ML19319D363
| ML19319D363 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/14/1968 |
| From: | Hadlock G US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8003160198 | |
| Download: ML19319D363 (17) | |
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Sec ter.cnt of the C. ce Thic proceeding involves the cpplication of Elorida Pouer Corpora tion (applicant), d:.ted August 10, 1967, cnd five cr. cud ::.:r.ts thereto ("the application") filed under G 104 b. of the Atomic Enercy Act of 1954, cs cr. ended (the "Act"), for c conctruction perr.it to construct a prescuriced voter recetor designated Crystal River Unit 3 cud designed to operate initially at power levels up to 2452 noget:ctts (thernal), to be loct.ted on the cpplicant'c 4,730 cero site located on the Gulf of licxico chaut 70 p.iles north of Tu.pc, Florida, cnd ccven and one-hcif uiles north of the Toun of Crystal River, Floride.
The application s cc revieued by the regulatory ctcff (ctaff) of the Atomic Energy, Co:.uiscica (Cc.cniccion) cnd the Advicory Ceratittee on Recctor Safer,ucedc ("ACRS"), both of which concluded 8008160 AS
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that the proposed rcactor can be constructed cnd oper:ted e t the propoced cite without ucduc rich.to the hacith end.ccrety of the public.
- A notice of hearing usa iccued on May 29, 1908, deci ncting 3
an Atcr.ie Cafety and Licensing roard ("roard") to cor. duct thic proceeding to datermine thother a provisicr.nl conctruction peruit chauld be iccued to the applicant.
By Order dated June 23,196G, the Eor.rd granted a Petition to Intervene filed by the City of Gainecville, Flobida, and the Gainesville Utilitico Depcrtcant ("the intervenorc"), but licited the intervenors' participation to the question of the juricdiction of the Ccr.aiccica to iccue a conctruction pornit under G 104 b.
of the Act. 1] A Motion to Droeden Iscuco filed by the intervonora vac denied. As c result of this intervention, the proceedin3 ic c contccted proceeding oc defined by 10 CFR S 2.4(n). The State of Florida also uce percitted to participate in the proceedina purcuent to G 2.715(c) of the Co:.raiccion'c "Ruloc of Practice",
10 CFR Part 2, but did'not oppose the grenting of the application.
- 1) Th:re is no controversy anon 3 the parties uith recpect to cny other nctter in iccue in thic proceeding.
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i tlc hhard iccued itc Initici Decicion on Septenbcr 24,19CS, directing the iccuenec' cf a provisional construction perr.it for.
.t.hc proposed Cryctal River Unit No. 3, but recorcending to the Cc;siccion that a conditioa Le added to the conctruction pcroit to :rce.uire '"tha t data he developed upon ~c record c dc e t c public hearing'in this contected cace concerning the uce of cither a chenlesi sprcy ec an ' iodine fixing additive' or other devici c
' for purpocen of controllius the relecco of radioactivo icdinc...".
(I.D.,-pp. 10 and 19.)
3 In cecordance with the provisions of 5 2.762(c) of the Cc=-
niccion'c "aules of Practice",10 CFR 2, the staff hac filed execptions to the Initial Decicion.
L II Arnc=ent A.
The Record In Thic Case Supports The.Isouance Of An Unconditioned Provicional Conctreetion Pernit Pursuant To S 50.35 Of The Cer'n! h r. ion 'c Regula tionc The.containuent cpray system which util be incorpora ted. in the
' Crystal River ' facility is designed to limit containment precourcs to deci n valuce !~ollouing en accumed loss o'f coolant' accident and 3
to reducc - the level of fission products in the containacnt building atascphere. The description and evclustion of this engineered safety s '
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- feature cro cont.a.ined in the Prclininary Scfety Anr.lycin Repc,r::
(PSAR) cubmitted with the cpplicci. ion.
(PSAR, Vol'. 2, Section 6, perncraph 6.2.)
To reduce the enount of rcdiocctive iodine evcilchic for 1cch2cc from the containment, the applicant propocc to inject
- an iodine ft::ing caditive into the contaituent cpray unter. The cdditive propoced ic' cn c1haline buffered colution of codiua thto-sulfcte. ff Since the propocod Cryctc1 River recctor is identicci to the reactor approved in the 1:etropoliten Edinon* ccsc, 3/ the applicction incorporates by reference cortcia portions of the cpplice tion cubaitted by the lictropolitan Edicon Coapeny eci.".ing 2_/ The Eocrd ccens to imply in its Initial Decision, pcrticulcrly footnote 8, page '9, that the applicent'c propocci to uco an alkcline colution of codium thioculfate beccue knoun to the Docrd for the first time at the hearing. Houever, it ic c1ccr from the applicction, particulcrly the portion of the lietro-politen Edicon applicction, Docket Ho. 50-289, which uca
-incorporated in the Cryctc1 River application by reference,' thet,
the cdditive prepoced vec to be an c1hcline colution of sodium thioculfcto uhich would be'ncintained in en c1hcline condition by -the cddition of sodium hydroxide or' other similar chemiccis.
r In any event,-the tactimony c1ccrly indicatcc that the applicant'.
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had clutyc intended to uco such a combination solution. (Tr., pp. #
-473,-476-7) cud thet the ctcff ucc cuarc of the applicant's-intention and had cyclucted the system on this bacis.
(Tr.,
- pp. 3 60-63, 477.).
3/ In the 1:.cter of 1:etropoliten Edison Ccunany, Dochet No. 50,259.
.The Initici Decision of the Atcaic Scfoty and Licensing Bocrd 1
in this cece, iccued May 16,195S, becccc the final Decicion of l
the Co::aiccion on July '1,1968.
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to the uce of chenicci cprcyc. Thic porticn of the application discucccc the design criterin for llc propoced chepical spr y cnd
- providee e list of references thereto. (uccpence to succtica 5.13, Metropolitan Edicen cpplicction, Dochet No. 50-259, Su?pic cnt 1, pcacc 5.13-1 through 5.13-3.)
In addition, the applicction con-tcins a detailed'deceription of the co:.grchencive rccccrch ced develop:: cat procrca being ccrried out by the cppliccnt'c contrcctor,
'E bc coch cad Uilcon Cor.peny, to octablich the effcetivenocc of the clhdiino codium thioculfate colutic.n ac en iodin'c abccrber, es i
ucil cc the etcbility cnd cc patibility of the col'ution under
' accident conditions.
(Recponce to quection 17.4, Metropoliten Edison cpplication, Supplenent 3, dated Dece=ber 8,1967, Docket No. 50-209, peccc 17.4-1 through 17.4-8.). The procrea relics on experiraents by Och Ridge Nctional Lcboratory to estchlich rc=ovel rctcc. A lict of the experiments to be conducted is cet forth
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in thic cpplication.
(Addendu= I to the recponce to question 17.4 in.the Metropolitan Edicon cpplication.) In cd,dition, the Ecbcock and' Wilco:: Company hoc under ucy:n roccarch cnd development progrca to deconctrcte the compatibilf ty of the solution with' the boric
~ccid uhich is also precent,in 'the cprey solution.
(Tr., pp. 492-3.)
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.. The reguintory staff reviewed the propoced research and l
- development prograu end concluded that thu applicent's progrca, in conjunction with the current ctudica under uay at the och Ridge National Lsboratory,chould establich that the reduction factors necessary to reduce the iodinc concentrations et the cite boundcry to Part 100 guidelines could be cchicved or exceeded.
(S fety Evaluation, pp. 42 -5.)
In feet, the reports on several of the experiments conducted et the Och Ridge National Laboratory had become availabic by the time of the hearing and were referred to on the record. The appliccnt tootified that a preliminary evaluation of the results of these c::periments indicates that they substantiate the effective-ness of the chemical spray system.
(Tr.,p. 325.) Referenecc were provided to reports which demonstrate that under many varying con-dicions, including temperature, iodinc concentrctions, stcem content in the 'a tmosphere, spray colution composition, spray nozzles,' spray flow rate and spray solution temperature, the iodine, removal rates have been greater than those set forth in the application. An experiment 'at the Nuclear Safety Pilot Plant at the Och Ridge National Laboratory, under cond!.tions closely approximating post accident conditions', indicated en iodine removal rete constcnt of
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4 81 per hour ubich, when c::trapolated to the Crystal River building conditione, indicates an iodine removal rcte conctant of about 100 per hour, u5ich ic cpproxittacoly four times creater than that escused in the application end approximately 50 times creater thcn that required to ncet part 100 guidelines. The applicant provided I
cdditional references to experiments relating to the stcbility of the spray colution.
(Tr., pp. 325-30.)
The reccarch and development progrcn relating to both the iodinc cbcorbing ability of the chemical spray and to the etability cnd cospatibility of the colution will be continued both at the Cah Ridge National Laboratory and by rabcoch und Wilcox cnd others.
(Tr., pp. 325-30, 3 61 and 492.)
In the event the research and development prograus do not cctablish that the cpray cyctea is acceptabic for iodine rcnoval, altern:tive canno to reduce iodine concentrations at the cite bound:ry vill be caployed. Chercoci filters cnd redu'ction of the contcir. mat icak rcte are cuong the citernatises that could be uced.
(PSAR, Vol.1, Section 1, paragraph 1.3, item 11; Scfety Evaluntion, p. 45.)
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-G-Section 50.35 doen not require that all design details of the facility munt be supplied ct the construction permit stage, nor that every cafety quection scust'actually have been cctis-factorily resolved at that stanc. ff
'A'ho record in this proceeding fulfille all the requirements of f 50.35 of the co..uf asion'c regulations for the iscucnce of cn unconditio'ned pr visional conctruction permit. Ao indicated above, the cppliccat' has deceribed the proposed danica of the containment apray cystem cud outlined a comprehencive roccerch and development program to reco1ve any questions remaining con-ccrning the effectivent::s of the sprcy system to absorb radio-active iofine, its stability under accident conditions and co -
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patibility uith other parte of the system. If, for any reccon, the spray cystem is not acceptabic, charcoci filters can bc installed in the facility to reduce the iodine availabic for release to the environment.
~/ In the Ma tter of 'Jerecy Central Pouer nnd T.inht case, 3 AEC 28, 4
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14ay 6,1965; In the Metter of Florida Pouer and Linht, 3 AEC
- August 4,1967.
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B. ' There Is No neaconable Ihcii. Set Forth In The Initial h cicicn To Simnort Ibnrd's : a c ~~ *:nd.' el on i.
In cup;, ort of itc recou:endation that a condition be included in;the construction permit for th:~ Crystc1 River fccility, the
~ ~ Bocrd relics on certain.uncpecified reporta of cxperinct.tc con-ducted at the och Ridge National Laboratory. 5_/ The Eccrd etotes at pcce 8 of the Initici Decision th:t:
"[T]hc uork uhich huc been undertchen [presurably by the Oak Ridge National Labo atory] to this time lendo doubt uhother the [containacnt cpray solution propocod by the applicant) cchievec tho' necessary iodine rcdiocctive fcetorp."
Again, at p:3c 9 of the Initial Decision, the Eocrd statec th:t:
"The Ock Ridge National Laborctory repo tts indi-
.cccc thct neither of the applicant'a chc=icci additivco for cprays vill achieve the necccccry l
reduction factors."
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5/ Purcuant to the Docrd'c requect, the staff submitted a lict of references to reports on the offectiveness of the con-tainment. sprays ucing a chenical cdditive cc cn iodine
'abcorber. The applicant nico raade reference to various reports in its application and tcctinony'. The Eonrd did not.
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rcquest comento from the applicant or tho etcff uith respect to any of thece reports. Our response here is directed at those reports to' which we accune that the Bocrd vcs referring
' in-the Initial Decicion.
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l The Eccrd'scen: to bacc these conclusions on,a report to the cffcet that such chemical'solutionc "und:rco radiction decorpo-sition..." during recirculation cooling of the reretor f/ The possibility of radiation instability, houcvcr, was recogniacd by the appliennt and ito reactor supplier ans t;as concidered by the staff in ite review..The research end develop =cnt program proposed
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by the cpplicant includea a thorough invectibetion of thic natter.
(Tr., pp. 325-30 cad 492.)
- 1:orcover, the etaff'c cciculations of the iodino reuovel i
capacity cvcilcbic for the Crystal River facility would not be affected by the reduction of total iodine capccity on tbc order l'
of that' set forth in the Initial Decision for the sprcy solution ie proposed. These calculations cetablich that boccuse of the 1 cree execsc of rcccent av,cilabic, the reduction factors necoscary to limit iodir.e concentrations at site boundaries to Pcrt 100 guide-4 L-f/ Op;L-/;228, Nuclect Sp_fo_ty Proy,rcm, Annuci Pronress Report for Period Ending December _ 31, 19 6_7,, p. 23 2.
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e lines ~could be cchieved.vith only one of the two contcirc.:ent sprays. -(Scfety Evcluation, pp. 43 cuJ 56.) As -an cdditional
- factor of conservatism, the staff's calcula tions also assumed t.hct 10 percent of the iodine in the contain=cnt ucs non-rci.ovabic by sprays. - (Tr.,
p,>. - 3 65 - 6 6. )
The Board also refers to data in an 0.'tNL report conterring the production of hydroscu gas when the chemical coditive is
- cxposed to.rediation. The Board quotes from the report as follous:
"The results obtained to date in the study of the various proposed sprcy.colutions indicate that radiolytic U2 -is produced in quantitics sufficient to be of concern in the - proposed spray systcra." 1/
Follouing the sentence quoted by the Board, the repoct indicates that another study _had been initiated to deter.:ine the feasibility of using other cdditives to decreccc the radiolytic hydrogen Jproduction._ The report then continues:
' ...the nitra to ion is known. to J over the radiolytic hydrogen yield by scavenging
'the hydrogen atom. Therefore, c brief study 2/ C2NL-4228, p. 235.
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9 of tac effects of nuch added nitrate t:ac ucdc....
The detn chot:n a definite decreccc
'in radiolytic ll.froductirn uith incroccing 2
NO3 - ccacentration. Uoucver, while thhcc da te indien te thct the radiolytic U2 pro-duction mcy be reduced by addition of 'scaven-gers,' tho' question of the compatibility of such cdditives uith the uccgo and purpocc of the sprcy colutions r.ust be studied in de tail. " (Emphasic added.)
While the actters-raised in the reports discusced in the Initial Decision nust, of cource, be concidered in the finci evaluction of the containment spray system, they do not, t>cr Ic,, support the Eocrd's conclusions that the systc:a uill not cchieve the neccesary reduc-tion factors. The quection of the stability of the spray solution cnd the g'cncration of rcdiolytic h,drogen are i'ncluded in the applicant's research and develope.cnt program. The r2 ports referred to by the Board do not provid'e a reasoncble basis for its recom-mandation that the construc'tian pernit for the Crystal niver
. facility be conditioned to require a further hearing.
The Board citcc the Florid: Pouer cnd Light case in support of its rococracndation that a condition be included in the Crystal Riv r coactruction permit.
(I.D., p.10, footnote 10.) g/ In
}/ The Docrd seems to suggcet that thic reco: acndation ic justified 2 beecuce. this proceeding is "contosted".
(I.D., pp. 10 and 19.)
ihe-Eocrd did not c:: plain why matterc chould be considered in 3
another public hearing in a "contestad" cccc and not in cn "uncon-tested" cace. ' In thic ccsc the intervention by Gainesville, uhich provided the only basic'for making thic case "ccatcated", relcted
.colely to'the jurisdictional issuc uhether a provisionci conctruc-tion permit.cey be granted under S 104 b. of the Act, cnd the Board specifically limited the intervenors' pcrticipction to the (Continued)
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-that case the nacrd imposed a condition in the conctruction permit
, requiring c ' further hearing uith respect - to certain citern.tive safeguard fccturca, including contcit.nent cprny cud cherecci filtern, required to reduce tho' concent.rctionc at the cite boundcry to Pcrt
-100 limits if' additional tacteorologieni informatioa indicated that such radicactive safegucrd featurcc t:cro noccascry..The Cc=c.icsion, citer noting that the Board did not have the cuthority to direct
' the holding of hearings following the iccuence of'c construction
. pentit, resanded the proceedings to the Locrd for the purpose of rocciving cdditional eva.dence with regard to the alternative
.safegucrds.
(Foo tno to 8 con ' t. )
jurisdictional questica. There is no controvercy crong the parties to this proceeding with' respect to the iodine recoval question. In this connection, S 6(c)(2) of Appendix A to 10 CFR '2, "itules of Prccticc", provides that:
"In c.,nsidering thoce icsues, however, the board uill, cc 'to cctterc not in controversy, be ncither required nor expected to duplicate the revicu already performed by the Co:cission's regulatory staff and the ACRS; the bocrd ic cuthorized to v
rely upon the uncontroverted tectimony of the regulctory staff cud the cpplicant and the' uncontroverted conclusionc ' of the t.CRS.'.'
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14 In the Florida Pouer and]Linht; caco, houcver, the cpplicant choce to' rcly solely on its ' expectation that additional meteoro13-gical information could establish that the additional cafety JIcaturce are not required. The record contained no evidence con-cerning the cdequacy of the alternative cafety featurec. The applicant did not propoco a reccarch and develop cnt program to resolve any quections which might have been out tanding with respect
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to such safety featuren. 'In thic case, the record containc an abundance of evidence concerning the proposed containment sprcy a
system cnd the research and development progrcm proposed with respect: to tlhat cystca.
Another case in thich the Cox:aicslon directed further. hecrings follouing an Initial' Decision cuthorizing the iscuance of a condi-tioned. construction perait, the Malibu case, 9/ provides no support for the Bocrd's.recoauendation in this casc. As stated by the Cozmiccion in the F_lorida Power cnd I.inht case:
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"...the alternative engineered safeguards.. 10/
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- cre hardly comparable either in their basic
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In tho' Matter of Department of Unter and Pouer, City of Los Annoles, -3 AEC 179, March 27,1967.
10/ - As indicated ab6ve', one of the enginecred safegu:rds was a containment spra'y systcu for the reduction of iodine.
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_I relationship ~ to the structure of ~ the facility or in their safety implientions to the natter of protection ancinct differential ground dic-placcuent dealt uith in our Malibu decicion."
'The.uce of containment sprays for the removal of radiocctive
~ iodine has been' proposed in many previouc fccilitiec which have been approved for construction, e.g., Wisconsin Electric Power l
Company and Wisconsin Michigan Powe'r Company, Point Becch Units I cnd 2.-
Morcover, as indicated above, the propoced Crystc1 River fccility is identical to the facility recently. approved
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for construction by the Met'ropolitan Edison Compaby.
A contain-
. cont: spray system using the same iodine "f t::ing" additive to reduce iodine -concentrations is alco propoced for the Metropolitan Edison facility. Tlic deceription of the chemical cpray system and the proposed'research and develop =cnt progrca uith respect to the systou contained in the Metropolitan Edison cpplication was incor-porated in the record of this proceeding by reference. In cddi-tion, this record contains discuccions of the results of so=e of
'the resecrch and development studics-Ohich ucre not cvailcble at L tho time of the hearing on the Metropolitan Edicon facility.
The Initicl~ Decision of clu Eocrd, in the Metropolitan Edison case iscued May 16, '1963, which hss since become the fincl uccision s
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. ~ f the Cox.:lcr.icn,:cutLc.rized ti c' iocucnce of cn "uncondition:.d" o
provicional coastreet. ion perrJ t.
Th:. construction pernit hr.c been iscued cud t.'ie facility is nou under construction..
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The Ceminaion's EntsblichedJr_ocedures Arc l.dsy..te The objectivo cppcrently sought to be achieved by the Eccrd's reccx.endedon c:n be cchieved under the Comicsion's cctabliched precedures. In cecord uith thece procedures, the infornccica.
developed in the recccrch and developnent program and the final design -of' engineered cafety features for the Cryctal River facility
- uill b'c submitted as part of the cpplication for an operating!
licence. If the Cc=iscion, for any reason, determinec that a'
- further hearing is desirable, or if any member of the public whose intercct night be affected requests a hecring, c further hearing can be held at that tiuo. In any event, the results of the reccarch c.nd development program and the final design of the engineered safety featurcs, including any alternative safety featurcs, cuch as chcrecal filters, will be revicued.by the staff and the ACRS cs part of their revicu of the application for an operating liccuse.. Tbc situation presented in this case uith J respect to the containment spray. system is essentially no different from the situation' in ncny other cases in which a research and =
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i developuent pregram ic required to cctablich core definitively the adcquacy of n' safety feature.
_ Conclusion The staff rcepcetfully requests that its exception: to the
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Initial Decicion be granted and that the Coreaiccion reject the reco::acndation of the Ecard that the construction pcrait incued to Florida Pot:cr Corport. tion be conditioned to require a further public hearing concerning the use of. the containment spray as an iodine absorber, a
Respectfully submitted,
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Gerald F. Iladloch Councel.
AEC Regulatory Staff
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Dated at Ecthesda, Maryland,
- this 14th day of October,1968.
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