ML19329D538
| ML19329D538 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/14/1968 |
| From: | Hadlock G US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| References | |
| NUDOCS 8003160137 | |
| Download: ML19329D538 (17) | |
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ATCJIC ENT.RGY CG3ISSION In the 1:atter of
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i 7_CTpe Sta ter.ent of the C.nce Thic proceeding involves the cpplicaLion of P,lorida Po: cr Corporation (cpplicant), dated August 10, 1967, cnd five caend :ents thereto- ("the applica t*on") filed under G 104 b. of the Atcaic Energy Act of 1954, cs amended (the "Act"), for a construction c
permit to construct a prescurized veter recctor designated Crystal River Unit 3 and designed to operate initially at power icvols up to 2452 mescuatts -(thercal), to be loccted on the applicant'c 4,738 cero site located on the Gulf of 1:cxico chaut 70 miles north of-Tce.pa, Florida, and coven and one-half uiles north of the Toun of Crystal River, Florida.
The application Aes revieued by the regulctory staff (acc.ff) of the Atomic Energy, Cot:.11scica (Cc.caiscion) cnd the Ad. ;cory Committoc on Reactor, Safeguards ("ACRS"), both of which concluded D**]O
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constructed and operated c t L1.:
propocod site withcut unduc rich.to the hecith end.ccfety of the public.
A notice of hecring ucc issued on May 29, 1958, designeting
. an Atemic Ccfety and Licensing 22ard ("2aard") to cor. duct thic proceeding to determine thother a provisional construction permit should be iccued to the cppliccat.
By Order dated June 23, 1960, the Ear.rd granted a Petition to Intervene filed by the City of Gainesville, Flo?cida, and the Ccinesville.Utilitics Depcrt=cnt ("the intervenors"), but limited
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the intervenors' pcrticipa tion to the quection of the juricdiction of the Cc=aiccicn to iccue a consti*uction permit under 5 104 b.
of the Act, 1/ A Motion to Droaden Iscues filed by the intervenors was denied. As c recult of this intervention, the proceeding is -
a contcoted procccains ac defined by 10 CFR S 2.4(n). The State of Florido cico wec permitted to participcte in the proceeding
' purcuent to 5 2.715(c) of the-Connicsion'c " Rules of Practice",
10 CFR Part 2, but did not oppoce the grcntin; of the applicction.
1/ There is no controversy crong the pcrties uith recpect to cny other retter in iccue in this proceeding.
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The Eoard icaued itc Initici Decicion on Septcaber 24,19CS,
' directing the issuance of a provicion:1 conctruction per.?.it for the proposed Crystal River Unit No. 3, but recornendin3 to the Couniscion that a. condition be added to the conceruction permit to requiro "that data be developed upon a record c:dc et a public
~ hearing in this contested ecsc concerning the uce of cither a chenical sprcy as an ' iodine fixing additive' or other deviccc for purpocco of controlling the relcaco of radioactive iodine...".
(I.D., pp. 10 and 19.)
In accordance with the provisions of 5 2.762(c) of the Com-miccion's "Jules of Practice",10 CFR 2, the staff has filed exceptions to the Initial Decision.
II Arnument
..A.~ The Record In This Case Supports The Issuance Of An Unconditioned Provicional Construction Porait Pursuant Ta S 50.35 Of The Conniccion's Renulationc The containuerit cpray cystem which will be incorporated in the Crystal River facility is designed to limit containment preocurec to decign values following an assumed loss of coolant accident and to reduce the level cf fission producto in the containment building 3
atcosphere. The description and evaluation of this engineered Bafety l
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. fecture are contcined in the Prolinin.,ry Scfety Anclycis Report (PSAR) cubuitted uitif the applicction.
(PS.'.R, Vol'. 2, Section 6, peregraph 6.2.)
To' reduce the cuount of radiocctive iodine avcilcbic for lechsco frca the containment, the applicant propoccc to ir.joct an iodinc fining caditive into the containment cprcy unter. The cdditive proposed ic cn c1hcline buffered colution of codiua th.u-sulfcte. 2/ Sinec the propoccd Cryctc1 River recctor is identiccl to the rccctor approved in the Metropoli ten Edinoa' ccsc, 3/ the applicction incorporates by reference cortnin portionc of the cpplication cubaitted by the Metropoliten Edicon Company relcting 2/. The Eocrd ccome to imply in its Initici Decision, particulcrly footnote 8, page 9, that the cpplicant'c propocci to uce an
. c1hcline colution of codium thioculfate beccue knoun to the Bocrd for the firct time et the hearin3 Houever, it ic cicar from the applicction, particularly the portion of the Metro-politen Edicon opplicction, Docket No. 50-289, uhich uce incorporated in the Cryctal River applicction by reference, tha t,
the additivo prepoced use to be an alkcline colution of codium thioculfcte thich would be unintcined in cn alkcline condition by the addition of sodium hydronide or other ctmilar chcciccis.
In any event, the testicony c1ccrly indicctcc that the cpplicant had clunya intended to uce such c combination solution (Tr., pp.
473, 476-7) cud that the staf f ucc cucre of the appliccnt's intention and had cyclucted the sys tem on this bccis.
(Tr.,
pp. 360-63, 477.)
3/ In the IMtter of 1ptrepoliten Edison Cenonny, Dochet No. 50-259.
The Initici Decicion of the Atcale Safety cnd Licensing Bocra in this case, iccued Mcy 16, 1968, becccc the finci Decicion of the Comniccion on July 1,1968.
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- 4.. to the use of ch;;d' sprcyc. Thic portion of the cpplication diccusccc the design c:.teric for the propoccd cheaical spr: y cnd providec c li e
reforcaces thereto.
(necpence to c;ucction 5.13, Metropolitan Edicoa appl.icction, Dochet No. 50-259, Supplement 1, pages 5.13-1 throug!. 5.13-3.)
In addition, the cpplicction con-tainc c detailed deceription of the cc:.grchencive recocrch cad develor:: cat progrca being carried out by the cpplicent'c contractor,
-'thbcoch cnd Uilcon compcny, to octchlich the effectivenecc of ti.c clhci.ine codium thioculfate solution no en iodiric absorber, es ucil ac the etcbility cnd cc pctibility of the colution under accident conditions. (Responce to quection 17.4, Metropolitan Edicon cpplicction, Supplccent 3, dcted December 8,1967, Dochet No. 50-209, pcccc 17.4-1 through 17.4-8.). The program relica on experimento by Och Ridge Nctimm1 Leboratory to estchlich renoval ra te s.
A lict of the exps ciments to be conducted is cet forth in thic cpplication.
(Addendu: I to the responce to question 17.4 in the Metropolitan Edicon cpplicction.) In addition, the Echcock and Wilco:: Company has under ucy a reccarch cnd development progran to deconctrate the compatibilj ty of the solution with the boric acid which is cico procent,in the spray solution.
(Tr., pp. 492-3.)
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. The reguintory staff reviewt. the proposed research cnd development prograu and concluded that the applicant's procrcu, in conjunction with the current studies under uay at the 00h Ridge National Laboratocy,should catablis_h that the reduction factors necessary to reduce the iodine concentrations at the site boundcry to Part 100 guidelines could be cchieved or exceeded.
(Ssfety Evaluation, pp. 42 -5.)
In fcet, the reports on several of the experiments conducted at the Oak Ridge National Laboratory had become availabic by the
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time of the hearing and were referred to on the record. The applicant testified that a preliminary evaluation of the results of those enperiments indicates that they substantiate the effective-ness of the chc=ical spray system.
(Tr.,p. 325.) Refercacca were provided to reports which demonstrate that under unny varying con-ditions, including temperature, io' ine concentrctions, steam content d
in the atmosphere, spray solution ecmposition, spray nozsics,' spray flow rate and spray solution temperature, the iodine,rczoval rates An have been Creater then those set forth in the cyptication.
experiment at the Nuclear Safety Pilot Plant at the Oak Ridge National Laboratory, under conditions closely approxicating post accident conditions *, indicated an iodine removal rate constcnt of 4
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i 81 per hour which, when extrapolated to the Crystal River building conditions, indicates an iodino removal rate constant of about 100 per hour, uhich ic cpproximitely four times greater than that ascumed in the cpplication and approximately 50 times greater thcn that required to nect Part 100 guidelines. The applicent provided I
cdditional references to experiments relating to the stcbility of the spray solution.
(Tr., pp. 325-30.)
The rer:enrch and development progrca relating to both the iodine absorbing ability of the chemical spray and to the stchility and cocpatibility of the solution will be continued both at the Oak Ridge National Laboratory and by Babcoch cnd Wilcox and others.
(Tr., pp. 325-30, 361 and 492.)
In the event the research and development programs do not cctablish that the cpray system is acceptable for iodine rceoval, alternative c2cnc to reduce iodine concentrations at the cito boundary will-be er. ployed. Charcoal filters cud redu'ction of the containment icak rate are caong the alternativco that could be used.
(PSAR, Vol.1,' Section 1, paragraph 1.3, item 11; Scfety Evaluation, p. 45.)
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Section 50.35 does not require that all design details of the facility east be supplied ct the construction permit stage, nor that every cafety question must actually have been actis-factorily resolved at that stage. 4/
4 The record in thic proceeding fulfills all the requirements of f 50.35 of the Comiccion's regulations for the iscucnce of ca
- unconditio'ned provisional construction peimit. As indicated cbove, the cpplicant has deceribed the proposed design of the containment spray system cnd outlined a comprehencive research cnd development program to recolve any questions remaining con-cerning the effectivences of the sprcy system to absorb radio-active iodine, its etcbility under accident conditions and com-patibility uith other parts of the system. If, for any reccon, the spray cystem is not ceceptabic, charcoal filters can bc installed in' thc. facility to reduce the iodine availabic for relence to the environment.
4/ In the Metter of Jercey Contral Pouer ent Linht case, 3 AEC 28, May 6,1965; In the Matter of Florida Pouer cnd Light, 3 AEC
. August 4, 1967.
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B.. There Is No neaconable' Banic Set Forth In The Initial Decicion
- To Simport Donrd's neccv nnda tion
'In support of itc recorct.:endation that a condibion bc included
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in, the construction permit for the Crystal River fccility, tho
' Board relics on certain unspecified reports of cxperimente con-ducted at the Och Ridge National Laboratory. 5/ The Locrd ctates at page 8 of the Initial Decision that:
"[T]he.vork which hac been undertchen [preau= ably by the Cah Ridge national Laboratory]- to this tico 1cnds doubt uhother the [containcent cpray solution proposed by the applicant] cchievc=
the necessary iodine radiocctive factor,s."
Again, at pcce 9 of the Initial Decision, the Bocrd states that:
"The Oak Ridge Nationc1 Laboratory reports indi-ca te. tha t neither of the applicant's chenicci additivcc for sprays vill achieve the neccccary reduction factors."
5/_ Purcuant to the Bocrd's request, the staff suir.aitted a list of references to reports on the effectivencas of the con-tainment sprays ucing a chenical cdditive as an iodine absorber. The applicent also made reference to various reports in its application and tcctinony' The Eoard did not request co.r.ments from the applicant or the staff with respect to any of these reports. Our response here is directed at those reports to which we ascune that the Bocrd was referring in the Initial Decicion.
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..s The Eccrd seems to baco these conclusions on a report to the effect that such chcraical solution "und:rgo radiction docc=po-sition..." during recirculation cooling of the renetor, s/ The possibility of radiation' instability, houcvcr, was recot;niacd by the appliennt and its reactor supplier and was considered by the staff ir. its revicv. The research end developuent progran proposed by the applicant includes a thorough investi[,ation of this rate.r.
(Tr., pp. 325-30 cud 492.)
1:orcover, the ct ff's cciculations of the iodine reuovc1 capacity cvallabic for the Crystal River facility would not be affected by the reduction of total iodine ccpccity on the crder of that set forth in the Initial Decision for the sprcy solution proposed. These calculations catablich that Leccuce of the largo e
excess of reagent avcilable, the reduction factors neccsecry to lirait iodine concentrations at site boundaries to Part 100 guide-f/ CEL-4228, Nuclear Sofety Progrc a, Annuci Progress Report for Period Ending December 31, 19 67_, p. 23 2.
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. lines could be cchieved with only one of the two.contaire.:ent sprays.
(Scfety Evaluatio;i, pp. 43 cud 56.)
/.o.cn cdditional factor of conservatism, the staff's calculations also assumed that 10 percent of the iodine in the contain=cnt ucs non-:cmovable by
- sprays. - (Tr., pp. 3 65-66.) -
The Bocrd also refers to d:ca in an 02WL report concerning the production of hydrogen gas uhen the chemical additive is exposed to radiation. The Board quotes from the report as follous:
"The results obtcined to date in the study of the va,rious proposed sprcy solutions indicate that radiolytic 112 #s produced in quantitics sufficient to be of concern in the proposed spray systen." 1/
Following the sentenec quoted by the Board, the report indicates H
that cnother study had been initiated to detcraine the feasibility of using other cdditives to decrease the radiolytic hydrogen produc tion.- The report then continues:
I'...the nitrate ion is known to,louer the radiolytic hydrogen yield by scavenging the hydrogen atom. Therefore, a brief study e
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, of the effects of cuch addad nitrcte uac ncdc....
The detn chet.:n a definite decrecce in radiolytic lip _ product _igt3 uith increccing NO3 - concentration. Uowever, while th'ecc data indicate that the radiolytic H2 ' pro-duction mcy be reduced by addition of 'scaven-gers,' the question of the compatibility of such cdditives uith the uccco and purpoco of the cprcy solutions nust be studied in de tail."
(Emphasis added.)
While the :stters rcised in the reports discussed in the Initial Decisiot$.nuct, of cource, be concidered in the finct cycluction of the containment spray system, they do not, por go, support the Board's conclusions that the syctcm will not achieve the t}ccccsary reduc-tion factors. The quection of the stability of the spray solution
'and the g'ncration of radiolytic hydrogen are i'ncluded in the c
applicant's research and developa:nt program. The reports referred i
to by the Eocrd do not provide a recconcble basis for its recom-mendation that the construc' tion permit for the Crystal River facility be conditioned to require a further hearing.
The Board cites the Florid 2 Pouer cnd Linht case in support of its reconriendation that a condition be included in the Crystal River conctruction permit.
('I.D., p.10, footnote 10.) 3/ In 3/ ' The Docrd seems to suggect that thic reco::acndation ic juctified boccuce this proceeding is " contested".
(I.D., pp. 10 and 19.)
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The Board did not e:: plain why t:2tecro should be considered in another public hearing in a " contested" case and not in cn "uncon-tested" cacc. In thic case the intervention by Gninesville, which provided the only basic for mhing thic case "centested", relcted colcly to the jurisdictional issuc uhather a provisionni construc-tion permit may be granted under 5 104 b. of the Act, cnd the Locrd specifically limited the intervonors' pcrticipation to the (Continued)
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~ hat cacc the nacrd impoced a condition in t".ic conctrucMo. peruit t
requiring a further hearing with rcrpect w certain citern.tive safeguard featurec, including contcinment cprny cud chcrec,1 filtere, required to reduce the concentrations at the cite boundary to Pcre 100 limite if cdditionci ucteorological infernction indicated that such radicactive safegue.rd featurcs i:cre necccscry. The Cc=ciccion, af ter noting that the Board did not have the authority to direct the holding of hecrings following the iscuence of'c conctruction pernit, re cnded the proceedinga to the Eocrd for the purpose of receiving additional evidence with regard to the citernative 7
safeguardo.
(Footnote 8 con't.)
jurisdictional question. There is no controvercy anong the parties to thic proceeding with respect to the iodine retraval question. In this connection, G 6(c)(2) of Appendix A to 10 CFR 2, " Rules of Practice", provides that:
"In considering those icsues, however, the board uill, cc to catters not in controversy, be neither required nor expected to duplicate the review aircady performed by the Coa 2:ission's regulatory staff ~cnd the ACRS; the board ic cuthorized to l
rely upon the uncontroverted tectimony of the regulatory staff and the applicant and the uncontroverted conclusionc of the t.CRS."
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l-In the Florida Pau.~r and _'L!".ht, cace, however, the cpplicr.nt chocc to rely solely on its 'expectatloa that additional ucteorolo-gical infort.ation vould establish that the additional safety
'fcaturec ucre not required. The record contained no evidence con-ccrning the cdequacy of the alternative cafety featurec. The applicant did not propoco a reccerch and developcent pro;;tnra to resolve any quections which uight have been outstanding with respect to such ccfety features. In this case, the record containc an abundance of evidence concerning the proposed contain=cnt sprcy systou cad the research and development progrca proposed with recpect to that cystem.
Another case in which the Co.::aission directed further. hecrings follouin, an Initial Decicion cuthorizing the iscuance of a condi-J tioned cons.. uction permit, the Malibu case, 9_/ provides no support for the Board's recor.uendation in this casc. As stated by the Comiccion in the Florida Power and I.inht case:
...the alternative engineered safeguards... M/
cre hardly comparabic cither in their basic 9,/
In the Matter of Departnent of Unter and Fouer, City of Los
' Anneles, 3 AEC 179, March 27,1967.
M/ As. indicated abdyc', one of the engineered safegu:rds vac c containment spra'y system for the reduction of iodine.
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. c relationchip to the ctructure of the facilicy or in choir safety implications to the matter of protection accinct differential ground dic-placcuent dealt uith in our Halibu decicion."
The use of containment sprays for the removal of radioactive iodine has been proposed in acny previous facilitiec Which have
-I been cpproved for construction, c.g., Wisconcin Electric Power Company and Wisconcin Michigan Powe'r Company, Point Bacch Units I cnd 2.
Morcover, ac indicated above, the propoced Crystal River fccility ic identical to the facility recently. approved for construction by the Metropolitan Edison Compaby. A contain-mont spray system using the same iodino " fixing" additive to reduce iodine concentrationc is also propoced for the Metropoliten Edicon 4
facility. The deceription of the chemical cpray system and the proposed research and development program with respect to the 4
system contained in the Metropolitan Edison cpplication uns incor-porated in the record of this proceeding by reference. In addi-tion, this record containa discuccions of the results of some. of the recccrch and development studies uhich ucre not availcble at
. t'he time of the hearing on the Metropoliten Ed', in facility.
The Initici Decision of the Eoard, in the Metropolitan Edison 4
ccsc issued May 16,'1963, which has since become the final Decision v
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of thc.Co naicsion, authorized the Locuence of an " unconditioned" provisional construction permit. The construction pcruie, hcc been issued and the facility 10 nou under construction.
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The Comir:aion's Es tabliched ry_ocedu;cs f.re t.derwr.t3 The objectivo apparently sought to be achieved by the Ecard's recommendation 'can be achieved under the Conmiccion'c cctablished f
procedures. In accord with thecc procedurec, the infornction developed in the research and developacnt program and the final design of enginecred safety featurcs' for the Cryc al River facility i
will be submitted as part of the application for an operating licence. If the Coc.r.iscion, for any reason, determinec that a further hearing is desirable, or if any member of the public whose intercot might be affected requests a hearing, a further hearing can be held at that time. In any event, the recults of the rcccarch and development program and the final design of the engineered safety featurcs, inclading any al'ternative safety featurec, cuch'es charcoal filters, will be revicued,by the staff and the ACRS as part of their revicu of the application for an operating licence. The situation presented in this case with respect to the containment spray. system is escentially no different from the situation in many other cases in which a research and 0**
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,. development pregram is required to cctablich teore definitively the adequacy of a safety feature.
Conclusion The 'ct ff recpectfully requesto that its exceptionc to the Initial Decision be' granted and that the Cortniccion reject the reco:cacuc'ntion of the Ecard that the construction pernit icceed 1
to Florida,Poner Corporation be conditioned to require a further I-public hearing concerning the use of the contain:acnt spray as an iodine abcorber.
Respectfully submitted,
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Gerald F. Undloch Counccl i
AEC Regulatory Staff 1
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Dated at Ecthesda, Maryland, thic 14th day of October,1968.
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