ML20055B284
| ML20055B284 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 06/07/1982 |
| From: | Jamarl Cummings NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | Ahearne J, Gilinsky V, Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML20049H240 | List: |
| References | |
| FOIA-82-272 NUDOCS 8207210165 | |
| Download: ML20055B284 (24) | |
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- June 7,1982 MEMORANDUM FOR: Chairman Palladino Commissioner Gilinsky Commissioner Ahearne
. Commissioner Roberts Commissioner Asselstine FROM: Jame J. Cummin s, Di c or Office of Insp ctor a Auditor
SUBJECT:
GA0 FINAL LETTER REPORT ENTITLED,
" REVISING THE CLINCH RIVER BREEDER REACTOR STEAM GENERATOR TESTING PROGRAM CAN REDUCE RISK" Attached for your information is the subject GA0 report.
GA0 conducted their review in response to a request by the Chairman, Subcommittee on Oversight and Investigations, House Committee on Energy and Commerce.
Because this report does not contain any recommendations to the Chairman, NRC, no response to the Congressional Committees is required.
Attachment:
Subj GA0 rpt dtd 5/25/82 cc: W. Dircks S. Chilk L. Bickwit C. Kammerer J. Fouchard F. Remick G. Cunningham H. Lenton R. Minogue H. Bassett V. Stello R. DeYoung P. Check T. Rehm CONTACT: Tracy Wiest, 0IA 49-24463
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May 25, 1982 B-164105 The Honorable John D. Dingell Chairman, Subcommittee on Oversight and Investigations Committee on Energy and Commerce House of Representatives
Dear Mr. Chairman:
Subject:
Revising the Clinch River Breeder Reactor Steam Generator Testing Program Can Reduce Risk (GAO/EMD-82-75)
Your September 2, 1981, letter asked that we review the technical outlook for several components of the Department of Energy's (DOE's) Clinch River Breeder Reactor (CRBR)--the Nation's first liquid metal fast breeder reactor demonstration plant. In February 1982, your office requested that we issue an interim re-This port on DOE's program for testing CRBR's steam generators.
report responds to that request.
Steam generators for liquid metal fast breeder reactors have had a history of serious technical problems. Small breeder re-actors in this country and demonstration breeder reactors in Steam foreign countries have experienced steam generator failures.
generators for the CBBR have also experienced a number of problems during their development.
Despite that history, DOE does not plan to conduct complete and thorough tests of the steam generator design to be used in the CRBR. Instead, DOE plans to conduct (1) a series of limited tests on a steam generator which differs significantly from those designed for use in the CRBR, (2) a vibration test on a one-third scale model steam generator, and (3) some inplant testing on a i
CRBR steam generator after all CRBR steam generators have been fabricated. Without conducting more thorough tests of the CRBR DOE is steam generator design before building the CRBR units, assuming _that the CRBR units will operate as predicted.
i If DOE is correct, the CRBR will be able to proceed on its current schedule, and the cost will be lower than if more complete and thorough testing were done. If DOE is wrong, the costs and delays associated with redesigning and modifying or rebuilding the CRBR steam generators would be substantial.
N m
(305178) l l
E-164105 CCE's decision to f oregc note thorough tests is based on (1) a belief that the tests that will be done can be extrapelated tc predict stear generatcr performance in the CRBR and (2) ccnfidence that the stean generator design will be successful. Conversely, the history Lf problens with steam generators and with develop-ment of the CRBR steam generators argues for a more conplete and thorough testing progran.
The following sections present the objective, scope, and methcdology of our review; a background on CRBR stear generators; our findings in more detail; and our conclusions and reconnenda-tions.
CEJECTIVE, SCCFE, AND METHODOLCGY Cur objective was to evaluateTo COE's currentthat accomplish prcgran for test-objective, ing the CRER's steam generators.
we reviewed the history of the development of the steam gener-ators, including the results of past tests and DOE's future plans for testing. We also compared the current CRBR stear generator design with the design of the Cocuments steam generators tested concerning the in the past testing and currently being tested. D.C.;
progran were obtained fron DCE headcuarters in Washington, the CRER Project Office in Cak Ridge, Tennessee; the Energy Tech-nology Engineering Center in Santa Susana, California; Westing-house Advanced Reactors Division in Waltz Mill, Pennsylvania; and the Atomics International Division of Rockwell International Cer-potation at Canoga Park, California.
We also discussed COE's testing program with the majcr con-tractors involved in the stear generator prcgran and with CCE officials. Information concerning steam generator development in foreign countries was obtained from CCE subcontractors and technical publications. To assist us in the technical aspects of this assignment, we enployed a consultant who has worked in the nuclear industry for over 30 years and who has an intimate kncwledge of liquid netal fast breeder reactors and steam generators.
The information contained in this report represents the test It should be infornation available at the time of our review.
recognized, however, that the testing progran changed during our review and, even at the time we issued this repcrt, COE was ccn-sidering other options.
We performed our work in accordance with GAC's " Standards for Audit of Governnental Organizations, Progrars, Activities, and Functions."
2
1 E-164105 BACKGRCUND CN THE CRBR AND THE CFBR STEAM CENERATCRE In 1970, the Congress authorized the Atomic Energy Commission (AEC) 1/ to enter into cooperative arrangements with industry to build and operate the CRBR. During the early and mid-1970s, great urgency was attached to the CRBR program because predictions showed that current generation nuclear reactors would be running out of uranium fuel by the year 2000. The CRER was initially scheduled to be completed by 1980 to permit a decision in the mid-1980s on commercial deployment of breeder reactors. We are currently com-pleting work on a report which addresses the options available for the timing of the CRBR. That report includes infctmation on a number of factors which have changed since the CRER was originally authorized. Specifically:
--Current COE data show sufficient natural uranium to fuel the light water nuclear industry well past the year 2020.
--Latest CCE data show breeders may not be economical until after the year 2025.
In commenting on a draft of that report, COE argued that it is imperative to proceed with the CRBR schedule--current plans are to have the CRER operating by 1990--and that any slowing of the program could lead to industrial disruption, constrained economic growth, and increased reliance on foreign energy sup-plies. While recognizing COE's comments and concerns over possible delays in its current program, we concluded that the changes in the f actors affecting the timing of when breeder reactors may be needed show that slowing the program has become a viable option.
Developing and demonstrating reliable steam generators have been and still are one of the most significant technical problems facing the CRBR project. Steam generators provide the transfer of heat from the reactor coolant to water, which is heated to steam to drive the plant's turbines. According to a Nuclear Regulatory Commission report, 33 of 45 operating nuclear plants with steam generators have experienced some form of steam generatcr problems.
During the 1970s, these problems caused about 21 percent of forced outages at those plants. Many of these problems are operational problems and are not related to design deficiencies or inadequate testing. It is obvious, however, that steam generators are the source of considerable problems in existing nuclear plants. In 1/The Atomic Energy Commission and the Energy Research and Cevel-opment Administration (ERCA) were predecessor agencies to CCE.
AEC was abolished on Jan. 19, 1975, and many of its functions were transferred to ERDA. ERDA's functions were transferred to DCE on Oct. 1, 1977.
3
B-1641C5 conpariscn to comnercial reactors, the steam generators needed for the CRBR represent a nere difficult challenge because scdiun is used as the reactor coolant. Sodium stean generators inpose severe nechanical stresses on the netal barrier between sodium and water within the steam generator. Even a small failure allowing contact between the two fluids raises the possibility of a fire or ex-plosion resulting from a sodium-water interaction.
Breeder reactor stean gencrator history According to Atomics International, the fabricator of the prototype steam generator for the CREF, many designs have been used for breeder reactor steam generators around the world. Aten-ics International maintains that problems have been experienced in all cases where the steam generator design has not been thor-oughly tested.
Snaller breeder reactors in the United States have experi-enced steam generator problems. For example, a stear generator in the Enrico Fermi reactor (near Detroit, Michigan) failed in 1962 when vibrations and other problems created holes in the retal tubing, allowing contact between the sodium and the water. Other countries have also experienced stear generator problems in breeder reactor plants. Structural integrity problems in a demonstration breeder plant in Russia caused leaks in four of six steam generators.
Similar problems delayed full power operations at the Eritish de-nonstration breeder plant when four of nine stean generatcrs leaked.
As recently as April 1982, the French demonstration breeder reactor was shutdown because two sodiun leaks in a steam generator caused a fire.
CRER steam generator program In 1974, AEC chose a steam generator design for use in the CRER that wac quite dif f erent f rom any previous donestic stean generator, and it was also different from the steam generators used in foreign breeder reactors. Curing 1974 and 1975, Atcmics International was selected to design and fabricate (1) two acdel steam generators, (2) a prototype steam generator, (3) nine stean generators fcr use in the CRBR, and (4) one backup unit. Until 1982, DCE's steam generator development program consisted of three major elements.
- 1. Testing the Model Steam Generators. The model steam gen-erators, tested in 1978, were full-length steam generatcrs but contained only 7 water-carrying tubes instead of the 757 tubes in a plant unit. The purpose cf testing the model steam generators was to obtain data en full power steam
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generator performance and endurance.
- 2. Testing a Frototype Steam Generator. The prototype steam generator, to be tested in 1982 and 1983, was 4
B-164105 originally to have been a full-size, 757 tube prototype However, changes to the of the CRBR steam generators.
CRPR design resulting from the testing of the model steam generators and subsequent design reviews could not be fully incorporated in the prototype steam generator and, as a result, the prototype differs significantly from the CRBR steam generator design. The original purpose of building the prototype was to verify the steam generator manufacturing process and to test the structural integ-rity of the prototype under simulated operating condi-tions. Prototype steam generator testing is proceeding on schedule.
- 3. Fabricating and Installing the CRBR Steam Generators.
Tne CRBR steam generators are the units which will ulti-mately be installed in the CRBR. As previously noted, the design of the CRBR steam generators has changed signifi-cantly over the past several years, and DOE does not plan to conduct complete and thorough testing of the current CRBR steam generator design prior to installation of the steam generators in the CRBR.
CRBR officials are currently adding another element to the CRBR steam generator testing program--fabrication of a one-third scale model of the CRBR steam generator--to test the design's ability to withstand flow-induced vibration.
DOE terminated the steam generator contract with Atomics In-ternational in 1981 and is currently resoliciting proposals to fabricate the nine redesigned CRBR steam generators and one backup unit. DOE expects to announce award of a contract in the near future.
DOE IS NOT MINIMIZING RISKS IN ITS STEAM GENERATOR TESTING PROGRAM DOE's program for testing CRBR's steam generators is deficient in that
--model steam generator testing and prototype fabrication were conducted concurrently, thus deficiencies found in the models were not corrected in the prototype;
--prototype testing involves testing a design which is significantly dif ferent from the design for the CRBR steam generators;
--prototype testing will not include simulating important operating conditions; and
--the steam generator design to be used in the CRBR will not be completely and thoroughly tested prior to fabrication and installation of all CRBR steam generators.
5
P-16410' Problems noted during model steam generator testing were not corrected on the prototype pro-Because of the perceived urgency of building the CRBR, gram of ficials began f abrication of the prototype steam generator Under before completing testing of two model steam generators.the models should normal conditions, Initial tests on the model fabrication of the prototype began. but they were prematurely steam generators began in May 1978,in December 1978 because of deficient p concluded Subsequent examination showed that the model steam generators could not withstand fluctuations in temperature because of fab-rication errors and inadequate tube spacing and tube support.
The contract for the design andfabrication thus fabricationofofthe theprototype prototype was awarded in September 1975, results from the steam generator was well underway when the test As a consequence, model steam generators became available in 1979 fabrication problems noted in theInstead, model steam the design and major gen-changes erators were not corrected in the prototype. Therefore, the pro-were made to the CRBR steam generator design. through totype steam generator scheduled for testing from May 1982is no March or April 1983 and it contains many of the same deficiencies as theidentify model steam all generators.
Thus, testing the prototype will not In the total, problems that could occur in the CRBR steam generators.the
$8.2 million.
Prototype testing inadequate DOE officials have concluded that the prototype might fail if tested to the limits originally specified to simulate antici-the test program for As a result, pated CRBR operating conditions.the prototype was changed to delete tests that were originally planned. The revised test plan ap-proved in July 1981 does not include requirements to demonstrate the
--structural integrity of the steam generator, a major cause of failure in foreign breeder reactors, or large
~~ ability of the steam generator to withstand temperature changes occurring over a short period of time, the major cause of the model steam generator failure.
In< addition, the prototype test never was planned to include the ability of the steam generator to withstand flow induced vibra-tion, the major cause of the Fermi steam generator problems.
These tests are critical to predicting performance because they involve the areas most likely to cause failure.
6
F-164105 DOE will not_ fully test the CFBR steam generator design As currently planned, DOE will not conduct complete and thorough tests of the steam generator design before they are installed in the CFBR. The nine CRBR steam generators and one backup unit are scheduled for delivery between January 1985 and May 1986. DOE plans to test a one-third scale model for flow-induced vibration and at a later date, install various perfor-mance-measuring instruments in two CFBR steam generator units and, after all units are installed, conduct pre-operational testing in the CRBR.
The one-third scale model tests will not provide all needed data on the structural integrity of the steam generator design or its ability to withstand large temperature changes over short periods of time. As mentioned previously, problems in these areas have plagued other breeder reactor steam generators. The inplant tests would provide some information related to these issues, but it would be conducted only after the CRBR steam generators have been ccmpleted, resulting in the same situation as the concurrent model steam generator tests and prototype fabrication.
That is, by the time the inplant tests could occur, it would be too late to modify the CRBR steam generators to correct any major problems that may be discovered without incurring substantial costs and delays.
DOE previously considered complete and extensive testing of a full-scale CRBR steam generator at its Santa Susana, California test facility, in addition to the tests for flow induced vibrations.
DOE currently, however, does not plan any additional tests of a full-size steam generator. DOE's Chief of the CRBR plant com-ponent branch said that the current steam generator test program is adequate to confirm the design, and that DOE does not wish to unnecessarily delay the CRBP project. According to DOE of ficials, testing a full-scale CRBR-design steam generator could delay the program by as much as 45 months if fabrication of the CRBR steam gen-erators is halted. If fabrication of these units is not halted, l
eight CRBR steam generator units would be delivered by the time The remaining CRBR
- the test results are available in April 1986.
! steam generators and the backup unit would be substantially ccmplete by that time and would be too far completed for major modifications without incurring large cost and schedule slippages.
Clinch River project of ficials contend that despite the prob-lems that have been experienced with steam generators, more extensive CRBR steam generator tests are not required, and the tests being conducted are adequate and can be extrapolated to provide the in-formation necessary to predict inplant performance. A Clinch River project of ficial believes additional testing prior to fab-(
' rication of the remaining CRBR steam generators would unnecessarily delay the project. Our consultant recognizes the potential problems in the areas of structural integrity and ability of the CRBR steam He also acknowledges generators to withstand temperature changes.
the planned tests will not provide adequate data in these
! that l
' 7
1 E-164105 areas. However, he agrees with DOE that any steam generator tests that would result in a delay in the construction of the CFBR are not appropriate.
DOE's prime contractor for the CRBR--Westinghouse Electric--
stated that the information gained from the prototype tests will be inadequate for resolving concerns about vibrations and recom-mended the one-third scale model tests. Westinghouse, however, also recognized that neither test would provide data concerning structural integrity or the CRBR cteam generator's ability to withstand temperature changes.
In a February 26, 1982, letter to us, officials of Atomics International--the original designer and fabricator of the proto-type steam generator--expressed disagreement.with DOE's CRBR steam generator testing program. Atomics International officials recognized that it is highly desirable to minimize development cost, but that it is also highly desirable to minimize the risk of (1) forced outages from f ailure of untested features and (2) delays in licensing due to a lack of data from component testing under simulated reactor conditions. They noted that the CRBR steam generator design incorporates features which substantially differ from the prototype and are unsupported by tests. According to Atomics International officials, even after completing the proto-type test, CRBR steam generator design and performance uncertainties will remain. Atomics International officials concluded that exten-sive testing of a full-scale CRBR steam generator and a scale model steam generator would eliminate the uncertainties.
In addition to delaying the program for up to 45 months, DOE officials estimate that installation and testing ofThis a full-scale would CRBR steam generator would cost about $7 million.
however, eliminate the need for testing the prototype steam genera-tor. Cancellation of the prototype test would save about $3.2 million, which would reduce the additional cost of testing a full-scalc CRBR steam generator to less than $4 million. The resulting program delay and any accompanying inflationary increases would also, of course, impact on the overall CRBR cost and schedule.
We note that DOE's position on testing steam generators is inconsistent with its programs to develop other, perhaps less criti-cal CRBR components. For example, DOE is testing the sodium pumps extensively. These tests have already preved worthwhile because a deficiency, which may result in a change in the plant unit design, has been discovered. It is exactly this type of situation which causes our conceln over not testing the CRBR steam generators.
In lieu of tests to provide assurance that CRBR's steam gen-erators will operate as required, DOE could obtain cperabilityHow-guarantees from the steam generator designer or fabricator.
ever, the contractor, which is selected to fabricatethe thesteam CRBR gen-steam generator, will have to guarantee only that erators will be built in accordance with the design provided by Westinghousc. DOE officials stated that they will not request an operability guarantee for the fabricator because no company 2
E-A6410t would provide such without first reviewing in detail the steam generator design. DOE officials stated that such a review would delay the program and increase program costs.
If the steam generators were to be built in accordance with the stated technical requirements, but failed because of design deficiencies, the Government would have to assume the additional costs of amending the design and reworking the steam generators because the design has not been guaranteed by Westinghouse--the lead reactor manufacturer. DOE officials explained that Westing-house officials would not likely guarantee the steam generator design because it is developmental and a guarantee of that nature would be too risky.
CONCLUSIONS In essence, DOE's steam generator testing program is based on the urgency of proceeding with the CRBR. This has been pointed out most recently in a DOE letter containing comments on fast a draft GAO report on options for the timing ofWhile the liquid metal recognizing DOE's breeder reactor program. (See p. 3.)
concerns and its desire to move forward as expeditiously as possible, our work shows that changes in the factors affecting the timing of when breeder reactors may be needed make s1cwing the breeder program and the CRBR a viable option.
The highly critical nature of the steam generator to overall CRBR success makes a strong argument for taking a cautious, conser-vative, and prudent approach to developing, fabricating and testing the CRBR steam generators. DOE--as well as our consultant--dis-agree and are confident that the steam generator, as currently designed, will operate as predicted. They base this position on their confidence in the technical design and testing program, and because they do not believe the CRBR program should be delayed by steam generator testing. This position, however, is not sup-ported by (1) the history of steam generator development, (2) the test results to date, (3) DOE's program to test other CRBR compo-nents, and (4) the DOE contractor who designed and fabricated the prototype steam generator.
We recognize that all steam generator problems are not re-lated to design deficiencies and that testing cannot eliminate all elements of risk. The ultimate test must come when the steam gen-erators are operated in the CRBR. A good testing program can, however, minimize the risk involved. In this regard, DOE's cur-rent test program does not minimize the risk involved as it will not provide complete and thorough information in two critical areas where problems have been experienced in other breeder reactor steam generators, both in this country and abroad--the structural integrity of the steam generators and their ability to withstand large temperature changes over short periods of time. With-out testing the CRBR steam generator design to obtain data in these two areas prior to fabricating the CRBR steam generators, DOE is assuming that the steam generators will work. If DOE is 2
B-16410-right, CRBR will be completed sooner at a lower o /erall cost.
If wrcng, it will prove a more costly and time-consuming risk to take.
In our view, CCE has several fundamental options to obtain the required data. More complete and thorough tests of the one-third scale model would provide much of the required data, but would Testing be limited in that it would not provide full-scale data.
a full size CRBF steam generator could theoretically provide more A third complete data, but may not provide full vibration data.
option would involve a combination of the scale model and Al- full-scale tests and would provide data in all critical areas.
though conducting any additional testing would increase program costs and delay the program, we believe that minimizing the risks through a more complete and thorough testing program is far more attractive than the risk associated with purchasing steam steamgenera-tors which may not operate as required. Should the generators DCE would have prove inadequate for optimal operation in CRBR, to finance modification of the 10 conpleted steam generators or scrap the completed units and build 10 new steam generators.
We recognize that because of the complexity of the CRBR and because it is a research and development However, effort, we some believe a element of cautious, risk will always be involved. fabricating conservative, and prudent approach to developing,should be taken to and testing this highlyForcritical component this reason, theinformation developed minimize that risk.
is most supportive of the following courses of in our review action.
--Stopping the CRBR prototype steam generator test program because of the limited value of testing a steam generator which differs significantly f rom the current CRBR design.
--Canceling the current solicitation for the fabrication of 10 CRBR steam generators.
--Developing a prcgram for more complete and thorough testing of the CRBR steam generator design in as expeditious a timeframe as possible.
--Kithholding a decision on procuring the CRER steam generators until test results are received and evaluated and any necessary design modifications made.
1 j RECCMMENDATICN We reconmend that the Secretary of Energy evaluate the in-l formation presented in this report, as well as the risk assumed in not conducting more complete and thorough tests of the steam generator design, in deciding on how to proceed with the pro-curement of the CFBB steam generatcrs.
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B-164105 4
unless you release or publicly As arranged with your of fice,its contents earlier, we plan announce At no further d of this report until 30 days from the date of the report.
that time, we will send copies of this report to the Director, Office of Management and Budget,' the Secretary of Energy; and to other interested parties and make copies in order availablethis to provide to others report upon request. At your request, in time for use during the appropriation The process, we didpre-information not solicit DOE's comments on this report.sented in this report was, ho DOE officials to ensure accuracy.
Sincerely yours, Comptroller General of the United States l
11
< x l08E J16.<,4 Gd.vECA 704 f3T ?h G/Mf Enclosure 1 CRBRP STEAM GENERATOR TESTING AND DESIGM.FVOLifTION COMPLETED TESTS
- o Modular Steam Generator (1972-1974)
Results: Successful; No failure indications in 9300 sodium exposure hours, 4000 steaming hours.
c Hydraulic Test Model (1969-1976)
Results: Successful.; Confirmed hydraulic acceptability- of CRBRP prototype steem generator.
Flow-induced vibration of. redesigned plant unit. . ' -
Open Item:
o Departure from Nucleate Boiling Test (1975-1976) -
Results: Successful- Established corrosion allowances: and acceptable.
Inermal ratigue lire.
o Thermal Performance / Stability Test. (1975-1977)
Results: Successful 1 Established heht. transfer corralations. .
Open Item: Need for- orifices. in evaporators..
o Few Tube Test Models (1978)
Results: Moderate success; Demonstrated integrity: of the water-to-Insufficient design /
sodium boundary with severe loading. conditions.
manufacturing tolerances and improper material selections resulted in mechanical failure of some internals.
Open Item: Plant unit redesign to account for identified deficiencies, o Tube-Tubesheet Veld Qualification Tests (1976-1980)
Results: Successful; Established manufacturing specifications and.
procedures.
o Friction and Wear Testing (1973-1979) .
Results: Successful;. EstabHshed materials of construction for plant units.
0- Mechanical Properties Other Than Tube-Tubesheet (1968-1980)
Resul ts: Successful; Provided ASMF Code design: data base.
2 o Sodfran-to-Water Boundary Leak Testing. (1974-Present)
Results: Successful;. Demonstrated conservatism of CRSRP design basis.
leak, confinned in-service inspection capability to detect: tube degrada-tion from leak growth and propagation. ,
. i o Materials . Design Model Verification (1977-1981!-
Results:. Successful; Provided high-tsmperature inelastic hehavior model-for materials of construction of steam generator, o Scale Hydraulfc Model Feature Test (1980-1982)
Results: Successful; Configurations of redesigned plant. unit internals-were confirmed acceptable.
o Mechanical Assembly Test (1982)
Results: Successful; Manufacturability of key features of redesigned plant unit was confirmed.
TESTS IN PROGRESS AND~ PLANNED o Prototype Steam Generator (1982-1983) _
Scope: Perfonnance af 70 Mwt. test of full size steam. generator at ac. 4y . ..*. . 4 4 u, a *.a s, .a c . . w.-
l l Expected Results: Confirmation of design analytical methods and models, resolution of need for evaporator orifices, further confirwation of integrity of water-to-sodium boundary.
o Plant Unit Scale Model Flow-Induced Vibration Test (1982-1983)-
Scope: 1/3 size scale model water test up to 125 percent full power flow.
Confirmation of absence of flow-induced vibrati3 in Expected Results:
redesigned plant unit. Resolution of open item from hydraulic test model.
o Water Flow Test of Plant Unit Spare (1984-1985)
Scope: Full size: water test of sodits side of plant unit up to 125 percent full power flow for superheaters.
Expected Results: Confirmatiott of 1/3 scale model flow. induced vibration test.
- . - - - . - . _ , _ . - , m
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3 o Pre-operation and Startup Testing of CRBRP Plant Unit Evaporator (1988--
1989)
Scope: Thermal / hydraulic and transient testing with plant operating condi tions. ,
Expected Results: Confirmation- of design margin in design .
specification, final confirmation af plant. unit. design.. .
- o. Pre-operation and Startup Testing of CR8RP Plant Unit.Superheater t
(1986-1989) ,
i Scope: Flow-induced vibration testing to full sodium flow capability of intermediate system, anticipated to be at least 110 percent ' full power-fl ow.
Expected Results: Confirmation of 1/3 scale model and plant spare water.
test results. .
CRURP STEAM GENERA,T,0R OfSIGN: EVOLUTION Design Confirmation Reviews o July 1978 Steam Generator Operations- and Maintenance RevieA.
Scope: Review of CRRRP plant ope [etion and maintenance procedures for steam generators.
Results: Identified procedure impacts on steam generator. design to be resolved through plant unit final design.
o May 1979 Steam Generator Internals Independent Design Reyfew.
~
Scope: Independent steam gederator designer / manufacturer review of 1979 design of plant unit for impact of Few Tube Test Model defi fencies.
Resul ts: Identified design deficiencies to be corrected ~pHoe to plant "
unit fabrication release. ,,
September 1979 Steas Generator Pressure. Boundary Independent Design o
Review Scope:- Independent steam generator designer / manufacturer review of 1979 design of plant unit for impact of Few Tube Test Model deffetencies.
. . .a . .
Resul ts: Identifled design deficiencies to be corrected prior to plant unit fabrication release. ..
o October 1981 Plant Unit steam Generator Independent Design Review
.. Scope: Independent steam generator designer /manufactursrCreview of redesigned plant unit. ,
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Steam Generator Testing Progran carr Reduce ~-
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General Comeents
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DOE's steam generator program is based on the most thoroughTjrir)Vf.uwed' design and most complete testing program ever carrie+ out :enraB.% teen .gener-ator in history. This program is outlined in Enclosure 1.2Thieprogram -
. includes materials qualification, design model verification,'."sia1A models full $1w unit and plant. pre-operation and startup testings.iEsupporting...
the design in an integrated manner with findings of testiniG8pams'~bec'oming
- an integral part of the design process. The success of thiscreparoach is further assured by the involvement. of the. major US steam generator.Wsign -
and fabrication campanies.
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The Project is taking an extremely cautious, conservative.and;.pMdebt. .
approach tu developing, fabricating and testing the' CRBRP steamr;generato.rs.,
This approach is a well doctpsented complete program supported,br-e. v M Jafge component designer and fabricator consulted to date. (incl.vdirig.:GA915:... . . . 7 _.
own consultant). De CRBRP steam generator program approA:Tr:i% W. fact. .
being copied by the other nations in the free world when dWeMpMf-Diefr' programs. This fact is supported by the large number of fhfopiati_uh exenanges taking place. . . _. . s+M .
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1 From the start of the program we wrote standards for the siistisfsMUtesting-and inspection of these. critical components that were and ytHFjshe:t.he most _
F- stringent that have ever been used. For- example, we purchaiidriiWrirF.~ refined ~
L materials (double vacuum remelt VAR and Electroslag remelt 4SRifniks)~ ~for L alt-lsodhan-water boundary materials. We instf tuted .ultrJsoTM-Mbpisction-F- standheds that are- far more demanding than code requirements...s.W; designed' 4 H bact-face weld to preclude any crevices on the water si~di'dfEt6iefi7 units.
h- - We used P0d anode X-Ray equipment that' will show a 0.002 incheil.3faineter b" perosity or inclusion. We post-wcld heat treated the weldL74sCdsiird helium
- Teek testing, ultrasenic testing' and dye penetrant inspecitorG.:nn'I!Mn cr itical g, tuDe to tubesheet welds. .
gg;gg_j It is' certainly true that "all. steam generator' problems tiirEdhdtWeTiGd'to design deficiencies and that testing cannot eliminate alMkT_iiiin_WK risk."
The facts are that insufficient attention to details suen.ase.astertMs, welding, heat treating, cuality assurance, water chemistry 7?aiidTacce'ptance testing of the fabricated parts are the major causes. of LNFlEQ$saQaneratar i fattures. It is difficult to see the wisdom of spending severae_ttees. the .
- ' vost of 10 steam generators to test one when design or "st[ruc.tur.iXfnugrity"
<-* problems usually do not show up for some period of time. 5tameEginerators b -n-. are not usually tested for a sufficient time to snow up~ttrere@ttfec.tural
= "- integrity problems." Most L.MFSR steam generator problems aWigfMthe p- . -lack of attention to details cited above.
The present steam."_xm w r
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- testing.The CRBRP successesconf to 1dence in the date, and theSteam generatormanner comprehensive program is suMAihdthplM in..wttftfr the. Pro j"ect has .been able to address the historical results of all predecessor steam i generator programs, both US and fareign. The position. f s wpwreHrtesW-
.rs e ults to date, testing approaches for the other CRBRP egihts"ahdMne ;
~ CR82P prototype staam generator designer / fabricator. ._;<.5.7.w.';7.?. .T-
- . --- .= sew -u xt.-; j
- The CRBRP steam generator testing program, when combined'iNf-tfrMxMistne independent design analyses and reviews by organizations .no1pdurreirtlyMo, ject
' participants, does minimize rish All open concerns will"beraddresseW4y the ~
' design / testing program. The structural integrity and the'..'Wid)Tshfpeffpistance.
. capability will be denonstrated. This demonstration wi1MMRdompTTstMd prior:
' to 'any.. substantive fabrication of the CRBRP steam generatoff.2E-~Nif,ff.s-' :
- g. . . . .
~J DOE iisagrees completeTy with GAO*s conclusions and.' conte 55INeMMM -
.l.Gk-9&ki]l.Uli$5% ..
'o The current prototype is prototypic of the current dasVgiffrid.%Ef=l6 =.- .
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testing of this unit should and will ne done.
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o The present progem for testing is adequate and 'prQ~denEMT# " = =-Y - -:= = -
course.n :
suggested by GAO is very costly and is unnecessary. .; =:=.;;;:- . u. . ., .,.
'. a- Due to the current low- level of orders. the ten plant antts".can=coow bF fpstihased.a't an unusually competitive price.
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. .-: . ::: f.7-o A11. steam generators should be procured at this timer.- : .- ~..- ---
..~ :- -____ . ' " :. ::.U., . _. .::: f ==.i . 1.:.s.;.
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o The stem generator program should continue on its presect=.cDur,sg and. ,
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.1. Page 2, 3rd paragrtph 1st sentence
- Developing and u-iNESMU2.C <'O ,
read ". .. facing LMSR's worldwide." "'--'* fif: :zf: w ...r-
. . . . . . . . . . . . . . . ~ ~ . = ... . . . . . . .
~2. Page 2, 4th paragraph starting "We also ...*: The G@lipi8Fifhndamental conclusions provided by their consultant. The GAO points oct .Wemployed..
a consultant to assist in the technical aspects' ort,ne~YeyTmC;^Un~ pagM GAD aamits its consultant agrees with the approach CRUR1h;is-tadng wittr the steam generatcr test program and is " confident thaEttis steam: generator, as currently designed, will operate as predicted." ".2..:m..G......C=I: ~.. ~.: . . .
Page 2, 5th paragraph starting "The infomation ..*:. .7Ms..is- factually
~,
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incorrect.
The GAO cnose what they wanted to include"ad:entarip1fzed from the test p1an. - .=. =. 2. ">M.H.. .S_.,
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.4. Page 3~, last sentence "In comparison to ...": This stateiieViffs"----- i" misleading. The challenge may be greater because a TememRa .
[, potentially damaging sodium water reaction, however..1.t..is .lessidiffi.i. .' .
cult to solve since sodium on the shell side is noncorrosite. cuev red-to water. Sodium steam generators have not experiendid'.'thEniajoE---" ,
. Jorrosion and denting problems which have been the primeFfMissse ifO
~
water reactor steam generator problems. This challefigEWaYhdigWizid-- " .
early and as a result the CABRP design has no crevicer'6iFtfie%attF--
Side' and tnc wPlds are heat treated and meticulously tMtEdrh'aMfF
~
the deficiencies previously experienced in the USSR and. United Kingdoii, R1gorous attention to design, fabrication and testinfh'as-'bfe'n' es' tab-
.Tished on the program to ensure structural integrity of{.Mteam !
-. generator. - . . - - - - . - - . . \
fL __,
-;.yn;;=5; :
i
' 5 .. Page 4. 2nd sentence " sodium steam generator ...": This :nai~.cnt is incorrect. The stresses in the CRDRP tubes separatTW~thFidifir ffam the- . I
' sodium are not " severe" as stated. Some water reactor.isim.Tenerators',
~ l on the other hand, have suffered failures in the small-4aseter U-bend regions as a result of stresses approaching the inatoff41.- y;tieI_f.s.trength.
Care Is taken in the sodium-heateo steam generators to assurg..that this 7_g.-j'Md:-7:
~-
' type of severe situation does not occur. :-
'- -9_-:-: e.-:f-:
- h. Page 4. 3rd. sentence "Even ar small failure . . .": Th4-comment 3:s(-
- 6. .
misleading and does not recognize that the CRBRP desi.gtt.pr. ovide.s .for
- the accommodation of- leaks in such a.way as to avoid " trpl-osions" .and. . .
" fires". These safety systems have been demonstrated Fffsmif4&s tutr.
.~
ra, The' sodium, tater reaction may or may not cause furthcFMilags7 depending- .
- g. on how soon the leak is detected and tenninated. The safety ~feffef
'~_ system can accommodate very large leaks without a firfahd 2 expresfon.
The extensive knowledge of sodium water reactions and 5eW;atssdant I.'.
L_'. ~ '
effect on LMr0R steam generators has provided full to^Rfi'di'ncF Tif ~the-ability of the pTunt design to accommodate these potenit.aE. . react _iops.
L. -
- 4
- 7. Page 1, 2nd par:ag3aph . starting " Steam generators ..." and vage 4, '
2nd paragraph "According to ...": The statements are s,impT-i~stic, misleading and in the last statement, if taken literally, incorrect.
Virtually no testing was done of the EBR-II steam generatorsrwhich have -
c cxperienced no water-to-sodium leaks after more than 17 years of opera-L tion; whereas the steam generators for the BN-600 plant which started up P-- recently nad two failures within the first year of operation, even though
' a prototype _had been tested pr1or to their installation in this plant.
l . ., The success of a steam generator development activity dispeiidren many
~~
ractors besides conducting a Large compoonent Test, including the extent of supporting R&D the standards utilized, care 'and attention to detail l._ during design, fabrication, selection of materials, proper specification L;'
of operat. tonal and maintenance requirwoents, etc.. The-CRBRP development.
E. . -_. program embodies all the elements necessary to assure the requisite quality and integrity of the plant steam generaturs.
(.. .- -
i.' .
e .
Q.
E'-
N'.'."
4 e . .-. :...... . . -
'?.
- 8. Page 4, 3rd paragraph starting "5maller breeder reactors ...": Steam generator perforsances on other breeder reactors in the United States show different experience from that cited by the GAO. The EBR-II has
,-- ._ operated for more than 17 years with only minor problems.,and no water to sodium leaks. .
1 9. Page 3, 3rd paragragh, last sentence "As recently as .. ": The statement is incorrect. The two sodium leaks in a steam generator" did-not cause
.-~~ . a . fire. The GA0 report states that "As recently as April 1982, the Trench demonstration breeder reactor was shut down hecause of two sodium leaks in a steam generator which caused a fire."
Q In fact the total sedim released was less than 6 liters. The reactor
". was shut down and the steam generator drained and isolated insnediately
( ..
- and wi thout incident. Upon refilling with sodium and locating the L
leak, a nitrogen pressure valve failed allowing sodits to leak to the
. .. ater w side-of the steam generator, filling a tube, and reaching a steam .
f__ valve, This steam valve was not designed to contain sodium and 5-6 s.
liters was leaked into the steam generator building. The small fire
~
which resulted was extinguished in less than:a minute' by the automatic.
fire suppression systcm. We were apprised of the event by Jean Petit..
I L.. of L. Energie Atomique, who said the reactor could be on line immedi-T. ately, but estimated it would be in service in .less than 1-2 months.
- p. - - The delay is for rwasons other than the fire.
j_._** >.
u - _. -- The problems' wt,th the Russiar; and British LMFBR steam generators were-L associated with lack of attention to quality and metallurgical. concerns.
L. i.e., welding, inclusions, and lack of post: weld heat treating.
p._.
Page 4, 4th paragraph,1st sentence 'In 1974 ...": The statement is .
10 .
'incorrec t. We suggest this sentence should be changed to read- *In 1974, E
AEC cnose a steam gancrator design for use in the CRBRP based on the . .
successful testing of a 30 MWt Modular Steam Generator (MSG) designed and fabricated by atomics International. This 30 MWt MSG was successfully 7
tested in the Sodium Components Test Installation in 1973. This test demonstrated that tne hockey stick concept could be designed and built to meet LMFBR requirements. The selection was made based on a fully successfal large scale test. In both this MSG test and the subsequent CRBRP Few Tube Test Module tests in 1978 there were no cracks, no corro-
.ston and no leaks in the sodium / water boundary in spite of the severe transients scen by thesa units.
- L .
~
~11. Pages 4, 4th paragraph, last sentence "Until 1982 ...." and accompanying 7
- 3 elements: The statement that "Until 1982. DOE's steam generator H "~
development program consisted of three major elements." is incomplete and l does not reflect the extensive R&D and testing associated with the hockey
~
- stick design.
These programs provide high confidence that the CRBRP steam generator design will fully meet the spect fied requirements. The unit.*a be l~: '
l - .
--* em -
- l. - __
5 tested at ETEC is still sufficiently " prototypic" of the plant unit design. As In the case of most prototypes, design refinements have been
- made to enhance the reliability, performance and fabricability of the plant units. All of these changes will be verified by key feature testing and/or analyses.
The purpose of building and testing tb prototype steam generator also includes demonstrating plant start-up procedures, inservice inspection techniques and leak detectors.
12 . Page 5,1st paragraph starting "CRBR officials ...": The statement is incorrect. On August 25, 1981 Westinghouse requested approval for a flow-1Douceo v1Dration T.est. Tne utta tied Wwat invieuwaar Lechni sel reasennends .
- I tion was submitted on March 17, 1962. and DOE-PO~ approval was granted on April 9, 1982. The April 9,1982 action was a decision point on these i
tests which had been in the planning stage for a. considerable length of tbne. Furthemore, the reason for the 1/3 scale model flow test is to veriry calculations which show there is no probicm with flow induced
- . - vibration. There is no indication of a flow. induced vibration problem:
The GA0 report should aske this clear. .
The
~~ 13. Page 5, last paragraph starting " DOE's program for testing ...":
statement is a.GAO opinion and is incorrect. The bullets provided to suDstantiate the statement are also incorrect and misleading. The DOE-
~
L test program 1s not deficient.
- 1st bullet: The "de'ffciencies" cited in the first bullet for the L
L . .- - FTTM were in fact corrected in the prototype. There were other items .
which would be design improvements in the plant units that could not l_
I" be incorporated. .
1.) The lower shroud centering The " deficiencies" in the FTTM were:
bolts were tightened 1-3/4 turns instead of loosened 1-3/4 turns.
All centering bolts on the prototype have at least 0.020" clearance.
2.) The vib' ration suppressors on the FTTM were 2-1/4 Cr-1Mo and were l too closely, spaced to the tubes. The material for the vibration .
l.
suppressors on tno prototype was changed to Inconal 718 and the clearances were increased.
- 2nd bullet: The prototype is not significantly different from the plant unit. The design is substantially the same. Some features have been changed to improve reliability, performance and fabricability.
- 3rd bullet: The prototypeAt test will simulate many of the plant the time the test was originally established
- operating onditions.
it was found that 60 percent power was adequate and sufficient, and tne results could'be scaled. These findings are still valid.
l 7, ,
4th bullett The statement in the report is not. factual. .There are l
l
. key feature tests, a 1/3 scale model test, the prototype, and the plant unit with a hydraulic flow test on the sodium side. These g e
m . . . . .
- - - 6 tasts will provide a reasonable assurance of a sound reliable design-in a timely manner.
- 14. Page 6,1st paragraph. 7nd sentence "Under nomal conditions ...":'
The statement is incorrect. Model testing is nomally done at several' stages of prototype fabrication. The statant may be an opinion as i to what mignt. be done under ideal conditions.t but is neither a norm, necessary nor realistic.
~
- 15. Yag4 '6.1st paragraph. 3rd sentence " Initial tests ...": The statement !
.i.s. incorrect. The test was not terminated because of " deficient" performance. The test articles could' have been repaired. The dst was-terminated in order to determine design changes that were indicated for
-the prototype and plant unit design.
- 16. peel 6.. ist paragraph, last sentence " Subsequent examination ...*:- The' statement is incorrect. The proper words are:
" ... because of inappropriate vibration suppressors tolerances and a - '
Tabrication error of tightening, instead of loosening, three shroud-to-shell spacer bolts."
17, 'Page 6, 2nd paragraph, 2nd sentence "As a consequence ...": The statement is incorrect. The problems noted in the model steam generator which
. coujd. affect the prototype test were corrected. Subsequent analyses -
showed tnat Insufficient space was allowed in the prototype for the tubes
-tcr erpand ar contract during large thermal transients to prevent contact with the elbow. shroud or the first tube spacer. This limitation could
. no.t.be corrected on the prototype unit.
~ '~
- 18. Pag'e 6, 2nd paragraph, 3rd sentence "Instead, major changes ...": The statement is incorrect. The changes are not major. They are design refinements. A " major" change between the prototype and the plant units design is a welded steam head instead of a bolted steam head. This change eliminated 6 gaskets per unit but does not impact prototypicality.
19 .. Page 6. 2nd paragraph. 4th sentence. "Therefore, the prototype' ...": The statement is Tncorrect. The prototype is prototypic of the plant units
'in most features and does not contain those deficiencies that caused
. JafTuru of the FTTM model.
20 Page_6. 3rd paragraph starting " DOE officiais ...": The statement- in -
the first sentence is incorrect. DOE officials did not conclude "that
.the prototype might fail if tested to the limits originally specified to simulate CRBRP operating conditions". The July 1981 documents referred-to was the testing specification for the prototype steam generator.. It t . as;not the " revised test plan."
w
.a. -
7 l
- 21. Page 6, 3rd paragraph, last sentence "The revised test plan ..." and- .
accompanying bullets: The statements are incorrect.
- - 1st bullet: The structural integrity of the unit will be tested.
i .
The majority of of integrity failures which have occurred in LMFBR steam generators, both domestically and abroad, have been related to '
- - material and fabrication deficiencies and design deficiencies (vibration, erosion) not associated specifically with large-themal transients. No 1.MFBR powerplant steam generator failure has been- - -
1dentifled to date, the cause of which.can be attributed to inability i of the design to accommodate thermal transients.
2nd bullet: The "large temperature changes over a short period of.
time" was not the cause of the FTTM test temination. DOE hat included significant transient tests in the prototype test. The GA0
- _ .was informed of this.
- 22. phe 6, last paragraph, "In addition ...": The prototype test was never i intended as the primary method of demonstrating acceptability from a 4 -
fT6w) induced vibration standpoint. Water testing is adequate, was hsed for the design currently embodied in the prototype, and is used in s' team generator development progress world-wide since the necessary instrumentation and over-testing norreally can not be provided in a prototypc-test. There is no reason to suspect a problem with flow
- induced vibration. Both the test and the design analysis work indicate this ~1s not a problemJ The extensive water test program includes a substantial effort to verify this result. This is because of the conser-
, vative approach taken, not because DOE expects a problem.
- 23. TCa general reply to the assertions made on page 6,'the CRDRP hockey
'.siWck design has been extensively analyzed and supported by numerous -
feature tests. A large number of these supporting tests (e.g., hydraulic madel tests) were specific to features of'tne prototype design.. The ,
" prototype is full size with 757 tubes. The changes between the prototype - -
and the plant units are primarily 1) replacing bolted connections by more reliable weldments, 2) improving materials compatibility, and 3) loosening -
tolerances to enhance fabrichbility, perfomance and reliability.
- 24. hagd /,.1.st paragraph starting "As currently planned ..." and 3rd paragraph,
.Ast four sentences.; The statements give an inaccurhte perspective of the
. test program. The DOE has evaluated the need for a number of testing -
options and variations', starting in 1973 and continuing to the current time. The conclusion of these reviews is that the carrent test plans are.
adequata and sufficient to prove the required results. There is no need -
.forna full scale test of the first plant unit--such a test is not
~tecnnically justifiabi,e. . : . ,
3 DOE suggests that an objective assessment of the CRBRP stean generator test program should be included, which neflects the completed and p1anned ,
00E testing program. .The detailed 00E testing program description was e a e
- e. ea
-6 '.
/ .
8 provided to GAO in draft font in February 1982, as a revised draft in March 1982, and in. final form May 18, 1982. There were no substantial changes between the 'first draft and the final test plan.
- 25. Page 7, 2nd paragraph.1st sentence "The one-third scale ..." and 3rd yaragraph, 1st;four sentences: The statement. is. misleading and incorrect. Structural integrity is. to be verified by the prototype test and other key feature tests. The 1/3 scale model. is to confim Jflow induced vibration analyses. It is not intended to test " structural -
--- jnteg ri ty."
26'.~ ~Page 7, last paragraph starting " Clinch River project ...": The GAO should provide DOE a copy of their consultants report, which we understand was issued in February 1982. Since the consultants report is, mentioned it _would appear reasonable to include it in the report. It- is not clear' why-the GA0 has not considered the conclusions of their consultant beyond-
[a simple statement that "He agrees with DOE...".
27~. Page 8, 2nd paragraph " DOE's prima contractor ...": The statements'are Jncorrect. Prototype tests by themselves rarely validate all' features of a design. Their purpose and utility must be viewed in the Context of the-tutal test program used to confim the design. The program that supportso the CRBRP is well conceived, extensive and provides adequate infomation to qualify the design. It includes a 1/3 scale model test for flow induced vibration testing. This feature test was under consideration for- :
. moYe than a year and recoeunended formally to DOE by Westinghouse in March- .
1982. This test, together with the planned fullisize hydraulics test ofN r Yplant unit at 125' percent of' full power flow, wiM provide. complete ,. .
conf.imation of the absence of flow induced vibration in the design.. A- .
1/3, scala model 'for testing structural integrity was never proposed nor -
. felt. necessary by Westinghouse. , ,
- 28. Page 8. 3rd paragraph starting "In a Febr' u ary ...": Atomics' International' .
.(AI) is a division of ESG, the operator of ETEC. The fim has strong
, tasting capability and. lean toward testing. The AI letter represents l AI's judgement which copld be influenced by that philosophy. The GAO's craft inaicates Inat sne anc* s consultant, to wnom.tne letter was a1rectee, I agrees with DOE and not with the AI letter. UDE transferred design l . responsibility for the steam generator from AI to Westinghouse, and.
l Westinghouse subsequently made changes in design features to improve .
reliability, perfomance and. fabricability. Westinghouse does not see l
the need for testing a plant unit at ETEC. Even Al has not suggested
.that fabrication of pihnt units be held up until another unit is tested at ETEC. -The.Westingt9use changes will be verif.ied, by key fjtature ,
. testing.- ,
', p 29, Page 8, 4th paragraph ' starting "In addition to ...*: This presents a a gr.ossly distorted picture of the cost impacts outlined. The: impact of.a ,
ful.T power first article steam generator test is estimated by DOE to .
delay criticality of CRBR by a minimum of 26 months and havera minimus overall cost impact of $350-400 million This includes 5115 million to i
e t
l .
9 modify the ETEC facility for 117 MWt ful1 flow testing and the cost af.
physically conducting the tests. The GAO is incorrect in stating that testing the CRBRP first plant unit at ETEC would eliminate the need for ,
completing the prototype test. The opposite is true in the opinion of-the technical experts. The prototype as pointed out earlier is still prototypic. of the plant units and will be '. tested in 1982-1983. The -
earliest we could test the first article would be 1985-86.. 00E strongly l believes the best approach is to test the prototype (including transient tests), conduct feature tests on design changes on the scale model .
' Gydraulic tests), conduct hydraulic flow tests of an early plant unit . l fn 1985-86 at' 125 percent full power flow, and detailed preoperational and startup tests on the highly instrumented unit at both design and .
off-design conditions with full interaction of all plant systems. ,
- 30. . P' age 8, last paragraph starting "In lieu of tests ...", and following paragraph on page 9: The GAO report does not recognize that in order to ootain a guarantee of the sort referred to here, any vendor would have -
, .to charge the government a substantial amount of money to guarantee such -
first of a kind equipment over its 40 year life of plant operation. More .
fundamentally, the GAQ.did not consider that guarantees are not appropri-ate or obtained for developmental equipment used in demonstration plants.-
- 31. Page 10, 2nd paragraph starting "We recognize .:..': DOE disagrees
' completely with GAO s conclusfons and contends: ,
'o The current prototype is prototypie of the current design and the .
testing of this unit should and will be done. , -
i
- o The present program for testing i's adequate add prudend. The: cours'e'- I
- suggested by GAO is very costly and is unnecessary. '
I ~
o Due to the current low level of orders,. the ten plant units can now .
be purchased at an unusually competitive price., ,
)
o All steam generators should be procured at this time.
'[ .o The and schedule.
steam generator program should r,ontinue on its present course :
'The CRBRP steam genera' tor testing prog"am, when combined with the
' exhaustive independent design analyses and reviews by organizations not
. currently Project participants, does minimize ri~sk. All open: concerns
'wil1 be addressed by the design / testing program. The structural integrity and the transient performance capability will be demonstrated. This
' demonstration will be 3ccomp1ished prior to any; substantive fabrication i
'of the CRBRP steam genWraturst 'NN f -
1
) :
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