ML19329D517
| ML19329D517 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/29/1968 |
| From: | Fairman J FLORIDA, STATE OF |
| To: | |
| References | |
| NUDOCS 8003160117 | |
| Download: ML19329D517 (12) | |
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ATOMIC ENERGY COMMISSION .-
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In the Matter of )
Florida Power Corporation ) Do chet No. 50-302 (Crystal River Unit 3 Nuclear )
Generating Plant)
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PROPOSED FINDINGS AND CONCLUSIONS BY INTERVENORS, CITY OF GAINESVILLE, FLORIDA, AND GAINESVILLE UTILITIES DEPARTMENT Pursuant to Part 2 o f the Commission's Rules and Regulations, Section 2.754, the City of Gainesville, Florida, and the Gainesville Utilities Department ("Gainesville") hereby submit 6
its proposed findings of fact and conclusions of law.
4 Findings of Fact 'c
- 1. The Crystal River Unit 3 nuclear generating plant
' is based upon the design and operating experience of prototype and I
large electric power production pres- -ized water reactors ("PWR's"),
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. evolution of the latter having commenced thirteen years ago with i
Indian Point No.1 (Consolidated Edison). (Tr. 245). During twelve of these last tilrteen years the Applicant has been engaged in watching and evaluating.the progress the industry has made (Tr. 131, 251-52).
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The Applicant now has filed for a license to operate under Section 104(b)
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of the Atomic Energy Act of 1954 (Tr.125), which class of license covers "a production or utilization facility involved in the conduct of research and development activities leading to the demonstration of practical value. " (10 CFR 50.21(b)).
- 2. "The Crystal River Design is based on this existing power reactor technology and has not been extended beyond the boundaries
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of known information or operating experience. " (PSAR Vol.1, Section
- 1. 3, p. 1 -4). In fact, the marked uniformity (See genera 11yf PSAR Vol.1, Table 1-2, and Section 1. 3, pp.1-4 to 1-6) of the core mechnical design parameters, when compared with the Duke Power Company's Oconee units (Docket 50-269 g. seq.), Metropolitan Edison's 3 Mile Island i
Station (Docket 50-289) and Florida Power and Light's Turkey Point i Project (Docket 50-250) is due to the optimization of operating parameters i for this type of reactor (PSAR, Vol.1, Section 1. 3, Item 2, p.1-5).
, 3. 5te' search and Development.
There is submitted by the Applicant a list of R & D
- programs numbering eight items:
a) Once Through Steam Generator b) Control Rod Drive Unit .
c) In-Core Neutron Detectors
'd) Core Thermal and Hydraulic Design .
e) Emergency Core Cooling and Internal Vent Valves
- / Preliminary Safety Evaluation Report l
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f) Fuel Failure g) Xenon Oscillptions h) Sodium Thiosulphate
, (Applicant's Exhibit A, pp. 22-25, following Tr. 264; also Safety Eval. Report. pp. 58-60, following Tr. 276).
"Mr. Chairman, in the entire list of R & D items, all but the sodium thiosulphate are essentially the same items listed in the Oconee application. " (Tr. 333). The sodium thiosulphate exception i
is a design feature of the 3 Mile Island (Metropolitan Edison) plant.
(Tr. 333).
- 4. "So-called" R & D (Tr. 69).
a) Once Through Steam Generator.
This is asserted to be a new design based on ten years of work by Babcox and Wilcox ("B&W") on boiling heat transfer (PSAR, Vol.1, Section,1. 2. 7, p.1-4; Applicant Exh. No. 1, p. 2 3).
The reactor system is essentially identical to the Duke Power (Oconee) units and Metropolitan Edison's 3 Mile Island plant (Tr. 141, Safety Eval. Report, p.11 following Tr. 276), and includes the steam generator, control rod drive, pressure vessel design and the core thermal and hydraulic design (Tr.141). The nuclear steam system supply is similar in design to other units now in operation or under construction (Tr. 244-45).
Further, the~ steam and power conversion systems are similar in concept
and design to turbine-generator cycles in successful use for many years (Applicant's Exh. A, p.18). " Blowdown" tests required of the steam generator system show that even a simultaneous " blowdown" will not damage the steam generator or jeopardize the integrity of the reactor coolant system (PSAR, Vol. 4, Supp. No. 1, p. 8). The response of the reactor and feedwater system is documented in the Duke Power Oconee project (Docket 50-269, g. seq. ) (Ibid. )
b) Control Rod Drive.
No unusual problems (Safety Eval. Report, p. 18, following Tr. 276). There is nothing new when compared with the Oconee unit (Tr. 341) and 3 Mile Island (Tr. 342). The same tests are being run "for all the plants that have been previously licensed. " (Tr. 343).
c) In-Core Neutron Detectors.
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' Prototype detectors are currently under test in c onnection with the Big Rock nuclear plant and the results will provide predictable characteristics (PSAR, Vol.1, Section 1. 5. 3, p.1-27).
In fact, these tests have accumulated forty months of equivalent operation and have demonstrated the successful development of the detectors for use in pow er reactors (Tr. 320).
d) Core Thermal and Hydraulic Design.
This item was asserted to be, in addition to sodium thiosulphate, the second "new" R & D program (Tr. 345), but
in fact, means exist today for predicting thermal performance that demonstrates the adcquacy of what the manufacturer proposed (Tr. 346).
More significantly, with regard to the Crystal River unit, the parameters involved amount only.to a " scaling down" and do not alter the safety related characteristics (PSAR, Vol.1, Sc : tion 1. 3, Item 1, p.1-4). The peak specific power level of 17. 5 kw/ft (Safety Eval. Report, p.15, following
'fr. 276) is comparable to other reactors of this size and therefore does not represent an extrapolation of technology (PSAR Vol.1, Section 1. 2. 3,
- p. 1-2).
e) Emergency Core Cooling and Internal Vent Valves.
Vibrational " experiment" on the vent valves will verify the vibration analysis presented in Docket 50-289 (3 Mile Island),
which indicates the valve will not open due to vibration (PSAR, Vol. 4,
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Supp. No. 2, Informal Question No. 6). Turbine stop valves which have been used in 200 turbine generator units (400 valves) since 1950 will be used as steam isolation valves in the proposed Crystal River plant (PSAR, Vol. 4, Supp. No.1, p. 6).
f) Fuel Failure.
Evidence that fuel rod failure during ioss-of-coolant accident had no significant affect on the ability of the ECCS to prevent clad melting was required in the Oconee and 3 Mile Island. plants (Tr. 322).
4 Preliminary work completed in January,1968, confirmed analytical '
conclusions. What fuel cladding deformation occurs will not impair the performance _ of the core cooling system (Tr. 323).
g) Xenon Oscillations.
The Licensing Board understands this to be "one
-l of the oldest'R & D items" (Tr. 335) and r ay predate 1958 (Tr. 332).
B & W concedes this is not a serious public safety problem and has demonstrated its belief that the plant can operate and " live with these xenon oscillations" (Tr. 337). It is more of a detailed operating t
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problem (Tr. 338) and not considered R & D (Tr. 339).
h) Sodium Thiosulphate.
- In response to the Licensing Board's inquiry as i
to whether there are complications -(Tr. 72) connected with the area, the Applicant responded with reference to Docket 50-289, Metropolitan Edison's 3 Mile Island project (Tr. 324), and work by the Oak Ridge I
[ Na'tional Laboratory ("ORNL) showing the substantial effectiveness of i
the spray system (Tr. 325-26). The system proposed is fifty times more effective than 10 CFR 100 requirements (Tr. 327). B & W 's, 1
"R & D" program is for the purpose of confirming prior results 1
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A mixture of sodium thiosulphate and boron solution does not present complicatioqs of itself (Tr. 359). From a safety stand-point redundancy in the co rtainment cooling system provides adequate cooling should either the spray or the fan-cooler system be completely inoperative (Safety Eval. Report, pp. 42-43, following Tr. 276). Use of sodium hydroxide as an alkaline agent is reported in the literature (Tr. 477).
Sodium hydroxide alone presents no storage or handling problem and it has been used by the Applicant in the normal course of water treatment (Tr. 481). There is no storage problem when dealing with a mixture of sodium hydroxide and sodium thiosulphate (Tr. 484, 487-88). As the Applicant clearly stated, this aspect of plant design is not the laboratory problem of an analytical chemist; no spray clogging due to precipitation is anticipated and the reagent will be available in quantities several I hundred fold in excess of what is required (Tr. 477-78).
- 5. Fan Coolers.
Fan cooling bearings (a stated concern by the Board, Tr. 414) are to be tested in connection with 3 Mile Island (Tr. 415).
Furthe r, "there are a number of fan assemblies installed in each of the pressurized water reactor types that are under construction today which we (Staff) are going to perform the full system tests of the integrated unit, and we will have that information available to us long before Crystal River becomes an operational matter" (Tr. 419). Motor insulation will have been demonstrated to withstand radiation exposure L #
greater than expected during lifetime or a design basis accident (Safety Eval. Report, p. 22, following Tr. 276).
- 6. Reactor Building.
It is essentially the same design as the containment buildings for Turkey Point (Docket 50-250), Oconee (Docket 50-269,
- g. seq. ) and 3 Mile Island (Docket 50-289). Several engineered safe-guards are similar "and present neither uncommon solutions to en-gineering problems nor significant extrapolations in technology. "
(PSAR, Vol. 1, Section 1. 2. 4, p.1 -2 revised April 8, 1968).
- 7. Reactor System.
The reactor ' system chosen is a practical type of proven design. (PSAR, Vol. 1, Section 1. 7(b), p. 1 -28,29).
- 8. The Oconee and 3 Mile Island construction permits precede the proposed permit for Crystal River (Applicant's Exh. No. 1,
- p. 2, following Tr. 264) and the first Oconee unit will be in operation by 1971 (Tr. 289), a year ahead of the vital 1972 in service date for J
Crystal River (Intervenor's Exh. No.1).
- 9. Florida Power Corporation Representation of the Proj e ct.
It is a prudent investment for the purpose of serving the public with timely, continuous, reasonably priced electricity (Tr.. 200-201),
needed in 1972 to perform this public responsibility (Tr. 202). A prime requirement is that the plant operate continuously to supply reliable electric power to the company's customers (Tr. 255). Indeed, this in-
- sta11ation is of vital importance to the reliability of the system. Without the Crystal River unit " installed capacity margins are less than the
., .. .s operating reserves required for reliable operation, thus leaving no margin for maintenance outages, forced outages or forecast errors. "
(Intervenor's Exh. No.1). -
Nuclear power plants are quite similar to fossil-fired plants Florida Power is now operating (Tr. 249). Evaluations are made on unit size and operating economics expected during the life of the plant (Tr. 290). In , regard to evaluation of nuclear plants, except for the magnitude of the' licensing activity, one deals with criteria that are identical to other steam plant additions (Tr. 290-91). Evaluations leading to the selection of the Crystal River plant design indicate generating costs lower than any fossil-fired plant on its system (Tr. 310).
Competent management is of the opinion that the reactor will operate continuously, excluding refueling and maintenance periods (Tr. 255), and that the project will be successful (Tr. 310).
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This judgment is reflected by the fact that financing of the project will be an-integral part of the company's five year construction program and viewed in the usual art of planning public utility expansion programs (Tr. 229). No consideration was given to the financial con-aquences should the project not operate because of failure to conform
The nuclear plant was assigned a lifetime (40 years) j capacity factor of 80 percent, implying much higher values f.or portions i g of its period of operation (Tr. 293-95). For the design, construction,
4 testing and operation the Applicant will follow practices used success-fully with major generation facilities now in service or planned (Tr. 253).
Conclusions of Law The Intervenor, Gainesville, upon consideration of the foregoing findings and in light of the record in this entire proceeding conclude that:
- 1. The Licensing Board in its order of June 23, 1968, and during the course of the hearing, imposed an improper'.y narrow restriction on the scope of the testimony relevant to the showing of practical value in connection with this proceeding in which the Applicant
. proposes to qualify under the provisions of Section 104(b) of the Atomic
/ Energy Act (42 U.S. C. 2134). The record maker manifest the real character of this project, namely, that this unit is evaluated just as are
- fossil-fired plants and the selected criteria cause the Applicant to choose I this unit as more economical than any plant on its system (Finding of Fact No. 9).
- 2. The Licensing Board erred in its refusal to enlarge the issue to be determined so as to include the matters requested by i
Intervenor's motion of June 14, 1968. Section 105(a) exempts "nothing contained in this chapter" from the operations of provisions beyond the narrow question of jurisdiction. (42 U. S. C. 2135a). l
- 3. The term research and development means "(1)
' theoretical analysis, explanation, or experimentation; or (2) the
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extension of investigative findings and theories of a scientific or
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technical nature into practical application for experimental and demon-
- stration purposes, including the experimental production and testing of models, devices, equipment, materials, and processes. " (42 U. S. C.
2014(v)).
The application is void of any program that is unique to Crystal River (Findings of Fact Nos.1 - 4). The racord clearly indicates through admission by the Applicant the project "has not been extended beyond known information or operating experience. " (Findings of Fact Nos.
2 - 7). In contrast to the Duke decision (Docket No. 50-269, y sec.,
' January 3,1968) where the Commission referred to " scaled-up" plants and included them within the purview of Section 104(6), the Crystal River unit design is " scaled-down. " (Finding of Fact No. 4d).
- 4. The Applicant seeks to come within the provision of Section 104(b) through wh olesale incorporation of so-called research and development programs from the Oconee and 3 Mile Island projects.
(Findings of Fact No. 4). The demonstration of practical value called for in Section 104(b) w~ill coincide with the operation of 3 Mile Island i
and Oconee plants well before Crystal River is in service (Finding of Fact No. 5, 8). Even the original intention manifest in Section 104(b) belies the propriety of the Applicant's submission in that "In issuing such licenses, priority:shall be given to those activities which will, in the i'
opinion of the Commission, lead to major advances in the application r
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of ' atomic energy for industrial or commercial purposes. " (42 U. S. C.
2134).
- 5. The Intervenor reserves its rights as to the doard's errors in limiting the intervention of the undersigned parties to the issue of whether the nuclear reactor facility proposed to be constructed and operwted by Florida Power can be authorized pursuant to Section 104(b) of the Act (Board's Order, June 28,1968, p. 4), and in denying its motion to enlarge the issues.
Respectfully submitted, CITY OF GAINESVILLE, FLORIDA and GAINESVILLE UTILITIES DEPARTMENT By h. .
hw mes F. Fairman, Jr.
heir Attorney [
2600 Virginia Avenue, N. W.
July 29,1968 Washington, D. C.
{
Law Offices:
George Spiegel 2600 Virginia Avenue, N. W.
Washington, D. C. 20037 i
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