and the effe iveness of the 4-1/2 inch turbine missile shield now requires further evaluation.
The Staff also concluded that the FNP is adecuately protected bv the 4-1/2 inch thick steel missile shield against design oversoeed turbine 4N34 /
-136-
missiles ejected below the turbine floor (or centerline). The Board finds that a mi.ssile shield can and will be provided to effectively protect vital targets ard the hull bottm fra; design overspeed missiles ejected below the turbine centerline (PDR Sections 3.5.4.3.3.3 and 3.5.4.3.4.2 and Staff's Testimony, Page 34).
308. The Staff also evaluated design overspeed turbine missiles (SER Section 3.5.3, Staff's Testimony, Pages 1, 2, and 34 an$
Kiessel Affidavit).
The Board previously has considered protection against design oversoeed turbine missiles ejected below *he turbine floor (or centerline). For targets above the turbine floor, the Staff conclu5ed that 'the strike and damage probabilities for design over-speed missiles are less than the strike and damage probabilities for destructive overspeed missiles, the Staff evaluation of which is dis-cussed in Paragraohs 311 ard 312, infra. (Staff's Testimony, Page 34).
309. The Board firds that the probability, at design over-smed, of generating a turbine missile that strikes an essential safety system is sufficentlly stall to meet the Staff criteria, and that the WP design with respect to this matter is adecuate to protect the public health ard safety.
Destructive Overspeed Turbine Missile Evaluation 310.
The Apolicant evaluated destructive oversoeed turbine missile. This evaluation consists of a fault tree analysis of the F:;P ks 9
l
/t
-139-
turbine control and cierspeed protection system that was used to evaluate the probability of reaching destructive overspeed. Improve-ments in and increased redundancy of the RTP turbine overspeed protection syste'".s, relative to those associated with the machines inclu5ed in the data base for the Bush report were considered in the Applicant's fault tree analysis and reduced the probacility of destructive overspeed.
As discussed in Paragraph 294, supra, the rip turbine valves incorporate design chances to improve their relia-bility. Be probability of reaching destructive overspeed was cal-
~
culated by the Applicant to be on the order of 10 / year for the Rip. 0 Since the probability of even reaching destructive overspeed is on the order of 10' / year, the Applicant, in accordance with the Staff criteria, has excluded destructive overspeed from the FNP design basis.
(PCR Sections 3.5.4 and 3.5.4.4 and Applicant's Testimony, Pages 17 and 18.)
311. The Staff also evaluated destructive overspeed turbine missiles (Staff's Testimony, Pages 1 through 11, and SER Section 3.5.3).
Unlike the Apolicant, the Staff did not eliminate destructive overspead frr the design basis solely on the groun5s of a suffici-ently low probability of reaching destructive overspeed.
Rather, the
-5 Staff utilized a destructive overspead probability of 4 X 10 / year
-6
- or a conservative case and 4 X 10 / year for a realistic case. Be 67The actual valm calculated by the Applicqt as tne probability of reacnina destructive overspeed is 6 X 10 per year (PDR Section
- 3. 5.4.4. 2).
gJr
-140-
/g
Staff then computed the strike and damage probabilities to determine if the overall probability of missile generation, strike and damage met the Staff criteria referred to in Paragraph 303, supra. (Staff's Testimony, Pages 1 through 11.) The conservative value of 4 X 10- /
year is based on the data in the Bush report (Staff's Testimony, Page
-6 36, Tr. 5707, 5708 and 5827). Le valm of 4 X 10 / year is obtained by taking a factor of ten reduction in the destructive overspeed probability in view of the improved turbine overspeed protection system on the FNP (Staff's Testimony, Page 10).
312.
High trajectory turbine missiles were fouM by the Staff to be a snall contributor to the overall risk frcxn destructive overspeed turbine missiles.
Bus the Staff's destructive overspeed micsile evaluation was primarily with resoect to low trajectory missiles.
(Staff's Testimony, Pages 1 aM 2.) The Staff's analysis utiliced the most penetrating of the possible turbine missile (Staff's Testimony, Pages 3 aM 4). The seven foot thick concrete partion of the turbine support (denoted as structure "B" on Applicant's Exhibit OPS-103, Sheet 2,
and as structure "BB" on Sheet 3) provides sub-stantial protection to certain safety related areas of the FNP since a destructive overspeed missile cannot penetrate this barrier (Tr. 5128, 5699 and Staff's Testimony, Pages 4 and 8). The Staff concluded that the overall probability of unacceptable damace from a destructive
-6 overspeed missile is in the range of 10 (for the conservative case) to 10~
(for the realistic case), which is within the Staff criteria, Paragram 51, supra (Staff's Testimony, Page 10 and 11).
Acl
..) l l/
-141-
313. The preliminary design of the turbine mount and con-denser is set forth in Applicant's Affidavits I and II which were furnished in response to a Board regaect (See paragraph 256 supra).
Information contained in these affidavits did not change the Staff's earlier conclusion concerning the probability of generation of a micsile at both design and destructive overspeed (Kiessel Affidavit, Page 7).
314. Atlantic County witness Dr. Luchak asserted that if a large missile o.: curs in the "in-line"68 turbine orientation, very little can be done practically to alleviate the possibility of damage.
Dr. Luchak estimated, based on his review of the Bush report arri a paper by Swan and Meleis,69 that the probability of missile damage to the contaiment, given missile generation, is 0.25. (Luchak's Testi-mony, Page 4, and Page 5 as altered at Tr. 4332). Dr. Luchak's estimate and conclusion regardinc missile strike and damage did not take into account the correct orientation of the F'IP turbine vis-a-vis the contai= ent.
Rather, Dr. Luchak's evaluation was based on a tangential turbine orientation, which is quite different from the E'NPs offset turbine orientation as shown in Applicant's Exhibit OPS-103, 00The Board interprets "in line" to mean the turoine orientation depicted in Applicant's Exhibits CPS-100 and 101, which are taken from the Bush repart ax3 the Swan-Meleis paper, resoectively.
69' A Method of Calculating Turbine Missile Strike ard Damage Probabil-ities," by S.
W.
Swan and M.
Meleis, Nuclear Safety, 1975.
(Luchak's Testimony, Page 4).
<f t s 0 4 l4
-142-
Sheet 1.
(Tr. 4616.) In addition, Dr. Luchak's admitted that in reaching his conclusions, hc did not consider the rip snielding andother protection systems (Tr. 4820-4824).
The Board rejects Dr.
Luchak's conclusions regarding the probability of turbine missile damage because his evaluation was not based on the FNP turoine crientation and other design features of the RIP.
315. The Board fiMs that the probability of generating a destructive overspeed turbine missile that strikes an essential safety systems is sufficiently small to meet the Staff criteria, and that the FNP design with respect to this matter is adequate to protect the public health aM safety.
Turbine Orientation 316.
The Staff requires all plants to be Mecuately pro-tected against the effects of missiles that might result from equip-ment failures, in accordance with General Design Criterion 4 of Acpendix A tc 10 CFR Part 50 (Staff's Testimony, Page 41). Regulatory Guide 1.115 discusses low trajectory turbine missiles. Tae regulatory gosition set forth in this guide permits alternate means for providing protection agains low trajectory turbine missiles.
Turbine orienta-tion, or evaluation of turbine missile strike probabilities for essential safety systems to demonstrate that they are sufficiently low, are each acceptable means for providing protection against lov trajectory turbine missiles. (Applicant's Testimony, Page 18, and 6
-143-lT
Staff's Wstirony, Page 42).The Staff does not have any specific requirements on turbine-generator orientation with respect to the containment (Staff's 'Ibstimony, page 41).
317. Recent Commission action has included licensing of and-based plants with non-radial turbine arrangements for which the owners subnitted missile probability analyses. 0 ( Applicant's Testi-many, Page 19). 'Ihe Board therefore conc 1txSes that the FN? design considera*. ions for potential turbine missiles are in consonance with both current Staff criteria and recent licensing actions. Accordingly, there is no basis for Mr. Effenberger's statements that the F!G turbine orientation is unacceptable relative to Staff criteria or that the Comnission made a special exception for the pip design. Further, the Board finds incorrect Mr. Effenberger's assertion (Tr. 4110) that PIP size anS turbine orientation were dictated by the graving dock, crane and slipway dimensions at the Applicant's manufacturing f acility. Rather, the size of the plant dictated the crane size, the slipway, and the graving dock. (Tr. 5103-5104).
Applicability of the Bush Report Data 318. To some extent, both the Applicant's and Staff's turbine missile analysis utilize the data in the Bush report to estimate the probability of turbine missile generation (PDR Secticn 3.5.4.3, OSee, for example, Docket tios. 50-454,455sf56,546 an3 547.
JsY
-144-
Applicant's Testimony, Page 17, Staff's Testimony, Page 36, and Tr.
5707, 5708, 5712, and 5827). Atlantic County witness, Dr. Luchak, raised several cuesticas concerning the Bush data wnich are discussed below:
Turbine Aging Effect 319.
Dr. Luchak alledged that the Bush re prt incorrectly asse.es failures occur randomly, claiming that the failure rate would increase with time (with the age of the turbine).
Dr. Luchak alleged that, since the Bush data is based solely on turbines 20 years old, or less that the turbine failure rate over the 40 year design life of the FTG cannot be estimated fran such data. (Luchak's Testimony, Page 2).
320. The Acplicant testified ' hat in Table 3 of the Bush report the average service life of the plants listed was slightly over 18 years and about 43,000 of the total of approximately 70,000 turbine years listed correspond to turbines 20 years old or older (Tr. 4716, 5164 and 5165).
On cross examination, Dr.
Luchak agreed that approximately 60 mrcent of the total number of turbine years in Table 3 of the Bush report were data on turbines 20 years old or older (Tr.
4725).
321.
Dr. Luchak also claimed that a data point relevant to the variation of the failure rate over time was omitted from a table and graph in the Bush report (Tr. 5038 to 5040). However, the Board U/
-145-
finds that the data point described by Dr. Luchak as " missing" was, in fact, appropiately included (Applicant's Testimony, 5171 - 5176).
322.
Dr. Luchak admitted he had no direct evidence of a statistical nature or no facts related to actual turbine experience to support his contention that the turbine failure rate increases with time (Tr. 4760 and 4761). In response to a hypothetical question, Dr.
Luchak testified that if the turbine failure rate is higher in the early years than in later years, then the Bush analysis is conserva-tive (Tr. 4762 to 4763). Se Applicant's witnesses then supported the hypothetical by testifying that the turbine failures noted in the Bush report occurred early in the life of the turbines 1 (Tr. 5163 through 5166).
323. 'Ihe Staff's witnesses testified that it was not neces-sary to adjust the Bush data for " turbine aging effects" because the Bush reprt included turbines of various ages and therefore, intrin-sically included any such effect (Tr. 5708).
324. The Board therefore finds Dr. Luchak's criticism of the Bush rep rt witn respect to " turbine aging effect" to be invalid.
71Tne Applicant testified that of the turbine failures reprted by Bush, one turbine failed at 5 years, 11 months, one failed at 4 years, 4 months, and the remainder, with the exception of one f ailure for wnich the Applicant was not able to obtain this in-formation, "-jled at 2 years or less (Tr. 5163 through 5165).
e I48
-146-
Turbine Size Effect 325.
Dr. Luchak alleged in his written testimony that the Bush data is predminantly representative of small turbines less than 100 megawatts, thereby making its direct applciation to the much larger FNP turbine questionable, since according Dr. Luchak, larger turbines would have increased stresses, decreased safety factors and increased chance of corrosion failures.
326.
Dr. Luchak, on cross examination, sdmitted that ha is not an expert with respect to scaling of turbine size ard the rela-tionship tetween scaling and resultant stresses (Tr. 4520). In contra-diction to his written testimony, Dr. Luchak on cross examination admitted that stresses may not increase as the physical size of a tur-bine increases (Tr. 4522), and in further contradiction stated that for purposes of his testimony he did rot issume that stresses increase ard safety factors decrease with increasing turbine size (Tr. 5009).
Accordingly, Dr. Luchak's assertion that the Bush data are not appli-cable to the FNP turbine, because such data are based prirarily on turbines of less than 100 m, is not supported by the record and is rejected by the Board. The Board previously has found several aspects of ENP turbine design (see Paragraphs 263, 286, 294, 305 ard 310, supra) which make application of the Bush data to the FNP turbine conservative.
149
-147-
Alleged Bush Report Data Qnissions 327.
Dr. Luchak originally calculated that the lack of any failures from 1961 to 1969 (as reported by Bush) had odds against it of 20 to 1 (Luchak's Testimony, page 2). The method used by Dr. Luchak in this calculation was incorrect (Tr. 5170). Subsequently, Dr. Luchak
.mrformed other calculations, using a revised method, and revised his previously calculated odds to 15 to 1 (Tr. 5035-5036, 5170).7
Dr.
Luchak claimed that those high odds support the hypothesis that not all data were re.arted by Bush. H2 wever, Dr. Luchak's revised cal-culation, which gave the a3ds of 15 to 1, improperly utilized ten turbine f ailures rather than seven missile producing c' lures.
Acplicant witness, Dr. Shaffer, stated that if Dr. Luchak's revised test had been properly performed utilizing the seven missile producing failures, the resulting odds would be about 3.5 to 1 (Tr. 5168-5171).
Dr. Shaffer also performed an inSependent calculation and concluded that the correct cdds were approximately 3 to 1 (Tr. 5166). Dr. Luchak agreed (Tr. 4751-4752) that odds of 3 to 1 do not supcort his hypo-thesis that data were anitted by Bush (Tr. 5168-5171; Exhibits ACCCE 5B and SC).
2Dr. Luchak's calculation of the 15 to 1 odds is contained in Exhibit ACCCE-5B and 5C, admitted at Tr. 5087.
{M t
-148-
/
323.
Dr. Luchak also implied in his direct testimony that the Bush data did not include testpit turbine failures (Luchak's Testi-mony, Page 3). However, on cross examination, Dr. Luchak admitted that factory test failures were included in the Bush data (Tr. 4801-4807).
329.
Further, as part of his testimony concerning test pit f ailures, Dr. Luchak stated his urderstanding (although he was not sure) that the NP turbine would rot be factory tested. (Tr. 4537a and 4538). The Applicant, however, testified that the factory testing to be performed by Westinghouse on the mP will be the same as that which is performed on any land-based turbine (Tr. 5198).
Ginkley Point Failure 330.
Dr. Luchak stated that the nuclear plant turbine at Hinkley Point produced a missile.
Assmiing the Bush estimate of 10 / year for the probability of turbine missile generation, and 73Dr. Luchak's pre-filed testimony stated that at least two nuclear plants experienced turbine failures which produced missiles, Hinkley Point and Shipoingport (Luchak's Testimony, Page 3).
Dr. Luchak subsequently irdicated he really did not know if Shippingport produced a missile (Tr. 4331, 4332, and 4527).
The Applicant's Testimony, at Page 10, irdicates no external missiles were generated by the Shippingport incident.
Dr. Luchak revised his testimony on the assumption that Shippingport did not produce a missile (Tr. 4543 and 4544). Due to an oversight, the odds of 40 to 1 on the 7th line of page 3 of Dr. Luchak's pre-filed testimony were left unchanged.
Howaver, it is clear to the Board that, in light of the ocher changes given by Dr.
achak at Tr. 4543 and 4544, the 40 to 1 cx3ds must change in a like manner, to 20 to 1.
$s fY
/n)
.v
-149-
considering the nuclear plant turbine subclass, Dr. Luchak calculated the odds against occurrence of the Hinkley Point failure as 20 to 1.
Dr. Luchak infered that because of these high odds, the actual probability of missile generation is higher for nucearl turbines than
-4 the Bush estimate of 10 / year. (Luchak's Testimony, Page 3).
331. The Hinkley Point failure was evasidered in the Bush re;rrt but was excluded from the data us. J by Bush in his estimate of turbine missile probability. Bush exclu5ed the Hinkley Point turbine because improvements have been made in turbine materials which would prevent the type of failure experienced at Hinkley Point frcra occur-ring again (Tr. 5179).
331. 'Ihe Board finds that Dr. Luchak's use of the Hinkley
-4 Point failure to test the validity of Bush's 10 / year turbine missile probability to be impr oper because the Hinkley Point turbine is atypical of the population of turbines for which Dr. Bush estimated the probability of missile generation.
Luchak's Missile Generation Probability 333.
Dr. Luchak calculated, as an alternative favored by him over the Bush probability, a probability of turbine missile generation of 2 X 10 3/ year as a " base" value. He then applied a factor of 2 for decreasing reliabili'; with age, a factor of 2 for decreasing reli-ability with scale, and a factor of 2 for a tw unit EUP installation,
$a; C
/^
-150-
giving a resulting probability of 1.6 X 10 ~/ year for a two unit RF site (Luchak's Testimony, Page 3: Tr. 4386, 4543 - 4544).
334. With respect to such applied fac. ors, the invalidity of decreasing realiability with age is addressed in Paragraphs 319 through 324, supra. 'Ihe absence of sucport in the record for d&
creasirs reliabilig with size is addressed in Paragraphs 326 and 327, sucra. In addition, Dr. Luchak's application of the " size factor" of 2
-3 ta his " base" probability value of 2 X 10 / year is not proper because
-3 the valm of 2 X 10 / year is already based on the subclass of nuclear plant turbines, over half of which are 400 megawatts or larger. (Tr.
5166 - 5167).
-3 335.
Dr. Luchak's " base" value of 2 X 10 / year was obtained by dividing the one nuclear plant turbine miisile producing failure (Hinkley Point) by an estimate of 500 nuclear plant turbine years (Tr.
4555). It is not proper to utilize the Hinkley Point failure to predict the probability of FNP turbine #ailure because current turbines, includire the RTP turbine, utill:e improved materials to prevent such a failu e (Tr. 5179 - 5181).
336.
The Board therefore firds that Dr. Luchak's estimate of the probability of turbine missile generation for the FNP turbine is not correct. The l'oard further firds that the data in the Bush repart were properly utilized by the Applicant and Staff in estimating the probability of turbine missile generation for the FNP.
4"614
,lQ
-151-
Conclusions 337.
In summary, the Board concitdes that the ENP design features. with respect to ptential turbine missiles are adequate to protect ti.e public health and safety, and the allegations raised by Mr. Effenberger aM Dr. Luchak are without merit.
L.
CDNTENTION XII - EFFECT ON BIOrA ACCE Contention 3a:
"Subpart 3a contends that the Applicant has not given adequate consideration to adverse effects on the aquatic biotn fran the thermal p1trne, from radioactive liquid dis-charges, aM from entrairrnent."74 338. On this contention, both Applicant ard Staff presented oral testimony.
No written testimony was presented.
None of the intervenors presented witnesses, testimony or other information.
A hearing session with regard to this contention was held on April 4, 1979, and the testimony appears at Transcript pages 7269-7277 and 7370-7374.
339.
Tne Environmental Report (ER) aM the Final Environ-mental S*.atenent (FES) extensively discuss aM give consideration to 4Admitted as interpreted by Board Order dated May 21, 1974, p. 5.
454 1 54/
-152-
adverse effects on the agaatic biota from the thermal plume, from rMioactive liquid discharges, ard from entrainment and impingement.75 340. The Applicant and the Staff testified that adequate consideration was given to the matters raised by this contention. (Tr.
7269-7277 and 7370-7374).
341. The Board finds that adequate consideration has been given to adverse effects on the aquatic biota frca the thermal plume, from radioactive liquid discharges, and from entrainment.
M.
CO7TENTION XIII - DISCHARGE OUTFALL ACCCE Contention 3b:
"Subpart 3b asserts that the Applicant has not given adequate consideration to the functional design of the discharge 'utfall." 6 SThe Applicant sdmitted " Identification of the Evidence of the Apolicant (49)" cn March 23, 1979.
The NRC Staff submitted its identification of evidence in a letter to the Board on March 23, 1979. These s'dnittals identify the specific sections of the ER and the FES wilere wese topics are considered.
76Admitted as interpreted by Board Order dated May 21, 1974, p. 5.
434 iSf-
-153-
342. On this contentica, both Applicant and Staff presented written and oral testimony.I None of the intervenors presented testimony or other information. Hearing sessions with regard to this contention were held on July 12, 1976 and the testimony appears at Transcript pages 6984-7008 and 7015-7021. 8 343. The function of the discharge outfall is to disperse the heat of the cordenser cooling water. Be discharge outfall must be designed for each specific site by the owner, taking into considera-tion the environment 1 aspects of that site (Applicant's Testimony, Page 1).
344. A generic evaluation of discharge outfalls and their characteristics was performed by the Applicant aM by the Staff.
Estimates of expected dilution for different types of subnerged and surface single port discharges ard multiport discharges were cal-culated. ( Applicant's Testimony, Page 2).
The Applicant's written testimony, Exhibit No. OPS-47, entitled
" Applicant's Testimony Regarding XIII. Functional Dasign of Dis-charge Outfall" was aimitted at Tr. 6988 (7/12/78). We witnesses sponsoring this testimony were Dr. Jchn Nutant, Mr.
P. Blair Haga ard Dr. John Edinger (Profescional Qualifications aimitted at Tr.
609, 1024 and 6986 respectively). The Staff's written testimony entitled "Sunplemental Testimony of Staff in Response to ACCCE Contention 3b" by Howard F.
Bauman was admitted at Tr. 7018.
(Professional Qualifications of Mr. Bauman were admitted at Tr.
7016).
78Applicant witnesses were examined by counsel for the State of New Jersey, the Staff ard the Board. The Staff witness was examined by the Board.
11 t,
U4 l%
Cf
-154-
345. 'Ibe temperature rise from the thermal plune at the shoreline for an FNP sited offshore is expected to be less than 1.5 F (Ac;..icant's Testimony, Page 3). 'Ihe natural diurnal water temperature change along the coastal regions of the Atlantic and Gulf coasts ranges from less than 2 F to 9 F (Applicant's Testimony, page 3).
346.
Since the cooling system for a shoreline-sited FNP is indistinguishable fram the system for a lard-based plant at the same site, there do not appear to be any aspects of shoreline FNP discharge design that would be unique to ENP's or different from the state-of-the-art (Staff's Testimony, Page 3).
347.
FES II considered the effects of tidal, wind-driven and littoral currents. The effect of tidal currents is significant only as to the ptential for recirculation. Analyses indicate that for most tidal currents there will be no significant recirculation. In addi-tion, net drift dm to wind driven or littoral currents would reduce the potential for recirculation. Further, recirculation can be minimized by utilizing a subnerged discharge rather than a surface discharge. (Apolicant's Testimony, Page 2).
348. 'Ihe analyses in the ER II, Supplement No. 2 and the FES II irdicate that temperature variations that might be caused by an FNP discharge offshore are expected to be lost within the natural diurnal temperature fluctuations of the coastal regions ( Applicant's Testi-mony, Page 4).
454 157
-155-
349. The detailed outfall design will be performed by the owner of an FNP (Applicant's Testimony, Page 1). The Board agrees with the finding of the.'taff that any of several discharge outfall designs could be used for an offshore-sited EUP (Staff's Testimony, Page 2).
The Board also agrees with the j tdgment of the Staff that, within present technology, an ENP cwner wuld be able to select an adequate cooling water cordenser discharge design for a shoreline-sited EUP (Staf f's Testimony, Page 3).
350. 'Ihe Board firds that zdequate consideration has been given to the functional design of the disebarge outfall.
N.
CO MENTION XIV - FOOD CHAIN ACCCE Contention 3c:
"Subpart 3c asserts that the Applicant has not given adequate consideration to the cumulative effects of radio-plankton through htnans."g (sic) active substances ingeste along the food chain from 351. On this contention, both Applicant and Staff presented oral testimony. No written testimony was presented. None of the intervenors presented witnesses, testimony or other information.
A hearire sc.ssion with regard to this contention was held on April 4, 1979 and the testimony appears at Transcript pag:s 7269-7277 and 7370-7374.
79A r.itted as interpreted by Board Order dated May 21, 1974, pp. 5, 6.
45'4 lJ8 c
-156-
352. The Environmental r eport (ER), tbe OPS Topical Paport No. 22A60 (Exhlbit OPS-65) a:d the Final Ent ironmental Statem7nt (FES) give consideration to the cumulative effects cf r adicactive substar;ces ingested along the food chain from plankton through humans. 1 353. 'Ihe Applicant and the Staff testified that adequate consideration was given to the matters raised by this contention. (Tr.
7264-7277 and 7370-7374).
354. The Board finds that adegaate consideration has been given to the cumulative effects of rMioactive substances ingested along the tood chain from plankton through humans.
O.
CONT!2EION XV - DREDGING ACCCE Contention 3f:
"Subpart 3f asserts that the Applicant has not given adequate consideration to the inpact on the aquatic biota that will be caused by dredging within the breakwater aM near its perimeter."82 80Exhibit OPS-65 was Mmitted into evidence at Tr. 7266.
81The Applicant subnitted " Identification of the Evidence of the Apolicant (#9)" en March 23, 2979.
The NRC Staff subnitted its identification of evidence in a letter to the Board on March 23, 1979. 'Ihe subnittals identify tne specific sections of the ER, the OPS Topical Report and the FES where these topics are considered.
82A nitted as interpreted by Board Order dated May 21, 1974, p. 6.
4.9..
-157-
/ 3,
355. On this contention, both Applicant and Str ff presented written ard oral testimony.83 None of the intervenors presented witnesses, testimony or other information. Hearing sc3sions with regard to this contention were held on July 12, 1978 ard the testimony appears at Transcript pages 7021-7032 and 7033-7041.
356. Consideration of the impact on the acuatic biota that will be caused by dredging within the breakwater and near its per-imeter has been given in both the ER II, Section 4.3.1 (Pages 4-7 to 4-11), and Section 5.7 (Page 5-81) and in FES II, Section 5.4.1.3 (Pages 5-9 to 5-12), Section 6.11.2.2 (Page 6-81) and Section 11.3 (Pages 11-4 and 11-5).
357. Bis contention concerns maintenance dredging since the contention assumes exi:tence of the breakwater (Staff's Testimony, Page 1). Dredging within the breakwater wuld be undercaken only if 83The Applicant's written testimony, Exhibit No. OPS-46, entitled
" Applicant's Testimony Regarding XV. Dredging" was admitted at Tr.
7025 (7/12/78). We witnesses sponsoring this testimony were Dr.
John Nutant, Mr.
P.
Blair Haga, ard Dr. Gerald J.
Lauer (Pro-fersional Qualifications admitted at Tr. 609, 1024 and 7023 respectively). Tne Staff's written testimony entitled " Supplemental Testimony of NRC Staff in Response to ACCCE Contention 3f" by Dr.
Richard B icLean ard Dr.
S.
Marshall Adams was admitted at Tr.
7037. (Praassional Qualifications of Dr. McLean ard Dr. Marshall were admitted at Tr. 7034 and 7035 respectively.)
04Applicant witnesses were examined by the Staff and the Board. We Staff witnesses were examined by the Board.
A t
-158-
significant sedimentation occurs. The dminant parameters that will affect the amount of sediment deposited within the breakwater incitrie the location of the FNP, the amount ard type of susperded solids, entrances to the basin and the neight of the entrance cills, the voltraetric flow of cooling water, and the circulation pattern within ard i: mediately o: tside the basin. (Applicant's Tcstimony, Page 2).
358. Dredgirg within the breakwater may cause destruction of all benthic organisms involved. A total loss of all benthic organisms was asstned and is listed as an erwironmental cost in the FES II, Table 5.8.1 (Page 5-24) and in the cost-benefit evaluation in Section 11.3 (Pages 11-4 and 11-5). Such loss is considered not to be a sig-nificant environmental impact because of the relatively small arer, affected. (A;plicant's Testimony, Page 2).
359. Should dredging near the outer perimeter of the break-water be required, the area of impact is expected to be less than or of the same order as the site area of approximately 100 acres. The loss of benthic organisms due to suc'1 dredging also is considered not to be a significant environmental impact because of the relatively mall area affected. (Applicant's Testimony, Page 2).
360. Paintenance dredging is feasible for any breakwater design (Tr. 7031). The impact on aquatic biota from maintenance dredging is not expected to be significant because of the relatively mall area affected (Applicant's Testimony, Page 2).
I;' C s V
/ 'b O
-159-
361. The Board finds that adecuate. consideration has been given to the impact on the aquatic biota that will be caused by maintenance dredging within the breakwater and near its perimeter.
P. CON'ID7FIW XVI - IMPACT ON RESORT ECONOMICS Atlantic County Contention 1:
"This contention asserts that fears of a nuclear acciderc.
can have impact on resort economics by frightening vacation and leisure seekers from going to resort areas in proximity to floatirg nuclear generating stations.
This contention does not contest whether these fears might La technically justified but is limited to the effects of these fears, justified or not, on the resort communities.,,85 362. On this contention both Applicant ard Staff presented written and oral testimony.86 Intervenor Atlantic County presented 85Admitted as interpreted by Board Order dated April 15, 1974,p.8.
0The Applicant's written testimony, Exhibit No. OPS-44, entitled "Acplicant's Testimony Regarding XVI. Impact on Resort Economics,"
was admitted at Tr. 6242.
The witnesses sponsoring this testimony were Dr. John A. Nutant and Messrs. P. Blcir Haga, K. T. Mao and Dr.
Dennis S.
Mileti (Professional Qualifications admitted at Tr. 609, 1024, 6230 and 6232, respectively).
The Staff's written testimony entitled " Supplemental Testimony of NRC Staff in Response to Atlantic County Contention #1 (concerning impacts on tourism) " by Loui:3 M.
Bykoski, Donald P.
Cleary, Earl J.
Baker and Steven G.
West; and " Impact of Offshore Nuclear Generating Stations on Recreational Behavior at Adjacent Coastal Sites" by E. J. Baker, D.
J.
Moss, S. G. West and J.
K. Weyant which follows Tr. 6715, was admitted at Tr. 6715.
The Staff's testimony was sponsored by Drs.
Baker, West and Bykoski and Mr. Cleary.
(Professional Qualifica-tions of Drs. Baker, West ard Mr. Cleary were admitted at Tr. 6707.
Professional Qualifications of Dr. Bykoski were Ef:nitted at Tr.
6710).
4 p
-160-d
written and oral testimony.0 No other intervenor presented wit-nesses, testimony or other information.
Hearing sessions with regard to this contention were held on May 17, 18, 19 and 20, 1977 and Ju]y 10 and 11, 1978. Le testimony appears at Transcript pges 6226-6260, 6261-6374, 6375-6529, 6668-6691, 6692-6790 and 6791-6974, respectively.00 363.
Investigations were made by both the Applicant and the staff to determine the impact of the presence of nuclear reactors on the resort-oriented economy of coastal communities located near operating nuclear plants (Applicant's Testimony, Page 1 and Staff's Testimony, Page 7).
364. We Applicant investigated economic characteristics of three resort-oriented ccx:Taunities near coastal commercial nuclear pwer plants in the United States.
te Applicant also conducted on a qualitative basis investigations of several coastal resort cocmunities in proximity to coastal nuclear power plants.
(Applicant's Testimony, Pages 1, 2 and 7).
87Written testimony of Intervenor, Atlantic County, entitled "Testi-many on Behalf of Atlantic County Regarding Atlantic County's Contention #1" by Dr. Marshall E. Irvine, was atnitted at Tr. 6814.
(Professional Qualifications of Dr. Levine were admitted at Tr.
6808).
88Applicant witnesses were examined by counsel for Atlantic County Citi:: ens Council on Err /ironment (ACCCE) and Atl&ntic County.
Staff witnesses were examined by Counsel for Atlantic County, the State of New Jersey and the Board.
Intervenor witness was examined by counsel for the State of New Jersey, the Applicant and the Staff.
A c-nob f
-161-
365. 'Ibe Staff undertook an investigation to determine if any changes in usage of water-oriented recreational facilities could be attributed to the existence of a nearby operating nuclear power plant.
Ten nuclear plants having nearby water-oriented recreational facil-ities used by tourists were selected for analysis.
(Staff's % stimony Paces 8 and 9). Three of these 10 nuclear plants are the same as those w
investigated by the Applicant ( Applicant's hstimony, Pages 1, 7 and Staff's Testimony, Pages 9 and 10).
366. A study under Commission contract using survey research methcds was corducted by Professors 3aker and West of Florida State University to estimate the pssible reaction of tourists and leisure-seekers to siting of an offshore nuclear generating station near resort areas (Staff's Testimony, Page 2).
367 An investigation by the Applicant also was made to determine the impact of the presence of nuclear weapons testing at the Nevada Test Site on the resort economy of nearby Las Vegas, Nevada.
This latter investigation was prformed on the basis that the situa-tion in Las Vegas is analogous to other resort communities wtien considering whether the presence of nearby nuclear operations will adversely impact tourism.
(Applicant's Testimony, Page 1).
358.
In 1975-76, resec.shers from Oak Ridge National Labora-tory studied the socioeconcraic effects of operating reactors on two f
F*
l b
-162-
cat = unities : 09 the town of Plymouth near Boston Edison Company's Pilgrim Nuclear Povar Station aM the town of Waterford near Northeast Utilities' Millstone Nuclear Power Station (Applicant's Testimony, Page 2).
369. 'Ihe Pilgrim Nuclear Power Station Unit 1 is located in the Ca =onwealth of Massachusetts, near the town of Plymouth.
Unit 1 is a 670-megawatt net electrical output reactor.
Unit I received its construction pennit in 1967 aM went into connercial operation i.n June 1972.
At the time the testimony was presented, the proposed Unit 2, an 1180 MNe reactor, was undergoing licensing review for a construc-tion permit.
Pilgrim 1 occupies a 517-acre site within the town of Plynouth, Massachusetts on the shores of C w Cod Bay about 35 miles south of Boston.
( Applicant's Testimony, F > s 2 and 3).
370.
"he Pilgrim Noclear generating station has been the subject of substantial controversy and publicity.
"he proposed Unit 2 caused further controversy and continued to draw public attention to the Pilgrim site.
(Applicant's Testimony, Page 4).
89" Socioeconomic Effects of Operating Reactors cn Two Host Communi-ties: A Case Study of Pilgrim aM Millstone", Elizabeth Peelle, presented at Atomic Industrial Forum Symposium, State-of-the-Art of Socioeconanic Impacts Associated with Construction / Operation of Energy Facilities, January 17-18, 1977 (hereinafter referred to as the Oak Ridge StMy) (Applicant's Testimony, Page ll).
y' Y
-162-
371.
In the summer months, a large influx of seasonal visitors reside in the Pilgrim are', attracted by its many tourist and recreational facilities.
Pilgrim 1 has an overlook where people can view the plant aM also has a shore-2ront area Mjacent to the plant where pople picnic and fish.
'Ihis area opened in April 1972, ara! is open frcra April throtsh Novetber.
The annual average attendance is approximately 75,00's with a pak day atteMance of 3,000 visitors.
(Applicant's Testimony, Page 3).
372.
Forulation growth is an indicator of growth in tourism in a resort econcray (Tr. 6313, 6314, 6318 and 6319).
373. With respect to P1pouth, the economic growth trend as reported in the Oak Ridge study showed that, af ter growing slowly and steadily during the 1950 's and 1360 's, Plymouth suddenly underwent explesive growth beginning in 1968 when construction of the Pilgrim I station began. ( Apolicant's 'Iestimony, Page 3).
374.
The Millstone Nuclear Power Station, Units 1 and 2, is located near Waterford, Connecticut. Unit 1 is a 652 and Ur.it 2 is an 828-megawatt net electrical output reactor. Unit 1 received its construction prmit in May 1966 and went into comercial operation in December 1970. Unit 2 received its construction permit in December 1970 and went into commerical operation in October 1975. (Applicant's Testimony, Page 3).
4S4 166
-164-
375. As reported in the Oak Ridge study, Waterford's growth has been relatively gradual.
It was noted in the sttdy that this gradual growth was due primarily to restrictive zoning ordinances.
However, land values have experienced sharp increases. ( Applicant's Testimony, Page 5).
376. Bere are two resort-oriented cor:raunities located in cloe proximity to the Millstone Nucleat Power Station.
New I4 Mon
'has beaches and emusement parks.
East Lyme, which averages over 250,000 tourists per year, has an unobstructed view of Millstone 1.
Three miles east of the plant is the Harkness Memorial State Park with 235 acres available for swiming, boating and fishing.
Five miles west is the R 7ky Neck State Park with 560 acres available to the general public.
n?2 rage annual attendance for the two parks is between 500,000 to 600,000 visitors.
(Applicant's Testimony, Page 4).
377. As reported in the Final Environmental Statement for Millstone 1, the area around Millstone Point is a favored sport fish-ing site, ard pleasure boating is another major fom of recreation in the area. (Applicant's Testimony, Pages 4 and 5).
378. Also reported in the Oak Ridge sttdy were the results of an attitude survey corducted in the sumer of 1975 on the residents of Plymouth and Waterford.
Those sampled expressed satisfa: tion with their comunity in general. De conclusion reached in the survey with respect to tourism was that tourism is little affected by the pres 2nce
$a4s 6f
-165-
of the nuclear pwer plant in either comunity. There is no evidence to suggest that the presence of nuclear power plants has had any edverse impact on the resort econcray of communities near the Piladm and Millstone nuclear plants.
In fact, the data show that nearby canunities enjoyed sustained econanic growth.
(Applicant's W stimony, Page 5).
379. Se Applicant also examined certain economic data on comunities near the Oyster Creek Nuclear Generating Station.
Oyster Creek is 1650-megawatt net el ctrical output reacter. A construction permit was issued in Decer2er 1964. The plant first produced electric pwar in 1969.
L'=ediately adjacent to the Oyster Creek plant is the site of Fcrked River Nuclear Power Stat'on, Unit 1, a ll68-megawatt net electrical output reactor. A construction parmit was iusued for Forked River 1 in July 1973 aM the plant is urder construction.
( Applicant's Testimny, Pages 5 ard 6).
380. ne site location of Oyster Creek in Ocean County, New Jersey is part of the New Jersey shore area.
te area serves as a favorite su:mer place for vacationers from New Jersey and the sur-rounding states. Saltwater fishing, boating, waterskiing, and bathing a;e popular pastimes in the area.
(Applicant's Testimony, Page 6).
181. Both the Oyster Creek and Forked River nuclear plants encountered considerable controversy.
Extensive anti-nuclear matters
5 4' i68'
-166-
have been frequently reported ard given prcxninent attention in the local and regional press.
(Applicant's Testimony, Page 6).
382. A review of the demographic data of New Jersey discloses that while some areas have lost residents at a high rate, Ocean County leads all other New Jersey counties in population growth and posted the largest migration of people into the area between 1970 and 1975.
Large nunbers of new housing comunities, for sunmer and permanent living, are continually being established in the County. (Applicant's Testimony, Pages 6 and 7).
383.
Based on information concerning the demographic charac-teristics of the ccmnunities near the Oyster Creek plant, there is no evidence to suggest that the presence of this nuclear power plant has had any aaverse impact on the resort econcxny of nearby ccanunities.
In fact, the data show that Ocean County has experienced spectacular growth.
(Apolicant's Testimony, Page 7).
384. The Applicant also conducted investigations on a qualitative basis of other coastal resort communities in proximity to several coastal nuclear power plants.
The plants incltded:
Florida Power ard Light Ccrnpany's Turkey Point Plant (Units 3 and 4, com-mercial operation 1972-73), Maine fankee Atomic Power Company's Maine Yankee Plant (comercial operation 1972) and Southern California Edison Ccrnpany's San r ert Plant (Unit 1, comercial operation 1968).
In no case was
- 7 W ication that the economy, particularly the 4O n
-167-
tourist economy, of nearby co:r:nunities was adversely af fected.
(Applicant's hstimony, Pages 7 ard 8).
385.
In the spring of 1976 the Staff undertook an investiga-tion to determine if any changes in usage of water-oriented recrea-tional facilities could be attributed to the existence of a nearby operating nuclear ;ower plant. nn locations having water-oriented recreational facilities used by tourists were selected for analysis.
Between five and thirteen government (local, state and federal) officials ard representatives of local business were interviewed at each location. 'I5ese irdividuals were chosen because of their know-ledge of local tourism ard recreational activities. The interview was structured to: develop information on recreation and tourism activity ard trerds in the vicinity of the plant; draw out information which might indicate impact, positive or negative, of the plant on tourism ard recreation; ard finally elicit the respordents' personal opinion concerning plant impac ts. This study was updated with followup interviews during May/ June 1978. (Staff's Testimony, Pages 8 and 9).
386. The ten nuclear power plant locations investigated by the Staff were Brunswick (Units 1 and 2), Cook (Units 1 and 2), Hadden Neck, Irdian Point (Units 1, 2 ard 3), Maine Yankee, Millstone (Units 1 and 2), St. Lucie, San Onofre, Three Mile Islard (Units 1 and 2) and "icn (Units 1 and 2) (Staff's Testimony, Pages 9 ard 10).
s.
/75
-168-
387. Nu:nerous officials interviewed by the Staff at each of the ten plant locations said that the nuclear plant (s) in their areas had no discernible impact on tourism or recreational activity in their vicinity. In most cases there has been a continuing growth in sumer populations aM tourism in these areas. Many officials interviewed by the Staff felt the nuclear plants' visitor's centers psitively influenced their tourism industry. Cook and Maine Yankee, for in-stance, are advertised in local tourist pamphlets and officials credit them with drawing nore visitors to the sicinity. (Staff's Testimony, Pages 10-32).
388. The Staff contracted with the Florida State University for the services of Drs. Earl J.
Baker aM Stephen G. West, aM a research team under their direction, to apply survey research techniques aM thecry, drawn fran several areas of the behavioral sciences, to the question of potential tourist behavior in the vicinity of B'P's (Staff's Testimony, Page 33).
389. Using the estimates of net tourist avoidance developed by the Caker & West study, the Staff computed the impact on the local economy.
These computations were made with the assistance of the regional econanic and demographic forecasting capability of the U. S.
Dapartment of Canmerce.
Baseline economic forecasts were first adjusted to account for the contribution of plant operation to the local economy.
This forecast was then adjusted ta account for the loss in tourisn activity. The net calculated impact on total earnings gJQ ta
/,f
-169-f
of each area frcrn siting an FNP at the mid-point along each beach was found by the Staff to be less than one percent. (Staff's Testimony, Page 64).
390. Using what the Staff considers to be very conservative assumptions, the potential impact of an FNP on a local economy was found to be very small and well within the year to year fluctuations in local econcrnic activity as well as within the band of measurement error (Staff's Testimony, Page 64).
391. An investigation was by the Applicant made to determine the impact of the presence of nuclear weapons testing at the Nevada Test Site on the m;,4 t economy of nearby Las Vegas, Nevada (Appli-cant's Testimony, Page 1).
The presence of nearby nuclear operations to a resort area make Las Vegas, Nevada analogous to a resort com-munity having a nuclear plant nearby (Tr. 6256 and 6410).
392. Since 1951, the federal government has b en corducting nuclear weapons tests at the Nevada Test Site about 65 miles northwest of Las Vegas, Nevada. As of the date of the testimony, a total of 473 announced tests had been conducted and tests are continuing. Prior to 1963, 84 of these tests were surface detonations. The flash from some of these surface detonations was visible in Las Vegas.
Since 1963, all tests have been corducted underground.
The shock waves from the larger undergrourd tests are felt in Las Vegas. ( Applicant's Testi-mcny, Page 8).
454 1g
-170-
393.
Since the inception of nuclear weapons testing in the late 1940's, considerable local and national controversy concerning its hazards has been reported in the media.
Between 1966 and 1970, the late Howard Hughes raised serious opposition to coMucting nuclear weapons testing near Las Vegas and expended considerable money to wage a campaign against the Nevada Test Site operations.
(Applicant's Testimony, Page 9).
394. Despite the presence of nuclear weapons testing near Las econcrny has flourished.90 (Applicant's Testimony, Vegas, its resort Pages 9 and 10).
395.
Dr. Marshall E. Levine testified on behalf of Intervenor Atlantic County on this Contention. Dr. Levine utilized a newspaper advertisement along with followup parsonal interviews anS letters in an attempt to exanine the fears held by the citizens of Atlantic County concerning the proposed siting of an ENP off the coast of 90The number of visitors to Las Vegas increased frc a about 6.8 million in 1970 to 9.8 million in 1976, at an annual average rate of about one-half million visitors.
Be number of persons employed in the resort industry increased frcrn about 12,000 in 1958 to about 44,000 in 1974, en average annual growth rate of about 8.5 percent.
We number of hotel roczns in Las Vegas increased frcrn about 4,800 in 1954 to about 18,000 in 1974, an average annual growth rate of about 9 percent.
The number of motel rocrns increased from about 3,700 in 1954 to about 14,000 in 1974, an average annual growth rate of about 5.8 percent.
Gross gaming revenues (calculated in 1967 dollars) increased frcrn about $69 million in 1954 to about $465 million in 1974, an average annual growth rate of about 10.8 percent. (Appl-icant's Testimony, Page 9).
l,
-171-
Brigantine, New Jersey. (Atlantic County's Testimony, Page 1). During cross examination of Dr. Levine, the Applicant established that his study had no external validity and questionable internal validity.
(Tr. 6967 and 6969).
396. External validity refers to the extent to which findings can be generalized beyond the particular people studied to a broader group of people (i.e.,
extrapolated from the sample to the total population) (Tr. 6967).
Dr. Levine testified that his survey had no external validity (Tr. 6857). His sample was biased because it only reached members of the county who read the newspaper and because the people who responded to the newspaper a5vertisement decided if they would be included or excluded in Dr. Levine's study rather than him selecting them (i.e., the sample was self-selected). In addition, Dr.
Levine did not know if one person or one group sent in more than one response. (Tr. 6858-6861). Accordingly, the findings in Dr. Levine's study cannot be generalized beyond the particular people who responded to the survey.
397.
Internal vallidity refers to the extent that a particu-lar survey provides answers to that which the researcher desires to measure concerning the sample surveyed. If a study lacks internal validity, there is no basis to concltrie that what the sttx3y is trying to measure has in fact been measured, and no basis to know what has been measured at all. (Tr. 6869-6872 and 6969-6972). Dr. Levine's survey has gaestionable internal validity (Tr. 6969). Dr. Levine 454 I;'$l
-172-
admitted that he did not establish internal validity for his study (Tr. 6871). Accordingly the Board concludes that there is no way of knowing that what Dr. Levine was trying to measure with respect to the samole surveyed was in fact measured, and there was no way to know what Dr. Levine measured at all.
398.
Dr. Levine also testified that the assumptions drawn in his written testimony, that long time regular vaca* 4cners and people from Atlantic County and other coranunities who are considering moving to or vacationire in Atlantic County would go elsewhere, have no statistical validity and that he could rot make a statement that they are true (Tr. 6922 and Atlantic County's Testimon-Page 6).
In addition, Dr. Levine testi f.ed that the sample obtained from his survey has no statistical uignificance (Tr. 6832).
399. The Board firx3s that the economy of resort-oriented communities near coastal operating nuclear power plants has not been adversely affected by the presence of nuclear plants.
Ite economy of these areas has had sustained growth and, in sane cases, has shown dramatic improvement.
400. 'Ihe Board finds the potential impact of siting an FNP on a resort econany which is characterized by the presence of tourists and leisure seekers is very small and vall within the year to year fluctuations in the local econanic activity of the coastal resort area.
f ^E A 17 [
-173-
R. CONTENTICN XVIII - NET ENERGY YIELD, COST-BENEFIT BAIA'JCE ACCCE Contention II:
"'Ihe FES Pat t II cost-benefit analysis underestimates che total direct ard iM irect cost of the FNP's and grossly overstates the benefits because of (1) the conclusion that FNP's will prcduce a net energy yield (positive), without regard to the energy impact if less than eight are con-structed aM sold or if the FNP's, due in part to the unique stresses of the alien marine environment, fail to operate for their planned useful life, (2) the failure to consider cost of decommissioning the breakwater as a po-tential cost, (3) the failure to compute the cost impact if the ENP's are required to use coclng towers at inshore sites, (4) the failure to consider the various direct and indirect costs resulting from the foreclosure of alterna-tive uses of coastline, and because of (5) the fact that the costs were based upon 1972 costs whereas the beneff s 91 are 1988 benefits.d 401. On this contention, both Applicant and Staff presented written ard oral testimony.92 None of the intervenors presented witnesses, testinony or other information. Hearing sessions with 91Admitted as interpreted by Board Order dated August 1,1977, pp.4,5.
92The Applicant's written testimony, Exhibit No. OPS-49, entitled
" Applicant's Testimony Regarding XVIII. Net Energy Yield, Cost-Benefit Balance" was admitted at Tr. 7069 (7/12,78). The witnesses sponsoring this testimony were Dr. John Nutant, Messrs.
P.
Blair Haga, "illiam F. Trappen ard Thcmas A. Mantia (Professional Qualif-ications zdmitted at Tr. 609,1024, 7055 and 609 respectively). 'Ihe Staff's written testimony entitled " Supplemental Testimony of IGC Staff in ACCCE Contention II," by Dr. Paul C. Fine and Messrs. Fred J. Clark, Norman E.
Hinkle aM Fred G. Taylor was admitted at Tr.
711J. Mr. Taylor was unavailable for the hearing ard was represented by Dr. Glenn W.
Suter. (Professional Qualifications of Dr. Fine, Messrs. Clark and Hinkle, and Dr. Suter were 2dmitted at Tr. 7060, 637, 637 and 7106 respectively.)
ftJ 4i,g
-174-
regard to this contention were held on July 12 and 13,1978 and the testimony appears at Transcript pages 7067-7076 and 7103-7130.93 Net Energy Yield 402. The Applicant performed an analysis of the net energy yield for the FNP. This analysis was performed on a per-plant basis, assuming the manufacture of both one and four B7s, taking into account the energy raquired to build the manufacturing facility as well as an asrumed breakwater. Utilizing the methodology employed by the Staff, A@licant's analysis shows that the thermal energy reqaired to build and operate an ENP is approximately 6.1 percent of the thermal energy output for one plant, assuning only one FNP is manu-factured and its operating life is 30 years. Assuming four FNPs are manufactured, the corresponding figure is approximately 5.9 percent.
(A@licant's Test imony, Page 2). Applicant's results were comparable to the results of the analyses reported by the Staff (FES-II, Section 12.10.4 at page 12-71).
403. Assuming eight ENPs are built, the crossover point at which the cositive energy yield begins is at 3.7 months of operating time for an B'P.
If only two FNPs are built instead of eight, the 93Applicant and Staff witnesses were examined by the Board.
$'C4 I?y
-175-
crossover paint would increase from 3.7 to 3.9 months, an insignif-icant charge canpared to the assumed 30 year operating life. (Staff's Testimony, Pages 3 and 4).
Breakwater Decaumissioning 404. Decomissioning the breakwater is discussed in Section 9.5.3 (page 9-12, et seq. ) of FES II. Additionally, there is a discussion regardirs the alteration of the breakwater as a prerequis-ite to moving the ENPs out of the breakwatet enclosure, should that be included in the overall deccmnissioning plan. There exist a nunber of alternative methods for decomissioning the breakwater: prpetual care, alternative use, ard removal. 'fhe FES II contains an adequate discussion of major considerations of cost and benefit for the various decomnissioning options. (Staff's Testimony, Page 6).
Cost of Cooling Towers 405.
Se cost imnact for closed-cycle cooling systens for FNPs located at inshore sites is discussed in Section 10.1.1 (Page 10-5) of the FES II. The cost imoact is given in Tables 10.1.7 (Page 10-16),11.2.2 (Page 11-3) and 11.2.3 (Page 11-4).
406. Table 10.1.7 of FES II presents costs for an offshore FNP, inshore ENP with and without coolire towers, and a landused plant with once-throtrJh cooling. Generally, the capital cost of Y
1, l/
-176-
inshore-sited FNPs with cooling towers ccrnpares favorably with the upper end of the range of costs likely for land-based nuclear stations without cooling towers in the coastal zone of the Atlantic and Gulf coasts (Staff's % stimony, Page 17).
Foreclosure of Alternate Uses of Coastline 407. Sections 9.4 (commencing p. 9-5) and 12.8.1 (coninencing
- p. 12-62) of the FES II discuss conflicting uses of the continental shelf inc1tding the coastline. Potential conflicts are site dependent and will be evaluated on a site-specific basis during an owner's construction permic process. However, the effects of such p tential conflicts are judged t.o be of minor significance or avoidable.
(Apolicant's Testimony, Page 3).
408.
ENPs at inshore sites will have no more effect on land use than land-based power stations. Offshore siting will involve even less conmitment of land. Be snall a:nount of lard actually disturbed will be much less than for other types of industrial facilities.
(Staff's Testinony, Page 35).
Alleged use of 1972 Cost Estimates ard 1988 Benefits 409. The costs for an ENP are discussed in Section 10.1.1 (p.
10-1) and su:nnarized in Section 11.2 (coninencing p. 11-3) of the FES 4
l
//p
-177-
II. Se costs are not " based upon 1972 costs." Be costs were cal-culated usirg a 1973 base cost. Escalation and interest during construction werc then added to arrive at a co:rpleted cost in
" current" dollars up to tho time of comercial operation. Two analyses were performed, assuming commerical operation ecmnencing in 1981 and in 1985, respectively. Operating costs for the entire life of the plant were discounted back to the comercial operation date for each analysis. (Acolicant's Testimony, Page 4).
410. Se bert_rits for an R;P are set. forth in Section 11.1 (Page 11-1, et seq.) of the FES II. We benerits are not "1988 bene-fits." P.a direct benefit from an RG is the electricity generated.
This direct benefit for each plant will begin when the FNP ccxnnences operation and is set forth in the FES II in terms of kilowatt-hours of electricity producec. The value of these kilowatt-hours will be dependent upon applicable rates durin; the period of plant operation.
(Applicant's Testimony, Page 4). Indirect benefits, such as taxes and employment, also are discussed in the FES II (Sections 11.1.3 and 11.1.4, conTaencing Pace 11-1).
Conclusions 411. The Board p eviously has concluded that adequate consideration has been given to the marine environment (Sec Section C.
Contention III - MARINE ENVIROtNENT, supra.). We further fird that the net energy yield from an rip has not been overstated che to the Ip' 1
-178-
failure to consider the unique stresses of the marine environment on the planned operating life of an FNP. In fact, a positive energy yield would occur within four months of initial operation of an ENP.
412. The cost benefit analysis in the FES properly considers tha various options for decommissioning and the attendant costs for each op..on.
413. Be cost benefit analysis in the FES properly considers the costs associated with cooling towers at inshore FNP sites.
414.
Proper consideration is given in the FES to ptential foreclosure of alternative uses of the coastal area ard shoreline naeded for eight FNPs. Such potential foreclosure is jtdged to be of minor significance and does not alter the overall cost-benefit balance.
415. Se costs aM benefits in the FES were properly assessed using appropriate ti ne frames for their calculation.
416. Accordingly, the Board finds that the FES II cost-benefit analysis does not urderestimate the total direct and indirect costs of the Pips and does not overstate the benefits.
f.s:g,
/of n
-179-
S.
CONTENTION XIX - SPECIAL ENERGY REQUIREMENTS Board Retained Issue (Originnily Brigantine Contention I.4):
'Setion 12.10.4 of Part II of the FES is inadequate in that i.t does not take into account the special energy re-quirements needed to procure breakwater luot.ecial, to construc
- the breakwater, to tow plants to the site and to provide snore to barge t=bilicals."94 417. On this contention, both Applicant and Staff presented written and oral testimony.95 None of the intervenors presented witnesses, testimony or other information. Hearing sessions with regard to this contention were held on July 12 and 13,1978, and the testimony appears at Transcript pages 7053-7058, 7059-7067 and 7087-7103.96 94Brigantine Cmtention I.4 was originally admitted by the Board at the May 20, m77 a:gtment, see Board Order dated August 1,1977, p.2. Upon the withdrawal of Brigantine as a party the Board retained this contenti:;n as an issue (Board Order dated August 1,1977, pp.
12-13).
The Applicant's written testimony, Exhibit No. OPS-50, entitled "Acplicant's Testimony Regarding XIX. Issue Retained by the Board" was ainitted at Tr. 7058 (7/12/78 ). 'Ihe witnesses sponsocing this testimony were Dr. John A. Nutant, Messrs, P. Blair Haga, Thcznas A.
Mantia, and William F. Trappen (Professional Qualifications ainitted at Tr. 609, 1024, 609 and 7055 respectively). The Staff's written testimony entitled " Staff 'Destimony in Response to the Issue Re-tained by the Board Regarding Special Energy Requirements for Floating Nuclear Power Plants" by Dr. Paul C. Fine and Mr. Clifford A.
Haupt was admitted at Tr. 7062 (Professional Qualifications of Dr. Fine and Mr. Haupt were admitted at Tr. 7060 and 7011 respectively.)
96The Staff witnesses were examined by the Board.
,/h
-180-
418. Special energy regairements needed to procure breakwater material, to construct the breakwater, to tow FNPs to an owner's site and: to provide shore-to-barge tnbilicals were calculated (Applicant's Testimony, Page 1).
Breakwater Construction 419 The calculations of the energy regaiements for con-struction of a breakwater were based on the two unit breakwater design described in Section 3.1 (pages 3-1, et seq.) of FES II. (Applicant's Testimony, Page 1).
420. he energy regaired for gaarrying the stone for the breakwater was estimated to be 0.28 trillion BW. Asstnirs the stone would bo trans;orted 200 miles to the site, the energy required to transport the stone was estimated to be 0.6 trillion BW. (Applicant's Testimony, Page 2).
421. %e energy required to manufacture the cement required for the concrete in the caissons and dolosse was estimated to be 1.7 trillion BW. Sa energy required for the other elements in the manufacture of concrete was considered negligible. (Applicant's Testimony, Page 2).
422. We energy required fo.
actual construction of the breakwater was estimated to be 0.7 trillion BTU. (Applicant's 'Ibsti-mony, Page 2).
/:yh In I(
-181-
423. The total energy required for the breakwater was estimated to be 3.3 trillion BTU per FNP. This amount represents less than 0.2 of one percent of the energy generated over a 30 year period of plant operation. (Applicant's Testimony, Page 2).
424.
Se total energy required for providing materials and for constructire an offshore breakwater was calculated by the Staff to be 8.1 trillion BTU. Since an offshore station was assumed to coraist of two FNP units, the energy per unit is about 4.1 trillion BTU (Staff's Testimony, Page 4).
425. We Staff's estimate of energy required for breakwater construction was higher than the Applicant's estimate due to the assumption by the Staff that one-half of the concrete would be reinforced (Tr. 7089). The Staff estimate may be conservative in that reinforcement of the concrete may not be necessary, (T 7095).
Towing 426. Assuming a distance of 2000 miles for tug deployinent, including towing distance from the Blount Island manuf acturing facility to an owner's site, the energy required for towing one FNP was estimated by the Applicant to be 0.08 trillion RTU (Applicant's Testimony, Page 4). We Staff considered the Aoplicant estimate to be conservative and aSopted it (Staff's Testimony, Page 4).
$r4 3
./y W
-182-
E'P-to-Shore Circuits 427. Tva electrica' circuits are regaired to link an n'P with the owner's power grid (PDR, Page 8, U -1), To calculate the energy regaired w manufacture the material in the cables ard to manufacture the cables, it was assumed that the distance frm the shore to the plant is three miles (Applicant's Testimony, Page 3). We energy regaired was estimated to be 0.46 trillion BHJ. The energy to lay the cables was estimated to be 0.6 trillion BTC. Bus the total energy regaired to provide the n'P-to-shore circuits was estimated to be 1.06 trillion BTU. (Applicant's Testimony, Page 4). De Staff estimated the energy requirement to be 1.2 trillion BTU par FNP (Staff's Testimony, Page 6).
Conclusions 428.
Be energy requirements needed to procure breakwater material, to construct the breakwater, to tow an FNP to the ow.er's site and to provide ENP-to-shore circuits represent approximately 0.3 of one percent of the overall expected energy output of an B'P during an assumed 30 years of operation (Tr. 7091). The Board firds that these energy regairements as were taken into account properly in the FES ard are insignificant cmpared to the expected energy output ';
an ENP during its operating life.
- f y
0
-183-
T.
COtIIm rION XX - HEAT PUMPS AND SECONDARY AND TERTIARY RECOVERY OF OIL Board Question:
The Applicant and the Staff are reauested to present evidence $ on the following Scard question: "To what extent, if any, would the consideration of the utili::ation of heat pumps ard of secondary and tertiary recovery from oil wells serve to modify the discussions and/or conclusions reached in Part II of the FES ?"9 429. On this Board cuestion, both Applicant and Staff presented written and oral testimony.90 None of the intervenors presented witnesses, testimony or other information. Hearing sessions with regard to this Board question were held on July 12 and 13,1978 aM the testimony appears at Transcript pages 7078-7083, 7131-7134 and 7134-7137.99 Heat Pumps 430. A heat purt.p is a device which uses an electric motor and fluid systems to bring in ar.bient low temperature energy from the This question was raised by the Board in our Memorandum and Order Re: Motions to Amend and Expand Contentions, dated August 1,1977, p.10.
9~AThe Applicant's written testimony, Exhibit No. OPS-51, entitled
" Applicant's Testimony Regarding XX. Board Question," was admitted at n. 7080 (7/12/78). The witnesses sponsoring this testimon'y were Dr. John Nutant ard Mr. P. Blair Haga (Professional Qualifications aimitted at Tr. 609 ard 1024 respectively). The Staff's written testimony entitled " Testimony of NFC Staff in Response to Board Question" by Norman Hinkle was aimitted at Tr. 7133. (Professional Qualifications of Mr. Hinkle were admitted at Tr. 637).
90' Applicant witnesses were examined by the Board.
$tM
-184-O
natural environ lent and elevate it to useful temperatures for space heating. By reversing the flow of the working fluid, heat pumps also provide space cooling. Heat gnps can be utiliced in new construction aM in the replacement of existing heating systens. (App]icant's Testimony, Page 1).
9 431. Using a heat pump in new construction or as a replace-ment for existing fossil fuel heating will require additional electric energy generation. Using a heat pmp as a substitute for existing electric resistance heating will result in a reduction in electric energy consumption. This will te offset, in par t, by newly created demard for su:nner space coe.ing in homes currently without space cooling systems (Applicant's Ibstimony, Page 2).
432.
In the Ford Foundation Sttdy reported in A Time to Choose.
Final Report by the Energy Policy Project of the Ford FouMation, Ballinger Publishing Co., Cambridge, Mass., 1974, esti-mates were made of the increase in overall electric energy demand. In the loweet projection case (:ero Energy Growth scenario), it is esti-mated that electric energy demand will gros oy 1.5 Quads (Q) between 1975 and 1985 asstnirs widespread use of heat pumps in new construc-tion. In this proj ection, the conversion 3f one-third of the 7.5 million homes with electric resistance heating in 1975 to heat pump heating by 1985 would result in a reduction in electric energy demaM of 0.1 Q. If all of these 7.5 million homes were converted to heat pr.p heating, a maximum reduction in electrip7. energy demand of 0.2 Q
' J <j
,/9
'O
-185-
would be achieved beyond the reduction already incltx3ed in the Zero Energy Growth scenario. 'Ihus, even with the maximum possible reduction by conversion to haat pumps, the increase in electric energy demand in the Zero Energy Growth scenario will still be 1.3 Q. This is equiva-lent to the annual energy output of sixty-two 1000 MWe power plants operatire at 70 percent capacity. (Applicant's Testimony, Page 2).
433. More recent studies project an increase in electric energy deman3 that is significantly greater than the lowest projected demand of the Ford Foundation Study (Applicant's Testimony, Page 3).
434. The use of heat pumps is not expected to reduce the overall growth in electric energy requirements (Applicant's hstimony, Page 5; Staff's Testimony, Page 6).
Secordary And Tertiary Recovery of Oil 435. Since 1970, annual danestic production fran existing oil fields has fallen each year, with almost half of the current den.and made up by imported oil (Applicant's Testimony, Page 4).
436.
Since the total U.S. domestic production of oil by all methods of recovery is estimated to meet only about half of the demand in 1985, secondary and tertiary recovery of oil alone will not be sufficient to eliminate the need for oil imports to make up the shortfall (Applic. ant's Testimony, Page 4).
-186-
437. SeccMary and tertiary methods of recovery of oil are only expected to maintain total overall dmestic production and are not expected to significantly reduce the requirements for imported oil. Therefore, oil supplies are not expected to be available to meet the overall projected growth of electric energy demaM (Applicant's Testimony, Page 5; Staff's Testimony, Page 4).
Conculsion 438. The Board firds that conclusions reached in the FES are not changed or modified by consideration of heat pumps ard secondary ard tertiary recovery of oil.
454 7g9
-187-
APPENDIX A A.
Application Documents Exhibit Admission into y'rr.ber Title Date Evidence 1.
20 Application for Manufac-May, 1973 Tr. 1031 turing License ard Sup-plemental Information 2.
21 Plant Design Reprt January, 1973 Tr. 1031 3.
4 Err /iromental Report May, 1973 Tr. 614 Supplement to Manufac-turing License Appli-cation 4.
5 Suoplement No. 1 to October 8, 1973 Tr. 614 Environmental Report Supplement to Manufac-turing License Appli-cation 5.
6 Supplement No. 2 to January,1974 Tr. 614 Err /ironmental Report Supplement to Manufac-turing License Appli-cation 6.
7 Supplement No. 3 to June 7, 1974 Tr. 614 Environmental Report Supplement to Manufac-turing 7icense Appli-cation 7.
8 Supplement No. 4 to August 6, 1974 Tr. 614 Ervirornental Report Supplement to Manufac-turing License Appli-cation 8.
9 Supplement No. 5 to January 30, 1975 Tr. 614 Err /ironmental Report Supplement to Manufac-turing License Appli-cation 9.
10 OPS Letter re Environ-January 23, 1975 Tr. 614 mental Report *w Mr.
Gordon K. Dicker of the Staff
,A54
/96 a-1
Exhibit Admission Into Number Title Dat Evidence
- 10. 57 Enviro = ental Report, June, 19L Tr. 6786 Part II, Supplement to Manufactu,'v; License Application
- 11. 58 Environmental Report, June, 1973 Tr. 6790 Part II, Appendices, Supplement to Manufac-turing License Appli-cation
- 12. 59 Supplement No. 1 to March, 1974 Tr. 6790 Environmental Report, Part II, Surplement to Manufacturing License Application
- 13. 60 Supplement No. 2 to May, 1974 Tr. 6790 Environmental Report, Part II, Supplement to Manufacturing License Apolication
- 14. 61 Supplement No. 3 to December 3,1974 Tr. 6790 Enviromental Ratort, Part II, SJpplement to Manu' cturing License application
- 15. 62 Supplement No. 4 to September 19,1975 Tr. 6790 Enviromental Report, Part 1, Supplement to Manufacturing License Application
- 16. 63 Supplement No. 5 to May, 1976 Tr. 6790 Err /iromental Report, Part II, Supplement to Manufacturing License Application
- 17. 64 Supplement No. 6 to June, 1977 Tr. 6790 Enviromental Report, Part II, Supplement to Manufacturing License Apolication At.
T.
/
A-2
B.
Staff Review Docinents Publication Aimission Into Title Number Date Evidence 1.
Safety Evaltation NUREG-75/100
$ 9/3045.
Tr. 1043 Report Related to Offshore Power Systems Floating Nuclear Plants (1-8) 2.
Supplement No. 1 to IUREG-0054 3/16M6 Tr. 1043 Safety Evaluation Repr Related to Operation of Offshore Power Systems Float-ing Nuclear Plants (1-8) 3.
Supplement No. 2 to IUREG-0054 10/8M6 Safety Evaluation Report Related to Operation of Offshore Power Systems Floating Nuclear Plants (1-8) 4.
Final Environmental IUREG-75/091 10M5 Tr. 642 Statement Related to Manufacture of Float-ing Nuclear Power Plants by Offshore Power Systems 5.
Final Envirornental NUREG-0056 9/76 Tr. 3626 Statement Related to Manufacture of Floating Nuclear Power Plants by Offshore Power Systems, Part II (Staff Exhibit I) 6.
Final Adderdtn to IUREG-0056 6/78 Tr. 7014 Final Err /ironmental Statement Related to Manufacture of Float-ing Nuclear Power Plants by Offshore Powar Systems,Part II At:
A-3
~' d 'I l
9
Publication Idmission Into Title Ntrl>er Date gidence 7.
Final Envirornental NURtri-0502 12/78 Tr. 7264 Statenent Related to Manufacture of Float-ing Nuclear Power Plants by Offshore Power Systems, Part III hf'y,1
/ Og A-4
APPENDIX _B, LISTItX3 OF CONTENTIO1S ADMITTED AS ISSUES IN CONTROVERSY AND '7THER MATTERS OF BOARD INQUIRY I
A.
EMERGDCY PDNER (CO!EDEIOJ I )
Brigantine Amended Contertion 3
" Motion by Intervenor City of Brigantine to Amend and Expand Its Contentiens" (hereinafter " Brigantine Motion") (10/21M5), page 2.
' ttM
" Fourth Prehearing Conference Order and Ruling on Mo.
(nereinafter " Fourth Prehearing Conference tder")
(12/29/ /5), page 4.
B.
UNDERWATER ELECTRICAL TRANSMISSION LINES (COTTDEION II)
ACCCE Contenticn 4b
" Atlantic County Citizens Council on Environment's Petition to Intervene in the Above-Cited Matter; Contentions Therefor" (here-inafter "ACCCE Petition") (4/15M4), page 3.
Admitted, as interpreted by the Atomic Safety and Licensing Boa-d, "Second Prehearing Conference Order" (5/21M4), page 7.
C.
MARINE 2NVIROiMENT (COEDElai III)
Brigantine Amended Contention 6 Brigantire Motion (10/21M5), page 3.
Admitted, " Fourth Prehearing Conference Order" (12/29M5), page 5.
ACCCE Contention 2 ACCCE Petition (4/15M4), page 2.
Admitted, as interpreted by the Atomic Safety and Licensing Board, "Second Prehearing Conference Order " (5/21M4), page 4.
1This listing reflects the consolidation of related contentions for hearing and utilizes the Ranan numeral numbering segaence and subject matter design 7tions enployed by Applicant in its arious motions to establish schedule.
454
,a
'/
B-1
D.
CENTRAL CONTROL RODM (CONTEBTTICN IV)
ACCCE Contention 9 ACCCE Petition (4/15M4), page 4.
Admitted, as interpreted by the Atomic Scfety and Licensing Board, "Secord Prehearing Conference Order" (5/21M4), page 10.
E.
'IRANSEORTATION (CONTENTION V)
Atlantic County Contention 3 Atlantic County Letter (2MM4), page 2.
Admitted, "First Prehearing Conference Order" (4/15M4), page 9.
ACCCE Contention 5 ACCCE Petition (4/1554), page 3.
Admitted, "Second Prehearing Conference Order" (5/21M4), page 2.
Brigantina Origiral Contention Kenneth B. Walton Letter (12/13M3)
Admitted, "Second Prehearing Conference Order" (5/21M4), page 2.
Kenneth B. Walton Contention Kenneth B. Walton Letter (12/13M3)
A6titted, "MemoraMtn and Order" (5/8M5), page 2.
F.
SITE DNELOPE DATA (CO!7?ENTIW VI)
Prigantine Amended Contention 1 Brigantine Motion (10/21M5), page 2.
Admitted, as interpreted by the Atomic Safety and Licensing Board,
" Fourth Prehearing Conference Order" (12/29M5), page 4.
G.
PADIOIDGICAL IMPACT W SKIMMERS AND BOATERS (COtTTENTION VII)
ACCCE Contentior 3d ACCCE Petition (4/15M4), page J.
Adr.itted, "Second Prehearing Conference Order" (5/2154), page 6.
ll J.]
C.
19g B-2
H.
AIRCIUL"! (CONTENTIW VIII)
Atlantic County Contention 2 Atlantic County Letter (2MM4), page 2.
Admitted, as stated by the Atomic Safety ard Licensing Board, "First Prehearing Conference Order" (4/15M4), page 9.
Brigantine Amended Contention 4 Brigantire Motion (10/21M5), page 4.
Admitted, " Fourth Prehearing Conference Order" (12/2955), page 4.
ACCCE Contention 6 ACCCE Petition (4/15M4), page 4.
Admitted, as interpreted by the Atcmic Safety and Licensirg Board, "SecoM Prehearing Conference Order" (5/21M4), page 8.
I.
SHIP COLLISION (COtH'EtTTION IX)
Brigantine Amerded Contention 5
" Motion by Intervenor City of Brigantine to Amend and Expand Its Contentions" (10/21M5), page 4.
Admitted, " Fourth Prehearing Conference Order" (12/29M5), page 4.
ACCCE Contention 6
" Atlantic County Citizens Comcil on Envi:onment's Petition to In-tervene in tlw A!xne-Cited Matter; Contentions Therefor" (here-inafter "ACCCE Petition") (4/15M4), page 4.
A&titted, as interpreted by the Atomic Safety and Licensing Board, "Secord Prehearing Conference Order" (5/29M4), page 8.
J.
1CE COh"IADNENT (CONTENTIW X)
ACCCE Contention 7 ACCCE Petition (4/15M4), page 4.
Admitted, as revised by the Atomic Safety and Licensing Board,
" Memorandum and Order" (7/10M4).
AC rJ4 B-3
/
o K.
'IUFBI';E-GD; ERA'IG MATTERS (C7hEww 1SSUE XI~)
On Juni 15, 1976, Mr. Ernst J. Effenberger made a limited appear-ance statenent concerning turbine-generator matters (Tr. 999-1010). En Board requested the Applicant and Staff to address the matters raised by Mr. Effenberger (Tr. 1011).
L.
EFFECT Q1 BIOris (CONTOEION XII)
ACCCE Contention 3a ACCCE Petition (4/15B4), pages 2 3.
Admitted, "SeccM Prehearing Conference Order" (5/21M4), page 5.
M.
EUJCTICtAL DESIGM CF DIECHARGE CUIIJALL (CORENTION XIII)
ACCCE Contention 3b ACCCE Petition (4/15M4), page 3.
Admitted, "Second Prehe; rire Conference Order" (5/21M4), page 5.
N.
FOOD CHAIN (COtEC CION XIV)
ACCCE Contention 3c ACCCE Petition (4/15M4), page 3.
Ad:nitted, "SeconS Prehearing Conference Order" (5/21 B4), pages 5-6.
O.
DREDGING (COCDEIQ1 XV)
ACCCE Contention 3f ACCCE Petition (4/15M4i, page 3.
Admitted, "Second Prehearing Conference Order" (5/21M4), page 6 o'In the Board's "S(cond Prehearing Conference Order" (5/21/74) ACCCE Contention 4a pertaining to breakwater stability (ACCCE Petition (4/
15M4), page 3) was admitted as an issue in controversy.
In the early stages of the hearing this issue was referred to as Contention XI.
However, ACCCE Contention 4a was dismissed as an issue
'n concrcversy by Board Order dated April 20, 1977.
B-4 g
P.
IMPACT OJ RESORT ECO!GICS (CONEEIOi XVI)
Atlantic County Contention 1 Atlantic County Letter (2MM4), pages 1-2.
- &itted, "First Prehearing Conference Order" (4/15S4), page 8 Q.
PROGRIMTIC DiVIROtNDITAL STATEMDC (COtCDEIOi XVII)
NRDC Contention
" Petition for Leave to Intervene" dated January 9,
1974 ard "Amendnent of NRDC's Petition for Leave to Intervene" dated February 26, 1974.
Admitted, "First Prehearing Conference Order" (4/15M4), pages 2-3.
R.
NET DIERGY YIELD, CDST-BENEFIT BAIANCE (COEDEION XVIII)
ACCCE/ Atlantic County Contention II
" Motion to Amend and Ex;nnd Contentions" dated November 19, 1976.
Admitted, "Memorardtrn ard Order Re:
Motions to Amend and Expand Contentions" dated August 1, 1977 (hereinafter " August 1, 1977 Order), pages 4-5.
S.
ISSUE PSTAINED BY ' HIE BOARD - SPECIAL DIERGY REQUIRE?CES (COiTDCION XIX)
Identified, August 1,1977 Order, pages 12-13.
T.
BOARD QUESTIQI - HEAT PUMPS, E'IC. (CON 16n.u ISSUE XX)
Identified, August 1,1977 Order, page 10.
19g B-5
UtiITED SIL"3 OF AMERICA NUCLEAR REGLLMORY COMMISSION BEFORE THE ATOMIC SAFEIY AND LICD;SI?C BOARD In the Matter of
)
)
OFFSHORE POWER SYSTDiS
)
Docket No. SIN 50-437
)
(Manuf acturing License for Floating
)
Nuclear Power Plants)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Proposed Partial Findings of Fact in the Form of a Proposed Initial Decision" were served by deposit in the United States Mail (First Class), postage prepaid, upon the persons listed on attachment to this Certificate of Service this 1st day of June 1979.
Thmas M. Daugherty Counsel for Offshore Powe Systens
<l
/Sp
OPS SERVICE LIST Sheldon J. Wolfe, Esgaire, Chairman Harold R. Denton, Director (2)
Atomic Safety and Licensing Board Office of Nuclear Reactor U. S. Nuclear Regulatory Cmnission Regulation Washington, D. C.
20555 U. S. Nuclear fegulatory Commission Washington, D. C.
20555 Dr. David R. Schink, Men >er Atanic Safety and Licensing Board Docketing and Service Section.(21)
Department of Oceanography Office of the Secretary T w as A & M University U. S. Nuclear Regulatory Commission College Station, Texas 77840 Washington, D. C.
20555 Mr. Lester Kornblith, Jr., Member Martin G. Malsch, Esquire Atanic Safety and Licensirs Board Stephen M. Schinki, Esquire U. S. Nuclear Regulatory Commission Marc R. Staenberg, Esquire Washirgton, D. C.
20555 Michael W. Grainey, Esqaire Office of the Executive Legal Dr. David L. Hetrick Director Alternate Member U. S. Nuclear Regulatory Cannission Atomic Safety and Licensing Board Washington, D. C.
20555 Professor of Nuclear Engineering The University of Arizona Barton Z. Cowan, Esquire Tucson, Ari::ona 85721 John R. Kenrick, Esquire Eckert, Seamans, Cherin & Mellott Alan S. rosenthal, Esquire, Chairman Forty-second Floor Atanic Safety and Licensing 600 Grant Street Apoeal Board Panel Pittsburgh, Pennsylvania 15219 U. S. Nuclear Regulatory Camission Washington, D. C.
20555 Thanas M. Daugherty, Esquire Offshore Power Systems Richard S. Sal:: man, Chairman 8000 Arlington Expressway Atomic Safety and Licensing P. O. Box 8000 Agpeal Board Jacksonville, Florida 32211 U. S. Nuclear Regulatory Camission Washington, D. C.
20555 Carl Valore, Jr., Esquire Valore, McAllister, N Brier, Dr. John H. Buck, Member Aron & Westmoreland Atanic Safety and Licensing Mainland Professional Plaza Appeal Board 535 Tilton Road P. O. Box 152 U. S. Nuclear Regulatory Commission Northfield, New Jersey 08225 Washirgton, D. C.
20555 Richard M. Hluchan, Esquire Michael C. Farrar, Me:rl>er Deputy Attorney General Atanic Safety and Licensing State of New Jersey Acpeal Board Department of Law and Pablic Safety U. S. Nuclear Regulatory Carnission Division of Law - State House Annex Washington, D. C.
20555 Trenton, New Jersey 08625 Chief Hearing Counsel Anthony Z. Roisman, Esquire Office of the Executive Legal Natural Resources Defense Director Council,Inc.
U. S. Nuclear Regulatory Commission 917 Fifteenth Street, N. W.
Washington, D. C.
20555 Washington, D. C.
20005
$y Cs
Keith A. Onsdorff, Esgaire Assistant Deputy Public Advocate State of New Jersey 520 East State Street P. O. Box 141 Trenton, New Jersey 08625 Mr. George B. Ward Nuclear Power Plant Ccmittee City Hall Brigantine, New Jersey 08203 Mr. Harold P. Abrams, President Atlantic County Citizens Council on Enviroment 9100 Amharst Avenue Margate, ?bw Jersey 08402 Dr. Willard W. Rosenberg, Chairman Energy Cocraittee Atlantic County Citizens Council on Enviroment 8 North Rumson Avenue Margate, New Jersey 08402 Mr. John H. Williamson Energy Comittee Atlantic County Citizens Council on Enviroment 211 Forest Drive
'~.1 wood, New Jersey 08221 Y
.%:n
~Y,I