ML20062M317

Proposed Findings of Fact & Conclusions of Law in Form of Proposed Initial Decision.Certificate of Svc Encl

ML20062M317
Person / Time
Site:	Atlantic Nuclear Power Plant
Issue date:	12/11/1981
From:	Cowan B, Daugherty T, Kenrick J OFFSHORE POWER SYSTEMS (SUBS. OF WESTINGHOUSE ELECTRI
To:
Shared Package
ML20062M303	List: ML20062M299 ML20062M317
References
NUDOCS 8112170150
Download: ML20062M317 (134)

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I C OC .y K.E TED

'81 DEC 14 P4:18 l LNITED STKPES OF AMERICA 5ECF.E T4R (

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]

NUCLEAR REDUIATORY CDMISSIN BEEORE 'IEE ATOMIC SAFETY AND LICENSING BOARD I In the Matter of )

)

) Docket No. SIN 50-437 OFFSEDRE IOWER SYSTEMS

)

(Manufacturing License for Floating )

Nuclear Power Plants) )

I I APPLICANr'S PROPOSED FINDINGS OF FACT AND CINmEINS OF IAW IN THE FORM OF A PROPOSED INITIAL DECISICN_

I OF OXNSEL:

Bartcx1 Z. Cbwan, Esq.  ;

Thcznas M. Daugherty, Esq. l John R. Kenrick, Esq.

Vincent W. Campbell, Esq.

Offshore Power Systens Cbunsel for Applicant Offshore Power Systens I

Decenber 11, 1981 I

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LNITED STATES OF AMERICA NUCLEAR REUIATOlUf CIAEISSION BEEORE THE ATOMIC SAFETY AND LICENSING IDARD In the Matter of )

)

OFFSEDRE POWER SYSTINS ) Docket No. SIN 50-437

)

(Manufacturirx3 License for Floating )

Nuclear Power Plants) )

APPLICANT'S PIOPOSED FINDINGS OF FACP AND CNCLUSICNS OF IAW IN THE FORM OF A PIOIOSED INITIAL DECISICN OF OXNSEL: Barton Z. Cbwan, Esq.

Thcznas M. Daugherty, Esq.

Vincent W. Canpbell, Esq. John R. Kenrick, Esq.

Offshore Power Syatans Counsel for Applicant Offshore Power Systens I Decenber 11, 1981 1

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TABLE OF CENTENTS Page I. PRELIMINARY STATD4ENT AND DESCRIPPICN OF THE RECDRD 1 A. Introduction 1 B. Admissions and Withdrawals of Parties 5, C. Discovery, Hearirys and Mations for Sunraary Disposition 10 D. Interlocutory Appeals fran Board Rulings 14 II. FINDINGS OF FACF - HEALTH AND SAFErY 18 A. General 18 I B. Description of the FNP and Site Envelope 21 l

C. Safety Evaluation of the FNP 28 D. Research and Develognent 30 E. Reasonable Assurance 30 F. Technical Qualifications of Applicant 31 G. Financial Qualifications of Applicant 31 H. Camon Defense and Security 32 I. Matters Arising Fran Inssons IA.rned Fran Three Mile Island (TMI) 33 J. Generic Unresolved Issues 35 I K. Review by the Advisory Ocmnittee on Reactor Safeguards 36 III. FINDINGS OF FACP - CDMPLIANCE WITH THE NATICUAL ENVIIENMINTIL ICLICY ACT (NEPA), SECTICN 102(2)

AND 10 CFR PARP 50, APPENDIX D (NOW 10 CER PARr 51),

AND APPENDIX M 37 IV. FINDINGS OF FACT RE: CINTENTICNS AINITTED AS ISSUES IN CINTROVERSY, DOARD QUESPICNS, AND OTHER MMTERS 42 A. Cbntention I - Energency Power 43 B. Cbntention II I Underwater Electrical Transmission Idnes 48 I -i-I

I TABLE OF CDNTMfS (CDNT'D)

Page C. Contenticn III - Marine Envirorment 50 D. Contention IV - Central Control Rocm 64 E. Contenticn V - Transportation 69 ,

F. (bntention VI - Site Envelope Data 78 G. Contention VII - Radiological Impact on Swimners ,

and Boaters 94 H. Contention VIII - Aircraft 100 I. 03ntention IX - Ship Collision 107 J. Contention X - Ice Containnent 116 K. Contention XI . Turbine-Generator Matters ~121 L. Contention XII - Effect cn Biota 164 l M. Cbntention XIII - Discharge Outfall 168 N. Contenticn XIV - Food Chain 171 O. (bntention XV - Dredging 176 I P.

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Contenticm XVI - Impact on Resort Econanics Ctntention XVIII - Net Energy Yield, Cbst-Benefit 179 Balance 194 S. O mtention XIX - Special Energy Requirenents 201 T. Contenticn XX - Heat Punps and Secondary and Tertiary Rece*ery of oil 205 U. Board Questions of Mard 29, 1979 208 V. Board Questions of Novenber 12, 1981 209 V. CDNCLUSIONS OF LAW 210 Appendix A Listing of Application and Staff Review Documents A-1 Appendix B Listing of Contentions Admitted as Issues in Controversy and Other Matters of Bcard Inquiry B-1 Appendix C Listirg of Applicant's Exhibits C-1 I

I LNITED STATES OF AMERICA NUCLEAR REGUMIORY O@ MISSION BEFORE THE A'IOMIC SAFETY AND LICENSING BOARD

~

In the Matter of )

)

OFFSEDRE POWER SYSTENS Docket No. SIN 50-437 (Manufacturing License for Floating )

I Nuclear Power Plants) )

I APPLICANT'S PROPOSED FINDINGS OF FACP AND GECWSIGIS OF IAW IN THE FORM OF A PROPOSED INITIAL DECISIQ4 I I. PRELIMINARY STATENFNT AND DESCRIPPICN OF THE RECDRD A. INTRODUCTIQ1

1. This proceeding involves the Application filed by Offshore Power Systens (Applicant) for a license authorizing the manufacture of eight t andardized floating nuclear plants (ENPs) at its manufacturing facility located on Blount Island in Jacksonville, Florida, the last ENP to be canpleted by the end of 1999 (Application for Manufacturing License - General Information, Rev. 2 (Exhibit OPS-20A)) . Offshore Power Systens (OPS) is an unincorporated joint venture of Westinghouse Electric Corporation (Westinghouse) and Westinghouse International Ibwer Systens Cbnpany, Inc. (WIPSCD) , Westinghouse having a 99% interest and WIPSCD having a 1% interest (Final Environ-mental Statenent, Part II, Septonber,1976, NUREG-0056 (FES II), Vol.

1, p. 1-1).

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2. The ENP will be a totally integrated power station nountal cn a floatirg platform. The inanufacture and assenbly of the ENPs will be done at a production line basis at the Blount Island facility.

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3. The instant Application for a manufacturing license was subnittal to the Atanic Energy Comtission ( AEC)1 on January 22, 1973.

It was docketed by the Cbmtission on July 5, 1973. This Application was the first one accepted by the Comtission for licensing pursuant to the provisions of Appendix M to 10 CFR Part 50 pertaining to the j manufacturity license option of design standardization.

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4. Under Appendix M, an application for a manufacturing license must meet all of the requirenen'a of 10 CER Sections 50.34 (a)(1)-(9) and 50.34a(a) and (b), except that any required infonnation or analyses relatirg to site matters shall be predicated on postulated I site parameters which shall be specified in the application. Further-more, under Appendix M, an applicant for a manufacturirg license must subnit with the application an environmental report as required of applicants for construction permits, provided, however, that such I 1 As of January 1, 1975, the Nuclear Regulatory Q2mtission (NRC)

I assumed all the licensirg responsibilities of the ADC under the Atanic Energy Act of 1954, as amended.

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envirorrnental report shall be directed at the manufacture of reactors at the manufacturing site aM, in general terms, at the construction and cperation of reactors at hypothetical sites having characteristics that fall within the postulated site parameters.

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5. The instant Application, as docketed by the Ommission, was acccrnpanied by a Plant Design Report (PDR) and an Envirorrnental Report (ER) . On various occasions since original docketing the Applicaticn aM the PER have been amended and the ER has been supplanented. The Application as amended, the PDR as amended, and the ER as supplanented have been adnitted into evidence. Appenux A hereto lists by exhibit ntznbers the title, date and transcript admission page of the Applicaticn and amendment, the PIR and PDR amendments, the ER and the ER supplements.

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6. The NRC Regulatory Staff (Staff) perfonned a review of the Applicaticn. As a result of this review aM its own independent study, the Staff prepared a Safety Evaluation Report (SER) and four Supplements thereto. This Report arxl the Supplcments have been ad-mitted into evidence. The Staff also prepared as part of its review a multi-part Final Envirorrnental Statement (FES) which has been admitted into evidence. Appendix A hereto lists the title, publication ntrnber, date, and transcript adnission page of the SER, its Supplements, and the EES.

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7. Pursuant to the Atcmic Energy Act of 1954, as amended (AEA), the National Envirormental Policy Act of 1%9, as amended (NEPA), and the regulatiuts of the AEC, the AEC published cri Deceber 10, 1973, a Notice of Receipt of Application for Manufacturing License and Avail. ability of Applicant's Environmental Reports (Notice of*

Receipt) ard a Notice of Hearing cn Application for Manufacturing License (Notice of Hearing) (38 Fed. Reg. 34008) . The Notice of Re-ceipt advised that the Application had been docketed under one option of the (bmtission's recently announced standardization policy for nuclear power plants and would be governcd by the regulations set forth in Appendix M, 10 GR Part 50. The Notice of Hearing set forth the requirenents to be satisfied prior to the issuance of the re quested manufacturing license. The Notice of Hearing also appointed this Atcmic Safety and Licensiry Board (Board) to conduct the hearing and provided that any person whose interest might be affccted by the proceedirg could file, by January 9, '974, a petition for leave to intervene with respect to the issuance of the requested manufacturing license. Since Decanber 10, 1973 the Bmrd has been reconstituted to consist of its present mcmbers.

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l E. AEMISSICNS MID WITHDRAWAIS OF PARPIES

8. Petitions for leave to intervene were filed by the followirg persons or entities:

(a) Kenneth B. Walton cn behalf of the City of Brig-antine (Brigantine), New Jersey (subsequently, petitions for leave to intervene cn behalf of the City of Brigan-tine were filed by Mescrs. George W. Ward and Walter H.

Bew cn March 27 and 28,1974; however, these latter two petitions were withdrawn in April, 1974);

(b) Natural Resources Defense Council, Inc. (NRDC) , an envircrraental onJanization with a naticnwide menbership; (c) Atlantic (bunty Citizens (buncil cn Environment (ACCCE), a New Jersey envircrrnental organization; I (d) Board of Chosen Freeholders of Atlantic County, New Jersey (Atlantic County), the governing bcdy of Atlantic County, New Jersey; I

(e) Bruce Doueck; I l I

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I (f) Envirornental Law Society of the University of Miami School of Law, Inc. (however, the Envirormental Law Society withdrew its petition in February, 1974).

I 9. In February, 1974, the State of New Jersey filed a' petition to participate as an interested State pursuant to 10 CFR Section 2.715(c).

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10. Applicant and Staff filed answers to the petitions for leave to intervene filed by the aforenentioned persons or entities.

The Board heard argtment regarding the petitions at prehearing con-ferences held on February 11, April 9 and April 30, 1974, and ulti-mately admitted NRDC and Atlantic County as intervening parties in its First Prehearity Conference Order dated April 15, 1974 and Brigantine and AOCCE as intervening parties in its Second Prehearing Conference Order dated May 21, 1974. In additicn, in its First Prehearing Cbn-ference Order the Ibard (a) denied the Doueck petition for leave to intervene for failure to set forth contentions with the particularity required by 10 CFR Section 2.714(a), and (b) permitted the State of New Jersey to participate in the proceedirg pursuant to 10 GR Section I 2. .'15 (c) .

11. In its First and Second Prehearing Ocnference Orders the Board admitted certain contentions propounded by Brigantine, NRDC, Atlantic County and AOCCE as issues in controversy. The Board subse-quently adnitted other contentions as issues in co..troversy. Appendix I

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I B hereto lists the contentions adnitted by the Board. In additiw, Appendix B lists certain other matters which were the subject of inquiry in this proceeding.2 The Board's findings of fact with regard to the contentions and certain other matters which were the subject of j inquiry are set forth in Secticn IV. of this Initial Decisicn.

I 12. By letter dated March 25, 1975, Kenneth B. Walton filed a motion with the Board requestirg the right to participate as an individual intervenor in this proceeding rather than as a representa-tive of Brigantine. In our Memorandun and Order dated May 8,1975, the Board granted Mr. Walton'c request for individual intervention status and encouraged Brigantino to secure counsel to represent its interest.

Subsequently, Brigantine did secure representation of counsel.

I 13. In August, 1975, Atlantic County filed a motion to amend and expand its contentions. In October, 1975 Brigantine also filed a moticn to amerd ard expand its contentions. Applicant and Staff filed answers to these notions and this Board heard argtraent thereon at a prehearity conference held on Decenber 2, 1975. In our Fourth Pre-hearing Ccnference Order dated December 29, 1975, the Board admitted I

I 2 Since several of the admitted contentions in this proceeding per-tained to the same subject matter, they were consolidated by topic for consideration at hearing. Appendix B reflects this consolidation I ard utilizes the Ronan numeral numbering sequence and subject matter desigr.ations onployed by the Applicant in its various rrotions to establish schedule.

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1 I i certair of Brigantine's proposed amended and expanded contentions as issues in controversy. The Board in this Order denied all Atlantic County proposed amended and expanded contentions as either having been included within the original wording of previously admitted Atlantic I County contentions or as failing to set forth a proper contention-under applicable 0:mnissicn regulations. The Brigantine amended and expanded cententions which were admitted as issues in controversy are listed in Appendix B hereto.

I 14. On Novenber 19, 1976, NRDC filed a notion to amend and expani its contentions. Also on Novenber 19, 1976, counsel for ACCCE filed a joint notion cn behalf of ACCCE and Atlantic 03unty to amend and expand their contentions. Applicant and Staff filed answers to these notions and the Board heard argtraent thereon cn May 20, 1977.

15. On June 24, 1977, Brigantine filed a Notice of With-

, drawal as a party to this proceeding. Said withdrawal was approved by Board Order dated July 27, 1977.

16. This Board, in its August 1, 1977 Memorandum and Order Re: Motions to Amenci and Expand Contentions, admitted one proposed I ACCCE/ Atlantic 03unty contention as an issue in controversy. Addi-l tionally, in this Order the Board stated that in view of the with-drawal of Brigantine as a party, the Baard would treat the cne Brig-antine proposed amended and expanded contention which it admitted as an issue in controversy at the May 20, 1977 argunent as an issue I

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I retained by the Board. Finally, in this Order the Board requested Applicant and Staff to present evidence cn a Board question pertaining to consideration of the utilization of heat pumps and of secondary and tertiary recovery fran oil wells in the environmental assessment undertaken in ocnnection with the Application. The 1CCCE/ Atlantic ~

County contenticn, the Board issue and the Board question are listed in Appendix B hereto. I I

17. On June 15, 1976, Mr. Ernst J. Effenberger (Effenberger)

I made a limited appearance statenent before the Board concerning turbine-generator matters (Tr. 999-1010). The Board requested Ap-plicant and Staff to address die matters raised by Effenberger. Sub-sequeri'ly the Board authorized withdrawal of the limited appearance statr ent arri Effenberger testified on turbine-generator matters as a witness for A00CE.

I 18. In August, 1978, NRDC filed a notion to amend its con-tenticn. That moticn was denied by Order dated Septanber 11, 1978 and a notion to reconsider that Order was denied by Order dated Novenber 9, 1978. For additional discussicn of this matter, see paragraph 33, infra.

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19. In April,1977, Applicant filed a motion for reconsider-aticn of that porticn of this Board's K1y 21, 1974 Seccnd Prehearing Conference Order which had admitted an A00CE ccntention pertaining to breakwater stability as an issue in controversy. By Order dated April I

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I 20, 1977, the Board granted Applicant's motion and ruled that the ACCCE breakwater stability contention was site related and hence improper as a contention in this manufacturity license proceedirg.

Accuriingly, this contention was dismissed.

i 19.1 On October 16, 1981, the state of New Jersey filed a motion requesting that it be dismissed as an interested state partic- )

ipant in this proceedirg. Said rroticn was granted by Board Order dated Novenber 6,1981.

I C. DISCOVERY, HEARINGS AND M7PICNS EUR SLFNARY DISIOSITION

20. In its Seccrd Prehearity Conference Order the Board opened discovery cn all issues in controversy. Applicant, Staff and all intervenors ergaged in scme discovery thereafter, the majority of such discovery being conducted on an informal basis.

21. A Notice of Evidentiary Hearing was issued by the Board on March 11, 1976. The Notice of Hearing stated that hearings would be held in Jacksonville, Florida, on March 23 and 24, 1976, for the pur-pose of consideraticn of the Staff's Final Environmental Statenent, Part I (FES I) together with the Applicant's Envircrrnental Report, Part I, as supplemented (ER I) . These documents considered the envir-ormental impact of manufacturity activities to be conducted at the Applicant's Blount Island facility. The Notice of Hearing also stated i l I

I that limited appearance statments muld be received at this Jackson-ville hearirg sessicn. Finally, the Notice of Hearing advised that a public 1 caring session would be held in Atlantic City, New Jersey, cn Marcit 29, 1976, for the purpose of receiving limited appearance statements. l I 22. Evidentiary hearing sessions were held in Jacksonville en March 23-24, 1976. At the March 23, 1976 hearing, Arplicant's witnesses authenticated and the Board admitted into evidence, the IR I.3 In addition at the March 23, 1976 hearing, Staff witnesses authenticai , and the Board admitted into evidence, the FES I.

23. Limited appearance statments were taken by the Board at hearing sessions held in Jacksonville, Florida, cn Perch 23-24, 1976.

Heariry sessions were convened in Atlantic City, New Jersey, on March 29-30, 1976, and limited appearance statements were received at those I sessions. Limited appearance statments also were '.ake1 at a hearity session held in Bethesda, Maryland cri June .'5,1976 I

3 Exhibits OPS-4 through OPS-10. The witnesses who authenticated these exhibits were Dr. John A. Nutant ard Messrs. Thmas A. Mantia and Harlan L. Bowman. (Professional Qualifications admitted and incor-porated into the record at Tr. 609.) Appendix C hereto identifies all I Applicant Exhibits by number and descripticn and provides the trans-cript page and date of admissicn.

4 I FES was admitted into evidence at Tr. 642 and incorporated into the recxard followiry Tr. 637. Messrs. Fred J. Clark, Jr. and Roy Tcma were the sponsoring witnesses. (Professional Qualifications admitted and incorporated into the record at Tr. 637.)

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24. On May 11, 1976, the Board convened a special prehearing conference to consider the scheduling of hearire sessions, the status l I of disco rery in the proceeding and other matters. At the special prehearing conference the Board heard argument regarding NRDC's opposition to the establishment of a hearir:g schedule in accordance" with a Stipulaticn Concernirg Hearirg Schedule and Related Matters (Stipelation) dated March 8, 1976 which had been entered into by all parties to the proceedirg with the excepticn of NRDC.

I 25. Following the May 11, 1976 special prehearing confer-ence, the Board issued its Fifth Prehearirn Conference Order dated May 17, 1976. In that Order the Board rejected the NRDC argument that E

5 evidentiary hearirgs could not begin until the full final environ-mental statement had been published. In that Order the Board also ordered the restanpticn of hearirgs on June 15, 1976. The Board further stated,in its Order that all the conditions, limitations and qualific-ations in the Stipulaticn would be adhered to and that the schedule therein would be followed as closely as was reasonably practicable.

I 26. Pursuant to published notice, evidentiary hearirgs on radiological health and safety matters were held in Bethesda, Maryland, cn June 15-18, 1976, in Washirstcn, D.C., on July 6-9, 1976, in Silver Spring, Maryland, cn July 26-27, 1976, and in Bethesda, Maryland cn July 28-30, 1976, Septenber 20-24, 1976, Septenber 28-29, 1976, Novenber 3-4, 1976, December 8-10, 1976, December 16-17, 1976, February 28-March 4, 1977, May 9-13, 1977, May 16-17, 1977, Novender g

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L' 2, 1979 and Decenber 4, 1981. In addition to the hearings en FES I l l

held on March 23-24, 1976, hearings on environnental issues relating I to generic siting of FNPs were held in Bethesda, Maryland on May 17-20, 1977, July 10-13, 1978, April 4, 1979, Novenber 2, 1979 and Decenber 4,1981.

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27. On February 16, 1979, NRDC filed a notion seeking stm-mary disposition with regard to its sole contention in this proceed-ing. This contention alleges that the Final Environmental Statenent prepared by the Staff in connection with its review of the instant Application violates the requirenents of NEPA in that it is not a progranrnatic impact statenent. The Applicant's answer to the NRDC motion and the Applicant's cross-notion for simnary disposition was filed on March 8, 1979. The Staff's response to the NRDC motion was filed March 13, 1979. The NRDC reply to Applicant and Staff responses and its opposition to Applicant's cross-notion was filed on April 16, 1979. By Menorandtm and Order dated May 25, 1979 the Board granted Applicant's cross-motion for simnary disposition and denied NRDC's notion for simnary disposition. The Board held that the Final Environ-mental Statenent acrnplies with the requirenents of NEPA in addressing the proposed action herein - the manufacture of eight FNPs - and that NEPA does not require the preparation of a progrannatic impact statenent.

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I D. INTERIDC'JIORY APPEAIS Im0M BJARD RULINGS

28. Applicant cn March 17, 1977 filed a notion to establish schedule requestirg, inter alia, a schedulirg of hearings in May,1977 to consider certain enviremental contenticos which had been admitted-as issues in controversy. All previous hearirry sessicms dexrted to ecnsideration of admitted contentions had addressed radiological health and safety issues. On March 29, 1977, Brigantine filal a response in partial opposition to Applicant's notion to establish schedule in which Brigantine opposed the schedulity of any hearirgs on previously admitted environmental contentions, claiming that such schedulirg contravened the provisions of the Stipulaticn. By Order dated April 12, 1977, the Board scheduled hearings cn certain pending environmental contentions for the May, 1977 hearing sessions. On April 20, 1977, the Staff filed a moticn to modify the scheduled May, 1977 hearirg sessions. Brigantine again rairci the Stipulaticn ob-jection in an answer to the Staff notion dated April 26, 1977. On April 26, 1977, the Board issued an Order schedulirg May,1977 hearirg sessions cn cne admitted environmental contention of Atlantic (bunty pertainity to resort econcmic% On April 28, 1977, Atlantic County filed a noticn for reconsideration of the Board's April 26,1977 Order scheduling May,1977 hearing sessions cn the resort econcmics environ-mental contention. Atlantic Cbunty's noticn for reconsideration and Erigantine's objet.icn to enviromental contenticn hearirgs were rejected by the . 1 at the May 9, 1977 hearing (Tr. 5505-5509).

AOO:2 made an oral moticn fer reconsideraticn of the May 9, 1977 I .

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I ruling at the hearing sessicn of May 10, 1977 which was rejected by the Daard that day (Tr. 5643-5654). On May 19, 1977, Brigantine filed with the Atanic Safety and Licensirg Appeal Board (Appeal Board) a pleading entitled " Application for Review of Hearing Board Ruling and fcr stay of Further Hearirgs cn Atlantic County Contenticn No. 1" (Resort Econanics)". In that pleading Brigantine sought to have the Appeal Board review the detenninatiart of this Board that hearings could proceed with regard to consideration of Atlantic County's resort econanics contentien at the May, 1977 hearirg sessions. The Appeal Board issued a Manorandtzn and Order dated May 20, 1977 in which it denied Brigantine's applicaticn for review cn the ground that it was interlocutory and rot appealable as a matter of right, and cn the further ground that the Appeal Board saw no occasicn to invoke its discretionary authority to undertake review of the matter.

29. On February 2, 1978, Applicant filed a Motion for Relief in which it sought an order fran this Board directing the Staff to file the Adder:dtrn to Part II of the Final Envircrrnental Statement, Part II (FES II) not later than February 16, 1978, and to publish the Final Envirorinental Statenent, Part III (FES III), not later than March 10, 1978. In its Moticn for Relief, Applicant also sought declaratory relief in the nature of a directive fran this Board to the Staff not to include within EES III an analysis of the environnental effects of an accident more severe in consequences than those within the design basis (the " Class 9 accident" issue). This Board in its Order dated February 23, 1978, denied Applicant's Motion for Relief.

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I Applicant on March 18, 1978, filed a moticn for reconsideraticn of that Order. By Order dated March 30, 1978, the Board denied Appli-cant's motion for reconsideraticn. In this Order the Board did direct the Staff to publish FES III on or before April 24, 1978, and to I publish the Final Addendtzn to FES II cn or before June 6,1978. -

30. On April 7, 1978, the Staff petitioned the Appeal Board to direct certificaticn of that porticn of the Board's March 30, 1978, Order which required the Staff to publish the Final Addendum to FES II by June 16, 1978, and the FES III by April 24, 1978. On April 17, 1978, Applicant filed with the Appeal Board a pleading entitled

" Applicant's Opposition to NRC Staff Petiticn for Order Directing Certification and Applicant's Cross-Petiticn" . In this pleading, Applica.it opposal Appeal Board certification of the Staff appeal regarding the authority of this Board on schedule matters but cross-petitional seeking an order of the Appeal Board directing certifica-l I tion of the Class 9 accident issue.

31. By Order dated April 19, 1978, the Appeal Board granted

, both the petiticn of the Staff for certification of the issue pertaining to licensing board authority cn schedule matters and the I petiticn of the Applicant for certificaticn of the Class 9 accident issue. After briefing, the certified questicns were argued before the Appeal Board cn May 25, 1978, and the Appeal Board issued its decision on August 21, 1978, (AIAB-489), 8 NRC 194 (1978). In that decision

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• Appen w refusea to grant the declaratory relief sought by the i

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I Applicant with regard to the Class 9 issue. The Appeal Board also held that a licensing board may direct the Staff to publish its en-virormental doctments by specific dates if it, after affording the parties an opportunity to be heard cn the matter, finds that no further delay is justified. However, in this proceeding the Appeal-Board ruled that this Board's Order of March 30, 1978, setting a date for the filing of EIS III and the FES II Addendtri had not rested on such a finding and thus that portion of the March 30, 1978, Order was not allowed to stand. On Septanber 1, 1978, Applicant moved for reconsideration of that portion of ALA3-489 telating to the Class 9 accident issue and, in the alternative, requested the Appeal Board to certify that issue to the Ormission for its determination. The Appeal Board in ALAB-500 issued September 29, 1978, 8 NRC 212 (1978),

denied Applicant's motion for reconsideration but exercised its authority to certify the Class 9 accident issue to the Ccmnission.

I 32. By Order dated December 8, 1978, the Omrtission issued an Order accepting review of the questicn certified by the Appeal Board in AIAB-500. Briefs by certain of the parties to this proceed-ing as well as by amicus curiae parties were filed with the Ccrmis-sion. The Ctmnission issued its decisicn cn September 14, 1979, (CLI-79-9), 10 NRC 257 (1979) . In that decisicn the Ccmnission reft: sed to grant the declaratory relief sought by the Applicant with regard to the Class 9 issue.

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33. On August 9, 1978, NRDC filed a notion seeking Board permissicn to amend its sole contenticn in this proceedirg. Following receipt of pleadings filed by Applicant and the Staff opposing the '

NRDC moticn, this Board, by Order dated Septanber 11, 1978, denied the motion. In so cbing, the Board ruled that the proposed amended NRDC-contenticn constituted a challenge to 10 GR Part 50, Appendix M and therefore violated 10 CFR Section 2.758. Thereafter, NRDC filed a moticn for reconsideraticn of the September 11, 1978, order, ard in the alternative, for certification. Applicant opposed the NRDC motion for reconsideraticn and certification. By Order dated November 9, 1978, the Board denied both the NRDC motion for reconsideration and its request for certificaticn. Following this Board Order, NRDC on November 30, 1978, filed a request for directed certificaticn with the Appeal Board. By Mercrardtm and Order dated January 4, 1979 (AIAB-517), 9 NRC 8 (1979), the Appeal Board denied the NRDC moticn for directed certificaticn. By Order dated February 1, I 1979, the Ccm-mission, pursuant to 10 CFR Section 2.772, extended the time for Ccmnissicn review of AIAB-517 until February 9, 1979. The time for Ccmnissicn review of AIAB-517 has expired.

I II. FINDINGS OF FACT - HEALTH AND SAFEIY

,I A. GENERAL

34. The Board is required by the Notice of Hearing issued in this proceeding cn December 10, 1973, to determine:

I I-(a) Whether in accordance with the AEA:

I l (1) The Applicant has described the proposed I design of, and the site parameters postulated for,

• the reactors, includirg, but not limited to, the principal architectural and engineering criteria for the design, and has identified the major fea-tures or canpanents incorporated therein for the protecticn of the health and safety of the public; I (2) Such further technical or design informaticn as may be required to canplete the Applicant's design report and which can reasonably be left for later aansideraticn, will be supplied in a supple-ment to the design report; (3) Safety features or conponents, if any, which require research and developnent have been des-cribal by the Applicant and the Applicant has identified, and there will be conducted a research and developnent program reasonably designed to resolve any safety questions associated with such features or conponents; and I

(4) on the insis of the foregoing, there is rea-sonable assurance that (i) such safety questions will be satisfactorily resolved before any of the poposed nuclear power reactors are re eved frcm ti.e manufacturing site and (ii) taking into con -

sideraticn the site criteria contained in 10 GR Part 100, the proposed reactors can.be constructed and operated at sites having characteristics that fall within the site parameters postulated for the design of the reactors without undue risk to the health and safety of the public.

(b) Whether the Applicant is technically qualified to design and manufacture the proposed nuclear power reactors; (c) Whether the Applicant is financially qualified to design and manufacture the proposed reactors; and (d) Whether the issuance of a license for manufacture of the reactors will be inimical to the ccmucn defense I and security or to the health and safety of the public.

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B. DESCRIPTICN OF ' HIE ENP RID SITE ENVEIDPE

35. The basic shape of the ENP platform will be approxi-mately square with overall dimensicris of 400 by 378 feet. The plant systens aM structures, in gene ' , will be arranced on top of the ~

basic platform structure. Within the platform structure, there will be 44-foot-deep bulkheads which extend the full length of the platform in perpendicular directions. These bulkheads will form the basic support structum for the hull bottan, sides, arx1 main deck. (PDR, Section 1.2.1; SER, Section 1.4) . For convenience, the description of the HIP is divided into seven basic areas discussed below. The nuclear steam supply system and the site envelope are discussed separately below.

I Safeguards Area i 36. Four trains of engineering safeguards cysters will be providal. Each will be located in a conpartment separate fran the others and each will have its own diesel generator. The equipnent in each train will be arranged in similar vertical configurations to neximize the separation between trains. In order to ensure avail-ability of equipnent vital to safe shutdown in the event of the sinking energency, three of the four safeguard trains of equipnent will be located in three separated watertight canpartments. (PDR, Sections 1.2.2.4 arri 8.3.1; SER, Section 1.4.1) .

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i Contalment Area

37. The containment will house the reactor and reactor J coolant systen. Tha contairunent system for the RG will consist of a i contairrnent vessel and a shield buildirg. The containment vessel will-be a free-standing, welded steel cylindrical structure. A concrete shield buildirg will enclose the contairrnent and will provide an annulus within which any leakage fran the contairrnent follonng an accident will be collected prior to filtraticn and release to the envirorrnent. The containment fluid systens for the ENP include con-tairrnent spray systens, containnent isolaticn systens, an annulus filtration system and canbustible gas control systems. The mntairunent will utilize an ice mndenser. The cavity beneath the reactor vessel is fitted with a refractory ladle to retard the process of thermal attack for the postulated event of a degraded core accident with subsequent reactor vessel melt-through. (PDR, Sections 1.2.3, 6.2 and 6.4.2; SER, Sections 1.4.2 and 0.2; SHI Supplanent No. 3, passim) .

I Auxiliary Area I

38. The auxiliary area will house the spent fuel pit and radwaste treatment systems. Spent fuel transfer equipnent is designed such that the spent fuel pit will not be endangered by an accident involving the drop of a spent fuel cask. Each ENP will have radwaste systens to provide for controlla1 handlire arri treatment of liquid, gaseous and solid wastes. The liquid waste treatment system will t

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process wastes from egripment and floor drains, decontamination operations, laboratory wastes and laundry aM shower wastes. The gaseous waste treatmmt system will provide holdup capacity to allow decay of short lived noble gases stripped fran the primary coolant and treatment of ventilation exhausts through high efficiency particulate

• air and charcoal filters. The solid waste treatment systen will provide for the solidification, packaging and storage of radioactive wastes generated during ENP operaticn prior to shipnent offsite to a licensed facility for burial. (PIR, Sections 1.2.2.2, 11.2, 11.3 and 11.5; SER, Sections 1.4.3 and 11.1).

Otritrol Area

39. The control roon will be located in the control area.

4 The control roon will be surrounded by radiological shielding and will be provided with a ventilation systen incorporating dual air intakes and the capability of filtered recirculation. (PDR, Sections 1 2.2.5 and 6.5; SER, Sections 1.4.4 and 6.4).

1 m Turbine-Generator Area I 40. The turbine generator area houses the steam aM power conversion systen. The steam and power conversion systen for the ENP will be of conventicnal design, similar to those of previously ap-proved pressurized water reactor plants but with certain features provided to accomodate platfonn movenents, such as a spring-nounted I

I turbine foundaticn arx1 vacuum-balanced condenser. The systen will be designed to renove heat energy frcm the reactor coolant by four steam I

1 generators and convert it to electrical energy by the steam driven turbine-generator unit. The condenser will trans fer unusable heat in the cycle to the condenser coolirg water. The entire system will be ~ l designed for the maximtri expected energy frcm the nuclear steam supply systen. (PDR, Sections 1.2.2.6 and 3.7.2.1.1.8, Chapter 10; SER, Sections 1.4.5 and 10.1).

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Power Transmissicn Area I 41. The power transmission area will house the main and auxiliary transformers as well as various switchyard equipment.

Terminal facilities cn the ENP for plant-to-shore 345 KV transmission circuits also will be provided. (PDR, Sections 1.2.2.7 and 2.10.1; SER, Sections 1.4.6 and 8.2).

Administration and Service Area I 42. The administraticn and service area will contain the hc '. el , administrative and health physics facilities. (PDR, Section 1.2.2.3; SER, Section 1.4.7) .

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l Nuclear Stem Supply Syst e

43. The Westinahouse RESAR-3 (Consolidated Version) nuclear stean supply systen without loop stop valves will be the nuclcir steam supply systen for the ENP. The prorcsed initial core power for the ENP ~

is 3411 megawatts, thermal. The nuclear stean supply systen consists of a pressurized water reactor, a four-loop reactor coolant systen, and associated support systems. The reactor mre will contain 193 fuel e

assenblies, each containing 264 fuel rods (17 x 17 array) of slightly enriched uraniun encapsulated in Zircaloy tubes. Upper and lowr reactor internals will provide support, location, orientation, and guidance for the fuel assenblies and their control rods as well as defining a ficw path for the reactor coolant. (PDR, Secuon 1.1.3, Chapter 4; SER, Sections 1.5 and 4.1).

44. The reactor coolant systen will consist of four essen-tially identical loops of piping, reactor coolant pumps, and steam generators. Reactor molant will circulate through the core, where it will be heated; it will then go to the steam generator, where the heated coolant will transmit heat to the feedwater, thus producing steam. The coolant pressure will be controlled by a pressurizer and ancillary equipnent attached to one loop. (PDR, Section 5.1; SER, Section 1.5).

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45. Four auxiliary support systems will perform several functions necessary for reactor and reactor coolant systen operaticn.

The chanical and voltrne control system will maintain water inventory in the reactor coolant systen and will provide flow to the seal systan of the reactor coolant gunps; it will also control the coolant chan ~

istry, includirg borcn concentration and the purity of the reactor coolant. The boron recycle system will process effluent frun the reactor coolant systen ard chanical ard voltzne control systen to renove particulate matter, fission products, activation products, and I to reconcentrate boric acid. This processing v;ill minimize plant discharges by enabling the boric acid soluticn and reactor grade water to be recycled. The safety injecticn systen will function as part of the anerr;ency core cooling systen. Other plant systems performing as part of the energency core cooling systen will be the residual heat removal system and the upper head injection syst m. The safety in-jecticn systen ard the upper head injecticn syster will supply highly concentrated inrated water to the reac mr coolant system in the event of a loss-of-coolant accident, or a steam line rupture. These systans will use pressurized accumulators for rapid response, and high, intennediate, and low head pumping systens for continuous injection and long-term recirculation cooling. The residual hedt removal systen will remove heat fran the reactor core during normal plant cooldown and refueling and will provide 1cu head injecticn and recirculaticn as part of the safety injecticn systen. (PDR, Sections 6.3 and 9.3; SER, ,

Section 1.5).

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46. Many features of the design of the SNP are similar to l those approved previously for land based nuclear power plants now under construction or in operation, especially the McGuire Nuclear Staticn Units 1 and 2 (Dccket Nos. 50-369 and 50-370), and the Catawba I Nuclear Station Units 1 and 2 (Docket Nos. 50-413 and 50-414) . (SER,'

I Secticn 1.5) .

Site Envelope I 47. In accordance with 10 GR Part 50, Appendix M, the Applicant has developed site envelope parameters which will assure that the ENP is not subjected at an operating site to conditions for which it has not been designed. Ebrther, in accordance with Appendix M, a detailed review will be made of each individual site during construction permit proceedings to ascertain that the site falls within the site envelope parameters. (PDR, Chapter 2; SER, Section 1.6). A contenticn concerning the appropriateness of the site envelope parameters was raised by Brigantine in this proceeding. The Bcard's Findings of fact regarding this contention are set forth in Secticn IV. F, infra.

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I 1 C. SAFEIY EVAWATIm OF THE FNP

48. The Applicant in its PDR has described the proposed design of, aM site parameters postulated for, the FNPs, incitding, I but not limited to, the principal architectural and en9 meering' criteria for the design, and has identified the major features or conpanents incorp rated therein for coping with energencies in the operaticn of the reactor and for the protection of the health and safety of the pblic incitding plant design features required for conpliance with 10 CER Part 50, Appendix E. Further technical or design information, as may be required to conplete Applicant's design report aM wttich can reasonably be left for later consideration, will be supplied in an amendment to the design report. The PDR describes the quality assurance to ho applied to the Gesign, fabrication, ccnstruction, and testing of the facility. (PDR, passim) . The PDR also describes the design features for reactor vessel material surveillance required by 10 CFR Part 50, Appendix H (PDR Section 5.2.5).

I 49. The Staff perfonned a technical review and evaluation of the data subnitted by Applicant in the license Application and in the I

I Exhibit OPS-21, admitted into evidence at Tr. 1031. The witnesses wlo authenticated the Pm were Dr. Dee H. Walker and Messrs. P. Blair Haga and Robert A. Bruco. (Professional qualifications admitted and I incorporated into the record at Tr.1024.) Subsequent amendments to the Pm (Amendnents 23, 24, 24 (Errata), 25, 26, 27, 27 (Errata), 28 aM 30 ard further identified as Exhibits OPS - 21A throtsh 21H, respectively) were admitted by stipulaticn at Tr. 2978 and 7532.

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l PER. As a result of this review and its own independent studies, the Staff prepared the SER ard its Supplements.6 The SER analyzes and evaluates the following topics anong others: postulated site param-eters, includirg seisnelogy, geology, hydrology, and meteorology; the design, fabrication, construction, testing, and expected performance-of the ENP's structures, systens, and canponente important to saft.(;.yy the response of the facility to various anticipated operating trans-lents and to a broad spectrun of postulated accidents including design basis accidents; plans for conducting plant operations, the steps to I be taken for industrial seccity, as well as the financial and tech-nical qualifications of the Applicant (SER, passim) .

y 50. In sum, we have examined Applicant's manufacturing license Application, the PDR, and the Staff's SER as supplanented and I find that appropriate site parameters have been postulated. We further find that the ENP is designed adequately to take into account the postulated site parameters, incl #.ing meteorological, hydrological, and geological conditicns. Additionally, we find that there is reason-able assurance that a number of sites along the East and Gulf coasts meet the ENP site envelope parameters. (Tr. 1489; SER, Section 1.6).

I I 6 SER and SER Supplement No. I were admitted and irrorporated into the record at Tr. 1043. The witness sponsoring the testimcny was Mr.

Ralph A. Birkel. (Professional qualifications adnutted and incorpor-I ated into the record at Tr.1038.) SER Supplanent No. 2 was admitted at Tr. 7388. SER Supplements No. 3 and No. 4 were admitted by stipu-laticn at Tr. 7522.

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I D. RESEARG MD DEVEWPMENT

51. Applicant has described in the PER safety features or conponents which require research and developnent. (PDR, Section 1.5).

Applicant's R&D Irograms, which are essentially developnental in*

nature, are aimed at verifying certain aspects of the ENP design. The objectives and schedules for coupleticn are stmnarized in the PDR.

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52. The Board finds that Applicant has identified safety I features or cantonents which require research and developnent and that Applicant will conduct a research and develor-nent program reasonably designed to resolve any safety questions associated with such features or conponents.

E. REASWABLE ASSURANCE I

53. On the basis of the foregoing, the Board finds that there is reasonable assurance that (1) any safety questions associated with safety features or couponents which require research and de-velopnent will be satisfactor.ly resolved before any of the ENPs are retoved fran the manufacturirg site ard (ii) taking into consideraticn the site criteria contained in 10 CFR Part 100, the ENPs can be constructed and operated at sites havirg characteristics that fall Athin the site parametera postulated for the design of the ENPs without undue risk to the health and safety of the public.

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F. TEQNICAL QUALIFICATIWS OF APPLICINF

54. The PDR sets forth the Applicant's technical qualifica-tions. (PDR, Secticn 13.1 aM Appendix C) . The Staff, in the SER, '

determined that the Applicant is technically qualified. (SER, Section 22.0 and SIR Supplanent No. 4, Section II .J.3.1) . The Applicant's technical qualifications were not contested in this proceeding.

Against this background and in light of our own review of the record, the Board finds that the Applicant is technically qualified to design ard manufacture the ENPs.

G. FINANCIAL QUALIFICATINS OF APPLICANT The Applicaticn 6 .1 sets forth the Applicant's financial 55.

f qualifications. Included in the Application is data indicating that the relevant costs for manufacture of the ENPs can be financed in the

ordinary course of Applicant's business (Application, Section 6 passim). The Staff provided written testimony6.2 addressing the 6.1 0PS-20 admitted into evidence at Tr. 1031. The witnesses who 5 authenticated the Application were Dr. Dee H. Walker and Mesars. P.

Blair Haga and Robert A. Bruce (Professional qualifications admitted at Tr. 1024) . A subsequent revision to the Application, I further identified at Exhibit OPS-20A, was admitted by stipulation at Tr. 7533.

6.

I ne Staff's written testimony entitled "NRC Staff Testinony Regard-ing Update of Financial Qualifications Analysis" was admitted by stipulation at Tr. 7708.

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I Applicant's financial qualifications, and the matter was considered in a hearing session on Deceber 4, 1981; the testimony appears at Tr.

7708 to Tr. 7728 6 3. After reviewiry the Applicant's data and subject-ing that informa. tion to an independent check, the Staff testified that the Applicant is financially qualified (Staff Updated Testimcny,-

passir.) . Neither the Applicant's ror the Staff's financial determina-tions were contested duriry this proceedirg. Against this backgrourd ard in light of our own review of the record, the Board finds that the Applicant is financially qualified to design and manufacture the ENPs.

I H. CDbtm DEFENSE AND SECURITY

56. The activities to be corducted under the manufacturing license applied for will be within the jurisdiction of the United States (PDR, Section 1.1.3).

I 57. Applicant is not owned, ckminated, or controlled by an alien, a foreign corporation, or a foreign goverrment. The activities to be conducted do rot involve any restricted data, and no nuclear fuel will be secured or supplied in connection with the activities to I

performed pursuant to this license. Ebr these reasons, and in the I 6.be Staff's witness, Mr. Jim C. Peterson, was exa;: tined by the I Board. Mr. Peterson's Professional Qualificat. ions were admitted by stipulation at Tr. 7708. Applicant witness, Mr. P. Blair Haga, provided direct oral testimony and was exanined by the Board (Professicnal Qualifications admitted at Tr.1024) .

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, absence frcm the record of any evidence to the contrary, we find that the activities to be performed will not be inimical to the ccrmon defense and security.

E .

I I. MMTERS ARISING EPOM LOSENS IEAINED EFOM THREE MIIE ISLAND (TMI) 57.1 The requirements arising frcrn the accident at TMI which apply to the ENP are contained in the Staff document, NUREG-0718, entitled " Licensing Requirements for Pending Applications for Cbn-struction Permits and Manufacturing License" (SER Supplanent No. 4, pp. ix, x) . The Staff testified .46 that a containment pressure re-quironent in addition to the requirenents stated in NUREG-0737 has I been developed for Ccnmission consideration6 .5 ,

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I 6.4 Also see footnote 6.7. Staff testinony was prepared in response to the Board's letter of Noverber 12, 1981 as further described in Section IV.V, infra.

6.he Board takes rotice of the Ocnmissicn's engoing rulemaking I

proceeding in the matter of post-TMI requirenents for Near-Term Construction Pennit and Manufacturing License Applications.

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I 57.2 The Applicant has responded to the requirements of NUlun-0737 and to the additional containnent pressure requirenent noted in paragraph 57.1 (PDR, Appendix C, Section 13.1 aM Qiapter 17). The Applicant also provided testinony6 .6 addressirg this acMi-I, tional containment pressure requiremsit.

I 57.3 The NRC Staff reviewed the Applicant's responses to all of the post-TMI requirements and concluded that these requirenents have been satisfied (SER Supplanent No. 4, passim) . The Staff *also presented testinony concerning the proposed additional c:>ntainment 6

pressure requirenent .7 ard stated that the requiranent has been satisfied (Tr. 7688).

I 57.4 Neither the Applicant's responses to post-TMI matters ror the Staff's evaluaticn of the Applicant's responses were contested in this proceeding. .NJainst this background and in light of our own 6.6 Applicant prepared testimony in response to the Board's letter of Novenber 12, 1981, as further described in Section IV.V, infra.

Applicant's testimony, Exhibit OPS-69, entitled " Applicant's I Testimony in Response to the Novenber 12, 1981 Board Questions Nos.

4-7" was admitted by stipulaticn at Tr. 7692. Applicant witnesses (Drs. Dee H. Walker ard H. J. Stumpf and Messrs. P. Elair Haga and R. S. Orr) were examined by the Board at Tr. 7699-7708. (Pro-I fessional Qualifications admitted at 1024, 2881, 1024 and 1329, respectively).

I 6.7 The Staff's testimmy entitled "NRC Staff Response to Noventer 12, 1981 Board Questions 2 through 7" was admitted by stipulaticn at Tr. 7556. Staff witnesses (Andrew Marchese, Clifford Anderson, Dr.

I R.E. Johnscm, Dr. C.E. Rossi, Dr. W.T. Pratt, Dr. D.G. Swanscn and H.E. Polk) were examined by the Board at Tr. 7559-7597 and 7670-7691. (Professional Qualifications adnitted at Tr. 7415 and 7556) .

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I review of the record, the Board finds that the Applicant has satisfied the requirements arising fran the accident at 'IMI.

I GENERIC LNRETLVED ISSUES I

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57.5 The Staff has identified those generic unresolved safety issues which cane under the scope of AIAB-444 6 8 The Staff further evaluated each of these issues and concluded in each case that there is reasonable assurance that ENPs can be manufactured ard operated, before these issues have been resolved, without undue risk to the health and safety of the public. (SER Supplanent No. 4, Appendix C and Tr. 7685) .

57.6 The Staff also testified 6.9 that acceptable alternative courses of acticn are available in the event that present programs aimed at resolution of Generic Issues No. A-12 and No. A-47

• do not produce the anticipated results.

I 6.8 Gulf Statas Utilities Co. (River Bend Station, Units 1 and 2),

AIAB-444, 6 NRC 760, 775 (1977).

6.9 Staff testimcny was prepared in response to the Board's letter of I Noverber 12, 1981, as further described in Secticn IV.V, infra.

Staff testimony entitled " Response to Novcrnber 12, 1981 Board Questions 2 through 7" was admitted by stipulaticn at Tr. 7556.

Staff witnesses on generic safety issues (Drs. C.E. Rossi and R.E.

I Johnson and Mr. C. Anderson) were examined by the Board (Profes-sional Qualfiicaticus admitted at Tr. 7556).

6.10 I Generic issues A-12 and A-47 are described in SER Supplanent No. 4 (Appendix C) . In ovelview, A-12 deals with brittle fracture of support structures while A-47 deals with the possible effects of non-safety grade control systens on the course of an accident.

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I 57.7 The Staff's evaluation of Generic Unresolved Safety Issues were not contested in this proceeding. Against this background and in light of our own review of the re<rrd, the Board finds that l

there is reasonable assurance that FNPs can be manufactured and operated before these generic issues have been resolved, without undue

• risk to the health and safety of the public.

K. REVIEW BY THE ADVITRY CMIITTEE CN REACIOR SAFEGUARDS I 57.8 The Advisory Ctrmtittee on Reactor Safeguards (AQ1S) ccrtpleted its review of this Application during its General Meeting on October 16, 1981. In its letter to the Ommission, the ACRS concluded inter alia that ... the Advisory Chmtittee on Reactor Safeguards believes that Floating Nuclear Plant units can be manufactured with reasonable assurance that they can be sited and operated without undue risk to the health and safety of the public"6.ll 57.9 The Board concludes that the requiranent of 10 CFR Part

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50, Appendix M, Paragraph 1, respecting review of a Manufacturing License Application by the ACRS has been satisfied.

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ACRS letter,J. Carson Mark, Chairman, to the Honorable Nunzio J.

Palladino, Chairman of the U.S. Nuclear Regulatory Cmmission, dated October 19, 1981 was admitted at Tr. 7529. Previous interim I reports of the AQls are contained in SER Supplement No. 1 (Appen-dix B), Suppleent No. 2 (Appendix B) and Supplenent No. 4 (Appendix A).

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1 I III. FINDINGS OF FACP - CDMPLIANCE WI'ni THE NATICNAL HNIIGMFNPAL ICLICY ACP (NEPA), SECPICNS 102(2) MID 10 CFR PART 50, APPD; DIX D (NOW 10 CFR PART 51), MID APPHIDIX M i E i l

58. The Board is required by the Notice of Hearing issued in this proceeding on Decanber 10, 1973 to:

• I (a) determine whether the requirenents of 102 (2) . . .

of NEPA, 10 GR Part 50, Appendix D (rni 10 GR Part 51), and !O CFR Part 50, Appendix M, have been ocmplied with in this proceeding; I (b) independently consider the final balance among conflicting factors contained in the record of the proceeding with a view to detennining the appropriate action to be taken; and I (c) detennine whether the manufacturing license should be issued, denied, or appropriately conditioned to protect environmental values.

59. Applicant subnitted, in accordance with 10 GR Part 50, Appendix D (rru Part 51), and Appendix M a series of Envirorrnental Reprts in support of its Application. Applicant's Environnental Report, Pa.- I (ER I), as supplemented, considered the environmental impact of manufacturing activities to be conducted at the Blount Island facility. Applicant's Environnental Report, Part II (ER II),

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I together with Appendices and Supplements, evaluated envimental considerations associated with offshore, estuarine and riverine siting j I of FNPs.

I 60. The Staff performed a review and evaluation of the*

information subnitted by the Applicant in its ER. In addition, it perfonned an independent analysis and envirormer.tal -evaluation and prepared an Envirormental Statment in various parts. The Staff's Final Envirormental Statment, Part I (FES I), dated October 1975, considered the envirormental impact of the manufacturirx3 activities to be conducted at the Blount Island facility. In September 1976, the Staff published Final Envirormental Statenent, Part II (FES II) relating to its environmental assessment of the siting of ENPs at various hypothetical locations.O In February 1977, after receipt of ccrments on FES II frcm the (buncil m Environmental Quality, the I

I Exhibits OPS-57 through 64. See Appendix A for a listing of the I title, date and transcript admission page of these exhibits. The witnesses who sponsored these exhibits were Dr. John A. Nutant and Ms. Cynthia C. Spencer. (Professional Qualifications admitted at Tr.

609 and 6184 respectively.)

0 FES II was admitted into evidence and incorporated into the record at Tr. 3626. Mr. Fred J. Clark, Jr. was the sponsoring witness. (Profes-sional Qualifications admitted at Tr. 637.)

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Staff decided to publish an Addendtzn to EES II to address those connents. The Final Addendtzn to EES II was published by the Staff in June 1978.9 I 61. Mtile EES II was being prepared the Staff undertook a-generic consideration of the comparative risks and consequences between ENPs ard land-based nuclear plants concernirg a postulated accidental release of radioactive material through the liquid pathway.

'lonsideration of the liquid pathway analysis was included in Part III to the Final Environnental Statenent (EES III) which wasplished in Decenber, 1978.10 61.1 In its environraental evaluation the Staff concluded inter alia "that there is a reasonable degree of assurance that the eight floating nuclear power plants proposed for manufacture can, with suitable modifications, be sited and operated . . ." (EES III, p. xiv) .

The Staff identified the single modificction relating to plant design E

The Final Addendtrn to EES II was adntitted into evidence and incor-I porated into the record at Tr. 7014. Messrs. Clifford A. Haupt and Roy E. Ttrna were the sponsoring witnesses. (Professional qualifica-tions adntitted ard incorporatal into the record at Tr. 7014 and 637 respectively.)

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FES III w=s admitted into evidence by stipulation cn April 4,1979, as Staff Exhibit 3 (Tr. 7264). The Staff's Liquid Pathway Generic l Study (NUREG 0440) was also admitted into evidence by stipulation cn l l April 4,1979 as Staff Exhibit 4 (Tr. 7764) . Also on April 4, 1979 '

the Applicant's Liquid Pathway Generic Study, 'Ibpical Report No.

22A60, was admitted into evidence by stipulation as OPS Exhibit 65 l

I (Tr. 7266).

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I I statirg, "The Applicant shall replace the concrete pad beneath the reactor vessel with a pad constructed of magnesium oxide ... or othcr equivalent refractory material, that will provide increased resistance to melt-through by the nelten reactor core in the event of a highly unlikely core-melt accident and which will not react with core-debris to form a large volume of gases." (EES, Part III, page xv) .

I 61.2 Applicant has designal a core ladle to be constructed of magnesium oxide which satisfies the Staff's requirenent (PDR, Section 1.2.12). The Staff has evaluated the core ladle design and its I thermal performance and concurs with the Applicant that the design requironents have been met. In pr.rticular, the Staff found that the ladle will delay melt-through by a period of between two and seven days and that there are ro effects such as excessive gas generation which would adversely affect plant safety. (SER Supplanent No. 3,Section VIII).

I 61.3 Ibth the Applicant and Staff provided supplanental l0.1 written testimony h res m e e M gesh m we 1Mle design.

I 10.bestimony was prepared in resIonse to the Ibard's letter of Novenber 12, 1981, as further describal in Section IV.V, infra.

Applicant's written testimcny entitled " Applicant's Testimony in I Response to the Novenber 12, 1981 Board Questicn Nos. 4-7" was admitted at Tr. 7692. Staff's written testimony entitled "NRC g Staff's Responses to Novenber 12, 1981 Board Questions 2 through W 7" was admitted at Tr. 7556.

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I I The matter was considered in a hearing session on Decenber 4,19G1; the testimony appears at Tr. 7557-7579 and 7693-770810.2, 61.4 Applicant and Staff have agreed to a testing program which will supply additional information and data regarding core ladle" thermal performance. (SER Supplement No. 3,Section VI; Tr. 7565 and Tr. 7698-7701).

I 61.5 Ibth the Applicant and the Staff stated that in their judgment it is not feasible to provide canplete contaittaent of a molten core by enlarging the passive ladle. (Applicant Testimony, p.

2; Staff Testinony, p. 7; Tr. 7562-7563 and 7704-7707) . The Staff and Applicant stated that a delay period of at least two days can provide significant benefits with regard to accident mitigaticn. (Tr. 7559-7560, 7693-7694; EES Part III, pages 3-48 and 3-49) .

I 61.6 The Board finds that the core ladle design conserva-I. tively satisfies the Staff's design requirements.

I I 10.2Applicant witnesses (Drs. D.H. Walker and H.J. Stumpf and Messrs.

R.S. Orr and P. Blair Haga) were examined by the Board (Profes-

-I sional Qualifications admitted at Tr.1024, 2881, 1329 and 1024, respectively) . Staff witnesses (Drs. D. Swanscu and W.T. Pratt and Mr. A. Marchese) were examined by the Ibard (Professional Quali-fications admitted at Tr. 7556, 7556 and 7415, respectively).

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62. The couplete Final Divironmental Statenent (FES) des-cribes the major systens of the ENP, its manufacturing process, the envirrmmental effects of plant operation at hypothetical sites having characteristics that fall within the postulated site parameters, and postulated design basis accidents. The EES also contains an analysis-of alternatives to the ENP. In additicn, the FES contains a cost-benefit analysis which considers and balances the environmental effects of the ENP and the alternatives available for reducing or avoiding adverse environmental effects, against the environmental, econanic, technical, and other benefits of the facility. The EES concludes the cost-trnefit balance is favorable and that the manu-facturing license, subject to certain conditions for the protection of the environnent, should be issued (EES Part III, pages xiv and 4-13) .

The Staff review has also been supplanented by its evidentiary presentations at the hearing. These are discussed in Section IV.,

infra.

I IV. FINDINGS OF FACT RE: CNTENTIOIS AIMITTED AS ISSUES IN C NTROVERSY, DOARD QUESTIO1S, AND OTHER MATTERS s

I

63. The Board, in accordance with the Notice of Hearing, has decided the issues in controversy among the parties as set forth in thisSection IV of the Initial Decisicn.

I I

l l A. (IUPDTPIOi I - D4ERGENCY KMER I Brigantine Amended Contention 3:

I "There are insufficient experience and data with respect to the functioning of the high voltage electrical cables which Applicant proposes to be buried in the seabed to transmit electricity fran the shore to the facility and I the undersea electrical cable that Applicant proposes for connecticn to the facility to provide adequate confidence that a reliable source of energency power will be avail-able for safe operaticn of the facility."11 I 64. On this cxmtenticn, both Applicant and Staff presented evidence including both written and oral testinony.12 None of the intervenors presented witnesses, testimony, or other information.

Hearirg sessions with regard to the contention were held on June 15 and 16, 1976, and the testimony appears at Transcript pages 1044-1157, 1160-1324 respectively.13 I

Admitted as interpreted by Board Order dated Decenber 29, 1974, p.4.

The Applicant's written testinony, Exhibit No. OPS-22 entitled I " Applicant's Testimony Regarding I. Dnergency Power," was admitted at Tr. 1052 (6/15/76). The witnesses sponsoring this tectimony were Messrs. John W. Wanless, Raymcnd J. Cboney, P. Blair Haga and Dr.

Dee H. Witiker. (Professional Qualifications admitted at Tr.1049, I 1047, 1C24 respectively) . The Staff's written testimony entit1M "Supplanental Testinony cn Behalf of NRC Staff in Response to Brigantine Amended Contention 3" was admitted at Tr. 1163 (6/15/76).

I The Staff witness sponsoring this testimcny was Mr. Faust Rosa (Professicnal Qualification admitted at Tr.1161) .

13 I Applicant and Staff witnesses were examined by counsel for City of Brigantins, Atlantic County Citizens Council on Environment, Atlantic County 3oard of Chosen Freeholders, State of New Jersey, NRC Staff and the Board.

I I

65. The transmission circuits for craergency power are not within the scope of the ENP design. For ENP's that utilize underwater cable for these transmission circuits the cnly significant difference between the ENP offsite energency power aM that of land-based plants is the use of buried subnarine cables with flexible connections at the-plant end to accumu3 ate the motion of the ENP. (Staff's Testinony, Page 3).

I <

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66. The Applicant identified two types of high voltage I cables with proven experience installed both underground and under-water. These types of cable are known as pipe-type and self-contained type. (Applicant's Testinony, Page 2)

67. Ebr nest AC circuits, a pi l e-type cable consists of three conductors. Each conductor is insulated with layers of oil I iJnpregnated paper tape. The three coMuctors are installed in a pipe, which is then filled with oil. A protective polyethlene coating is 1

1 l

applied to the outside of the pipe. (Tr.1299) .

l

68. Self-contained cable consists of a hollow conductor surrounded with layers of oil impregnated paper tape insulation. Out-side of the paper tape is a layer of lead and surrounding the lead is a polyethylene jacket. Inside the hollow conductor is the oil used in conjunctical with the paper tape for the total insulation systen. When cables of this type are laid cn the botton unburied, an additional aner is usually applied over the polyethlene jacket for mechanical protecticn. (Tr.1300) .

I I

I

69. The adequacy of the oil-impregnated paper tape insula-tion systen for 345 kV cables was verified by an extensive utility iMustry testing program at Cornell University fran 1957 to 1%3 (Tr.

1050). A similar utility-sponsored program in the early 1970's verified the use of the same insulation systen for 500 kV cables.

• Both test programs established that experience data for cables operating at 138 kV ani 230 kV is applicable to cables operating at 345 kV. (Applicant's Testinony, Pages 2 and 3) .

E 70. Both pipe-type and self-ccntained cable systems are designed to conpletely protect the insulated ccnductors fran noisture.

Therefore the same cable is used both underground and underwater.

(Applicant's Testimony, Page 3).

I 71. The environment experienced by a cable installed underground when ca, pared with the envirornnent experienced by an identical cable installed underwater is sufficiently similar that no difference in failure rate m uld be expected. (Tr. 1182).

I 72. A tabulation in Applicant's Testimony of several significant high voltage cable installations in various parts of the world illustrates that cables utilizing voltages up to 575 kV are being designed and installed including subnarine cables up to 26 miles in length. (Applicant's Testimony, Pages 4, 6 and 7).

I

I

)

8

73. A developnent program for the flexible cable connection for the offsite power circuits of the ENP has established that a standard elf-contained 345 kV cable with an aluninun sheath is feasible and can withstand platform motion (PDR, Secticn 2.10.1.5; seu also Staff Testimony, Page 5). -

I  :

74. At each end of a high voltage oil cable installation there is an oil reservoir with an oil pressurizaticn systen end oil pressure alann. An oil pressure alann provides a warning that the cable insulaticn systen is deterioratirg. Such oil pressure alarms are normally provided on high voltage oil cable installations. (Tr.1116 -

1117).

B

75. A Megger test is used to test underwater and underground cable for deterioration of the protective polyethlene coatirg. This test is in use cn underground and underwater cables and is capable of detectirg pinholes. (Tr. 1301 - 1302).

I 76. The general locaticn of a hole in the outer polyethlene coatirg of an oil / paper cable can be found by applyirg a potential to the pipe or lead sheath. The route of the cable is traversed by boat with probes imnersed several inchee in seawater beneath the botton of the boat. A signal is detected where current leaves the pipe through the hole in the sheath. (Tr. 1301, 1312).

I E

I I

I

77. An Edison Electric Institute survey of forced outages of I

underground transmissicn circuits, based cn a 5-year average for 1,000 l 1

E nt les of cable, reported an outage rate of 0.00068 outages per mile per year. This average annual rate is about 1/5 the outage rate for overhead line and dmonstrates the reliability of underground power-transmissicn. (PIR Section 8.2.1) .

I 78. The regulatory requirments for mergency electric power are contained in General Design Criterien 17 which requires that both an on-site electric power system and an off-site electric power systs, each redundant in itself, be provided to permit functioniry of structures, systems and caiponents important to safety. The cn-site source of mergency power for the EUP consists of four diesel gener-ator sets. (Tr.1155) . The plant design is such that on-site power for essential safety systes is adequate even for the case of cmplete loss of all external power. ( Applicant's Testimony, Pages 1 and 2) .

79. The Board finds that sufficient experience and data exist to assure adequate confidence that high voltage underwater cable can provide equivalent reliability to overhead transmissicn lines for mergency offsite power.

80. The Board concludes that an off-site mergency power systs for an ENP which utlizies high voltage underwater cable can be designed to meet the requirements of Geretal Design Critericn 17.

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B. CIIERRICN II - LNDERWATER ELECTRICAL TRANSMISSICN LINES 1

E ACCCE Contention 4b:

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, "The Board interprets (bntention ntrnbered 4(b) as assert- ~

irg that the Applicant has not given adequate considera-tion to prevention of hazards which could h2 caused by

~

defects in underwater electrical transmission lines. As l interpreted, this (bntenticn is hereby admitted as an issue in controversy."14

81. On this Cbntention both Applicant and Staff presented evidence incittiirs both written and oral testimony.15 Nme of me

/-,.-

intervenors presented witnesses, testimcny or other information. A hearing sessicm regardirg this Contention was held on Septenber 29,

- 1976 and the testimony appears at Transcript pages 3785-3800.16

. 82. The Applicant and Staff considered possible hazards to people fran electric shock, chenical effect of the cable insulation and sudden rupture of the cable. (Applicant's testinony, page 1; Staff's Testimony page 2.)

Admitted as interpreted by Board Order dated May 21, 1974, p. 7.

I'The Applicant's written testinony, Exhibit No. OPS-33 entitled

" Applicant's Testimcny Regarding II. Underwater Electrical Trans-mission Lines" was admitted at Tr. 3787 (9/29/76) . The witnesses sponsoring this testimony were Messrs. John W. Wanless, Raymond J.

Cooney, P. Blair Haga an Dr. Dee H. Wilker. (Professional Qualifica-I tions admitted at Tr.1049, 1047, 1024, respectively.) The Staff's written testinony entitled " Supplemental Testimcny of NRC Staff in Response to ACCCE Contention 4(b)" was admitted at Tr. 3792 5 (9/29/76). The Staff witness sponsoring this testimony was Mr. Faust Rosa (Professional Qualifications admitted at Tr.1161) .

16 Both Applicant and Staff witnesses were examined by the Board.

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83. No shock bazard can exist with the cable metallic housing intact. Under normal operating conditions, a person can totch I the metallic housing of the cable while the cable is energized and receive no harmful effects. (Applicant's Testimony, pages 1 and 3) .

84. If the cable metallic housing were damaged exposing the ocnductor, the cable wocid be deenergized within a small fraction of a secmd. During this small fracticn of a second, most current would flow to this housing and only a very snall anount would return to the source tluuugh the earth or sea. (Applicant's Testimony, page 2)

I 85. Regarding chemical effect of the cable insulation, no hazard has been identified. Cable insulaticn materials are non-toxic.

( Applicant's Testimony, pages 3 and 4) .

I

86. The likelihood of sudden rupture of a cable occuring due to salt water ccming in contact with an energized conductor is extremely low due to the details of cable constructicn and the rapid cable deenergization which would result frczn loss of oil pressure, or frcm very low levels of current leaking through the insulation.

(Applicant's Testimony, page 3.)

87. In response to a Ibard question, the Applicant advised that it was not aware of any history of ships, boats, or swinmers R suffering as a result of contacting high voltage underwater cables.

(Transcript, p. 3789.)

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88. In 903 mile years of operation cf 345 kilovolt under-water cable, there were no failures experienced along the cable length. (Tr. 3797.)

I 89. The Staff reviewed the design of underwater / underground" transmission cables respecting hazard resultirx3 frcm defect induced cable failures and concluded that the hazards to the general public are negligible. (Staff's Testimony, page 1.)

I 90. The Board finds that adequate . consideration has been given to the possible hazards that could be caused by defects in underwater cable and concludes that, with available design features, underwater cables and their associated protective systems offer protection against such hazards.

C. GNrmTION III - !%RINE HNIIUMNT ACCG Contention 2:

"The Board interprets ACCCE contention ntsnbered 2 as I asserting that the Applicant has not given adequate ccnsideraticn to the effects of corrosion resulting in adverse changes in mechanical properties due to the I effects of both a salt water envircrrnent and radio-activity. This contention further asserts that there should be a monitoring system to detect corrosion and I other salt water effects. As so interpreted, this c tention is hereby admitted as an issue in ccntroversy."y I 1 Admitted as interpreted by Board order dated May 21, 1974, po. 4, 5.

I 9

I Brigantine Amended Contention 6:

"There are substantial uncertainties as to the behavior of I the reactor and essential safety systens in the marine environment." (Brigantine Proposed Amended (bntention 6 fran Moticn by Intervenor City of Brigantine to Amend and Expand its Contentions, dated October 21, 1975.) "Brigan-I tine's proposed amended contention 6, as interpreted by the Applicant and agreed to by Brigantine and the Staff,

• is AIMITTED, and it is understood and agreed that the phrase, ' reactor and essential safety systens' is con-I strued to refer solely to Class I safety systems and

' substantial uncertainties' refers to particular unique effects cn Class 1 safety systens fran the floating plat-fonn and marine environment."18

91. On these contentions both the Applicant and Staff presented evidence, including material contained in the Plant Design ReIort (PDR), the Safety Evaluation Report (SER), as supplanented, and written and oral testimcny.19 Ne of de h e m rs geseded 18 Admitted as interpreted by Board Order dated Decenber 29, 1975, p.5.

19 I The Appli m 's written testimony, Exhibit No. OPS-23, entitled

" Applicant's Testimony Regarding III. Marine Environment" was admitted at Tr.1715. The witnesses sponsoring this testimony were 4

Messrs. Joseph B. McAndrew, Clinton Dotson, Raymcnd J. (boney, Robert A. Bruce, P. Blair Haga and Dr. D. H. mlker (Professional Qualifications admitted at Tr.1713, 1712, 1047, and 1024, respec-tively.) The Staff's testimony, consisting of five separate I docunents each entitled " Supplemental Testimony of the NRC Staff in Response to Brigantine Amended Contention 6 and ACECE Contention 2" was admitted at Tr.1956. The witnesses sponsoring this testimony were Mr. Faust Rosa, Mr. Richard J. Kiessel, Mr. Herbert F. Cbnrad, I' Mr. Lauren J. Cbnnery, and CDR. John Deck III, United States (bast Guard (USCG) . The testinony sponsored by CDR. Deck was written by ICDR William E. Renley, USCG and LT. Thanas E. Thanpson, USCG. CDR.

Deck adopted this testimcny as his own at Tr. 1955. With the I exception of CDR. Deck's written testimony, the Staff testimony follows Tr. 1956. CIR. Deck's written testinony follows Tr. 2028.

3 The Professional Qualifications of Messrs. Rosa, Kiessel, Conrad, 5 Connery, ana CDR. Deck were aamitted at Tr. 1161 and 1946, re-spectively.

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witnesses, testimony or other information. Hearirs sessions with re-gard to this contention were held cm July 6, 7, and 8, 1976, and the testirrony appears at Transcript pages 17061799, 1800-1957, and 1958-2145, respectively.20 Protecticn of Interior Equipnent

92. The ENP ventilaticn systens are designed to prevent the entry of marine air into interior spaces with the exception of the Fuel Buildiry (see paragraph 97 below) . Ventilation systens supply air through denisters and filters which renove salt mist and salt partic-les, respectively. (Applicant's Testinony, p. 1; Staff's Testimony, Rosa, p. 4) Interior spaces are maintained at a pressure slightly higher than the outside environment thus preventing in-leakage of the marine atmosphere (Tr. 1777-1779).

I 93. Marine denisters which are capable of renoving all fog and mist fran ventilation systen intake air will be utilized on the ENP (Tr.1980) .

1 20 Applicant witnesses were examined by counsel for the City of Brigantine, (Brigantine), Atlantic County Citizens Council on Environment (ACOCE), Atlantic (bunty Board of Chosen Freeholders (Atlantic County), State of New Jersey, NRC Staff and the Board.

Staff witnesses were examined by Counsel for Brigantine, ACCCE, Atlantic County, State of New Jersey, Applicant, and the Board.

I I

I . .

I

94. Salt particle renoval filters to be supplied for ENP ventilation systens serving areas housing equignent important to safety will have an efficiency of 99.7 percent for the renoval of salt particles larger than two microns (Staff's Testinony, Rosa, p. 3; Tr.

1954, Tr. 1988) . These salt particle renoval filters meet U.S. Navy" Specifications for salt renoval in reactor ccupartment ventilation systems (Tr. 1979, Tr. 1991).

95. Relative htrnidity within the ENP will be cont. rolled to a maximtzn of 80 percent (Tr.1913) . The Applicant and Staff agree that under this condition any salt deposition which might occur would be dry salt (Tr.1913) which is non-corrosive (Staff's Testinony, Rosa, page 4).

I  %. The deleterious effect of any salt deposition on protection equignent is a long-tenn process (Tr. 1976) and plant operation could continue in the marine environment for over a year without airborne salt retaval (Tr. 19%) . However, to provide an additional degree of protection the Applicant will provide a specif-ication for acquisition by the owner of the necessary equipnent periodically to measure cunulative salt deposition (if any) (Appli-cant's Testimony., pages 1 and 2). Althotgh the rpecific method (s) have not been selected, several possibilities exist, each of which is considered feasible by both the Applicant and the Staff (Tr.1909, et I

I

-s2 g

I seq.; Tr. 2136, et seq.). The purpose of such nonitoring is to detect any potentially significant salt deposition before an equipment problen muld develop (Tr.1976) .

97. The fuel tuilding is maintained at a slightly negative ~

pressure with respect to the marine atmosphere to prevent the leakage of radioactivity to the surrounding atmosphere (Tr. 1839, et seq.).

Equipnent located in the fuel buildirg important to safety will be qualified for operation in the marine atmosphere (Applicant's Testi-mxty, p. 1; Tr. 1871-1873).

I 98. Ventilation systems are provided with instrunentatim to monitor systen floa rate, pressure drop across filters and denisters and differential pressure between the ventilated space and the atmosphere outside the plant (Tr. 1779-1780). These monitorire systems provide diverse indicatim of ventilation system performance and also prcvide on-line assurance that marine air is not entering ventilated areas (Tr. 1780, Tr. 1904) . Continued instrunentation accuracy will be assured by periodic naintenance performed by the owner (Tr.1781-1782).

I 99. Intrusion of marine air into interior spaces housing equipnent important to safety will be prevented during plant tow by operation of the ventilation systens. Other spaces will either be I ventilated or closed off to prevent intrusion of marine air. Power for ventilation systems will be provided during tow by the energency I  ;

1 l

diesel generators. (Tr. 1758, Tr. 1771-1773) . In the event of diesel generator failure during tow, it is expected that the load would be l transferred to another diesel generator within approximately thirty minutes (Tr. 1884).

Protecticn of Raw Water Systems 100. The Auxiliary Raw Water (ARW) and Essential Raw Water (EN) systens are the cnly safety-related systens which are expose.1 to raw (basin) water. The materials used in these systens were selected for their proven corrosion resistance and strength. (Applicant's Testimony, page 2) . Joints between dissimilar metals, such as the carbon steel trim tank-to-system piping (PDR, p. 9.2-43a), will be protected by a coal-tar epoxy coating (Staff's Testinony, Connery, page 4). The ARW and ERN systems do not cxine into contact with reactor coolant and are not exposed to neutron radiation (Staff's Testimony, Connery, page 3).

I Protection of the Platform Hull 101. Protection of the ENP hull fran corrosion is described in detail in Offshore Power Systems Report AD-7100-14A85, "FNP Platform Hull Drydocking Equivalency" (Applicant's Testimcny, page 2) . i The Applicant has divided the exterior of the platform hull into three corrosion control zones: the atmospheric zone, the splash zone and l

the inmersed (or crbnerged) zone (Staff's Testinony, Realey and Thanpson, page 2: Tr. 1858-1859).

1 102. The atmospheric zone is subject to corrosion by minute salt particles carried by the wind. (Staff's Testintmy, Remley and" Thanpson, page 2). Wetting in the atmospheric zone occurs mainly fran rain, dew and occasionally, spray (Tr. 1742).

103. The atmospheric zone will be protected fran corrosion by a coating systan consisting of alkyl silicate inorganic zine and vinyl copolymer (Staff Testimony, Ranley and Thcrcpson, page 2) . Protective fenders at the service dock will provide protecticn against possible danage to the coating fran service craft (Tr.1918) . Coating systems such as that proposed for the atmospheric zone have been in service since vbrid War II (Tr.1743) .

104. The splash zone is that area of the platfonn hull which is contintously wetted with aerated water (Staff's Testinony, Remley arti Thanpson, page 3) . The Applicant has defined the splash zone area as extending fran two feet below the waterline to four feet above the waterline based cn expected wave action in the basin and investigation of charts of corrosion rates for pilings protected at the waterline (Tr. 1738-1739).

105. The splash zone will be protected fran corrosion by a coating of nodified amine-cured epoxy resin filled with inert sil-icates (Staff's Testimony, Remley and Thcmpson, page 3). The Applicant has specified a coatirg thickness of three-sixteenths of an inch based on the coating manufacturer's recommendation (Tr. 1790-1791).-

Additionally, that part of the splash zone beneath the waterline will be protected fran corrosicn by the cathodic protection rystem (Tr.

1807).

106. Coatings of the type proposed for use in the splash zone have been in service for approximately seven years and lifetime predicticms are therefore based cn limited experience to date as well as general knowledge of the coating chenistry and characteristics (Tr.

1740, 2069-2070). It is reasonable to expect that crmplete recoatire of the splash zone will not be necessary during plant life (Tr.1740) .

I 107. The Applicant has considered repair or replacanent of splash zone coating in OPS Dwunent Number NA-1220-14A80, " Floating Nuclear Plant Platform Hull Corrective Maintenance Plan." Access to areas of defective coating can be obtained by trimning the plant up to 1 degree and through t? use of cofferdams where necessary (Staff's Testimony, Remley and hanpson, page 4) . The Applicant states that the frequency and extent of splash zone coating maintenance will depend largely cn the degree of mechanical damage caused by service vessels and flotsam (Tr. 1003) . The Applicant estimates that no more I . ,

than 5 percent of the splash zone coating area will require repair on l l

an annual basis (Tr.1803, et seq.) . l 108. The inmersed zone will be protected fran corrosion by an impressed current cathodic protecticm systen. Corrosion protection is ~

achieved by shifting the normal corrosion potential of the platform hull until it is equal to or more negative than 0.85 volts with respect to a standard copper-copper sul i tate reference electrode. At this potential, the corrosion rate of carbon steel in seawater has been shown to be reduced to a negligible value. (SER, p. 59).

I 109. Each owner will be responsible for providirg a suitable cathodic protection system at the operating site (SER, p. 60).

Included in the Site Envelope are functional requirenents for the on-site cathodic protection system (SER, Supp. 2, page 8). The Applicant will provide platfonn cathodic protection during plant manufacture while the platfonn is afloat in the slipway (SER, page 59).

I 110. During tow from the manufacturing facility to the owner's site, impressed current cathodic protection will not be provided. The Applicant estimates that the duration of tow will be no more than a few weeks and further estimates that, considering ackli-tional time out of service for maintenance, the platform hul1 will be without cathodic protection for a total of less than one year during the forty year life of the plant. (Tr. 1732-1733).

111. The impressed current cathodic protection systen will incorporate autocatic control of the rectifier units by hull-nounted reference electro &as (SER, Supp. 2, page 8) . The systen is therefore self-correcting in chat the reference electrodes are used to adjust autanatically rectifier current output to cunpensate for variations ~

fran the desired hull potential (Tr. 2026-2027). At nonthly intervals during plant life, the cathodic protection rectifier units will be inspected and the voltage and current output of each rectifier will be I recorded (Tr.1719) .

112. Impressed current cathodic protection in seawater has been in use at least since 1929. The rcost extensive experience with these systens probably is with the U. S. Navy reserve fleet where numerous ships have been maintained in excess of twenty years at a reduced corrosion rate. (Staff's Testimony, Remley and Thanpsca, page

7) . The basic difference between the fresh water reserve fleet system and systems used in the ocean is related to the resistivity of the water. The current requirenents in the ocean are higher than for (Tr. 1876-1877) .

I fresh water, which has greater resistivity.

113. In addition to protective coatings ard the impressed current cathodic protection system, the hull plating thickness has been increased by 0.20 inches beyond that required for platform strength and thickness. This increment is based cn a time-averaged I corrosion rate for steel in seawater of 0.005 inches per year over the forty year life of the plant. This corrosion rate would be expected 1

I were no means of corrosion control provided. (PDR, page 3.12-46; Tr. l 1733, et. seq.) . The asstrned annual corrosim rate of 0.005 inches per year does not incitxle ron-uniform wrrosion in the form of pitting; however, pitting penetration in carbon steel relative to total corrosion diminishes to a minor fraction after 1cng times such as the-forty year life of the ENP. Proper selection of weldirrj alloys will prevent pitting problems in the region of welded joints. (PDR, pages 3.12-46, 47; Tr. 1899-1900).

I 114. The Applicant has provided in OPS Doctrnent No. NA-1220-14A79, " Floating Nuclear Plant Platform Surveillance Plan," a program for periodic inspecticn of the platform hull. In order to assure the continuing effectiveness of corrosion prevention systens the U.S.

Coast Guard (USCG) will mnduct in-service inspections at four year intervals, or nore frequently if deaned necessary by the local USCG Officer in Charge of Marine Inspecticn. (Staff's Testimony, Remley and Thcznpson, pages 3, 6 and 7) . USCG inspections are required by law (Tr.

2024) and satisfactory resolution of any deficiencies found is required for continued plant operation (Tr. 2100-2101). The Applicant has considered underwlter weld repairs of the platform hull and has concluded that such repair is feasible using existing techniques (PDR, pcx3es 3.12-55, et seq.).

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Salt Water - Radiation Synergism

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115. With respect to the effects of radiation upon the nechanical properties of metals, experiments have shown that only neutrons have any effect (Staff's Testimony, Ocnrad, page 2, Tr.*

2080-2081).

116. The reactor vessel and its internals are the only R@

I components that are subject to significant neutron irradiation (Applicant's Testimcny, page 2; Staff's Testimcny, (bnrad, page 3; Tr.

1950-1951). The reactor vessel is located within contairment and is exposed neither to salt water nor to a salt atmosphere (Applicant's Testimony, page 2).

l 117. Applicant's investigations indicate that radiation levels would have to increase by 8 to 10 orders of macy.itude in those areaa exposed to salt water before there would even be any potential for synergistic effects (Tr. 1846). No normal or accident condition has been identified which would produce this level of radiation i

I exposure (Tr. 1845-1847).

I 118. Components of the nuclear steam supply system and associated safety systens will receive inservice inspection under the provisions of Section XI of the American Society of Mechanical Engineers Boiler and pressure Vessel Code (Staff's Testimony, Conrad, page 3).

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I _ _ _ _ _ _ _ _ _

I I Plant M2.icn in the Marine Enviru==:nt 119. The as-moored accelerations and angular displacements for which the ENP is designed are stated in the Site Envelope (Table 2.1-1) of the PDR. The Ctr, mission will require the plant owner to-daronstrate that these motions will not be exceeded at the proposed site. (Staff's Testimmy, Kiessel, pages 2-4) .

I 120. The Applicant presented analyses of several types of conponents for motions in excess of the stated design basis limits.

The calculated equivalent static accelerations are less than the accelerations for which these acrnponents otherwise will be designed to satisfy seismic requirenents. (PDR, Appendix B, pages B.9.2-5, 6; Applicant's Testimony, p. 3) .

I 121. It is an acceptable procedure to design ENP systens, I conponents and component supports for loads resulting fran wind and wave excitation on the basis of rigid body analyses, appropriate fatigue factors and the specified Site Envelope parameters. (Staff's

, Testimmy, Kiessel, pages 2-4; Tr. 2130, et seq. ; SER, page 47) .

Cbnclusions I 122. The Board finds that the Applicant has given adequate consideraticn to the effects of corrosion due to a salt water environ-ment which could result in adverse changes in mechanical properties.

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I The Board further finds that the desian of the ENP provides adequate protection against corrosion such that plant operaticn within the marine envircrrnent will not pose undue risk to public health and safety, 123. The Board finds that the design of the FNP, in conbina-tien with required inservice surveillance, provides adegaate monitor-i.s3 to detect corrosion and other salt water effects and further finds that no additional such rronitoring systens are required to detect corrosion and other salt water effects.

I 124. The Board finds that the Applicant has given adequate consideration to the canbined effects of salt water and radioactivity cn the mechanical properties of materials. The Board further concludes I that there exists reasonable assurance that the canbined presence of radiaticn of the type arxl intensity necessary to affect the mechanical properties of materials and either salt water or salt air, will not occur in the ENP. The Board finds that the postulated synergistic action of salt water and radiaticn cannot occur in the ENP and therefore such synergism does not im p e an undue risk to public health and safety.

1 125. The Ibard finds that the Site Envelope limits cn plant j rroticn in the marine envirornent are reasonable as regards both plant siting and equipment design.

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126. The Board finds m the basis of the foregoing that there are no substantial uncertainties as to the behavior of the reactor and essential safety systems in the marine environment.

I D. CNTENTICN IV - CENTRAL CONTFDL IOOM

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ACCG Contention 9:

" Applicant has not given adequate consideration to failure I or malfunction of control operations because the location of the structure housing the central control operations is in a relatively unprotected position exposing this struc-ture to severe meteological (sic) conditions and damage or I destructicn by fire, industrial sabotage, terrorists acts, flying debris or collisions." Further, "the design of the central control operation structure is inadequate to pro-tect it fran the hazards menticned above."21 127. On this cantention, both Applicant and Staff presented evidence including material contained in the Plant Design Report (PDR), the Safety Evaluation Report as supplanented (SER) and written and oral testimcny.22 None of the intervenors presented witnesses, I testimony or other infonnaticn. Hearing sessions with regard to this ccotention were held cn July 9, 26, 27, 28, 29 and 30, 1976, and the 21 Admitted as interpreted by Board Order dated May 24, 1974, p. 10.

22 The Applicant's written testimony, Exhibit No. OPS-24 entitled

" Applicant's Testinony regarding IV. Central (bntrol Roan" was admitted at Tr. 2164. The witnesses sponsoring this testimony were Dr. Dee Walker and Messrs. Raymcnd J. Cboney, P. Blair Haga and I Richard S. Orr (Professional Qualifications admitted at Tr. 1024, 1047, 1024 and 1329 respectively) . Mr. Charles Kirg ms added to the panel for the in-camera sessions (Professional Qualifications I

I admitted at Tr. R-5). The Staff's written testimony entitled "Supplanental Testirmny cn behalf of NRC Staff in response to ACCCE Contenticn 9" by Falk Cantor, Kenneth G. Harphy and Ray F. Priebe, which follows Tr. 2536, was admitted at Tr. 2536. NRC Staff I

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Y testimony appears generally at Transcript pages 2163-2869 and R1 -

R168. The matter of Control Rocm protection frcm toronado missile was further considered at a hearing session cm Decemoer 4, 1981 and the testimcny appears at Transcript pages 7652-7656).23.1 128. The control room is located on the starboard side of the platform. It is surrounded cn three sides by reinforced concrete walls of either one or two foot thickness and on the exterior side by a 1 1/8 inch thick steel plate wall.24 Se of sexe I (Footnote 22 Continued) which follows Tr. 2536, was admitted at Tr. 2536. NRC staff wit-nesses sponsoring this testimcny were Messrs. Murphy and Priebe together with Drs. John A. O'Brien and Jacques B. J. Read (Pro-I fessional Qualifications of Messrs. Murphy, and Priebe and Drs.

O'Brien and Read were admitted at Tr. 2534) . Messrs. Phillip Mathews and Charles long were added to the panel at Tr. 2798 (Professional I Qualificaticms were admitted at Tr. 2803) . The staff subsequently filed updated testimcny entitled "NRC Staff's Updated Testintny Regarding ACCCE Contenticn 9 (Control Roan)" which was admitted by stipulation at Tr. 7620.

23 Applicant witnesses were examined by counsel for Atlantic County Citizens (buncil on Enviroment (ACCCE), City of Brigantine (Brig-antine), Atlantic (bunty Doard of Chosen Freeholders (Atlantic County), State of New Jersey, NRC Staff and the Board. Staff witnesses were examined by counsel 'for ACOCE, Brigantine, State of New Jersey, Applicant and by the Board.

23.1 Staff witness (Mr. Owen O. Rothberg) was examined by the Board (Professional Qualifications admitted at Tr. 7620) .

2he Applicant's written testimony stated that the exterior wall of the control rocm was 3/4 inch thick steel plate. The thickness of I the steel plate was subsequently changed to 1 1/8 inch. The 1 1/8 inch thickness is provided for radiation shielding. (Applicant's Testimcny, Page 3, and PDR Secticn 12.1.2.5) .

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I ccnsists of a two foot thick reinforced cancrete slab. The floor of the cc.ntrol rotm consists of metal deck and concrete approximately 3 inches thick. The ccntrol rocm is located approximately 66 feet above the basin water level. ( Applicant's Testimony, page 1; Staff's

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Testimcny, page 1; FDR Secticn 6.5.3.1.2.)

I 129. The location of the control rocm in relation to the other structures, systems, and equipnent on the FNP and in relation to the exposure of the control rocm to the envirottnent is ccmparable to the location of control recrns m land-based nuclear plants which have been licensed by the Ocmnissim (Staff's Testintny, Page 2, and Tr.

2382 and 2567).

I 130. The primary criteria used in locating the control rocm were to minimize the length of low level signal cables and to place the control rocm at an elevaticn aEve the maximum water level assumed for the postulated sinking emergency (Tr. 2384 and 2516 and 2DR Section 15.6).

I 131. The ccntrol rocm is a structure important to plant safety and is designed to meet the design criteria and standards established for safety related structures. It is designed to withstand severe meteorological conditions (Applicant's Testinony, page 2; Staff's Testimony, page 2) .

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132. The control roon is designed to withstand the spectrun of missiles asstrned to be generated by the design basis tornado.25 I These missiles are nere energetic and therefore more potentially damaging than any other missiles or flying debris which could be postulated to occur as the result of other severe meteorological" phenonena or potential accidents (Staff's Testirony, page 4; PCR Sections 3.5.3 and 3.5.7; SER Section 3.5.2: Staff's updar.ed Testi-nony, Page 2.)

l 133. The ocntrol roon is designed to withstand the crash of a passenger carrying helicopter (PDR Section 3.5.5, SER Section 3.5 and Tr. 2237). Potential collisions with the ENP are additionally dis-cussal in the Findirgs of Fact on Ship Cbilision and Aircraft, infra.

I 134. The plant design provides the capability for effecting arx1 maintainirg a safe shutdown condition fran outside the control roon in the unlikely event that conditions necessitate evacuaticn of the control roon (Staff's Testimmy, Page 6) .

I I 25 A test performed for the Applicant subsequent to the original I hearings cn this contention resulted in penetration of a 3/4 inch steel plate by one of the specified tornado missiles (letter of Novenber 18, 1976 fran T. M. Daugherty to the Board and Staff's Updated Testimony, p.1) . As indicated in Paragraph 128 and footnote 24, supra, the exterior control roon wall is now 1 1/8 inch thick; this thickness will conservatively provide penetration protecticn against the full spectrtri of postulated tornado missiles (Staff's l Updated Testimmy, p. 2) .

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I 135. The control roon is protected against floating fires external to the plant by its location which is well abwe the basin water level (Staff's Testimony, Page 3). The site envelope requires that an owner provide site features which will prevent an oil spill outside the site structure fran approaching within 100 feet of the

• plant (PDR Table 2.1-1, SER Table 1.2 (Revised), and Staff's Testi-mcny, Page 3.) The ENP external fire protectico systen is designed to control and/or extinguish floating fires within 100 feet of the plant.

In addition, for those sites at which the risk fran radiant heat flux I fran exposure fires more than 100 feet fran the plant is significant, a falling water film system is provided as an option to protect the exterior walls of the plant, including the control roon. (PER Section 9.5.1.2, SER Section 9.5.1, and Staff's Testimony, Page 3.) The control roon ventilation systen is designed to protect the control roam operators fran the effects of smoke and other conbustion products (Staff's Testimmy, Page 3, and PER Section 9.4.1) .

136. The design of the ENP will enable an owner to meet the industrial security requirenents of 10 CER 73 and Regulatory Guide I 1.17 (Protecticn of Nuclear Power Plants against Industrial Sabotage) .

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( Applicant's Testintny, Page 3) .

137. The inherent structural characteristics of the ENP result in a well protected, blast and penetraticn resistant structure, and provide a facility at which intentional damage would be extremely difficult. Furthernere, the locaticn of the control rocm, tluee floors I

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above the boardingplatfonn and approximately 66 feet above the basin l

water level, substantially reduces the susceptibility of the control roan to credible external threats from a potential adverrary. (Staff's Testimcny, Page 1 and 5). ,

138. The owner of each FNP will be required to provide a conprehensive security program for the protection of the plant against I external threats. The principal elements of such a program will include physical protecticn features to prevent or deter surreptitious entry, administrative measures to control access, a trained security force for plant surveillance, and a response capability by armed gtnrds supplemented by arrangenents with offsite law enforcement authorities. (Staff's Testintny, Page 6) .

I 139. The Board concludes that the design and location of the central control roon is adequate to protect the central control operation from hazards due to meteorological conditions, fire, industrial sabotage, terrorist acts, flying debris or collisions.

I E. CNTENTIN V - TRANSERTATIN I ACCG Contention 5:

"The Applicant has not given adequate attenticn to provis-ions for preventing accidents in the handling and trans-I portaticn of radioactive materials to and fran the ocean site in the following areas:

a. Provisions to prevent damage to platforms, mooring )

systens, reactor buildings and breakwater in event of barge I

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collisim and possible resultant flying debris, all result-irg fran rapid onset of severe, unforeseen, extrane meteor-ological conditions.

I b. Provisions to safeguard reactor plant and platform in event of fire aboard a nuclear fuel-transportirg barge j

I while targe is within breakwater, entering or leaving breakwater, or in close proxinity to the offshore plant. ,

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c. Provisions to deal with a collision of a vessel with a barge or breakwater resulting in dispersal of hazardous cargo cn or around the breakvater or on the floati.'yJ plant."26 Atlantic County Contention 3:

"Intervenor contests the adequacy of procedures for safe I transfer of spent fuel and radioactive waste fran the floating nuclear plant _ to the ship, to account for the peculiar characteristics of floating nuclear power plants."

I Waltcn Contention:

I " Adequate consideration his not been given by the Applicant to accidents, that could occur during transportation of ra-dioactive materials between the facility and the shore."28 I 26 Admitted as interpreted by Board Order dated May 21, 1974, p. 7.

27 Admitted as interpreted by Board Order dated April 15, 1974, pp. 9,10.

Admitted as interpreted by Board Order dated May 21, 1974, pp. 2, 3.

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• I 140. These three related contentions were considered by the Board together. On these contentions, both Applicant and Staff presented evidence, including material ccxitained in the Plant Design Report (PDR), the Final Envircrrnental Staternent (EES), as supple-mented, the Safety Evaluation Report (SER), written and oral testi ~

mcny, and an affidavit. None of the intervenors presented witnesses, l testimcny, or other information.29 The Hearing sessions with regard to these contentions was held cn November 3 and 4, 1976, and the testimony appears at Transcript pages 3866 - 3905, 3916 - 3929, 3933 -

3989.30 I 141. A crane will be provided for the Floating Nuclear Plant (ENP) to transfer a spent fuel cask fran the plant to a barge (or I

29 I The Applicant's written testimcny, Exhibit No. OPS-34, entitled

" Applicant's Testimony Regarding V. Transportation," was adnitted at Tr. 3364. The witnesses sponsoring this testimcny were Dr. Dee I mlker, Mr. P. Blair Haga', and Miss Mary Ann Capo (Professional Qualifications admitted at Tr. 1024, 1024, and 3831, respectively).

The Staff's written testimony entitled "SupplErnental Testinony of NBC Staff in Response to the Pertinent Portion of ACCCE (bntention 5, Atlantic County Contention 3 and Brigantine Original Contention and Witon Contention" by Joseph R. Levine, John A. O'Brien, Edward B. Tonlinscn and Robert F. Barker, was admitted at Tr. 3915 (Pro-I fessional Qualifications of Mr. Irvine, Dr. O'Brien, and Fhssrs.

Tcalinson and Barker were admitted at Tr. 1476, 2534, and 3911, respectively). Applicant's Exhibit No. OPS-104, entitled " Affidavit of Dee H. Mlker," containing information requested by the Board at I 30 Tr. 3900, was filed cm thrch 29, 1977.

Applicant witnesses were examined by Mr. m iton, by counsel for I Atlantic (bunty Citizens Council en Environment (ATCE), and by the Board. The Staff witnesses were examined by Mr. Walton, by counsel for ATCE, by coun sel for the State of New Jersey, and by the Board.

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other form of transportation) alongside the plant ( Applicant's Testinony, page 2). The cask handling crane is designed for loads in excess of 200 tons (the largest spent fuel shipping cask proposed for 1

licensig under 10 GR 71 is only 125 tons) (Applicant's Testimony, I page 2). The FNP cask handling crane will be designed to ANSI E00.6-I I

standard (Staff's Testimony, Page 12 and Tr. 3%1) . The cask handling crane can be designed for the ENP to meet criteria for the health and safety of the public (Tr. 3958) .

I 142. It is the responsibility of the utility owner to perform the radioactive material transfer operations (Applicant's Testirtony, page 2). The nethod for transporting nuclear fuels will be included in the utility owner's application for an operating license (Staff's Testimcny, page 9).

Shipping Container Design 143. The specific shipping package and the shipping method to be enployed in transporting radioactive material frcm the Floating Nuclear Plant are the responsibility of the utility owner. Design and testing requirenents for radioactive material shipping packages and reqairenents governig their transport have been issued by the Nuclear Regulatory Ocnmission (10 CFR 71), by the Department of Transportation (14 GR 103, 46 QR 146, and 49 GR parts 170-189), and by the U.S.

Postal Service (Postal Service blinual, Section 124). These regulations require that radioactive materials, including spent fuel, be packaged I

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for shirpirg in containers of special design. In the case of spent fuel, the cask must be designed and licensed in accordance with the requirements of 10 GR 71. This part of the regulations requires that tM cask design be such that the contents of the container will not be released in the event of severe hypothetical accidents. (Applicant's" Testimcny, pages 2 and 3) .

Postulated Accidents During Transfer 144. An accident involvirx3 transfer of spent fuel would result in more severe radiological consequences than an accident involving transfer of low-level waste containern. Thus, detailed analyses of postulated accidents during transfer were limited to those involvirg spent fuel casks. (Staff's Testimcny, page 9; Applicant's Testimcny, page 2.)

145. Six spent fuel cask drop scenarios during the transfer operaticn fran the ENP to a transport vessel (barge) are analyzed in the PDR Secticn 15.4.7 (Applicant's Testimcny, page 3). These cask drop scenarios are the worst which can be developed using existing design parameters and procedural controls (Staff's Testimony, page 10). The cases analyzed include a drop fran the maximum height to which the crane will lift the cask above the basin water surface into the maximtrn depth of water acceptable for a site (Applicant's Testi-many, page 3) . In these analyses no credit is taken for the safety features and conservatisn in the design of cask handling systen i

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components (Staff's Testimmiy, page 9) . The analyses in the P31 show that none of the mses considered would lead to rupture of the shipping cask or release of any radioactivity (Applicant's Testimmy, page 3).

146. If a shipping cask should drop cnto the ccean floor, the retrieval of the cask would be the responsibilty of the utility owner, including the postulated case of a cask rolling !xneath the FNP (Tr.

3868). The device to retrieve the cask may consist of a portable barge-nounted crane (Tr. 3868). The cask retrieval could be accanp-lished in a reasonable amount of time before appreciable corrosion could occur (Tr. 3869). Even if the' radioactivity were released due to

, corrosicn, it would be a very small amount and would be below maximum permissible mncentrations (Tr. 3877) .

Radiological Ocnsequences of a Cask Rupture Accident 147. Although the analyses in the PDR show that a cask rupture will not occur, the radiological consequences of a cask rupture were analyzed and reported in PDR Secticn 15.4.7 (Applicant's Testimmy, page 3). Dose analysis was perfonned for the released radioactivity which passes through the sea water, is vented to the atmosphere, and carried away fran the site by atmospheric conditions (Tr. 3881) . The resulting hypothetical offsite dose (using conserva-tive meteorolcgical conditions) would meet the dose criteria of 10 GR 100; namely, 300 ran thyroid and 25 ren whole body (Applicant's I

Testimmy, page 3, and Staff's Testimony, page 11). The isotopes considered in this dose analysis are iodine-131 and krypton-85 (Tr.

3885).

148. Bounding calculations were also performed to estimate the concentrations dcunstream fran a dropped and ruptured cask if the iodine-131 available in the void space of the fuel elments in the cask was released approximately 100 days after the fuel was renoved fran the reactor. Those calculations indicated that for a distance about five to eight miles in the drift direction away fran the dropped cask the concentrations vould be three orders of magnittrie below

.4ximtzn Permissible Cbncentrations (Tr. 3873) .

149. In additica to the analysis required by Regulatory Guide 1.25 and Regulatory Guide 4.2 for a postulated cask drop accident, the applicant calculated the dose to the maximally exposed individual as a function of distance fran the cask drop location. Although 25 isotopes (fission products) were considered in the calculation, only Cs-137 and Nb-95 cmtribute significantly to the dose. The results of the analy-sis show that at a distance of 2 kilaneters fran the postulated cask drop the swimner is exposed over a two year period to a whole body dose of only 1.5 mran arx1 a skin dose of only 3.5 mran. (Affidavit of Dr. D.H. Walker dated March 29, 1977; Tr. 3894.)

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Explosion or Fire cm a Fuel - Resupply Barge 150. The ENP has been designed to withstand damage frm flying debris resulting frm an explosion of a fuel-resupply barge without jeopardizing plant safety functions (Staff Testimcny, page 7). "

The fire suppressicn syste(s) on the ENP can adequately oope with the diesel fuel barge fire (Staff's Testimcny, page 8, and Tr. 2828) . It can be concluded that the same fire suppression systes could easily cope with a fire cn a nuclear fuel transporting barge and simultane-ously, the tug (Staff's Testinony, page 8) .

Meteorological Cbnditions 151. With respect to stormy weather, the transportation of nuclear fuel or waste can be delayed or advanced a sufficient ntraber of days to avoid storms. Also, the time at which the movment takes place can be adjusted to avoid heavy traffic or conditions not suitable for safe novcment (fog, low tide, etc.) (EES II, page 6-87.)

I 152. The design of the ENP is such that the plant can withstand collisions or flying debris that might occur during the rapid onset of severe, unforeseen meteorological conditions while nuclear fuel is being handled or transported. The floating nuclear plant is designed to resist the effect of any of the following: (1) a 25 ten tornadc>-borne boat impacting the plant at its water line with a velocity of 29.3 feet per second and a kinetic energy of .67 million

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foot-pounds. This impact is in addition to the usual spectrtm of tornado borne missiles and debris required by the Staff for land-based plants. The tornado-borne boat of 25 tms is assumed to strike the platform whi;e the tornado wind and pressure drop are at their most severe conbination, so that a super-position of loads occurs; (2) a

• 3500 ton service vessel striking the plant without tornado effects; and (3) a helicopter weighing 19,000 pounds traveling at 30 miles per hour ard havirn a kinetic energy of .57 million foot-pounds striking any critical part of the plant. (Staff Testimony, page 4.)

Omelusions 153. The Board finds that the Floating Nuclear Plant has been designed so that spent fuel can be safety transferred to a barge (or other form of transportation) alongside the plant.

I 154. The Board finds that accidents in the transportation of spent nuclear fuel radioactive waste which could release radioactive materials fran the cask or package and thereby produce radiological consequences have been thoroughly considered and adequately treated on a generic basis.

155. The Board finds that the ENP has been designed such that the plant can withstand collisions or flying debris that might occur during rapid mset of severe, unforeseen meteorological conditions while nuclear fuel is being handled or transported.

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156. The Board finds that the analyses of fuel cask drop accidents show that the cask would not rupture, but even if it should rupture, the resulting calculated radiological consequences are well belcw the guidelines set forth in 10 CFR 100.

• I 157. The Board finds that adequate mnsideration ins been given to the preventicn of accidents in the hwilirg and transporta-tion of radioactive materials to and fran the RJP, and that adequate consideration also has been given to accidents which oculd occur during such transportation. The Board further finds that such con-sideraticn adequately acmunts for the characteristics of the RIP.

I I F. CNrHTTICN VI - SITE HWEIDPE DNTA I Brigantine Amended Contention I:

I "The postulated site parameters (10 CFR Part 50, Appendix M, para. 2) relatirg to climatic, meteorology, tidal, or other particular natural conditicns have not been properly selected and justified..31 I

I 31 Admitted as interpreted by Board Order dated December 29, 1975, p.4.

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I 158. On this mntention both Applicant and Staff presented evidence, includirg material contained in the Plant Design Report (P[R) , the Safety Evaluation Report (SER), as supplanented, and written and oral testimony.32 I None of the intervenors presented witnesses, testimmy or other information. 11 earing sessions with-regard to this contention were held on June 16, 17 and 18, 1976, and the testimcny appears at Transcript pages 1326-1353, 1354-1510, and 1511-1701, respectively.33 I 159. Paragraph 2 of Appendix M to 10 CFR Part 50 requires that the applicant for a manufacturing license provide an envelope of postulated site parameters. Paragraph 5 of Appendix M to 10 CFR Part I

3he Applicant's written testincny, Exhibit No. OPS-25, entitled

" Applicant's Testimony Regarding VI. Site Envelope Data", was I admitted at Tr. 1331 (6/16/76). The witnesses sponsoring this testimony were Dr. Dee Walker and Messrs. P. Blair llaga, Richard S.

Orr and Robert C. Beebe (Professional Qualifications admitted at Tr.

1024, 1024, 1329 and 1327 respectively). The Staff's written testimmy entitled " Supplemental Testimcny cn Behalf of NRC Staff in Response To Brigantine Amended Contentim I" by Edward F. Ilawkins, Gale P. Turi, Joseph R. Levine, Earl 11. Markee, Jr. ; and " Supple-I mental Testimmy On Behalf Of NRC Staff In Response To Brigantine Amended Content ton I" by Renner B. Iloffman, which follows Tr.1483, was admitted at Tr. 1483 (6/17/76). (Professional Qualifications of I Messrs. Ilawkiu, Irvine, Markee and llofmann and Ms. Turi were admitted at Tr. 1476; on June 18, 1976 Mr. Inwis G. Ilulnkm su1>-

stituted for Staff witness Ibwkins. Mr. Ifulntm's Professional Qualifications were admitted at Tr.1520) .

33 Applicant witnesses were examined by counsel for City of Brigantine (Brigantine), Atlantic County Citizens Council on Environment I ( AmrP), Atlantic Cbunty Board of Gosen Freeholders (Atlantic County), State of New Jersey, NRC Staff and the Board. Staff witnesses were examined by Counsel for Brigantine, ACCCE, Atlantic County, State of New Jersey and the Board.

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1 50 authorizes the Comtission to issue a license for one or more nuclear power reactors to be operated at sites not identified in the license application if the Connission finds that inter alia (1) "The applicant has described the proposed design of and the site parameters postulated for the reactor (s)...." The criteria for the design of nuclear power plants for protection against natural phenonena are stated in Criterion 2 of Appendix A to 10 CFR Part 50 and Appendix A to 10 CFR, Part 100.

I 160. Applicant's envelope of postulated site parameters including those pertaining to climatic, meteorological, tidal and other natural conditions associated with the marine enviorrrnent (and I conbinations of these phenonena) are suntaarized in the PDR at Table 2.1-1 ard in the SER, Supplenent No. 4, in Table 2.1 (Revised) . *

. Hurricane I 161. Hurricane is a windstonn which produces surge (or drawdown) and wave activity. Hurricane winds create pressure loading on FNP structures, while wind and wave together create plant motion I

33.he Site envelope table appeared in its original form as Table 1.2 of the SER, which was reprinted without revision in SER Supplenent g No. 1. Table 1.2 was first revised in SER Supple. ment No. 2 and i 5 later in SER Supplanent No. 4 where the revised table appears as Table 2.1 (Revised) . Throughout the transcript the tenn " Table 1.2 (Revised)" refers to Table 1.2 as it appeared in SER Supplanent I No. 2.

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(Applicant's Testinony, pp. 2-3; PER, Section 3.3.1). Surge (or drawdown) conbine with astrcunnical tide to produce the still-water depth (Applicant's Testintny, p. 4) . Hurricane is therefore an event of interest in each of the following site envelope parameters:

maxinun water depth, minintr2 water depth, plant motion and wind speed *

(pressure loading) (PDR Table 2.1-1) .

162. The Applicant has specified tse levels of hurricane intensity in the site envelope, the Hundred Year Stonn (HYS) and the Probable Maxinun ' Hurricane (PMH) (PDR Table 2.1-1).

The HYS is defined by its recurrence interval or equivalently by a probability of occurrence per year of 0.01 (Tr. 1336). The MI is a hypothetical hurricane having a conbination of characteristics which make it the most severe hurricane that can probably occur in the particular regicn I involved. PMH parameters have been developed by the Weather Bureau, now the National Oceanographic and Atmospheric Administration (NOAA) for the Atlantic and Gulf coastal Icgions frcrn maximization of hurricane parameters based cn historical data (SER, Secticn 2.2) .

I 163. The Applicant postulates the occurrence of a hurricane not exceeding HYS intensity subsequent to the postulated sinking emergency and while the plant remains in the sunken condition (POR, Secticn 2.3.2) . The Staff c3ncurs with the Applicant that this event ccxnbination is adequately conservative (SER, Section 2.3.2) . Site water depth at mean low water (MIM), the reference conditicn, must be I such that the stan of MEW depth, astronanical tide, storm surge and I

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wave height adjacent to the plant vital structures does not exceed 76 feet, the height above the bottcra of the platfonn to which plant areas housing equipnent necessary for safe shutdown are designed to be watertight. (PDR Table 2.1-1; Tr. 1333).

164. The HYS is the operating basis event with respect to wind pressure loading cn plant structures and with respect to plant motions resultirv3 fran wind and wave ( Applicant's Testim:my, Page 2) .

I 165. HYS wind speed was bounded originally by the Applicant at 130 mph for the Atlantic and Gulf Coasts. This magnittr'e was increased subsequently to 160 mph based cn the reocmnendation of 10AA (SER Section 1.10, Appendix C; SER Supp. 1, Section 1.10, PDR Table 2.1-1).

166. Each owner will be required to evaluate surge height for the HYS (SER, Section 2.3.2) . The applicant expects that each owner will deterniine a site specific HYS wind speed because a lower magni-tude than the generic bound established by the Applicant would be expected (Applicant's Testimcny, Page 3). Plant moticns resultiryg fran the HYS will be evaluated by the owner throtrJh model testing (SER, Section 3.7.2).

I 167. The Applicant postulates the occurrence of a hurricane no trore intense than the PHI with the plant in the nonnal, floating ccndition (PDR Table 2.1-1) . The Staff cancurs with the Applicant I

that the PHI is an adequately ocuservative maximum hurricane (Staff's Testinmy, Hawkins, et.al., Page 2; Tr. 1544 and 1661). The Site Envelope requires that plant notions rot result in platform contact with the basin floor durirs the passage of a IMI (PDR Table 2.1-1) .

Thus the minimtri acceptable basin water depth at MDi is equal to the ~

algebraic sum of plant draft, astroncmical tide, hurricane surge (or drawdown) and maximum plant moticn (downward corner displacement) produced by the IMI (Pm Table 2.1-1) .

I 168. The IMI is cxle of the design basis events with respect to wind pressure loading on plant structures (see our discussion of Tornado, below) and is the design basis event with respect to plant motions resultirg fran wind and wave (Applicant's Testinony, Page 2; P m Table 2.1-1).

169. The Applicant has based the FNP design on the maximum wind speed stated in HUR 7-97 34 for the Atlantic and Gulf Coasts (PDR, Section 3.3.1.1) . The maximum ten-minute wind speed of 163 mph fran HUR 7-97 is stated in the site envelope as an equivalent fastest mile wind speed of 204 mph (PDR Tables 2.1-1 and 3.3-2).

I U.S. Department of Ccmnerce, Environmental Services Mninistration, I Weather Bureau (Now NOAA), Meerandtzn HUR 7-97, " Interim Report Meterological Characteristics of the Probable M1ximtzn Hurricane, Atlantic and Gulf Coasts of the United States", my 7,1%8.

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I 170. Each owner will be required to evaluate storm surge and drawdown for the Rf1 (Staff's Testinony, IIawkins, et.al., Page 3) .

Each owner may determine a site-specific Ptil wind speed because a lower magnitude than the generic bound established by the Applicant would be expected at nest sites (Applicant's Testimcny, Page 2) . Plant" motions resulting frcm the R11 will be evaluated try the owner through mtxlel testing (SER, Secticn 3.7.2) .

Tornado 171. Tornado is a windstorm which produces direct loading on ENP structures resulting fran wind and pressure drop forces. Those forces in turn produce plant noticn (Applicant's Testimony, Page 5) .

Tornado is therefore an event of interest in the follcwing site envelope parameters: minimum basin wat.cr depth, plant noticn e'. d wind speed (pressure loading) (PDR Table 2.1-1).

172. The Site Envelope requires that basin water depth be sufficient to prevent contact between the platform and the basin floor during the passage of the design basis tornado (PDR, Section 2.3.1) .

The site envelope requires that basin water depth at MIN be at least equal to the sum of plant draft plus the maximum cbwnward notion produced by the design basis tornado (PDR Table 2.1-1).

I 173. The design basis tornado is cne of the design basis I events with respect to pressure loading cm plant structures and is cne I

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of the design basis events for plant motions resultirry fran extrane winds (see our discussicn of Hurricane, above) (Applicant's Testirmny, Page 3; PIR Tal,le 2.1-1) .

I 174. The tornado characteristics defined in Regulatory Guide ~

1.76 were used by the Applicant to design the ENP (PDR Section 3.3.2) .

The basis for these tornado characteristics is discussed in detail in

" Technical Basis for Interim Regional Tornado Criteria", IA91-1300, H3y, 1974. The '1brnado characteristics used by the Applicant are bounding for all areas along the Atlantic and Gulf (bats (Staff's Testimony, Hawkins, et.al. , Page 7 and 8) .

175. The principal parameters of the Applicant's design basis tornado are: rotational wind speed 290 mph, maximum forward speed 70 mph and a pressure drop of 3 psi (PDR Table 2.1-1) . These magnitudes represent conservative upee:- bounds. (Staff's Testimcny, Hawkins, et.al., Page 8).

I 176. The tornado characteristics developed in WASH-1300 resulted mainly fran data collected over land. The Applicant and the Staff agree that it is reasonable and conservative to extend data collected over land to the region of adjacent coastal waters for the purpose of predicting tornado characteristics (Tr. 1698-1699).

I 177. The owner will be required to analyze plant motions I resulting fran the design basis tornado and to deronstrate that I l 1

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neither platform contact with the basin ficor nor acceleration and/or angular displacanents in excess of site envelope limits occur. No further evaluaticn of torncdo intensity parameters is required of an owner unless the owner wishes to postulate a less severe design basis tornado for design of site features for the specific site (Applicant's" Testinmy, Page 5) .

178. Waterspouts are small regicns of intense rotational winds which develop over water and draw water into the rotating fluid.

Their potential effects upon da ENP are similar to those produced by tornado; however, the maximum wind force and pressure drop are aIproximately 30% of those of the design basis tornado. The Applicant and Staff agree that the large margin between waterspout and tornado forces assures that waterspout loadings will not be limiting for either plant design or siting (PDR, Section 2.7.5; PDR, Appendix 2D; I SER, Section 2.8.1.1).

Tsunami I 179. Tsunami are long period sea waves caused by underwater disturbances such as earthquake, volcanic eruption or landslide (PDR, Secticn 2.3.1; SER, Section 2.8.4) . As tsunami waves approach land, botton fricticn causes wave amplificaticn, and a significant series of alternating surges and drawdowns may occur (Staff's Testimony, Hawkins, et.al., Page 3; PDR, Secticn 2.3.1) . Tsunami is therefore an event of interest in the site envelope limitations for maximum and I

I I e

I minimtn basin water depth (PDR Table 2.1-1). The Applicant has n,t included tsunami as an event for which plant accelerations and angular displacanents are canpared to site envelope limits, because the response of the plant is expected to be a gentle rise and fall analagous to the response to tidal fluctuations (PDR, Section 2.3.1) . -

I 180. The Applicant postulated the occurrence of a tsunami coincident with the ten percent exceedance high spring tich subsequent to the hypothetical sinking energency and while the plant renains in the sunken condition. The sum of MIN depth plus astrononical tide plus tsunami surge height plus wave height adjacent to the plant vital structures is required to be less than 76 feet, the maximum water depth for which systens necessary for safe shutdown are protected fran flooding. (PDR Table 2.1-1).

181. The Applicant postulates the occurrence of a tsunrti coincident with the ten percent exceedance low spring tide with the plant in the nonnal, floating condition. Basin water depth at MIW is required to be be e yal to or greater than the sun of plant draft plus astronanical tide plus tsunami drawdown. Satisfaction of this lhnit assures that the platfonn will not contact the basin floor (PIR Table 2.1-1).

I 1P2. Global records of tsunami indicate that the Pacific is the most active regicn while tsunami along the Atlantic and Gulf I

I ,

I that the magnitude of tsunami wave heights would be less than hurri-cane-induced wave heights. (Staff's Testinony, Hawkins, et.al, Page 4; Applicant's Testimcny, Page 3).

I 183. Each owner will be required to estimate tsunami magni -

tudes based cn evaluaticn of potential initiatirg mechanisms, both local and distant (SER, Section 2.8.4).

I Astroncmical Tide 184. Site Envelope limits for both maximum and minimum water depth account for astronanical tide as a ccmponent of still water level (PDR Table 2.1-1; Applicant's Testimcny, page 4) . The HYS, Mi and tsunami are each postulated to occur in coincidence with ten percent exceedance tide levels (PDR Table 2.1-1). The ten percent exceedance tide levels (high and low) are those predicted tidal maxima and minima which are exceeded by cnly te,n percent of the predicted monthly maxima and minima over a continuous 19 year period. The Applicant postulated the occurrence of the design basis tornado at a water depth equal to or greater than MLW (PDR Table 2.1-1). MIN is the average water depth during low water conditicos . The design basis tornado event is not ccmbined with the ten percent exceedance low tide because the cmbined probability is small. (Tr. 1340; PDR, Section 2.3.1, 2.13).

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Eartiquake 1

185. Earthquakes required to be postulated for the design of nuclen Irwer plants are defined in 10 CER Part 100, Appendix A, in terms of probability of occurrence and magnitude. Appendix A is~

supplenented by Regulatory Guide 1.60. (Applicant's Testinony, Paga 4).

I 186. The Applicant postulated a safe shutdown earthquake (SSE) having maximun accelerations at the basin floor of 0.3g (hori-zontal) and 0.2g (vertical) (PDR Table 2.1-1). The Applicant testi-fled and the Staff concurred that the postulated SSE acceleration will meet or exceed the requirements of 10 CER, Part 100, Appendix A for most locations along the Atlantic and Gulf coasts (Applicant's Testimcny, Page 4; Staff's Testunany, Hoffman, Page 5; SER, Page 33; PDR, Section 2.5.3).

187. The Site Envelope parameter limits for horizontal SSE acceleration are derived frcm the maximun ground acceleration of 0.39 (Tr. 1442, 1462); the site envelope parameter limit for SSE vertical motion is the Regulatory Guide 1.60 ground response spectrun corres-ponding to a maximun vertical ground acceleration of 0.29 (PDR Table 2.1-1; Section 2.5.2.2).

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I E Se'.che I 188. Earthquakes, landslides and windstorm can produce starxlirry wave oscillations of a large enclosed or sani-enclosed water body known as seiche. Seiche will be evaluated for the environmental ^

phenmena specific to each site in order to assure that the maximum water level produced by each environmental phencmenon is used in site evaluation (Staff's Testimony, Hawkins, et. al., Page 7) .

I Precipitation I 189. Precipitation produces structural loadings from the accumulation of water on plant roof surfaces. The Site Envelope requires that the expected rainfall rate at an FNP site not exceed 13 inches per 'rar (PDR Table 2.1-1) . The Applicant and Staff agree that the precipitauen rate for all Atlantic and Gulf coastal locations is less than 1) inches per h:xtr (Applicant's Testimcny, Page 5; Staff's Testirtony, Hawkins, et.al, Page 5) . The Staff's estimate of precip-itation rate at sites along the Atlantic and Gulf coasts is based m the Probable Maximum Precipitaticn (INP) defined in Hydro-Meteoro-logical Report 33 35 of the U.S. Department of Ctrmerce. INP is I 1

'5 U.S. Department of Ccumerce, U.S. Weather Dureau (Now U.S. Weather I Service, NOAA), " Seasonal Variation of Prchable Maximum Precipita-tion, United States East of 105th Meridian for Areas 10 to 1,000 Sqaare Miles", Washington, D.C., 1956.

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I I defined by the U.S. Department of Ostmerce (NOAA) as "the theoretic-ally greatest depth of pcecipitation for a given duration that is meteorologically possible over the applicable drainage area that would produce flows of which there is virtually no risk of being exceeded".

(Staff's Testimcny, Hawkins, et.al, Page 5) .

I M.tninun Air Terperature 190. The platform hull is designed for a minimtm service tangerature (in air) of -15 P (PIR Sections 3.12.4.2, 3), although a lower service teneprature can be acccmodated by using a different hull steel (P!A, Section 3.12.4.3). The Applicant has incitxled in the Site Envelope the requirenent that the mininun air tenperature, at 0 to 5 meters above the basin surface, be no lower than -15 F (PDR, Table 2.1-1). Based on data reported in PDR Appendix 2D, the Applicant concluded that sites exist along the Atlantic and Gulf coasts which will satisfy this limit (PDR Appendix 2D; Section 2.7.2) . The Staff ccncluded that the Applicant's original limit of -5 F was sufficient for all of the East and Gulf coasts except for the northern portions of the coast of Maine (SER, Section 2.8.1.1) .

I Maxinun Water Tetperature I

191. Plant cooling water systens required for safe shutdown are designed to transfer their maxinun heat load at a maxinun heat sink tanperature of 95 F (Applicant's Testinony, Page 6) . The Site I

I Envelope requires that basin water tmperature not exceed 95 F (PIE Table 2.1-1). Based on data reported in PDR Apperrlix 2D (Section 2D.5), the Applicant ocricluded that sites along both the Atlantic and Gulf coasts will satisfy this limit. The Staff concluded, based on the Applicant's original limit of 85 F, that there are many areas" alorg the Atlantic and Gulf coasts where maximtm water tmperature will not exceed 85 F (SER, Page 36).

Mininun Water Tmperature

< 192. Platform hull material toughness testing requirenents are based on minimum service tmperature (PDR, Page 3.12-27a) . The Applicant requires that the Nil-Ductility Transition Tenperature (NUIT) of platform exterior plating be -30 F or lower. This te:pera-ture (-30 F) results frun the basic requirenent that the NUIT of platform exterior plating be approximately 60 F below the minimtm service tesuperature of the botton shell (PDR, Page 3.12-27f) . The Site Envelope requires a minimun basin water tenperature of 28.6 F (PDR Table 2.1-1) . This tenperature is the freezing point of sea water of average salinity and was the minimum water tenperature measured during the trans-artic cruise of the ice breaker Manhattan (PDR, Pages 2.7-5, 2.7-6). Slightly lower tenperatures resulting fran localired high salinity would not be of any significance (Applicant's Testimony, Page 6).

E iI I

e 5 (bnclusion I 193. There is adequate knowledge regarding climatic, meteoro-logical, tidal and other natural conditions at ocean and inshore locations at which ENP's could be sited. (Tr 1382-83, 1503-04) . The depth of krowledge regarding climatic, meteorological, tidal and other natural conditions at riverine, estuarine and coastal locations is documented in ntmerous Comtission dockets includirg, inter alia, Calvert Cliffs, Pilgrim, Brunswick, St. Lucie, Turkey Point, Oyster Creek, Millstone, San Orofre and Surry.

I 194. The Site Envelope yarameters specified in PDR Table 2.1-1 ard in SER, Supplanent 4, Table 2.1 (Revised), conservatively account for all reasonably expectab.;a envircrrnental occurrences that could adversely affect an ENP (Tr. 1381, 1453).

E 195. The Board has reviewed the envelope of site parameters with regard to the climatic, meteorological, tidal and other natural conditions described in PDR Table 2.1-1 and in SER, Supplanent No. 4 Tabid 2.1 (Revised). Included in this review were the site parameters specifically discussed in these findings of fact as well as all other site parameters set forth in those tables. The Board concludes that the Applicant, in accordance with the provisions of 10 CFR Part 50, .

Appendix M, Paragraph 5 and 1N.104 (b), has properly selected and justified the site parameters set forth in those tables (SER Sections 1.6 and 21.0; Applicant's Testinony, p.1, Tr. 1;97, 1435, 1489).

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I G. 0:NTINTICN VII - RADIOIOGICAL IMPACP CH SWIMERS AND BOATERS I ACCCE Contention 3d:

"Subpart 3d asserts that the Applicant has not given ade-quate consideration to the radiological impact on htsnans ,

who may boat er swim in the vicinity of the floating nuc-I lear plant. This contention is hereby admitted as an issue in controversy."36 I .

1%. On this contention, both Applicant and Staff presented evidence, incitding material contained in the Plant Design Report (PER) , the Final Envirorsnent Statenent (FES), as supplemented, and written and oral testinony.37 None of the intervenors presented witnesses, testinmy, or other information. The Hearing sessicn with regard to this contenticx1 was held on Novenber 3, I testinmy appears at Transcript pages 3833-3857.38 1976, and the E

36 Admitted as interpreted by Board Order dated May 21, 1974, p. 6.

37 The Applicant's written testinony, Exhibit No. OPS-35, entitled I " Applicant's Testimony Regarding VII . Radiological Impact on Swimners and Boaters", was admitted at Tr. 3834. The witnessec sponsoring this testimcny were Dr. Dee Walker, Mr. P. Blair Haga, and Miss Mary Ann Capo (Professional Qualifications admitted at Tr.

8 1024, 1024, and 3831, respectively) . The Staff's written testinony entitled "Supplanental Testinony of NRC Staff in Response to ACCCE I Contention 3(d)" by Dr. Reginald L. Gotchy, which follows Tr. 3849, was aantitted at Tr. 3848 (Professional Qualifications of Dr. Gotchy were admitted at Tr. 3847) .

I 0 Applicant witnesses were examired by counsel for Atlantic Cbunty Citizens (buncil on Envirottnent (ACCCE) ard by the Boani. The Staff witness was examined by counsel for A00CE and by the Ibard.

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I 197. Applicable parts of Title 10 of the Cbde of Federal Regulations (10 CER Part 20, the Annex to Appendix I of 10 GR Part 50, and 10 GR Part 100) are the cpverning regulations relating to radiological impact on htrnans, incitriing swimers and boaters. The Floating Nuclear Plant (ENP) is designed to be in ocmpliance with those regulations. (Applicant's Testinony, page 1.)

I 198. The Staff prepared an independent assessment of the potential radiological impact on routine releases frcm the ENP on htrnans, including swirmers and boaters, in the Final Errfirerinental Statenent, Part II, Section 11.3, page 11-7.

Normal Operation - Marimrn Permissible Cbncentrations I 199. The Maximum Permissible Concentrations of radioactivity in air and water above natural background for unrestricted use are defined in 10 GR Part 20, Appendix B, Table II. The estimated yearly quantities of radioactive discharges frcm an FNP during normal oper-ation are given in Section 12.4 (ccmnencing on page 12.4-1) of the Plant Design Report (PIR) . The average concentrations in air and surrounding water resulting frcm these estimated yearly releases during normal plant operation are otrnpared in PDR Section 12.4.3 (ccmnencing on page 12.4-23) with the Maximum Permissible Concen-tration limits and are below the acceptable limits for all isotopes.

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l I-Nomni plant Operation - Airborne Dose I 200. Estimates of the annual dose resulting fran released airborne radioactivity are presented in PDR Section 12.4-4 (cutmencing on page 12.4-25) as a function of distance fran the plant. In calcu-lating the cbse fran airborne radioactivity over a perial of a year, colservative values for atmanpheric disperson conditions given in PDR Section 2.7.1 were used; thus, these doses represent conservative limit values for Atlantic (bast aryl Gulf Coast sites. These data show

~

that the dose guidelines for releasal airbome radioactivity set forth in the Annex to Appervlix I (10 ntillirad ganun and 20 millirad beta for all reactors at a site) can be met for continuous occupancy for distances greater than about 200 meters fran the plant. The distance of 200 meters corresportin to the distance that is about as close as an inilvidual might tx3 able to approach a typical breakwater in a boat (Tr. 3841) . Asstming an occupancy of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year at 200 meters, an! using the annual doses in PDR Section 12.4.4 fran airtorne ralicactivity, a swinmer or boater would receive a dose of only 0.16 mran per year fran this ocurce fran an ENP.39 5 39 Dose value of 0.36 mran per year in Applicant's Testimony (pvje 2)

I was revisal in Ptn Ameninent 24 to the current value of 0.16 mran per year in conpliance with Regulatory Guide 1.112 (issual April, 1976), NURFr,-0017 (issual April, 1976), and Regulatory Gaide 1.109 (publishal March,1970), and Revision 1 (issued October,1977) .

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• I Normal Plant Operation - Direct Dose E

201. Estimates of the additional annual dose resulting fran direct radiation are presented in PDR Secticn 12.4.4 as a function of distance fran the plant. Asstzning an occupancy of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year at 200 meters fran the plant, a swinner or boater would receive a dose of 0.082 mran per year fran this source of radiation fran an ENP. The Annex to Appendix I of 10 CFR Part 50 does not require a consideration of the direct radiation fran the plant (Tr. 3843) . The direct dose is only a small fraction of that resulting fran natural background radia-tion, approximately 80 mran per year. ( Applicant's Testimony, page 2) .

I Normal Plant Operation - Dose Due to Liquid Releases I 202. Estimated annual doses to swimmers and boaters from liquid releases are presented in PDR Section 2.8 as follows: an individual spending 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year swinning in the mixing zone of the thermal plune and 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year boating in the mixing zone of the thermal p1trne would receive a dose of 1.2 x 10 mrcn per year and 4.3 x 10- mrem per year, respectively, fran an ENP.* These doses are I

40 Dose values of 6.7 x 10 -5 and 2.3 x 10 5 mrem per year in Appli-cant's Testimony (page 2) ye revised in_gPIR Amendment 24 to the I current values of 1.2 x 10 and 4.3 x 10 ,

pliance with Regulatory Guide 1.112 (issued April respectively, in ccm-

, 1976), NUREG-0017 (issued April, 1976), and Regulatory Guide 1.109 (published March, 1976), and Revision 1 (issued October, 1977).

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I only a anall fraction of the dose for a subnerged individual due to background radiation, approximately 60 mrem per year (Tr. 3855) .

I Doses for Postulated Accidents 203. In addition to the calculation of doses due to routine releases fran the plant, the Applicant is also required under 10 CFR 100 to calculate the doses due to postulated accidents which could result in release of a significant quantity of radioactive fission products. Activity release by isotope for each such postulated accident is set forth in PDR Sections 15.3 (catmencing on page 15.3-lf) and 15.4 (otmnencing on page 15.4-10) . Dases were calculated anploying these activity releases and the conservative aurospheric dispersion conditions set forth in PDR Secticn 2.7.1. Plots of these doses as a function of distance fran the release point en the plant are presented in PDR Sections 15.3 and 15.4. Evaluation of these dose plots denonstrates that an exclusion distance of 500 meters (0.3 miles) and a low population boundary of 1200 meters (0.75 miles) is adequate to meet the dose guidelines of 10 CFR 100 for sites along the Atlantic and Gulf (basts. The actual exclusion distance and low population boundary are site specific and will be calculated by each owner. ( Applicant's Testimcny, page 3.)

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I (bnclusions I

204. The floatiry3 nuclear plant is designed to be in canpli-ance with applicable parts of 10 CFR 20, the Annex to Appendix I of 10 O R 50, and 10 G R 100.

E 205. The Applicant's calculated doses to swinmers and boaters are not significant canpared to natural background radiaticn (Tr.

3844). The Staff concluded that the radiological impact ( fran ENP routine releases of radioactive effluents) on boaters and swinmers will be insignificant.

I 206. The Board firxis that adequate consideration has been given to the radiological impact on htmans who may swim or boat in the vicinity of the ENP. The Board further finds that routine releases of radioactive effluents fran the ENP will have no significant effect on htmans who may boat era swim in the vicinity of the plant. The Ebard also finds that the calculated doses for postulated accidents canply with the requirements of 10 GR 100 for sites along the Atlantic and Gulf coasts.

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I H. CNTHn'ICN VIII - AIRCRAET I Brigantine Amerded (bntention 4:

"The protability of aircraft crashing into the facility is understated, since the analysis is based on the frequency of commercial aviation flights without regard to the frgency of other kinds of flights, e.g., military and general aviation."41 Atlantic County Contention 2:

"With the continuance of air traffic and increases to air traffic along the Atlantic sea coast, we believe that the proposed Floating Nuclear Plants located in said zone I should be constructed to withstand the effects of a possi-ble callision with any existing size aircraft that may fly over or in the vicinity of the site and any reasonably foreseeable large size aircraft built during the lifespan I of the proposed plants that may operate as above without damage to the reactor core such that dosages of harmful radiation in excess of required limits would occur.

Our basis for thic belief is that

a. The crash probability is sufficiently high.

b. The resultant damage to the proposed plants ard attendant effects cn radiological safety in the event of a collision is sufficiently great.

c. The canbinaticn of the above indicate that the plant should be so designed.. 42 I Pertinent Part of ACCG Contention 6:

"The applicant has not given adequate consideration to ,

possible accidents resulting ... from an intentional I collision by an aircraft as part of industrial sabotage..43 1

I 41 Admitted as interpreted by Board Order dated Decenber 29, 1975, p.4.

Admitted as interpreted by Board Order dated April 15, 1975, p.9.

43 Admitted as interpreted by Board Order dated May 21, 1974, p.8.

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I I 207. Both Applicant and Staff presented evidence concerning l

this contention, incl'xling material contained in the Plant Design Report (PDR), the Safety Evaluation Report (SER) and written and oral testimony.M None of the intervenors presented witnesses, testimony or other information. Hearing sessicns with regard to this contention were held on September 23, 24, 28, and 29, 1976, and the testinony appears at Tr. pages 3413-3431, 3432-3504, 3505-3630, and 3631-3770.45 208. Standard Review Plan 3.5.1.6, Aircraft Hazards, and Regulatory Guide 1.70, Rev. 2 (NUREG-25/094) , Starrlard Format and Content of Safety Analysis Reports for Nuclear Pcwer Plants, Section 2.2.3.1, set standards for aircraft crash probability with which an owner must ccmply when siting a nuclear power plant (Staff's Testi-many, Page 2 and Applicant's Testimcny, Page 1). The PIR, Table 2.1-1, identifies plant-site interface requirenents. Table 2.1-1 I

be Applicant's written testimony, Exhibit No. OPS-26, entitled

" Applicant's Testimony Regarding VIII. Aircraft, "was admitted at I Tr. 3421. The witnesses sponsoring this testimcny were Dr. Dee .H.

mlker, Mr. P. Blair Haga, Dr. Douglas H. Shaffer, and Mr. John F.

Hanst (Professional Qualifications admitted at Tr. 1024, 1024, 2881, and 3419 respectively) . The Staff's written testinony entitled "

Supplemental Testimcny of NRC Staff in Response to Brigantine Amended Contention 4, Atlantic County Contention 2 and the Pertinent Portion of ACCCE (bntention 6," by Jacques B. J. Read, John A.

I O'Brien, Ray F. Priebe, was admitted at Tr. 3636. Professional Qualifications of Dr. Read, Dr. O'Brien, and Mr. Priebe were admitted at Tr. 2534.

45 11 W SWf hesses we ah W mel fx h-verer Atlantic (bunty Citizens Cbuncil on Environnent (ACTE) and the Board.

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includes the requirenent that the probability of an aircraft (carmer-cial, military, and general aviation) crashing into the plant and  ;

resulting in consequences exceeding the guidelines of 10 GR 100 must be of the order of 10 ~7 / year or less. Thus, by virtue of siting restrictions, the FNP need not be designed to withstand the crash of a large aircraft. (Applicant's Testimony, Page 1.)

209. The Applicant has analyzed in Appendix 2B of the PDR several locations to dancnstrate that suitable sites meeting the aircraft crash guidelines do exist along the Atlantic and Gulf coasts.

The sites selected for analysis were typical of potential sites.

(Applicant's Testinony, Page 2.)

210. Procedures are well established for determining the probability of an aircraft crash at any given site (Applicant's Testimcny, Page 2; Tr. 3425-3426) . Crash statistics gathered over the past decade shcw a correlation between the frequency of crash and the proximity of the crash location to an airfield. Similarly, a correla-tion exists between the crash frequency and the distance frcm a crash location to the flight's airway. (Applicant's Testimony Page 2.)

211. Calculational procedures discussed in the PDR, Appendix 2B differ depending cn whether a site is close to an airfield or close to an airway (Applicant's Testinony, Page 2) . Sites located beycnd five miles fran an airfield are evaluated using "in-flight" (or

" overflight") methodology. Sites within five miles of an airfield are I

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I evaluated usirg "near-airport" methodology, and, if in proximity of overflights, by "in-flight" methodology ac well. (Tr. 3572-3573.) The threat of a crash into a site is negligible if it is greater than about five miles frm an airfield and greater than ahxit fifteen miles frm an airway (Applicant's Testimony, Page 2) .

212. General aviation is separated for statistical pirposes by the Departrent of Transportation (National Transportation Safety Board) into two categories, large aircraft and small aircraft, with the break occurring at an aircraft weight of 12,500 pounds (Tr. 3467) .

213. The typical sites selected by the Applicant for analysis all were located farther than five miles frm the nearest airfield.

Evaluations' presented in PDR Appendix 2B, therefore, were based solely on overflight methodology. Ebr each of the sites studied, the analyses showed that the probability of a crash of a large aircraft into the ENP was of the order of 10~ / year or less. (Applicant's Testimony, Page 2.)

214. Military airspace is usually off-shore by a considerable distance, and operations in this airspace bring to identifiable risk to the coastal region itself, with the exception of specific areas associated with military bases usirg that airspace (Staff's Testinony, Page 3). Such an area enempasses the Shell Bluff Landing, Florida site, which the Applicant identified for further detailed study because of the significant military activity in the Jacksonville

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vicinity. The results of the Applicant's analysis demcnstrate that I

alth3 ugh the threat of a military crash at this site is greater than l

that frm cx2rmercial aviatien, the ctrnulative threat frm all aviation is of the order of 10 -7

/ year or less. (Applicant's Testimony, Page 3.)

215. The ENP, with substantial protection around its safety-related areas to satisfy NRC tornado missile protection requirements, is not vulnerable to the crash of small aircraft. The Applicant has calculated the thickness of steel or concrete required to prevent perforation of missiles resulting frm a crash into the plant of aircraft weighing up to 12,500 pounds. In all cases structures protecting safety-related plant areas exceed the required thickness.

I. ( Applicant's Testinony, Page 3.)

I 216. The probability of an aircraft crash into the FNP is de-termined by four factors, all first power terms such that none is more influential than any of the others. These terms are: 1) ntsnber of overflights, 2) accident rate, 3) density functicn, and 4) effective plant area. (PDR, Appendix 2B.) The Applicant treated these variables as discussed below.

I 217. Number of Overflights. The nunber of overflights is determined by " peak day" statistics which represent the heaviest traffic of the year. Yearly rates are obtained by assuming " peak day" I

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traffic every day of the year. (Tr. 3610.) This term is therefore conservative.

I 218. Accident Rate. The long term accident rate trend is downward (Tr. 3477) . Therefore, using the present rate is conserva-tive.

I 219. Density Function. The density function is a mathena-tical statenent that the likelihood of a crash decreases as the distance fran the airway increases. The function used by the Appli-cant was formulated by fitting to a curve offset distances fran airways at which serious crashes occurred in the years 1%4-1%7.

(PDR, Appendix 2B, Page 2B-11.) As such, this function is neither I conservative nor unconservative.

220. Effective Plant Area. Analysis by the Applicant indicated that the average shadow area is obtained by utilizing a 32 crash angle. The Applicant used a 30 crash angle which results in a slightly greater shacht area. (Tr. 3484.) In addition, dimensions of plant features were increased to account for engine separation of aircraft (Tr. 3429). The resultant is a conservatively calculated effective plant area.

I 221. In addition to the conservatism built into the factors I making up the probability calculation, another conservatism is the Applicant's simplifying assumpticn that a crash into the plant by an

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aircraft larger than 12,500 pounds is equatable to safety-related consequences. No credit is taken for the structural barriers incorpor-ated into the plant, especially the shield building, which the NRC Staff has estimated could survive a collision of a 70,000 pound F-lllB at approximately 100 miles per haar (Tr. 3574-3575, 3747.)

222. Present Nuclear Regulatory Ocmnission regulations do not require inclusion of intenticnal crash as a design basis event (Staff Testimony, Page 7). While acknowledging the possibility of threat of such a crash by a deranged individual, the Staff considers the execution of such a threat to be incredible (Tr. 3738).

I Conclusions I 223. The Board concludes that the ENP need not be designed to withstand the consequences of a large aircraft crash since siting restrictions limit the probability of such an event to the order of 10- or less.

224. The Ibard concludes that the ENP need rot be designed to withstarx1 the consequences of an intentional crash of an aircraft as a part of industrial sabotage.

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225. The Board finds that the Applicant has given adequate consideraticn to cannercial, military and general aviation, and that the Applicant has denonstrated that potential FNP sites exist along the East and Gulf Coasts where the probability of aircraft crash is acceptably low. Evaluation of aircraft crash probability at a specific site is the responsibility of the plant owner.

I I. CITTTENTION IX - SHIP (DLLISICN Brigantine Arnended Contention 5:

"The probability of ship collisions is understated, since inadequate consideration is given to potential changes in the pattern of ship traffic and the character of ships and their cargoes over the 40-year life of the facility."46 I

Pe.rtinent Part of ACOCE Contenticn 6:

"... the Applicant has not given adequate consideration to possible accidents resulting fran a collosion (sic) of the floating plant with a ship...."47 226. On these contentions both Applicant and Staff presented evidence, incitding material contained in the Plant Design Report (PDR), the Safety Eva'uation Report (SER), as supplemented, and I

46 Admitted as interpreted by Board Order dated December 29, 1975,p.4.

47 Admitted as interpreted by Board order dated May 12, 1974,p.8.

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I written and oral testinony.40 Nme of the intervenors presented witnesses, testinony or other information. Hearing sessions with regard to this contention were hold on July 30, September 20, 21, 22, and 23, 1976, and the testimony appears at Tr. 2869-3412.49 227. Regulatory Guide 1.70 (NUREG-75/094), Section 2.2.3 and Standard Review Plans 2.2.1 and 2.2.2 require that transportation I activities in the vicinity of proposed nuclear power plant sites be evaluated to determine if accidents that could result fran these activities need to be design basis events for the plant. Regulatory Guide 1.70, Secticn 2.2.3.1 and Standard Review Plan 2.2.3 indicate that potential accidents extemal to the nuclear plant should be considered design basis events if the probability of the accident exceeds m the order of 1 X 10~ per year and if the consequences may affect the plant to the extent that the requirenents of 10 CFR 100 could be exceeded. (Applicant's Testinony, pages and 2) . Ebr an be Applicant's written testimony, Exhibit No. OPS-27, entitled

" Applicant's Testinony Regarding IX. Ship Collision", was admitted I at Tr. 2884. The witnesses sponsoring this testimmy were Drs. Dee H. Walker, Douglas H. Shaffer and Henry J. Stumpf, Capt. Derek R.

King, Ms. Hyla Napadensky and Mr. P. Blair Haga (Professional Qualifications admitted at Tr. 1024, 2881). The Staff's written testimony entitled " Supplemental Testimcny of NRC Staff in Response to Brigantine Amendal Contention 5 and the Pertinent Portion of A00CE 03ntention 6" by Drs. Jacque B. J. Read and John A. O'Brien, I which follows Tr. 3284 was admitted at Tr. 3284 (Professional Qualifications of Drs. Read and O'Brien were admitted at Tr. 2534) .

49 Applicant witnesses were examined by (bunsel for City of Brigantine (Brigantine), Atlantic County Citizens Council on Environment (NYrR), State of New Jersey, NRC Staff and the Board. Staff witnesses were examined by Counsel for ACOCE, State of New Jersey, OPS, ard the Board.

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I I Applicant's consideration in determining design basis events, the Staff has identified several accident categories with the categories beirg based upm the effect that a particular type of accident could have on the plant. The accident categories include explosions, i flaninable vapor clouds, toxic chenicals and fires. (SER Supplanent 2, Appendix C, Section 5).

I 228. The Applicant examined available data on shipping accidents and then evaluated in rnore detail those accidents which presented a potential hazard to the plant (Tr. 2895). Seven classes of shipping accidents were identified as presentirg a potential hazard to the plant (PDR Appendix 2A) . Of these accident classes, three were determined to be design basis events for which there are specific plant design features and/or site requirenents (Ship Collision With Plant; Tanker Collision With Breakwater: Fire; Service Ship Acci-dents) . '1%o accident classes were detennined to be of sufficiently low probability to be excluded fran the plant design basis (Liquified Natural Gas (ING) Carrier Accident; Munitions Ship Explosions) . The renainirg tw accident classes were included within the plant design basis up to specific maximun design limits (Tanker Accident: Vapor-Air Explosion; Hazardous Chenical Carrier Accident: Toxic Vapor Cloud) .

(Applicant's Testimmy, pages 2 and 4). Each of the accident classes I is discussed infra.

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I Ship (bilision With Plant I

229. Site protective features (such as a breakwater) are required to prevent a large vessel fran colliding with the plant (PDR.

Table 2.1-1) . The Applicant has shown that protective barriers can be designed to prevent a ship collision with the plant. Applicant has also shown that a ship collision with the site protective structure, excluding cargo effects, will not result in unacceptable mnsequences with respect to 10 GR Part 100. (PIR Section 2A.2.) Potential hazards arising fran the cargo of a ship colliding with the site protective structure are discussed infra.

I Tanker Collision With Breakwater: Fire I

I 230. The site protective features are required to be such that tiley prevent a potential oil spill occurring outside the site structure fran reaching a point closer than 100 feet fran the plant (Applicant's Testimony, page 3: SER S( c~. ion 2.10.2) . The fire which muld result fran a collision of a tanker carrying fla:nnable fuel, other than ING (see paragraph 232), with the site protective structure I may be a design basis event at same sites. An adequate external fire protection systen is provided for these cases. (PDR Section 9.5.1.2.)

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I Service Ship Accidents l

I 231. Potential accidents involving the ENP and service ships are of three types: direct collision with the plant by the service.

ship; fire resultirg fran release of diesel fuel oil into the basin surrounding the ENP; explosion on the service ship. Vessels within the basin must be limited in size and speed such that potential impact c.

the plant will be no greater than that equivalent to a ship of 3150 long tons at 13 knots. (PIR Section 2A.8.1; Applicant's Testimony page 3; SER Section 2.10.2). The aqueous film forming foam systen is provided to extinguish a fire within 100 feet of the plant resulting frcm a spill of flantnable liquid. The applicant has evaluated the consequences of an explosion of a fuel-air mixture in a supply barge tank and has determined that preventative actions are possible. The Staff concurs. The owner will be required to: (a) inert the fuel barge tanks during offloading, or (b) maintain sufficient separation between the plant and fuel supply barge, or (c) limit the voltrne of individual tanks on the fuel supply barge. (PDR Section 2A.8.3.1; Applicant's Testinony, page 4; GER Supplanent 1, Section 2.10.2) .

I Liquified Natural Gas (ING) Carrier AccHent I 232. The Site Envelope requirua that the probability of a munitions ship explosicn, the consequences of which could exceed the plant design basis, be on the order of 1 X 10-7 per year or less (PDR I Table 2.1-1; SER Supplement 2, Table 1.2 (Revised)) . 'ite Applicant has l

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I concluded and the Staff has concurred that sites can be found such that the probability of an accident involving an ING accident, the consequences of which could exceed the plant design basis, be on the order of 1 X 10~ per year or less (PIR Table 2.1-1; SER Supplanent 2,,

Table 12 (Revised)) . The Applicant has mncluded and the Staff has I concurred that sites can. be found such that the probability of an accident involving an ING carrier affecting the site is on the order of 1 X 10- per year or less. (PIR Section 2.4.6; Applicant's Testi-many, page 4; SER Secticn 2.10.2) .

I Munitions Ship Explosion I 233. The Site Envelope requires that the probability of a munitions ship explosion, the consequences of which oculd exceed the plant design basis, be cn the order of 1 X 10- per year or less, (PDR Table 2.1-1; SER Supplement 2, Table 1.2 (Revised)). The Applicant has mncluded arri the Staff has concurred that for East Coast sites well removed fran munitions tenninals and for Gulf Coast sites the proba-bility that a munitions ship accident with mass detonation suffici-ently near the plant to affect it is negligibly low (PDR Section 2A.4; Tr. 3213-3220; SIR Section 2.10.2) . The owner will be required to deonstrate with an appropriate site specific nodel that the proba-bility of a menitions ship explosicn affecting the plant to the extent that 10 CFR Part 100 dose guidelines could be exceeded is on the order

~

of I X 10 per year or less (SIR Section 2.10.2) .

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I Tanker Accident: Vapor-air Explosion l

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1 234. The FNP is designed to withstand explosions which  !

produce a reflected overpressure of no more than 2 psi on the plant's, Category I stnictures (PDR Section 2.9.2). Ebr a site to be suitable, the owner must denonstrate that the probability of an explosion producing reflected overpressure of greater than 2 psi is on the order of 1 X 10 -7 per year or less. This can be done by showing that a site possesses protective features which provide adequate separation distance to insure that the plant design blast overpressure criteria will not be exceeded or that the probability of such an event is on the order of 1 X 10- per year or less. The Applicant has denonstrated and the Staff has concurred that sites can be found where the prob-ability of an accident ir.volving a petroleun carrier that results in a reflected blast overpressure greater than 2 psi at the Category I structures is cn the order of 1 X 10 -7 per year or less (PER Section 2A.5.5; SER Section 2.10.2).

Hazardous Chenical Carrier Accident: Toxic Vapor Cloud i

= 235. A toxic vapor clotd formed as a result of an accident involving a hazardous chenical carrier is included in the plant design basis up to a specified maximun limit (Applicant's Testinony page 4) .

For control roon habitability, the plant design will au.umcIate concentrations of toxic gases at the Control roon ventilation intakes as specified in Table 2.9-1 of the PIR. These limits were detennined I

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I by the methods of Regulatory Guide 1.78, "Assunptions for the Evalua-tion of the Hazards of a Nuclear Power Plant Control Roan durirq a Postulated Hazardous Chmtical Release". Ebr a site to be suitable for a ENP the owner must show that the probability of an accident, producing concentrations at the control room ventilation system intakes in excess of those specified is cn the order of 1 X 10 -7 per year or less. (Applicant's Testinmy page 5). The Applicant has denonstrated and the Staff has concurred that sites can be found where the probability of an accident involving a hazardous chenical carrier is cn the order of 1 X 10- per year or less (PDR Appendix 2A; I Applicant's Testimony page 6; SER Section 2.10.1).

I Future Ship Traffic, Character of Ships and Cargoes I

236. The Applicant has etaluated shipping trade flow and I traffic patterns with emphasis on the shippirs of various hazardous material cargoes (PDR Sect. 2A, 2A.4, 2A.6, 2A.7). Although these evaluations are based on current and inmediate past shipping and hazardous cargo traffic, these results can be exterxled reasonably to the future. Continuiry econcmic pressures indicate that growth in the shipping trades (except for ING) will be acuamulated by fewer overall ships of larger size. (Applicant's Testinony page 6; Tr. 2998, 2999, 3001, 3064, 3109, and 3210) . In a-idition ships of increased draft are less likely to be in shallow watars near an EIG site. Improvements in ship design and stricter safety regulations can also be expected to reduce accident probabilities. Therefore, future trends in shipping I

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I I are expected to reduce the overall likelihood of an accident at an ENP site (Applicant's Testinmy page 6; Staff's Testimony page 2; Tr.

3235, 3255, and 3315).

237. Projections of ING traffic have been made on the basis of proposed ING projects (PIR Section 2A.6; Applicant's Testimony page 6; Tr. 2994, 2995 and 3001). A study of the routes of ING ships show that most ships approach the eastern seaboard fran well out to sea and do not traverse the coastline; consequently they do not enter the

. general area of potential FNP sites. Although the present trend is for an increase in ING traffic fran fcreign ports there seems to be no evidence to indicate a significant future increase in coastal ING traffic. (PIR Section 2A'.6.2; Applicant's Testimony page 6; Tr. 3051, 3052, 3182 and 3312).

I Conclusion I 238. The Board finds that the seven classes of shipping accidents discussed in the Plant Design Report Appendix 2A encanpass the potential hazards to the ENP fran shipping.

239. The Ibard finds that the probability of ship collision has not been understated ard that adequate consideraticn has been given to potential changes in the pattern of ship traffic and the character of ships ard their cargoes over the 40 year life of the I facility.

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I 240. The Board finds that adequate mnsideration has been l

given to possible accidents resulting frcm ship collisions with site structures and frczn scrivce ship collisions with the plant itself.

241. The Board further finds that the ccmbination of WP design features and site envelope requirements provides reasonable assurance that shippirg accidents will not present an undue hazard to the health and safety of the public.

I J. CNTENTICN X - IG CINTAINMENT ACG Contention 7:

I "The refrigerated ice containment structure systen is in-novative and therefore should not be permitted without an I adequate pre-licensing testing taking into account the effect of roll, pitch, and yaw present cn a floating nuclear plant."50 I .

242. On this contention both Applicant and Staff presented evidence, incitdity material contained in the Plant Design Report (PDR), the Safety Evaluation Report (SER), as supplemented, and written and oral testimony.51 None of the intervenors presented 50 Admitted as interpreted by Board Order dated my 21, 1974, pp. 8,9.

She Applicant's written testinony, Exhibit No. OPS-42, " Applicant's I Testimony Regarding X. Ice Cbndenser (bntainment", was admitted at Transcript, page 6009 (5-13-77). The witnesses sponsoring this test-immy were Dr. Dee H. Walker and Messrs. P. Blair Haga, Richard S.

Orr, and John D. Sutherland (Professional Qualifications admitted I

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I l I witnesses, testinony or other infonnaticxt. Hearirg sessions with regard to this contention were held cn May 13, 16, and 17, 1977, and the testimony appears at Transcript pages 6002-6042, 6043-6117, and 6118-6150 and 6174-6226, respectively.52 ,

t 243. The ice condenser contairment has been adopted in the design of nuclear plants by the Indiana and Michigan Electric Co. (D.

C. Cook 1 & 2); Duke Power 03. (McGuire 1 & 2, Catawba 1 & 2); ard the Tennessee Valley Authority (Sequoyah 1 & 2, Watts Bar 1 & 2). In additicn, tm units utilizirg ice condenser contairment are under construction in Japan and tw in Finland. (Applicant's Testimony, Page 2; Staff's Testimtx1y, Pages 1-2) .

244. The design of the ice cordenser contairmient system is based cn an extensive ice condenser developnent program which began in 1%5. This program consisted of ccmprehensive systen testing as well as full scale static ard dynamic structural testirg of ice condenser (Footnote 51 Continued) at Tr. 1024, 1024, 1039, and 6004) . The Staff's written testina1y I entitled, "Supplanental Testimony of NRC Staff in Response to ACOCE Contention 7" by William C. Milstead, Jr. was admitted at Tr. 6085 (5/16/77). (Mr. Milstead's Professional Qualifications were admitted I 52 at Tr. 6083) .

Applicant witnesses were examined by counsel for Atlantic (bunty Citizens Council m Envirorment (ACCCE), State of New Jersey, NRC I Staff and the Board. Staff witnesses were examined by 0:)unsel for ACCCE, State of New Jersey, ard the Board.

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I I ccrnponents. Structural behavior of ice condenser components was measured during uatic and dynamic testing and confirmed analytical predictions of their structural adequacy. (Applicant's Testirony, Pages 1-2). .

I 245. Ice condenser heat absorption capability. during design basis accident was verified by blowdown tests cn a full scale ice condenser section at energy levels of up to 160 percent of those predicted. In these tests, 36 ft. long ice baskets were used instead of 48 ft. ice baskets which are used in the actual ice condenser. This reduced basket length provides a conservative indication of the heat absorption capability of the full length ice mndenser section. (Tr.

6097-6098).

246. In the full scale section tests, 'Cfaer than predicted drain tenperatures were observed. These high drain temperatures indicate that ice melt out is delayed in time and long term pressures are lower than predicted. (Tr. 6177-6183).

247. The first ice condenser plant, D. C. Cbok 1, achieved initial criticality in January, 1975, and ccmnercial operation in August, 1975. There had been no problens of safety significance associatal with the ice condenser and through Decenber 31, 1976, D. C.

Cook 1 had generated over eleven billion kilowatt-hours of electricity with a plant availability of greater than 83 percent. (Applicant's Testimony, Page 2; Tr. 6092).

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I I 248. There have been scme rormal " teething" problems with the ice condenser at D. C. Cook 1 including air handlirg units, refriger-aticn systen iminlances, air leaks and isolated incidents of ice buildup cn the lower inlet doors. In only a single instance did this-require a reduction of power, in this case a reduction to 20 percent of power to reclose 1cwer inlet doors. (Tr. 6056-6057 and 6111-6112).

. I 249. The ice condenser for the ENP will have substantially the same gecnetries, features, and materials of construction as those for land based plants (Applicant's Testimony, Page 1).

250. The ENP ice condenser is exposed to the same type of loading conditions as land based ice condensers. Additionally it is exposed to loads resulting fran roll, pitch, and yaw which are transmitted to the ice condenser through plant structures. A load acting cn an ice condenser conponent has an identical effect whether it is caused by roll, pitch, and yaw or by a seismic event. Maxinun loads which may occur as a result of roll, pitch and yaw are sig-nificantly less than the loads for which Mequacy was demonstrated durity the static and dynamic structural testing of ice condenser conponents. (Applicant's Testimony, Page 2)

I 251. Dynamic tests under simulated seismic loMings showed ice fallout fran ice baskets to be less than the allowable limit of one percent. As design basis wind and wave loadirgs at the ENP are about one-twentieth of the seismic loadings used in the test, it is I

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I I concluded that fauout during this condition will be also less then one percent. (Tr. 6023-6033).

I 252. 'Ib assure that the ice condenser installed on the FNP is.

able to perform its safety functicn, a monitority program will be per-formed throughout plant life. This program will include weighing of ice baskets, visual inspection of doors and flow passages, testing of opening forces on doors, monitoring of temperatures at various locations within the ice condenser, and checkirg the chenical atm-position of the ice. There is also a monitoring system that provides indicaticm that the door panels are all properly closed. This total program of procedures and equirrnent is very similar to the program at D. C. Cook. (PDR, Pages 6.2-ll7a(f) - 6.2-ll7c; Tr. 6055-6056) .

I 253. Ice may be replenished in the ice condenser by either adding water of the proper chemical ccrnposition at a controlled rate and allowing it to freeze or by melting down the ice bed ard ccm-pletely refillity with fresh flake ice. Tests have shown that fresh flake ice fuses within five weeks of filling to a level which provides adequate retenticn for high "g" loadings. It is not necessary to I partially melt the ice to ensure fusion. (Tr. 6047 and 6210-6211) .

I 254. The Boarti concludes that the ice condenser centainnent system, W11ch is being used cn a total of fourteen ctrnestic and foreign land based nuclear power plants, is not innovative for the ENP

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I I and that adequate prelicensing testing has been performed which appropriately takes into account the effect of roll, pitch, and yaw.

I K. OJtTTENTICN XI - TURBINE-GENERNIOR MRITERS .

255. On June 15, 1976, Mr. Ernst J. Effenberger made a limited appearance statenent before this Board concerning turbine--

generator matters (Tr. 999-1010). The Board requested the Applicant aM Staff to address the matters raised by Mr. Effenberger (Tr.1011) .

Both Applicant and Staff presented evidence cn these matters, includ-irg material contained in the Plant Design Report (PDR), the Safety Evaluation Report (SER), as supplemented, and written and oral testinony.53 Intervenors Atlantic County Citizens Council on Environ-ment (ACTE) and Atlantic County Board of Chosen Freeholders (Atlantic County) presented written ard oral testimony.54 I

The Applicant's written testinony, Exhibit OPS-38, entitled "Appli-I cant's Testimony Regardirg Turbine-Generator Matters," was admitted at Tr. 5095. The witnesses sponsoring this testimmy were Drs. Dee H. Walker ard Douglas H. Shaffer and Messrs. P. B. Haga, John F.

Hanst, John D. Dickinson, Harold C. Kersteen, and Francis S. Maszk I (Professional Qualifications adntitted at Tr. 1024, 2881, 3419, 5091, 5093, and 5094) . The Staff's written testimony entitled "NRC Staff Testimmy in Response to Limited Appearance Statenent of Ernst Effenberger," was admitted at Tr. 5659, 5660. The witnesses sponsority this testimony were Drs. Kazhnieras M. Campe and John A.

O'Brien and Messrs. Ronald F. Naventi, Richard J. Kiessel, Stefan S.

Pawlicki and Ralph A. Birkel (Professional Qualifications admitted I I at Tr. 5658, 2534, 5658,1946, 5658, and 1038) .

54 The June 15, 1978 limited appearance statement of Mr. Ernst J.

Effenberger was withdrawn (Tr. 4016 and 4033) and the written testimmy of 40CCE, entitled "Ccmnents on the Safety Evaluation Report, NUREG-75/ LOO (9/30/75), and Supplement, NUREG-0054 I (3/16/76), by the Office of Nuclear Reactor Regulation United States Nuclear Regulatory Ocmnission, Related to the Proposed Manufacturing

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I Hearing sessions with regard to the turbineqenerator matters were held cn Decenber 8, 9, 10, 16 and 17, 1976, February 28, March 1, 2, 3, and 4, May 9, 10, 11, 12, 13 and 17, 1977 and the testimony appears generally at Transcript pages 4004-6001 and 6151-6172.55 ,

I 256. In response to the Board's request at Tr. 5940 and 6377-6378, the Applicant provided additional informaticn with respect to the preliminary design of the turbine-generator spring rounted support and vacuum balanced condenser and the effect of these two I (Footnote 54 Cont'd) of Floating Nuclear Power Plants, Offshore Power Systems, Docket No.

SIN 50-437, Safety Evaluation of Mechanical Equipnent, Ctmnents by Ernst J. Effenberger, a (bncerned U.S. Citizen," dated June 1976, I was admitted into evidence at Tr. 4069. Mr. Effenberger, on behalf of ACCCE, read into the record at Tr. 4021-4026 additional direct testinony. (The Professional Qualifications of Mr. Effenberger were admitted at Tr. 4021.) Atlantic County's written testimcny entitled "Testimcny of Intervenor Atlantic County in Respect to Turbine-Gen-erator Design & Turbine Missiles," by Dr. George Luchak was admitted at Tr. 4343. (The Professional Qualifications of Dr. Luchak were ad-mitted at Tr. 4336.) Dr. Luchak testified that he was an expert in the areas of systens ergineerirg, applied probability, reliability and cost effectiveness studies (Tr. 5046) . Dr. LucFak testified that he is not an expert in the areas of turbine design, turbine sup-ports, valve systens, fracture mechanics, materials, stress corros-icn, instrumentaticn aM controls, bearing design, or the design of I

concrete structures; nor has Dr. Inchak ever designed a structure for dynamic loads or missile impact (Tr. 4398-4412 and Tr. 4763, 4764) . Atlantic (bunty's written testimony entitled "Testimcny of Intervenor Atlantic County in Respect to Turbine-Generator Design &

I Turbine Missiles" by Daryl F. Todd, Atlantic County Freeholder, was withdrawn aM not offered into evidence (Tr. 5081, 5082).

55 Applicant witnesses were examined by counsel for Atlantic County, State of New Jersey, ACOCE, NRC Staff, and by the Board. Staff witnesses were examined by counsel for Atlantic Cbunty, State of New Jersey, AOCCE ard by the Board. ATG witness Mr. Effenberger was examined by counsel for Atlantic County, NRC Staff, State of New Jersey, Applicant, and by the Board. Atlantic (bunty witness, Dr.

l Luchak, was examined by counsel for State of New Jersey, ACOCE, City of Brigantine, NRC Staff, Applicant, and by the Board.

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conponents cn the probability of turbine missile generaticn.56 Al m in response to the Doard's request, and as further clarified in the Board Order of February 28, 1978, the Staff provided an evaluaticn of the effect of the preliminary design of the turbine-generator support and, condenser on the probability of turbine missile generation.57 257. The Staff subnitted on Novatber 21, 1977, the " Affidavit of John A. O'Brien," which provided two anendments (pertainig to metal spalling and turbine foundation design) to the oral testinony which Dr. O'Brien gave at the May 13, 1977, hearing session. Dr.

O'Brien noted in his affidavit that these amendments did not affect the safety assessment conclusions in his earlier testintny.

On August 15, 1977, Applicant subnitted three affidavits entitled I " Preliminary Design of the Floating Nuclear Plant Turbine-Generator Support and Discussion of the Effect of the Preliminary Design of the Turbine-Generator Support and Vacuum Balanced Condenser on the Probability of Missile Generation," " Preliminary Design (Propriet-I ary) of the Floating Nuclear Plant Vacuum Balanced Condenser," and

" Preliminary Design (Non-proprietary) of the Floating Nuclear Plant Vacuum Balanced Condenser," each by P. Blair Haga, Richard S. Orr, and Dee H. Walker, and each dated August 12, 1978. These affidavits are hereinafter referred in as " Applicant's Affidavit I, II, or III," respectively. (Professional Qualifications of Richard S. Orr were admitted at Tr.1329) . The Applicant had previously supplied to the Staff a brief description of the spring mounted ENP t'trbine support and an indicaticn that a condenser was being designed to minimize the vacuum load on the support. This information is I contained in Applicant's Exhibit OPS-106, a letter (with attachnent) fran OPS to the NRC dated Septerber 8, 1976, admitt.ed at Tr. 5641.

Exhibit OPS-106 also contains other information concerning the ENP turbine.

57 On March 10, 1978, the Staff submitted a document entitled

" Affidavit of Richard J. Kiessel," hereinafter referred to as the  ;

"Klessel Affidavit."

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I 257.1 Subsequent to the hearing session cn May 17, 1977, additional informaticn became available which relates to the matter of

• 1 turbine missile generation This information was addressed in testinony presented by both the Applicant ard the Staff 57.2 at the, hearing sesion cn December 4, 1981; the testimony appears at tran-script pagu 7620-7659 and 7600-7615 . None of the intervenors presented witnesses, testimcny or other information cn these matters nor did any of the intervenors attend the hearing session.

.l Missile penetration tests, which were sponsored by the Electric Power Research Institute ani which indicatal that energy absorbtion in steel barriers might be less than predicted by the Ballistic Research Laboratory (BRL) Ebrmula, were reported in Mr.

S.M. Schinki's mcmorandtm to the Board dated Decenber 22, 1978.

The observation of cracks in the low pressure discs in a number of operating nuclear turbines was reported by the Acting Assistant Director for Light Water Reactxs, Division of Project Managenent in Board Notification IN-80-4 dated January 25, 1980. The failure of a disc in the low pressure unit of the Yankee-Rowe turbine was I reported by the Acting Assistant Director for Light Water Reactors, Divisicn of Project Managanent in Board Notification IN-80-8 dated February 19, 1980 and in a subsequent meterandun dated Mrrch 31, 1980.

Ne Applicant's written testimony, Exhibit OPS-68, entitled

" Applicant's Additional Testimony Regarding XI. Turbine-Generator Matters," was admitted by stipulation at Tr. 7601. The Staff's written testimony entitled "NRC Sta, f's Update of Its Testimony Regarding Turbine Missiles" was admitted,by stipulation at Tr.

7620.

57.3 Applicant witnesses (Drs. Dee H. Walker, Douglas H. Shaffer and Brij B. Seth and Messrs. P. Blair Haga and R. S. Orr) were examined by the Ibard (Professional Qualifications admitted at Tr.

1024, 2881, 7599, 1024 and 1329, respectively). Staff witnesses (Drs. Kazimieras M. Campe and John A. O'Brien and Messrs. Owen O.

Rothberg arrl C. D. Sellers) were exanined by the Board.

(Professional Qualifications admitted at Tr. 5658, 2534, 7620, and 7620, respectively).

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I 258. The design and supply of the ENP turbine-generator is performed by the Westinghouse Electric Corporaticn, a supplier of turbine-generators to industry for over 75 years (Applicant's Testi-rony, Page 2). .

I Turbine Rotor Deflecticx1 259. Mr. Effenberger made the followirg allegations relating to rotor stresses due to platform deflection:

l I "A standard land based T-G rotor is well over designed. The rotor stresses are in the range of 8 to 10 times the safety factor, because the bearirg diameter usually dictates the other dimensions of the rotor. The manufacturer of the ENP turbine asstnes a + 1/2 inch deflecticn allowance in the I operation of the turbine rotors. This in turn will increase the bending stresses in the rotor to an extent where the safety factors in certain areas will be r' educed to less than two, which will increase the probability of a rotor I failure in the same ratio." (Effenberger's Testimony, Page 3).  !

"Reducirg the stress safety factors in the shaft frcm 8-10 down to below 2 is increasing the possibility of a shaft failure and a missile generaticn." (Effenberger's Testi-many, Page 8). i 260. A Westinghouse criterica for rotor design, whether the rotor is for a land-based plant or an ENP, is that the stress safety factor will be no less than 2. Based upon long Westinghouse experience with land-based plants and marine propulsicn turbines, the stress safety factor of 2 or greater is good engineering practice. Art lyses corducted dernonstrate that the final design of the FNP turbine rotor

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I will meet this critericn, even with turbine-generator foundation l

I deflections of i 1/2 inch. (Applicant's Testimony, Pages 3 and 4, Tr.

5429 and Applicant's Affidavit I, Pages 45, 46, and 48.) The ENP turbine-rotor meets this criterion, even without the benefit of the-vacutm balanced condenser (Tr. 5430 and 5441) . The analysis of the EUP turbine rotor conservatively assumed the i 1/2 inch deflection was imposed cn every revoluticn of the rotor,58 even though such a deflection is an extrane condition that will seldcm occur, if at all (Tr. 5616, 5617, 5931 and 5932).

I 261. Westinghouse Steam Turbine Division analyses of rotors for land-based turbine generator units similar in design to that of the ENP show that, while there are locations where the ratio of 59 allowable to actual stress is in the range of 8 to 10, there are also locations where the ratio of allowable to actual stress is in the range of 2 to 3 (Applicant's Testimony, Page 3, and Applicant's Affidavit I, Pages 46 and 48). The stress safety factors for the ENP turbine rotor cn a spring support and with a vacutm balanced condenser i

be terms " shaft" and " rotor" appear to have been used interchange-ably in several portions of the transcript; accordirgly, the Board i makes no distinction between the two terms, l 59 The allowable stress is the endurance strength of the material which I is about 50% of the ultimate strength for the ENP rotor material (Tr. 5628 and 5629).

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I are similar to the stress safety factors for a land-based turbine rotor on a typical reinforced concrete support and with a typical condenser (Applicant's Affidavit I, Pages 46 and 48) .

262. Utilization of a vacuum balanced condenser reduces the vacuta load and the deflection of the FNP rotor. Also, the ENP rotor will be aligned so that the turbiru-generator foundation deflections, given in Section 10.2.4 of the PDR, will cause rotor deflections of equal magnitudo in the upward and downward directions, thereby minimizing the effect of these deflections. (Applicant's Testinony, Page 4, and Applicant's Affidavit I, Page 46) .

263. The sprirg trounted turbine support serves to attenuate local platform deflecticos, an advantage for which no credit was taken in the analysis discussed in the preceeding Paragraph 261 (Applicant's Affidavit I, Pages 11 and 47) .

Previous Experience With Rotor Deflections 264. Mr. Effenberger made the followiry allegations relating to previous experience with retor deflections:

4 "There is no ccmpariscn betwem a land based T-G and a floating T-G. A land based unit is erected and operated on its natural ' sagging line. ' The slightest. deviation frcm this line will cause an unrest of the rotor which will show up in excess vibraticn until the misaligrment is corrected.

Every T-G in the world operates that way. No other situa-tion is krrJwn." (Effenberger's Testinony, Page 2) .

I I * *

• 1 "As discussed earlier, the snooth operation of a turbine l shaft depends m an exact alignnent of the whole turbine. I Any deviation, experience shows about 15 mils, will induce I excessive vibraticn and therefore increase the possibility of a rotor failure." (Effenberger's Testinony, Page 6) . .

'bporating experience has shown all over the world that any I deviaticn fran the calculated 'saggirq line' will cause excessive vibration. No turbine in the whole world is known to operato under any other condition." (Effenberger's Testimony, Page 6).

I "Dending the shaft during operation is against any experience in history and totally unproven." (Effenberger's Testimony, Page 7) .

265. In the following statenent, Mr. Effenberger appears to contradict the above allegations:

, " Going inck to the proposed + 1/2 inch deflection of the turbine shaft, history has shown that it is possible to force a rotor to operate away fran the natural ' sagging I line'. This is strictly a stress problon in the rotor coupling and the shaft ends. Increasing the coupling size and the coupling bolts usually takes care of this condition. The specific bearing pressure will also increase, an1 this dictates a larger bearirg. These changes create no problem since the operation under this I arrangenent is the same as in any other design. In other words, a turbine rotor can be designed to operate at any different point or line as lorg as the rotor stresses are being taken care of." (Effenberger's Testimony, Page 6) .

266. During cross examination by counsel for the State of New Jersey, Mr. Effenberger clarified his concern as being related to the movanent (or flexirg) of the rotor across the natural " sagging line" I

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I rather than the operation of the rotor at sane constant deviation fron the " sagging line" (Tr. 4082 and 4083) .

I 267. Intervenor witness Dr. Luchak agreed with Mr. Effen .

berger's crmnents cn the bending of the turbine shaft during opera-ticn, changes in bearing pressures, arx1 the effects of hull vibrations on rotor strain, all in the context of the high-tuned mount (Luchak's Testincny, Page 5, as interpreted at Tr. 4648 and 4649, and Page 6, as nodified at Tr. 4333) . As acknowledged by Dr. Inchak (at Tr. 4649),

the ENP turbine foundation is a lcw-tuned nount, not a high-tuned trount (PDR Section 3.7.2.1.1.8). The Board notes that Dr. Inchak indicated that he would wish to reconsider these opinions with respect to the proposed (low-tuned) ENP turbine foundation design (Tr. 4649) .

The Board therefore finds the preceding opinions of Dr. Luchak are not relevant to the ENP design under consideration in this proceeding.

I 268. It is normal for turbine-generators to operate away frcm the natural " sagging line," including movesnent back and forth across the " sagging line" (Applicant's TestiInony, Page 5, Tr. 5195, 5443, and 5446) . Such deflections do not cause any problems unless they beccrne I excessive (Applicant's Testimcny, Page 5) . Based en previous experi-ence and analyses, the deflections of the ENP turbine-generator will not result in unacceptable vibration (Applicant's Testinony,Page 5) .60 I 60 Refer to the section cn Bearings (Paragraphs 276 through 280, infra)

I for additicmal informaticn respecting the effect of rotor deflection on bearing oil pressure and vibration.

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. I I Rotor Stresses and Plant Moticn 269. Mr. Effenberger rade the following allegation relating to rotor stresses induced as a result of plant notion: .

I "The increase in disc stresses due to plant motions are discussed, but what about rotor stresses? Since the plant I motions are not kept away fran the turbine shaft, the rotor will go through its own cyclic stresses, plus all the plant motions.

I "To illustrate the plant notions, a wave motion period of 20 seccnds is asstrned. Over a forty year life span, the I rotor will experience over 60 million additicnal stress cycles. This fact is totally ignored."

Testimcny, Page 4) .

(Effenberger's I 270. The effect of plant motion cri rotor stresses is con-sidered in the analyses of the turbine-generator as discussed in PDR Section 10.2.4. These stresses were included in the Applicant's analyses discussed in the previous section on Turbine Rotor Deflec-tions. The Applicant's calculations show that platform nntions I contribute a maximtzn of about 17 percent of the total cyclic stress in i

the rotor, and at nest locaticns the percentage is much lower. In

)

these calculations, the Applicant conservatively assumed that the rotor is contintously exposed to the maximtzn plant moticn rather than a range of lesser plant motions that would actually be present. The I Applicant also conservatively assumed that this maximtzn notion stress level is applied for each revoluticn of the rotor, whereas the actual stress would cycle less frequently as the plant naves through its moticn cycle. The net result of these asstanptions is that nore than I

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I I 30 billicn cycles of the maximtm moticn stress level are imposed or.

l l

the rotor in the Applicant's analysis, otmpared to the 60 million i cycles mentioned by Mr. Effenberger. ( Applicant's Testimony, Page 6) .

Accordingly,- the Board finds that the effects of plant motion on rotor.

stresses were not ignored, and in fact the Applicant has conserva-tively considered such effects.

I Rotor Stresses and Hull Vibrations I

271. Mr. Effenberger made the following allegation relating to rotor stresses and hull vibrations:

I " Hull vibrations will add to rotor strains and stresses and I increase rotor failures and therefore missile generations."

(Effenberger's Testimony, Page 8).

272. The design of the ENP provides for isolation between the turbine and the hull, as discussed in PDR Section 3.7.2.1.1.8. Accord-ingly, the effect of hull vibrations on rotor stress or strain levels and on the possibility of missile generation will be negligible.

(Applicant's Testimony, Page 7, and Applicant's Affidavit I, Pages 16 through 19).

273. The Applicant has conducted analyses to determine the dynamic response of the turbine-generator arx1 support system to an unbalanced rotating mass. Analyses were performed for the turbine-generator on the ENP (spring mounted) support as well as for the i

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I I turbine-generator on a typical reinforced concrete support. These analyws dcrnonstrate that the dynamic response of the turbine-gener-ator is not adversely affected by the spring moeted support. There-fore, the dynamic behavior of the turbine support will not add to the-probability of turbine missile generaticn. (Applicant's Affidavit I, Pages 12 through 16 and 47).

I Condenser vacutm Ioad 274. Mr. Effenberger made the following allegation relating to condenser vacuum loads:

I "It is impossible to otrnpensate life (sic) loads such as I vacuts loads by selective aligrrnent. In a conventional design the condenser is fixed, the turbine is on the foundation and between the turbine and condenser is a I flexible expansion joint. The full vacuum load is on the turbine. The only way to eliminate the vacuta load is to mount the condenser cn springs and eliminate the expansion joint. This arrangenent works cn a land based plant, not I on a floating nuclear power plant, because there is no way to restrain the hanging condenser, which is also exposed to the platform notions." (Effenberger's Testimony, Page 7).

275. As stated previously, a vacuum balanced condenser will be utilized cn the FNP to reduce the vacuum load cn the turbine-generator. The ENP design does not involve nounting the condenser on I springs or eliminating the expansion joint. (It is noted that there has been wide use in the power industry of vacutru balanced condensers incitxling nuny which & not involve spring mounting or eliminaticn of the expansicn joint.) Thus, contrary to Mr. Effenberger's allegation, I

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I I it is possible to conpensate for vacutan load on the ENP turbine-generator.61 (Applicant's Testimony, Page 8, Applicant's Affidavit II, and Tr. 5636).

Bearings 276. Mr. Effenberger made the following allegations relating to the ENP turbine rotor bearings:

I " Changing the bearing pressure during operation will induce vibraticn ard increase the possibility of a shaft failure and missile generation." (Effenberger's Testimcny, Page 8).

'Tne journal bearings of a turbine rotor are very precise.

I The weight of the rotor dictates the size of the bearing, the thickness of the oil fibn and the oil pressure. The gap between the bearirg and the shaft is filled with oil and well defined. If this gap is too large, the phenonena of an I oil whip moas up. If the gap is too small, then the oil will be over-heated and the babbit in the bearing melts.

The limitations between these two conditions are very small.

"Any bending of a turbine shaft during operation will I change the gap in the bearing, will change the bearing pressure and will cause all the conditions as discussed above." (Effenberger's Testimony, Pages 6 and 7) .

I 6he Board nolu that Mr. Effenberger himself subnitted to the I Applicant in late 1975 an invention disclosure for a condenser joint design that would reduce the vact.un load cn the ENP turbine-genera-tor. Mr. Effenberger's proposed design did not involve elimination of the expansien joint or mounting of the condenser en springs. The I design proposed by Mr. Effenberger was not selected for use cn the ENP because other proposed designs were superior. (Applicant's Testinony, Pages 7 and 8, Applicant's Affidavit II, Page 4, and Tr.

4091).

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I

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I 277. As indicated in POR Section 10.2.4, the ENP turbine rotor bearirg pressures have been evaluated under ENP loading con-ditions, and the results indicate that the final design will meet the Westinghouse design criteria applicable to all turbine-generators.-

Such evaluations included ccxisideration of potential for oil whip and bearing overload. (Applicant's Testimony, Page 9) .

278. Oil whip is a vibration of the rotor in a sleeve bearing that is caused by instability of the oil film. It has been sttriied intensively and is well understood. The potential for oil whip is governed by ccrnbinations of such parameters as bearing pressure, rotational speed, oil viscosity, bearing clearance and system flexi-bility. Analyses of the ENP bearings under the range of ENP bearing pressures indicate that oil whip will not occur. Additionally, Westinghouse experience shows that oil whip is unheard of cn 1800 RPM I '

rotors such as that cn the ENP. If oil whip were to occur, it would be detected by the vibrt2ticn sensors that will be cn the ENP unit, and the init could be safely shut down for corrective action without an increase in the probability of missile generation. (Applicant's Testimcny, Page 9) .

I 279. Design criteria for detenvining the maximtm pressures under which bearings can operate successfully have been established through experiments ocriducted by Westinghouse and others and through many years of operating experience with Westinghouse turbines.

I Analyses of the ENP bearings under the expected range of ENP bearing I

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I I pressures indicate that sufficient oil film will exist to carry the load. The ENP will contain redundant tmperature sensors that will show if a bearing is overloaded (and hence overheated) so that i corrective action can be taken, thus preventirx3 melting of the babbitt.

due to excessive tmperatures. ' he temperature alarm point is 210 F and the established trip limit is 225 F, which is well below the melting paint of the bearing babbit (approximately 450 F) . If the babbitt in a bearing were to melt, subsequent to the turbine being tripped, the resulting friction forces created between rotating and stationary parts would cause rapid deceleraticx1 of the turbine-generator frcm operating speed with no effect on the probability of missile generation. (Applicant's Testimony, Pages 9 and 10, and Tr.

5456).

I 280. Westinghouse field service experience has shown that land-based turbine designs similar to the FNP, which have met the above bearing design criteria, have not experienced " excessive vibrations". It is therefore concluded that the ENP turbine-generator will not experience, as a result of bearing pressure induced vibra-tien, any greater potential for missile generaticn than a similar land-based turbine-generator. (Applicant's Testimony, Page 10).

I Shippingport Failure I

281. Mr. Effenberger made the following allegation relating to turbine-generator materials:

I I - >>-

I I "The T-G manufacturer claims that no T-G failure in his I design has occurred. I wuld like to point out that Shippirgport, a nuclear power plant, failed at operating speed last year, not at design or destructive overspeed; it just fell apart after sixteen years of normal operation.

I Obviously the integrity of the material is only good for a limited time, definitely not for forty years as this ENP is .

planned to operate." (Effenberger's Testimmy, Pages 4 ard 5).

282. In February,1974, after 16 years service, the Shipping-port turbine of Duquesne Light Coupar.y experienced a disc failure at the second IP disc. In February 1980 the Yankee-Rowe turbine also-experienced disc failures. No missiles external to the turbine casing were generated by either incident. (Applicant's Testirrony, Page 10 and Applicant's Additional Testimmy, Page 5) . Other turbines with design features similar to the Shippingport turbine have been in operation for more than 40 years. ( Applicant's Testimmy, Page 11) .

283. Metallurgical examination of the failed Shippingport disc revealed that the fracture originated at cracks in the corner of I the keyway near the exhaust face of the disc. These cracks formed and slowly pr)pagated during the 16 years of operaticn, and failure occurred when the cracks enlarged to critical flaw size. M:xlern disc materials used for the ENP turbine exhibit more than twice the toughness of the material used for the Shippingprt turbine. In additicn, design changes which have occurred since about 1958 limit the stresses and the likelihood of crack formaticn. (Applicant's Testimmy, Page 11, and Staff's Testimcny, Page 30) .

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I I 283.1 Neither the ShippingIort turbine nor the Yankee-Rowe turbine received periodic ultrasonic in-service disc in-service inspection. The ENP turbine will be inspected in-service at intervals recotmended by Westirghouse to assure that any crack would not grow to, the critical size before the next inspecticn (Applicant's Additional Testinony, Page 3) .

I 283.2 Applicant stated that design improvenents presently in various stages of developnent will improve the crack resistance of the low pressure turbine discs (Applicant's Additional Testimcny, Page 3) .

I The Staff concurred with the Applicant and further stated that the present turbine design is acceptably safe, given inspection at an appropriate interval (Tr. 7622-7623 and 7645-7650).

283.3 The Board therefore finds there is no reason to expect the ENP turbine to experience a disc failure during its forty year design life.

g worspeed wm sysm i

I 284. Mr. Effenberger made the following allegations relating I

1 1

I to the overspeed protection systems for the ENP turbine-generator: l I "Three overspeed protective systens are provided in this design, but all systens act finally m the same valve spindle, so ro matter how many systens are installed for I overspeed protecticn, if the one valve gets stuck then there is little protection and the reasoning for having three systens is not valid.

I I --

8

I  !

I "The trip systens are part hydraulic and part mechanical.

I This means that the valves are spring loaded and the springs are kept open by hydraulic pressure. On impulse, the fluid is d'unped anc! the springs are closing the valves.

• No systems have the same drain line and any bending or I

plug-up of this line will make the main steam valves inoperable." (Effenberger's Testimony, Pages 3 and 4). .

I * * *

"All three mergency trip systems depend finally on the I reliability of a single valve as shown earlier.

really enough?" (Effenberger's Testimmy, Page 5).

Is this "The overspeed protective trip systens are acting on the I same valve spindle and therefore not reducing the overspeed possibility. Two of the three energency trip systens have the same dtznp lines. Any damage or plug-up of this line will increase the possibility of an overspeed mndition and I therefore missile generation." (Effenberger's Testimony, Page 8).

I 285. The three overspeed protecticn systens for the ENP turbine are described in PER Section 10.2.2.4, pages 10.2 - 6b, 6c, and 6d. The three systems are designated Electrical, Mechanical and SG7PS (Single Channel Overspeed Trip Systen) . In response to a Board request at Tr. 4181 and 4315, additional description of the overspeed protection systems was provided in Applicant's Exhibit OPS-104 (admitted at Tr. 5106) and in the testimony of Applicant's witness at Tr. 5107 - 5114.

I 286. The Staff has received a preliminary design of the ENP turbine overspeed protection systen (Tr. 5892). The improvenents in the ENP overspeed protection system (the double drain trip block and SG7PS) are not innovative, new or unusual (Tr. 5893 and 5898) . The SG7rs systen has been previously utilized m land-based nuclear plants

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I I (Tr. 5893 and 5894). The overspeed protecticn system will conform to the requirments of IEEE-279,1971.62 (bnformance with this standard,

specifically with the equipment qualification and periodic testing l requirments, should result in an enhanced reliability of the over ,

i speal protection system. (SER Section 7.6.1 and Tr. 5928 through 5931).

! I 287. All three overspeed protection systens cb not depend finally on the functioning of a single valve. In accordance with standard American pwer industry practice of many years e*anding, the FNP turbine will be furnished with redundant valve systems for the main steam piping (throttle and governor valves) and redundant valve systens for the reheat piping (reheat stop and interceptor valves) .

In each steam flow path into the turbine there are two valves in series to protect the turbine against overspeed. These valves are held open against a spring force by fluid pressure. Stainless steel tubes are used to carry the trip fluid. A 'oss of fluid pressure will cause the valve to close. Blockage of any cne drain line will not prevent valve closure. (Applicant's Testinony, Page 12) .

I I 62 Institute of Electrical and Electronic Engineers Standard 279, 1971,

" Criteria for Protection Systems for Nuclear Power Generating I Stations" (Tr. 5929). As noted in SER Section 7.6.1, the Staff requires that the overspeed protecticn systen conform to IEEE-279, 1971, except as follows:

I

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I I 288. In response to a hypothetical question by Applicant's counsel, Mr. Effenberger agreed that, if there are three separate drains for the energency trip fluid, if there is a separate line for '

the unergency trip fluid fran each c:xp valve, and if there is a third.

fully independent auxiliary overspeed protection system krxun as SCDTS, he rn longer would believe that two overspeed protection j systems have the same drain line and any bending or plugging of any single line will make the main steam valves incpe::able (Tr. 4197 through 4200) . The hypothetical question is shown to be based on )

1 factual infonnation in the PER Section 10.2.2.4 (Pages lO.2-6b, 6c, l and 6d), Applicant's Exhibit OPS-104 ard the oral testimony of the Applicant's witness at Tr. 5107 through 5114.

289. During cross examinar.icn, Mr. Effenberger agreed that if one valve fails to functicn ard the other nineteen valves operate, there is still protection fron turbine overspeed (Tr. 4210) .

(Footnote 62 Cont'd)

"(a) Section 4.4 of IEEE Std 279-1971 (Equipnent Qualifica-I tion). The equipnent of the turbine overspeea protecticn systen shall meet the environmental qualification requirements (includirg vibraticn) under all conditions of nonnal, abno:'nal, I and accident conditions, but excluding seismic qualification.

(b) Section 4.17 (Manual Initiation). Manual initiation at the system level in the control roon for the turbine overspeed I protecticn systen is not required. However, industry practice which provides for a means for manual trip locally at the turbine should be followed." (SER Section 7.6.1).

With respect to itan (a), the Staff required "The turbine overspeed protection systen should be designed and installed (equipnent quality, mounting, routing and I supportiry of associated circuitry and piping) such as to provide a high degree of assurance that it will retain its I functional capability durirg and after earthquake." (SER Section 7.6.1).

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I I 290. The Board concludes that failure of any cne valve or any one trip fluid line will not prevent tripping of the turbine.

I Plant !bticn and Valves .

I 291. Mr. Effenberger made the following allegaticn relating to the effect of plant moticn on the steam valves:

I "It has not been investigated what the platform motion could do to a valve spindle clearance. The steam chest which houses the main steam valves is also exposed to the I paltform (sic) motions." (Effenberger's Testimr.y, Page 5) .

292. Mr. Effenberger's statenent appears to imply that a reduction in main steam valve spindle clearance, due to the forces imposed cn the main steam valves by plant tretions, may prevent the

, main steam valves frcm closing. The main steam valves and steam chest have been analyzed ard found to be acceptable for accelerations about

, ten times the values of acceleration that may be experienced due to

, plant moticn. It is therefore concluded that platfonn tretions will not prevent the main steam valves frcm closing. (Applicant's Testi-mcny, Page 13).

Valve Testing 293. Mr. Effenberger made the followirg allegations relating to valve testing:

I " Turbine main steam valve stans build up deposits no matter how the feedwater is treated. Practice has shown that even

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I I valve testirry is not practical because the schedule is never kept by the operator. Only those who have worked in I and maintained a power plant know that. If every stuck valve would be reported by the utility industry, the in-I surance rates would go up to the extent that we would have no power stations in operation." (Effenberger's Testimony, Page 4). -

"Every valve testing makes it necessary to reduce the load I of the turbine to the point where the valve can be taken out of service to close. Having twenty main steam valves and nunerous non-return valves cn a 1200 Megawatt Unit, the time elenent involved will be such that the unit will never get above 75 -

80% of full load. This means that the utility owner will resist, and if necessary will cxane up i with,his own schedule for valve testing. This will further I I increase the probability of a valve failure and create a potential possibility for any overspeed condition."

(Effenberger's Testimony, Page 5).

I 294. Valve failures cannot result in unacceptable overspeed excursions unless at least two valves in series in the same steam flow path into the turbine fail to close simultaneously when there is a denand to close (see Paragraph 287, supra) . For the reasons discussed in PIR Section 3.5.4.4.2, it is unlikely that one valve, let alone two valves in series, will fail. Design features such as spiral grooves in throttle and governor valve stens, backseating of the stens and substantial closing force are provided to minimize the possibility that valves will stick open. (PIR Section 3.5.4.4.2, Applicant's Testimony, Page 14, and Staff's Testimony, Page 16). All-volatile treatment of the feedwater, which is provided in the ENP design, will reduce the particulate a >ntent of the steam passing through the valves. This particulate material is the cause of buildup on the valve stens and possible sticking. (PDR Section 10.3.5 and Staff's Testi-many, Page 16).

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I I 295. 'Ihe Ormissicn will require an owner of an ENP to include in its Technical Specifications the valve testing and in-service inspection program outlined in PDR Section 10.2.6 (Staff's Testimny, Page 13) . .

I 2%. The time required to test the ENP turbine valves amounts to a few minutes per valve, or approximately one hour per week for all turbine valves (Applicant's Testinony, Page 14, and Tr. 5116-5119).

Maximtm load reduction during test of any valve occurs when testing governor valves and is approximately 10 percent of full load when the s turbine is operating at full power (Applicant's Testimony, Page 14).

It is not necessary to reduce load on the ENP turbine prior to testing the turbine valves (Tr. 5137) . When testing is done at less than full load, the turbine control systen acts autcmatically to maintain load at a constant level. Interference with normal operation of the turbine is usually minimized by scheduling valve tests at off peak hours and by staggering the tests of the various groups of valves over a one week pericd (the period reemmended between valve tests).

(Applicant's Testimony, Page 14).

I 297. Testing of conventional nonreturn valves in the extrao-tion pipes between the turbine and feedwater heaters and in the drain lines between the noisture separator-reheater and feedwater heaters will not cause a significant load change (Applicant's Testimny, Page l 15).

lI lI

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l l'

I 298. Dr. Luchak testified that it is reasonable to asstune turbine valve testing cn the ENP will reduce the ENP capacity factor by five percent. (Luchak's Testimcny, Page 10) . Dr. Luchak's estimated reduction is based cn his observaticn that such a reduction is within.

the standard deviation of capacity factors he observed cn land-based plants and that such a reduction would, therefore, not be unusual (Tr.

4372 and 4373) . Dr. Inchak performed further calculations based en two issues of the Commission " green book"63 which additionally I ccnvinced him that a reduction in capacity factor of five percent is rossible due to valve testing cn the ENP (Tr. 5028 throtgh 5030 and Tr. 5034). The Applicant reviewed the two issues of the OtrTnission

" green took" to which Dr. Luchak referred at Tr. 5029 and 3030. These tw issues listed cnly two Westinghouse turbines that have valves functionally the same as the ENP turbine, ard only one of these two I turbines had a valve test. That cne turbine has a restriction which requires that load be reduced to at least 75% durirg valve testing.

Since the ENP has no such restriction, the information cn this one turbine is not applicable to the ENP. (Tr. 5597 and 5598) .

299. Utilizing Mr. Effenberger's estimates of valve test times (which are about 6 times higher than the times stated by the Applicant) and Mr. Effenberger's estimate of power reducticn (25% vs.

Applicant's maximtzn of 10%), the Staff calculated that weekly valve testing cn the ENP might reduce the capacity factor by about one-half j j of one percent. (Tr. 5982, 5983, 5989, and 5990).

I l 63" Operating Units Status Report, Licensed Operating Reactors, Data l 5 for Decisions," Nuclear Regulatory Commission, November and l December, 1975.

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I I 300. The Board finds that Dr. Inchak's estimate of capacity factor reducticn due to valve testing cn the ENP is not supported by the facts. The available information indicates that weekly valve testire cm the ENP will not have a significant impact cn the plant.

load or capacity factor.

Turbine Missiles I 301. Mr. Effenberger made the following allegations relating I to turbine missiles and applicable regulatory probability criteria:

I "N RC, Bush Report 4/7-1973, Probability of T-G Missiles.

This report cbes collect data cn a worldwide basis of T-G failures. Not a single floating T-G is included, just informaticn cn land based units. Therefore, this report is I totally unacceptable for an evaluaticn." (Effenberger's Testimcny, Page 2) .

"The conclusion in the Bush Reporti shows that a probable failure of a T-G is in the range of 10-4. m be m de safe

~

side, the NRC assumed a 10 failure rate on new land based I nuclear power plants is sufficient to guarantee the safety of the public. Ignoring the fact that the operation and envir-onnental conditions of a floating nuclear power plant is I totally different frcm land based plants, tnis requirement was also imposed cn the ENP. The EUP was and is evaluated as any other land based poi.er plant and this is wrong and dangerous, I because the probability of a T-G failure cn the ENP is greater than cn a land based plant." (Effenberger's Testimony, Pages 2 and 3).

" Missile generaticn depends cn the reliability of failsafe I equipnent, like an overspeed protective trip systen, re-liability of valve system, rotor failures - material I

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l l

I l

)

I integrity, disc failures - naterial integrity, valve testing, i

l I just to mention a few. The orientation of the T-G in a power plant should be decided considering all the above conditicns."

(Effenberger's Testimony, Page 3).

I "The NRC in its wisdon decided in a last year's ruling to locate the main T-G radial to the containnent in any future I nuclear power plants. The main reason was the probability of turbine missiles hitting the contairinent and .all the short-canings discussad earlier. The rest of the world has done

,I this for many years, and this makes sense. A special ex-cepticn was made for Offshore Power Systems. Why? Since the probabilities of turbine failures cn a ENP are greater than on land based plants, it is an absolute necessity, for our protection, to relocate the nest dangerous equipnent and largest missile producer, so as to reduce the probability of missiles." (Effenberger's Testimony, Pages 5 and 6) .

I '

"If the T-G should go cn the destructive overspeed then the largest piece ejecting the turbine casing will have a kinetic I energy of 32 millicn ft. lbs. There is nothing on the present ENP which could centain or stop these missiles which in turn would penetrate all the structures, the shield building, the

, containment and the reactor vessel itself and in addition would puncture the hull and sink the plant. What happens then, I will leave to your imagination." (Effenberger's Testinony, Page 1) .

302. Based cn the discussion in the preceding paragraphs, the Board finds that Mr. Effenberger's allegations regarding turbine rotor deflection, previous experience with rotor deflecticns, rotor stresses and plant motion, rotor stresses and hull vibrations, condenser vacuum load, bearings, the Shippingport failure, overspeed protection  !

systens, plant moticn and valves, and valve testing are not supported by the evidence. Therefore, these allegations provide no basis for expecting that the probability of a turbine-missile-producing event is I significantly different for land-based nuclear plants and ENPs.

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I I 303. The guideline enployed by the Staff in determining whether a postulated event needs to be a design basis event (for which specific additional protection is provided) are those events for which a realistic estbnate of the probability of occurrence is greater than-the order of 10 -7

/ year and which could lead to potential consequences in excess of 10 GR Part 100 exposure guidelines. (See Standard Review Plan 2.2.3). Stated another way, turbine missile protection is deaned to be adequate if the probability for unacceptable consequences (consequences in excess of 10 GR 100 exposure guidelines) is found to be of the order of 10 -6/ year for conservative evaluations, or of the order of 10 / year for realistic evaluaticns. These criteria, utilized in determinirs whether or not an event needs to be considered a design basis event or whether protection is adequate, are not dependent upon whether the plant is land-based or floating. (Applicant's Testinony, Pages 16 and 17, Staff's Testimony, Pages 2, 10 and 11, and Tr. 5869 through 5872).

I 304. The ENP has an offset turbine orientation. In response to a Board request at Tr. 4314 and 4315, the Applicant provided in Exhibit OPS-lO3 an example cf the barriers that intervene between the turbine and safety related equignent.64 Specifically, Exhibit OPS-103 I 64Applicant's Exhibit OPS-103, admitted at Tr. 5121, consists of three I sheets entitled, respectively, " Identification of Section Cuts,"

" Simplified Drawing Showing Significant Structures Between the Turbine and the Reactor Vessel," and " Simplified Drawing Showing Significant Structures Between the Turbine and Safeguards Area No.

I 2." Applicant's Exhibit OPS-102, marked for identification at Tr.

4813, was not offered into evidence because Exhibit OPS-103, Sheet 1, provided the same informaticn concerning the ENP turbine orienta-tion vis-a-via the containnent (Tr. 5122 through 5124).

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I I illustrates the material and material thicknesses for barriers that intervene betwem the turbine and the reactor vessel and the turbine and Safeguards Area No. 2. (Applicant's Exhibit OPS-lO3 and Staff's Testinony, Page 1) .

Design Overspeed Turbine Missile Evaluation I

305. The Applicant evaluated design overspeed turbine missile. This evaluation assumed the probability of generation of a turbine missile at design overspeed is 1 X 10 per year, based on a review of the Bush report.65 (PDR Section 3.5.4.3 and Applicant's Testimony, Page 17). Materials, manufacturing techniques and in-spection techniques have all sabstantially improved relative to those associated with the turbines included in the data base for the Bush report 66 (PDR Section 3.5.4.3 and Applicant's Testimony, Page 18) . As an example, the FNP turbine must meet the design, material toughness, and quality assurance provisions of Standard Review Plan 10.2.3,

" Turbine Disk Integrity" (Staff's Testimony, Page 30). The Board therefore amcitxles that the 10 per year value for the probability of turbine missile generation at design overspeed is conservatively high when applied to the FNP.

65 Bush, S.

I H., Probability of Damage to Nuclear Ortponents to Turbine Failure," Nuclear Safety, Vol. 14, No. 3, May , June, 1973. Dr. Bush published a later study of turbine missile probability (See Paragraph 331, infra.) in which the results empared favorably with

.I his originaly estimated probability (Tr. 7602-7603).

66 The data base in the 1973 Bush report includes 70,000 turbine years of operation fran turbines nunufactured fran the early to mid 1900's I to approximately 1970 (PDR Section 3.5.4.3 and Applicant's Testimmy, Page 18) .

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I 306. Considering both high and low trajectory design over-speed turbine missiles, the Applicant conputed the probability of a missile, once generated, striking an essential safety systen to be on the order of 10-3. This gives an overall probability (the product of ,

-4 and 10-3), at design overspeed, of generating a missile that 10

-7 strikes an essential safety system on the order of 10 per year. (PDR Section 3.5.4.3.3 and Applicant's Testimony, Page 17) .

307. The Applicant provided additional infonnation concerning observations of disc cracking, missile penetration tests and revised Westinghouse exit energy calculations which becarae available subse-quent to the hearing session on May 17, 1977 (Applicant's Additional Testimony, passim). Applicant has concluded that when both new missile enertJy data and new failure probability data are considered, the probability of damaging a vital target will be no greater than the probability stated in the Applicant's carlier testirony. Applicant stated that reanalysis of the ENP turbine is planned during the final design phase (Applicant's Additional Testimony, Page 4) .

I 308. The Staff in their testimony (Staff Testimony, Pages 1-2) limited their consideration of turbine missile damage to destructive overspeed, the evaluation of which is discussed in Paragraphs 311, 312 and 312.1, infra. I I

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I I 309. The Doard finds that the probability, at design over-speed, of generatirg a turbine missile that strikes an essential safety systen is sufficiently small to meet the Staff criteria and that the ENP design with respect to this matter is adequate to protect the p2blic health and safety. This will be reconfirmed during the firni design approval phase when specific information regarding the turbine purchased for the ENP is available.

I Destructive Overspeed Turbine Missile Evaluation 310. The Applicant evaluated destructive overspeed turbine missile. This evaluaticn consists of a fault tree analysis of the ENP I turbine control and overspeed protection system that was used to evaluate the probability of reaching destructive overspeed. Improve-ments in and increased redundancy of the ENP turbine overspeed protectdon systens, relative to those associated with the machines included in the data base for the Bush report were considered in the Applicant's fault tree analysis and reduced the probability of I " " ' ' " ' ' " " " " " " " " ' ^" '" """" ' " " " " ^ ' ' " " " " ' " " " ' ' ' ' " " " "

5 I

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I c

I turbine valves incorporate design changes to improve their relia-bility. The @bility of reaching destructive overspeed was cal-culated by the Applicant to be on the order of 10~ / year for the MIP.0 Since the probability of even reaching destructive overspeed I;

~7 on the order of 10 / year, the Applicant, in accordance with the Staff criteria, has excluded destructive overspeed from the R@ design basis. (PDR Sections 3.5.4 and 3.5.4.4 and Applicant's Testinmy, Pages 17 and 18.) The Applicant stated that none of the recently developed information affects the probability of occurrence of destructive overspeed (Applicant's Additicnal Testimcny, Page 5) .

I 311.

I The Staff also evaluated destructive overspeed turbine missiles (Staff's Testimony, Pages 1 through 11, and SER Section 3.5.3). Unlike the Applicant, the Staff did not eliminate destructive overspeed fran the design basis solely on the grounds of a suffici-ently 104 probability of reaching destructive overspeed. Pather, the Staff utilized a destructive overspeed probability of 4 X 10-5/ year for a conservative case and 4 X 10-6/ year for a realistic case. The Staff then ocrnputed the strike and damage probabilities to determine if the overall probability of missile generation, strike and damage met the Staff criteria referred to in Paragraph 303, supra. (Staff's Testimony, Pages 1 through 11.) The conservative value of 4 X 10~/

year is based cn the data in the Bush report (Staff's Testimcny, Page 0

The actual value calculated by the ApplicaJt as the probability of reaching destructive overspeed is 6 X 10 per year (PDR Section 3.5.4.4.2).

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1 36, Tr. 5707, 5708 and 5827) . The valte of 4 X 10-6/ year is obtained l

by taking a factor of ten reduction in the destructive overspeed probability in view of the improved turbine overspced protcetion systen cn the FNP (Staff's Testimcny, Page 10) . .

I 312. High trajectory turbine missiles were found by the Staff to be a snall contributor to the overall risk fran destructive overspeed turbine missiles.

Thus the Staff's destructive overspeed missile evaluation was primarily with respect to low trajectory missiles. (Staff's Testinony, Pages 1 and 2.) The Staff's analysis utilized the nost penetrating of the possible turbine missile (Staff's Testinony, Pages 3 and 4). The seven foot thick concrete portion of the turbine support (denoted as structure "B" cn Applicant's Exhibit OPS-103, Sheet 2, and as structure "BB" on Sheet 3) provides sub-stantial protection to certain safety related areas of the RF since a destructive overspeed missile cannot penetrate this barrier (Tr. 5128, 5699 and Staff's Testimony, Pages 4 and 8). The Staff concluded that I the overall probability of unacceptable damage fran a destructive overspeed missile is in the range of 10 (for the conservative case) to 10-7 (for the realistic case), which is within the Staff criteria, l

Paragraph 51, supra (Staff's Testimony, Page 10 and 11).

312.1 In subsequent testinary the Staff stated that tests ccmducted by the Electric Pcwer Research Institute after the original f

hearings cn turbine missile indicated that turbine missile exit speeds I

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I I could be higher than previously calculated (Staff's Updated Testimcmy, Page 2) . The Staff, therefore, reevaluated missile strike and damage probabilities based cn higher missile exit speeds fran the turbine I casirg. The Staff concluded that the higher missile speeds do not-l change the Staff's original conclusions regarding turbine missile risks for the Floating Nuclear Plant (Staff's Updated Testimony, Page 2).

313. The preliminary design of the turbine nount and con-denser is set forth in Applicant's Affidavits I ard II which were furnished in response to a Board request (See paragraph 256, supra).

Informaticn contained in these affidavits did not change the Staff's earlier conclusion concerning the probability of generation of a missile at both design and destructive overspeed (Kiessel Affidavit, Page 7).

I 314. Atlantic Cbunty witness Dr. Inchak asserted that if a large missile occurs in the "in-line"68 turbine orientaticn, very little can be done practically to alleviate the possibility of damage.

Dr. Luchak estimated, based on his review of the Bush report and a 6 h Board interprets "in line" to mean the turbine orientation depicted in Applicant's Exhibits OPS-LOO and 101, which are taken frun the Bash report and the Swan-Meleis paper, respectively.

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paper by Swan and Meleis,69 that the probability of missile damage to the contairinent, given missile generaticm, is 0.25. (Inchak's Testi-many, Page 4, and Page 5 as altered at Tr. 4332). Dr. Inchak's estimate and conclusicn regardirg missile strike ard damage did not ,

take into account the correct oriantation of the MP turbine vis-a-vis the contairrnent. Rather, Dr. Luchak's evaluaticn was based on a tangential turbine orientation, which is quite different fran the MPs offset turbine orientaticn as shown in Applicant's Exhibit OPS-103,

, Sheet 1. (Tr. 4816.) In addition, Dr. Inchak's admitted that in reachirg his conclusions, he did not consider the MP shielding and other protection systens (Tr. 4820-4824). The Board rejects Dr.

Luchak's conclusions regarding the probability of turbine missile damage because his evaluation was not based cn the WP turbine orientaticn and other design features of the MP.

I 315. The 130ard finds that the probability of generating a destructive overspeal turbine missile that strikes an essential safety systans is sufficiently small to meet the Staff criteria, and that the MP design with respect to this matter is adequate to protect the public health and safety.

I I 69"A Method of Calculatirv3 Turbine Missile Strike and Damage Probabil-ities," by S. W. Swan and M. Meleis, Nuclear Safety, 1975.

(Luchak's Testimony, Page 4).

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Turbine orientation 316. The Staff requires all plants to be adequately prr-tected against the effects of missiles that might result fran equip-ment failures, in accordance with General Design Criterion 4 of Appendix A to 10 CFR Part 50 (Staff's Testirtony, Page 41) . Regulatory Guide 1.115 discusses low trajectory turbine missiles. The regulatory positicn set forth in this guide permits ali.ernate means for providing protection against low trajectory turbine missiles. Turbine crienta-tion, or evaluation of turbine r.dssile strike probabilities for I essential safety systems to dancnstrate that they are sufficiently l

low, are each acceptable means for providing protection against low trajectory turbine missiles. (Applicant's Testimony, Page 18, and Staff's Testimony, Page 42).The Staff does not have any specific requirenents cn turbine-generator orientation with respect to the mntainnent (Staff's Testimony, page 41) .

I 317. Recent Commission action has included licensing of land-based plants with non-radial turbine arrangenents for which the owners subnitted missile probability analyses. 0 (Applicant's Testi-riony, Page 19). The Board therefore concludes that the ENP design considerations for potential turbine missiles are in consonance with both current Staff criteria and recent licensing actions. Acmrdingly, there is no basis for Mr. Effenberger's statements that the FNP O

See, for example, Docket Nos. 50-454,455,456,546 and 547.

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I l I turbine orientation is unacceptable relative to Staff criteria or that the Ccrmission made a special excepticn for the FNP design. Further, the Doard finds incorrect Mr. Effenberger's asserticn (Tr. 4110) that RIP size and turbine orientation were dictated by the graving dock, crane and slipway dimensions at the Applicant's manufacturing I facility. Rather, the size of the plant dictated the crane size, the slipway, and the graving (bck. (Tr. 5103-5104).

Applicability of the Bush Report Data I 318. To scme extent, both the Applicant's and Staff's turbine missile analysis utilize the data in the Bush report to estimate the probability of turbine missile generation (PDR Section 3.5.4.3, Applicant's Testinony, Page 17, Staff's Testimony, Page 36, and Tr.

5707, 5708, 5712, and 5827) . Atlantic (bunty witness, Dr. Inchak, raised. several questions concernirg the Bush data which are discussed below:

I Turbine Aging Effect I

319. Dr. Luchak alledged that the Bush report incorrectly asstrnes fai'.ures occur randcmly, claiming that the failure rate would increase with time (with the age of the turbine). Dr. Inchak alleged  ;

1 that, since the Bush data is based solely cn turbines 20 years old, or I

I ~-

I I less that the turbine failure rate over the 40 year design life of the ENP cannot be estimated from such data. (Luchak's Testintny, Page 2) .

I 320. The Applicant testified that in Table 3 of the Bush.

report the average service life of the plants listed was slightly over 18 years and about 43,000 of the total of approximately 70,000 turbine years listed correspond to turbines 20 years old or older (Tr. 4716, 5164 and 5165). On cross examinaticn, Dr. Luchak agreed that approximately 60 percent of the total 7trnber of turbine years in Table 3 of the Bush report were data on turbines 20 years old or older (Tr.

4725).

321. Dr. Luchak also claimed that a data point relevant to the variation of the failure rate over time was onitted fran a table ani graph in the Bush report (Tr. 5038 to 5040) . However, the Board finds that the data point described by Dr. Inchak as " missing" was, in fact, appropiately included (Applicant's Testimony, 5171 - 5176).

322. Dr. Luchak admitted he had no direct evidence of a statistical nature or no facts related to actual turbine experience to support his contenticn that the turbine failure rate increases with time (Tr. 4760 and 4761) . In response to a hypothetical question, Dr.

Luchak testified that if the turbine failure rate is higher in the early years than in later years, then the Bush analysis is conserva-tive (Tr. 4762 to 4763) . The Applicant's witnesses then supported the

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I I hypothetical by testifying that the turbine failures noted in the Bush report occurred early in the life of the turbines (Tr. 5163 through 5166).

323. The Staff's witnesses testified that it was not neces-sary to adjust the Bush data for " turbine agire effects" because the Bush report included turbines of various ages and therefore, intrin-sically included any such effect (Tr. 5700).

I 324. The Ibard therefore finds Dr. Luchak's criticism of the Bush report with respect to " turbine agirg effect" to be invalid.

I Turbine Size Effect I

325. Dr. Luchak alleged in his written testimony that the Bush data is predoninantly representative of small turbines less than 100 megawatts, thereby making its direct application to the much larger ENP turbine questionable, since according Dr. Inchak, larger turbines would have increased stresses, decreased safety factors and increased chance of mrrosion failures.

I I be Applicant testified that of the turbine failures reported by Bush, one turbine failed at 5 years, 11 months, one failed at 4 years, 4 ntnths, and the renainder, with the exception of cne failure for which the Applicant was not able to obtain this in-I formation, failed at 2 years or less (Tr. 5163 through 5165).

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I I 326. Dr. Inchak, cn croas examination, admitted that he is rot an expert with respect to scalirg of turbine size and the rela-tionship between scaling and resultant stresses (Tr. 4520) . In contra-diction to his written testimony, Dr. Luchak on cross examination admitted that stresses may not increase as the piysical size of a tur-bine increases (Tr. 4522), and in further contradiction stated that for purposes of his teethnmy he did not assume that stresses increase ard safety factors decrease with increasirg turbine size (Tr. 5009).

Accordingly, Dr. Luchak's assertion that the Bush data are not appli-cable to the ENP turbine, because such data are based primarily on turbines of less than 100 FM, is not supported by the cecord and is rejected by the Board. The Board previously has found several aspects of ENP turbine design (see Paragraphs 283, 286, 294, 305 and 310, supra) which make application of the Bush data to the ENP turbine conservative.

I Alleged Bush Report Data Omissions I

327. Dr. Luchak originally calculated that the lack of any failures frun 1%1 to 1%9 (as reported by Bush) had odds against it of 20 to 1 (Luchak's Testinony, page 2). The method used by Dr. Luchak in this calculation was incorrect (Tr. 5170) . Subsequently, Dr. Inchak performed other calculations, usirg a revised method, and revised his previously calculated odds to 15 to 1 (Tr. 5035-5036, 5170). 2 Dr.

Luchak claimed that those high odds support the hypothesis that not I 2 Dr. Luchak's calculation of the 15 to 1 odds is contained in Exhibit ACCCE-5B and SC, admitted at Tr. 5087.

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I all data were reported by Bush. Ibwever, Dr. Luchak's revised cal-culation, which gave the odds of 15 to 1, improperly utilized ten turbine failures rather than seven missile producing failures.

Applicant witness, Dr. Shaffer, stated that if Dr. Luchak's revised test had been properly performed utilizirg the seven missile producing failures, the resulting cx3ds would be about 3.5 to 1 (Tr. 5168-5171) .

Dr. Shaffer also performed an independent calculation and concluded that the correct odds were approximately 3 to 1 (Tr. 5168) . Dr. Inchak agreed (Tr. 4751-4752) that odds of 3 to 1 do not support his hypo-thesis that data were anitted by Bush (Tr. 5168-5171; Dchibits ACOCE 5B and SC).

I 328. Dr. luchak also implied in his direct testimony that the Bush data did not include test pit turbine failures (Luchak's Testi-mcny, Page 3). Ibwever, on cross examination, Dr. Luchak admitted that factory test failures were 4tolded in the Bush data (Tr. 4801-4807).

I 329. Furth s, _ .a of his testinony concerning test pit failures, Dr. Luchak stated his understanding (although he was not sure) that the ENP turbine would not be factory tested. (Tr. 4537a and 4538) . The Applicant, however, testified tJAt the factory testing to be performed by Westinghouse cn the ENP will be the satae as that which is performed cn any land-based turbine (Tr. 5198) .

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I I Hinkley Point Failure and Inchak's Missile Generation Probability 330. Dr. Inchak stated that the nuclear plant turbine at Hinkley Point produced a missile. Assunirg the Bush estimate of 10-4/ year for the probability of turbine missile generation, and I considering the nuclear plant turbine subclass, Dr. Luchak calculated the odds against occurrence of the Hinkley Point failure as 20 to 1.

Dr. Luchak infered that because of these high odds, the actual probability of missile generation is higher for nuclear turbines than

, the Bush estimate of 10 / year. (Luchak's Testinony, Page 3) .

331. The Hinkley Point failure was considered by Dr. Bush but was excluded frcm the data used in his original estimate of turbine missile probability (Tr. 5179) . r 332. In a subsequent study 73.1 Dr. Bush recalculated the probability of turbine missile failure, this time incitxling the Hinkley Point failure. The results of the later study compare I 3 Dr. Inchak's pre-filed testimcny stated that at least two nuclear I plants experienced turbine failures which produced missiles, Hinkley Point and Shippingport (Luchak's Testimcny, Page 3) . Dr. Inchak subsequently indicated he really did not know if Shippingport I produced a missile (Tr. 4331, 4332, and 4527) . The Applicant's Testirrny, at Page 10, indicates no external missiles were generated by the Shippingport incident. Dr. Inchak revised his testimony cn the assumpticn that Shippingport did not produce a missile (Tr. 4543 I and 4544). Due to an oversight, the odds of 40 to 1 cn the 7th line of page 3 of Dr. Luchak's pre-filed testimony were left unchanged.

However, it is clear to the Board that, in light of the other I charges given by Dr. Luchak at Tr. 4543 and 4544, the 40 to 1 odds must change in a like manner, to 20 to 1.

3.l Nuclear Safety, voltrne 19, Number 6, November - Decenber,1978.

I --

I .

I i favorably with the original work and cb not affect Applicant's prior testimony as to turbine missile probability for the RIP (Tr. 7603) .

I 333. Dr. Luchak calculated, as an alternative favored by him over the Bush probability, a probability of turbine missile generation of 2 X 10 3/ year as a " base" valm. He then applied a factor of 2 for decreasing reliability with age, a factor of 2 for decreasing reli-ability with scale, and a factor of 2 for a two unit ENP installation, giving a resulting probability of 1.6 X 10 /-2year for a two unit RIP site (Luchak's Testimony, Page 3; Tr. 4386, 4543 - 4544) .

I 334. With respect to such applied factors, the invalidity of decreasirs realiability with age is addressed in Paragraphs 319 through 324, supra. The absence of support in the record for de-creasirg reliability with size is addressed in Paragrarbs 326 and 327, supra..In addition, Dr. Inchak's application of the " size factor" of 2 to his " base" probability value of 2 X 10 -3

/ year is not proper because the value of 2 X 10-3/ year is already based cn the subclass of nuclear plant turbines, over half of which are 400 megawatts or larger. (Tr.

5166 - 5167).

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I 335. -3 Dr. Luchak's " base" value of 2 X IO / year was obtained by dividity the one nuclear plant turbine missile producing failure (Hinkley Point) by an estimate of 500 nuclear plant turbine years (Tr.

4555). It is not proper to single out the Hinkley Point failure to predict the probability of ENP turbine failure because current turbines, including the FNP turbine, utilize improved design, materials and periodic inspection to prevent such a failure (Tr. 5179

- 5181; Applicant's Additional Testimony, Pages 2 and 3) .

I 336. The Board therefore finds that Dr. n2chak's estimate of the procability of turbine missile generaticn for the ENP turbine is not correct. The Board further finds that the data in the Bush report were properly utilized by the Applicant and Staff in estimatiry the probability of turbine missile generaticn for the RTP.

. Ccmclusions I 337. In sumnary, the Board concludes that the RTP design features with respect to potential turbine missiles are adequate to protect the public health and safety, and the allegations raised by Mr. Effenberger and Dr. Luchak are without merit.

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I I L. CENTENTIGI XII - EFFECT CN BIOFA ACCCE Contention 3a:

I "Subpart 3a contends that the Applicant has not given adequate consideration to adverse effects on the aquatic biota fran the thermal plume, fran radioactive liquid dis-

• charges, and fran entrairnent."74 338. On this contention, both Applicant and staff presented oral testimony. No written testinony was presented. None of the intervenors presented witnesses, testimony or other infonnation. A-hearing sessicn with regard to this contention was held on April 4, 1979, and the testimony appears at Trans ript pages 7269-7277 and 7370-7374.74*1 I

339. The Environmental Report (ER) and the Final Environ-mental Statenent (EES) extensively discuss and give consideration to I

I 74 I Admitted as interpreted by Board Order dated May 21, 1974, p. 5.

74.l Applicant witnesses (Drs. D.H. halker, J.A. Nutant, T. Philbin, G.

Lauer and J. niinger) were examined by the Board (Professional I Qualifications admitted at Tr. 1024, 609, 7266, 7023 and 6986, respcetively) . Staff witnesses (Drs. R. McLean, R. Codell, K.

Eckerman and H. Berkson and Messrs. C. Haupt, H. Batraan, G. L.

I Chipman and A.R. Marchese) were examined by the Board (Professional Qualifications admitted at 7034, 7365, 7365, 7365, 7011, 7016, 7415 and 7415, respectively).

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I I adverse effects on the aquatic biota fran the thennal plume, fran radioactive liquid discharges, and fran entrairrnent and impinganent.

Inpact en Marine Biota Due to Thennal Effects I 339.1 The potential impact of the thernal pltrne on marine biota was considered by the Applicant in Section 5.2.4 of the ER, Section F of Supplanent I to the ER, and by the Staff in Secticns 6.2, 6.3, and 6.6 of the FES, Part II.

I 339.2 Ibtential thermal stress on marine biota can result in mortality or other physiological changes as well as behavioral changes. The extent of nortality is expected to be quite low because the areas of sufficient tanperature rise (greater than 6 F) are small and nest organisms either will not be able to stay in the higher tanperature areas because of high water velocities or will avoid these areas. (FES, Part II, Sections 6.2 and 6.3.) Analysis shows that a 5 F isothenn fran the discharge of 2 FNPs will cover an ocean surface area of less than 5 acres. (ER, Section 2.1.3). Behavioral or physio-logical charges will be mnfined to the region of the thermal pltrue where the tanperature rise is nere than 2 F. These changes are not generally expected to adversely affect ccmnunity structure or dynades (FES, Part II, Sections 6.2 and 6.3).

I be Applicant subnitted " Identification of the Evidence of the I Applicant (#9)" on March 23, 1979. The NRC Staff subnitted its identification of evidence in a letter to the Board on March 23, 1979. These subnittals identify the specific sections of the ER and the FES where these topics are considered.

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I I 339.3 The impact cn marine biota of the thermal plune will be restricted to a relatively small area near the discharge. The impact would be reduced with increasing distance fran the discharge. No adverse thermal effects are foreseen for potentially sensitive bio-logical cx2nnunities alcog the shoreline. (ER, Section 5.2.4 and Section F; FES Part II, Section 6.6).

I 339.4 The effects of a sudden decrease in thermal plume tonperature, i.e., cold shock, wre also considerM by the Applicant in the ER, Supplement 1, Section F and by the Staff in Section 6.7 of FES Part II. The potential for impact on marine biota due to cold shock is small and, therefore, does not warrant concern (FES Part II, Section 6.7).

I Impact on Marine Biota of Radioactive Liquid Discharges I

339.5 This contention is limited to releases of radioactivity associated with nonnal operation of the FNP (TR. 7276).

I 339.6 The radiological impact on aquatic biota during operation of the FNP was a3nsidered by the Applicant in Section 5.4 of the ER and by the Staff in Section 6.9.1 of the FES, Part II.

339.7 No biota have been discovered that show a sensitivity to radiation exposure as icw as those anticipated in the area sur- l rounding the FNP during normal operation. (ER Section 5.4, EES-II Section 6.9.1).

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B I Inpact cn Marine Biota of Entrairinent and Inpingement I 339.8 The effects of impingmient and entrainment were con-sidered by the Applicant in Sections 5.2.2 and 5.2.3 of the Environ--

mental Report and by the Staff in Section 6.3 and 6.4 of the FES, Part II. The entrairment and impinganent of aquatic organisns on the ENP will not unacceptably diminish productivity of coastal zone waters but may deplete the populations of various marine biota in the proximity of the plant site. This potential adverse impact has been found to be acceptable (FES, Part II, Sections 6.3 and 6.4).

339.9 The ability of fish to escape impingenent cnce they are exposed to intake currents varies in part with the swinning ability and endurance of the particular species. The ENP design intake approach velocity will be less than 1 foot per second. This is lower than the swinming speed of nest fish, allowing them to avoid the intakes. In addition, the traveling screens are located close to the intake openings (recessed less than 2 feet) to minimize space avail-able for fish to congregate. The fish also have an escape route under the hull of the ENP as well as lateral escape routes. (ER, Sections 5.2.2 and 5.2.3). (FES, Part II, Sections 6.3 and 6.4).

I 340. The Applicant and the Staff testified that adequate consideraticn was given to the matters raised by this contention. (Tr.

7269-7277 and 7370-7374).

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I I 341. The Ibard finds that adequate consideration has been given to adverse effects on the aquatic biota frm the thermal pitme, frm radioactive liquid discharges, and frm entrairrnent.

M. CDtTTENTICN XIII - DISTART OUTFALL ACXXE Contention 3b:

"Subpart 3b asserts that the Applicant has not given adequate consideration to the functional design of the discharge outfall." 6 I

342. On this contention, both Applicant M Staff presented written arxl oral testimony.77 None of the intervenors presented testimony or other infonnation. Hearing sessions with regard to this contenticn were held on July 12, 1978 and the testirrmy appears at Transcript A es 6984-7008 and 7015-7021. 8 I

I Mnitted as interpreted by Board Order dated May 21, 1974, p. 5.

The Applicant's written testinony, Exhibit No. OPS-47, entitled

" Applicant's Testimony Regarding XIII. Ebnctional Design of Dis-charge Outfall" was admitted at Tr. 6988 (7/12/78). The witnesses I sponsoring this testimony were Dr. John Nutant, Mr. P. Blair Haga and Dr. John Edinger (Professional Qualifications admitted at Tr.

609, 1024 and 6986 respectively). The Staff's written testimony entitled "Supplanental Testinony of Staff in Response to ACTE I Contenticn 3b" by Ibsard F. Bauman was admitted at Tr. 7018.

(Professional Qualifications of Mr. Batman were admitted at Tr.

7016).

78 Applicant witnesses were examined by counsel for the State of New Jersey, the Staff and the Board. The Staff witness was examined by I .

the Board.

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I I 343. The function of the discharge outfall is to disperse the heat of the condenser cooling water. The discharge outfall must be designed for each specific site by the owner, taking into considera-tion the envirorrnental aspects of that site (Applicant's Testimony, Page 1).

344. A generic evaluation of discharge outfalls and their characteristics was performed by the Applicant and by the Staff.

Estimates of expected dilution for different types of sutrnerged and surface single port discharges ard multiport discharges were cal-culated. ( Applicant's Testimony, Page 2) .

I 345. The tauperature rise fran the thermal pitzne at the shoreline for an FNP sited offshore is expected to be less than 1.5 F (Applicant's Testinony, Page 3). The natural diurnal water tenperature change along the coastal regions of the Atlantic and Gulf coasts 0

I ranges fran less than 2 F to 9 F (Applicant's Testinony, page 3) .

346. Since the cooling systen for a shoreline-sited FNP is indistinguirhable fran the systan for a land-based plant at the sane site, there do rot appear to be a7y aspects of shoreline FNP discharge design that would be unique to NP's or different fran the state-of-the-art (Staff's Testimony, Page 3).

I 347. FES II considered the effects of tidal, wind-driven and littoral currents. The effect of: tidal currents is significant only as to the potential for recirculation. Analyses indicate that for nest I

I I

tidal currents there will be ro significant recirculation. In addi-tion, net drift due to wirx' driven or littoral currents would reduce the potential for recirculation. Further, recirculation can be minimized by utilizing a subnerged discharge rather than a surface.

discharge. ( Applicant's Testimony, Page 2) .

I 348. The. analyses in the IR II, Supplanent No. 2 and the EES II indicate that tanperaturc variations that might be caused by an FNP discharge offshore are expected to be lost within the natural diurnal tunperature fluctuations of the coastal regions (Applicant'n Testi-I nony, Page 4) .

I 349. The detailed outfall design will be perfonned by the owner of an ENP (Applicant's Testimony, Page 1). The Board agrees with the finding of the Staff that any of several discharge outfall designs could be used for an offshore-sited ENP (Staff's Testinony, Page 2) .

The Board also agrees with the ;udgment of the Staff that, within present technology, an ENP owner would be able to select an adequate cooling water cxxxlenser discharge design for a shoreline-sited FNP (Staff's Testinony, Page 3) .

350. The Board finds that adequate consideration has been given to the functional design of the discharge outfall.

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I N. CINTETfI(N XIV - ECOD CHAIN ACCCE Contention 3c:

"Subpart 3c asserts that the 7pplicant has not given I adequate consideration to the cumulative effects of radio-active substances ingeste -

plankton through htrians."g (sic) along the food chain fran I -

351. On this contention, both the Applicant and the Staff presented oral testinony. Written testimony was presented by the Staff.79'1 None of the intervenors presented witnesses, testimtny or other informaticn. Hearirg sessions with regard to this content. ion were held on April 4,1979 and Novenber 2,1979; the testimony appears

.2 I at Transcript pages 7275-7573 (generally) and 7414-7472.

I Admitted as interpreted by Board Order dated May 21, 1974, pp. 5, 6.

• • Staff testimony was prepared in response to the Ibard's letter of March 29, 1979 as further described in Secticn IV.V, infra. Staff I testimony entitled "NRC Staff's Response to Questions Posed by the Licensity Board in its March 29, 1979 Letter" dated July 13, 1979 and " Supplement to the NRC Staff Response to Question 4 Posed by the Licensing Board in its March 29, 1979 Letter" dated October I 30, 1979 were admitted by stipulation at Tr. 7416.

.2 Applicant witnesses (Drs. D.H. Walker, J.A. Nutant, T. Philbin, G.

I Lauer and J. Riinger) were exanined by the Board (Professional qualifications admitted at Tr. 1024, 609, 7266, 7023 and 6986, respectively). Staff witnesses (Drs. R. McLean, R. (bdell, K.

I Eckerman and H. Berkstn arri Messrs. C. Haupt, H. Bauman, G.L.

Chipnan and A.R. Marchese) were examined by the Board (Profes-sional Qualifications admitted at 7034, 7365, 7365, 7365, 7011, 7016, 7415 and 7415, respectively).

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I 352. Tne Environmental Report (ER), the OPS Topical Report No. 22A60 (Exhibit OPS-65)80 aM the Final Envircrrnental Statenent I

(FES) give consideration to the cunulative effects of radioactive l 1

substances ingested along the food chain frcrn plankton through

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Plant Normal Operation 352.1 The Applicant's Envirorinental Report, Section 5, page 5-52, considered the cunulative effects of radioactive substances ingested alorg the food chain to humans. On the basis of annual average daily ingestion of fish and invertebrates which are in equilibriun with radionuclides in the plant discharge mixirg zone, the dose to the maximally exposed individual was an organ dose of 0.15 mran per year to the thyroid gland. The whole body ard gastrointes-tinal tract receive smaller doses. All of these doses are a snall fraction of the dose fran natural background radiation (approximately 100 mran/ year) and well below applicable regulations of 10 CFR Part

20. These conclusions are substantiated by the Staff's data presented in Section 6.9.2.2 of the Ims, Part II, which discuss doses via ingesticn of either fish or invertebrates. Whole body and organ doses were calculated by the Staff to be less than 0.01 mran per year.

I 80 Exhibit OPS-65 was admitted into evidence at Tr. 7266.

The Applicant subnitted "Identificaticn of the Evidence of the Applicant (#9)" cn thrch 23, 2979. The NRC Staff subnitted its I i lentification of evidence in a letter to the Doard on March 23, l>79. The subnittals identify the specific sections of the D1, the OPS Topical Report arrl the FES where these topics are considered.

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I Accidents 352.2 Calculated doses due to postulated releases of radio-activity for accidents within the design basis were reported by the Applicant in Supplanent No. 5 to the ER, Part II and by the Staff in-NUREG-0440, "NRC Staff Liquid Pathway Generic Sttxly", Section 2.4. The spectrum of accidents defined in NRC Regulatory Guide 4.2 was inves-tigatal. It was concludal that risks fram accidental releases to the liquid pathway fran design basis accidents are small enough to be insignificant (FES III, Section 3.3.1.2).

I 352.3 The Applicant in Exhibit OPS-65 " Liquid Pathway Generic Sttriy", OPS Topical Report 22A60, and the Staff in its Exhibit 4

" Liquid Pathway Generic Study", NUREG-0440, and in FES III gave consideration to the cumulative effects of radioactivity released to liquid pathways and ingested along the food chain fran plankton through htsnans for accidents beyorri the design basis.

I 352.4 The Staff concluded that the addition of a refractory core ladle (see paragraphs 61.1 through 61.6, supra) could result in achieving a level of core-melt risk clearly otrapatible with that associated with the current generation of land based plants (EP) (FES III, p. 4-12).

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5 l 352.5 The Staff testified that WASH-1400 81*1 data was utilized in their attenpt to quantify many of the risk factors associated with core melt accidents in the ocmparative FNP/LBP study.

However, use of the data fran NASH-1400 was not key in the decision making process but rather supported and confirmed the qualitative" conclusions reached by the Staff. (Staff's Testimony, July 13, 1979,

p. 5). The Applicant used the methodology of NASH-1400 for cx2nparative analysis (Tr. 7278).

t 352.6 The Applicant and Staff testified that the cost / benefit conclusicn in the FES III was reasonable ard favorable in spite of the conservative assumptions which were anployed in the analysis (Tr. 7280 and Staff's Testinony, July 13, 1979, p. 6). Applicant testified that the cast / benefit balance would have been even nure favorable if realistic assumptions had been anployed in the analysis (Tr. 7280) .

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352.7 With respect to consideration of interactions with sediments in offshore cases, there are two considerations: interaction of sediments with the water colunn and particle transport. Calcula-tions by the Applicant to assess the impact of sediment scavenging showed that maximun individual dose is greatest when no scavenging into the sediment takes place (OPS Topical Report 22A60, Appendix C) .

The population dose would be unaffected since the isotopes would be resuspended over a period of time (Tr. 7292) . For particle transport 0 1 Paragraphs 352.5 through 352.10 address testimony provided in response to the Board letter of March 29, 1979 (see Paragraph 439, infra). 1 I

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h the Staff concluded that the doses to man would not increase sig-nificantly fr m swinming, beach usage and fish ingestion (Staff Testimmy, October 30, 1979, Page 10).

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352.8 With respect to rmoval of radioactive iodine fran the sunp water by the waste treatment systan, the danineralizers will reduce the iodine activity by a factor of at least 100; operation of the evaporators would reduce the activity even further. (NUREU-0440, pp. 2-13; Tr. 7284). With respect to speciation of released iodine, the species aM their fractional distributions were obtained fran Regulatory Guide 1.4 (Tr. 7285) .

352.9 Applicant testified that iodine is not a major mntrib-utor to the liquid pathways dose analysis for an accident beyoM the design basis (Tr. 7285). The Applicant and Staff agree that iodine contributes less than 1 percent to the dose catmitment for the fish consumption pathway (OPS Topica1 Report 22A60, p. 6-51 and Staff's Testimmy, July 13, 1979, p. 13).

I 352.10 The Applicant testified that bioaccumulation factors such as those used in NURD3-0440 wi 1 be affectal by chenical speci-ation and that isotopes leached fran cnre melt will likely take the canu speciation as natural elanents. (Tr. 7287, 7288).

I 353. The Applicant and the Staff testified that adequate consideraticn was gives to the matters raised by this contentim. (Tr.

l 7274 and 7370).

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I I 354. The Doard finds that adequate consideration has been l

l given to the ctinulative effects of radioactive substances irx3ested along the food chain fran plankton through humans.

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O. CrtEENTIN XV - DREDGING ACC Contention 3f:

I "Subpart 3f asserts that the Applicant has not given adequate consideraticn to the impact on the aquatic biota that will be caused by dredging within the breakwater and near its perim-eter."82 355. On this contention, both Applicant and Staff presented written and oral testinony.83 None of the intervenors presented witnesses, testimony or other information. Hearing sessions with regard to this contention were held on July 12, 1978 and the testinony appears at Transcript pages 7021-7032 and 7033-7041.

Admitted as interpreted by Board Order dated May 21, 1974, p. 6.

83 The Applicant's written testinony, Exhibit No. OPS-48, entitled

" Applicant's Testimmy Regarding XV. Dredging" was adntitted at Tr.

7025 (7/12/78). The witnesses sponsoring this testimony were Dr.

John Nutant, Mr. P. Blair IIaga, and Dr. Gerald J. Lauer (Profession-I al Qualifications admitted at Tr. 609, 1024 and 7023 respectively) .

The Staff's written testimmy entitled "Stf.plemental Testimony of I NRC Staff in Response to ACCG Contention Jf" by Dr. Richard B.

McLean and Dr. S. Marshall Adams was admitted at Tr. 7037. (Profes-siomi Qualifications of Dr. McLean and Dr. Marshall were adntitted at Tr. 7034 and 7035 respectively.)

I Applicant witnesses were exantined by the Staff ard the Doard. The Staff witnesses were examined by the Board.

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I 356. Consideration of the impact on the aquatic biota that will be caused by dredging within the breakwater and near its per-imeter has been given in both the ER II, Section 4.3.1 (Pages 4-7 to 4-11), and Section 5.7 (Page 5-81) ard in FES II, Section 5.4.1.3 I (Pages 5-9 to 5-12), Section 6.11.2.2 (Page 6-81) and Section 11.3-(Pages 11-4 and 11-5).

357. This contention concerns maintenance dredging since the contention assumes existence of the breakwater (Staff's Testinony, Page 1). Dredging within the breakwater would be undertaken only if significant sedimentation occurs. The daninant parameters that will affect the amount of sediment deposited within the breakwater include the location of the FNP, the anount and type of suspended solids, entrances to the basin and the height of the entrance sills, the volumetric flow of cooling water, and the circulation pattern within and inmediately outside the basin. (Applicant's Testimony, Page 2) .

358. Dredging within the breakwater may cause destructicn of all benthic organisms involved. A total loss of all benthic organisms was asstaned and is listed as an envircrrnental cost in the FES II, Table 5.8.1 (Page 5-24) and in the cost-benefit evaluation in Section 11.3 (Pages 11-4 and 11-5) . Such loss is considered not to be a sig-nificant environmental impact because of the relatively snall area affected. (Applicant's Testimcny, Page 2).

I 359. Should dredging near the outer perimeter of the break-water be required, the area of impact is expected to be less than or

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I of the same order as the site area of approximately 100 acres. The Ices of benthic organisms due to such dredging also is considered p>t to be a significant envirorrnental impact because of the relatively small area affected. (Applicant's Testimony, Page 2) .

360. Maintenance dredging is feasible for any breakwater design (Tr. 7031). The impact en aquatic biota fran maintenance dredging is not expected to M significant because of the relatively snall area affected (Applicant's Testimony, Page 2) .

I 361. The Board finds that adequate consideration has been given to the . impact on the aquatic biota that will be caused by maintenance dredging within the breakwater and near its perimeter.

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I P. CINTENTIOT XVI - IMPACF 01 RESORP HI110MICS Atlantic County Cwtention 1:

"This contention asserts that fears of a nuclear accident can have impact on resort econonics by frightenirg vacation I

and leisure seekers frcm going to resort areas in proximity to floatire nuclear generating stations. This contention -

does not mntest whether these fears might be technically I justified but is limited to the effects of these fears, justified or not, on the resort ocmnunities."O 362. On this contention both Applicant and Staff presented written ard oral testimony.86 Intervenor Atlantic County presented Admitted as interpreted by Board Order dated April 15, 1974,p.8.

86 The Applicant's written testinmy, Exhibit No. OPS-44, entitled I " Applicant's Testinony Regarding XVI. Irtpact on Resort Econanics,"

was admitted at Tr. 6242. The witnesses sponsorirg this testinony were Dr. John A. Nutant and Messrs. P. Blair Haga, K. T. Mao and Dr.

Dennis S. Mileti (Professional Qualifications admitted at Tr. 609, I 1024, 6230 and 6232, respectively). The Staff's written testimony entitled " Supplemental Testimony of NRC Staff in Response to Atlantic County (bntention #1 (concerning irapacts on tourism)" by Inuis M. Bykoski, Donald P. Cleary, Earl J. Baker and Steven G.

West; and " Impact of Offshore Nuclear Generating Stations on Recreational Behavior at Adjacent Coastal Sites" by E. J. Baker, D.

J. .tss , S. G. West and J. K. Weyant which follows Tr. 6715, was I admitted at Tr. 6715. The Staff's testimony was sponsored by Drs.

Baker, West and Bykoski and Mr. Cleary. (Professional Qualifica-tions of Dra. Baker, West ard Mr. Cleary were admitted at Tr. 6707.

I Professional Qualifications of Dr. Bykoski were admitted at Tr.

6710). The Staff subsequently filed updated testinony entitled "NRC Staff's Post-TMI Update of its Testimony Cbncerning Atlantic (bunty I Contention #1 (Concerning Impacts on Tourism)". This updated testimony was admitted by stipulation at Tr. 7537.

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I written and oral testimcny.O7 No other intervenor presented wit-nesses, testinmy or other informaticn. Hearing sessions with regard to this contention were held cn May 17,18, 19 and 20, 1977 and July 10 and 11, 1978. The testinony appears at Transcript pages 6226-6260, 6261-6374, 6375-6529, 6668-6691, 6692-6790 and 6791-6974, respective -

ly. The impact of the accident at Three Mile Island on previous testimony was considered in a hearing session on December 4, 1981 and that testimony appears at Tr. 7537-7553.88.1 I 363. Investigations were made by toth the Applicant and the Staff to determine the impact of the presence of nuclear reactors on the resort-oriented economy of coastal communities located near operatirg nuclear plants (Applicant's Testinony, Page 1 and Staff's Testimtny, Page 7).

I I O Written testinmy of Intervenor, Atlantic County, entitled "Testi-many en Behalf of Atlantic County Regarding Atlantic Cbunty's Contention #1" by Dr. Marshall E. Levine, was admitted at Tr. 6814.

I (Professional Qualifications of Dr. Levine were admitted at Tr.

6808).

OO Applicant witnesses were examined by counsel for Atlantic County Citizens Council cn Envirorment (ACCCE) and Atlantic County. Staff witnesses were examined by (bunsel for Atlantic County, the State of New Jersey and the Board. Intervenor witness was examined by counsel for the State of New Jersey, the Applicant and the Staff.

88.l Staff witnesses (Messrs. D. P. Cleary arxl C. P. Hickey, Jr.) were exanined by the Board and the Applicant (Professional Qualifications admitted at Tr. 6707 and 7537, respectively) .

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364. The Applicant investigated econcrtic characteristics of three resort-oriented cm munities near coastal ca mercial nuclear Imr plants in the United States. The Applicant also conducted on a qualitative basis investigations of several coastal resort co1munities in proximity to coastal nuclear Inwer plants. (Applicant's Testimony,-

Pages 1, 2 and 7).

365. The Staff undertcok an investigation to determine if any changes in usage of water-oriented recreational facilities could be attributed to the existence of a nearby operating nuclear power plant.

Ten nuclear plants havirg nearby water-oriented recreational facil-ities used by tourists were sel.ected for analysis. (Staff's Testimony Pages 8 arx19). Three of these 10 nuclear plants are the same as those investigated by the Applicant (Applicant's Testimony, Pages 1, 7 and 8 and Staff's Testimony, Pages 9 and 10) .

I 366. A study under Comtission contract using survey research methods was corxlucted by Professors Baker arri West of Florida State University to estimate the possible reaction of tourists and leisure-seekers to siting of an offshore nuclear generatity station near resort areas (Staff's Testinony, Page 2).

I 367. An investigaticn by the Applicant also was made to detennine the impact of the presence of nuclear weapons testing at the Nevada Test Site cx1 the resort econany of nearby Las Vegas, Nevada.

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I This latter investigaticn was performed cn the basis that the situa--

tion in Las Vegas is analogous to other resort otmnunities when considerirg whether the presence of nearby nuclear operations will adversely impact tourism. (Applicant's Testintny, Page 1) .

I .

368. In 1975-76, researchers frcm Oak Ridge National Labora-tory studied the socioeconanic effects of' operating reactors cn two ecmnunities: the town of Plymouth near Bostcn Edison Canpany's Pilgrim Nuclear Power Station and the town of Waterford near Northeast Utilities' Millstone Nuclear Power Station (Applicant's Testimcny, Page 2).

369. The Pilgrim Nuclear Power Staticn Unit 1 is' located in the Ccmnonwealth of Massachusetts, near the tcun of Plynouth. Unit 1 is a 670-megawatt net electrical output reactor. Unit 1 received its constructicn pennit in 1%7 and went into ccmnercial cperation in June 1972. At the time the testimony was presented, the proposed Unit 2, an 1180 We reactor, was undergoing licensing review for a construc-tion permit. Pilgrim 1 occupies a 517-acre site within the town of Plymouth, Massachusetts cn the shores of Cape Cod Bay about 35 miles I south of Boston. (Applicant's Testimony, Pages 2 and 3).

09"Socioecononic Effects of Operating Reactors cn Two Host Ctmnuni-ties: A Case Sttdy of Pilgrim and Millstone", Elizabeth Peelle, presented at Atonic Industrial Fortm Symposium, State-of-the-Art of I Socioeconanic Impacts Associated with Construction /Operatico of Energy Facilities, January 17-18, 1977 (hereinafter referred to as the Oak Ridge Sttdy) (Applicant's Testinony, Page 11) .

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I 370. The Pilgrim Nuclear generating station has been the subject of substantial controversy and publicity. The proposed Unit 2 caused further controversy and continued to draw public attention to the Pilgrim site. (Applicant's Testintriy, Page 4) .

371. In the summer months, a large influx of seasonal visitors reside in the Pilgrim area, attracted by its many tourist and recreational facilities. Pilgrim 1 has an overlook where people can view the plant ard also has a shore-front area adjacent to the plant where people picnic and fish. This area opened in April 1972, and is open fran April through November. The annual average attendance is approximately 75,000 with a peak day attendance of 3,000 visitors.

(Applicant's Testinony, Page 3) .

I 372. Pog11aticn growth is an indicator of growth in tourism I in a resort econouy (Tr. 6313, 6314, 6318 and 6319).

373. With respect to PlytTouth, the econonic growth trend as reported in the Oak Ridge sttdy showed that, after growing slowly and steadily during the 1950's and 1%0's, Plymouth suddenly underwent explosive growth beginnirg in 1968 when constructicn of the Pilgrim I station began. (Applicant's Testimcny, Page 3).

I 374. The Millstone Nuclear Power Staticn, Units 1 and 2, is located near Mterford, Oxinecticut. Unit 1 is a 652 and Unit 2 is an 828-megawatt net electrical output reactor. Unit 1 received its I

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constructicn 3,armit in May 1966 and went into ccmnercial operation in Decenber 1970. thit 2 received its construction gnnit in Decenber 1970 and went into ccmnerical operatien in October 1975. (Applicant's Testhnony, Page 3) .

375. As reported in the Oak Ridge study, Waterford's growth has been relatively gradual. It was noted in the study that this gradual growth was due primarily to restrictive zarting ordinances.

Ibsever, land values have experienced sharp increases. ( Applicant's Testimcny, Page 5).

I 376. There are two resort-oriented omraunities located in close proximity to the Millstone Nuclear Power Staticn. New Iondon has beaches and amusement parks. East Lyme, which averages over 250,000 tourists per year, has an unobstructed view of Millstone 1.

Three miles east of the plant is the Harkness Memorial State Park with 235 acres available for swinmirg, boatirg and fishirg. Five miles west is the Pocky Neck State Park with 560 acres available to the general public. Average annual attendance for the two parks is I between 500,000 to 600,000 visitors. ( Applicant's Testimony, Page 4) .

I 377. As reported in the Final Envirortnental Statenent for Millstone 1, the area around Millstone Point is a favored sport fish-iry site, and pleasure boating is another major form of recreation in i the area. (Applicant's Testimony, Pages 4 and 5).

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378. Also reported in the Oak Ridge study were the results of an attitude survey ocnducced in the sunmer of 1975 on the residents of Plymouth and Wterford. Those sampled expressed satisfaction with their conmunity in general. The conclusion reachal in the survey with respect to tourism w s that tourism is little affected by the presence-of the nuclear power plant in either comiunity. There is no evidence to suggest that the presence of nuclear power plants has had any adverse impact on the resort econany of calmunities near the Pilgrim and Millstone nuclear plants. In fact, the data show that nearby catmunities enjoyed sustained econanic growth.

(Applicant's Testimcny, Page 5) .

379. The Applicant also examined certain econonic data on catmunities near the Oyster Creek Nuclear Generating Station. Oyster I Creek is a 650-megawatt net electrical output reactor. A construction permit was issued in Decenber 1964. The plant first produced electric power in 1%9. Imnediately adjacent to the Oyster Creek plant is the site of Forked River Nuclear Power Staticn, Unit 1, a ll68-megawatt net electrical output reactor. A construction permit was issued for Forkal River 1 in July 1973 and the plant is under construction.

(Applicant's Testimony, Pages 5 arx16).

380. The site location of Oyster Creek in Ocean County, New Jersey is part of the New Jersey shore area. The area serves as a I

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i I l favorite sumer place for vacationers fran New Jersey and the sur-roundirg states. Saltwater fishing, boating, waterskiirg, and bathing are popular pastimes in the area. (Applicant's Testimony, Page 6).

I 381. Both the Oyster Creek and Forked River nuclear plants

• encountered considerable controversy. Extensive anti-nuclear matters have been frequently reported arri given proninent attention in the local and regional press. (Arplicant's Testimony, Page 6).

I 382. A review of the datographic data of New Jersey discloses that while mme areas have lost residents at a high rate, Ocean County leads all other New Jersey counties in population growth and posted the largest migration of people into the area between 1970 and 1975.

Large numbers of new housing ccmnunities, for sumner and permanent living, are continually being established in the (bunty. (Applicant's I Testimony, Pages 6 and 7) .

383. Based on information concerning the demographic charac-teristics of the connunities near the Oyster Creek plant, there is no evidence to suggest that the presence of this nuclear power plant has had any adverse impact en the resort econany of nearby comtunities.

In fact, the data show that Ocean County has experienced spectacular growth. (Applicant's Testinony, Page 7) .

= 384. The Applicant also conducted investi.,utions on a qualitative basis of other ccastal resort comtunities in proximity to l

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I several coastal nuclear power plants. The plants included: Florida Power and Light 02npany's tirkey Point Plant (Units 3 and 4, can-mercial operation 1972-73), Maine Yankee Atanic Power 02npany's Maine Yankee Plant (comiercial operation 1972) and Southern California Ediscn Canpany's San Orofre Plant (Unit 1, ccmnercial operaticn 1968) .-

In no case was there any indication that the econany, particularly the tourist economy, of nearby connunities was adversely affected.

(Applicant's Testinony, Pages 7 and 8).

I 385. In the sprirg of 1976 the Staff undertcok an investiga-tion to determine if any clanges in usage of water-oriented recrea-tional facilities could be attributed to the existence of a nearby operating nuclear power plant. Ten locations having water-oriented recreational facilities used by tourists were selected for analysis.

Between five and thirteen cpverrrnent (local, state and federal) officials and representatives of local business were interviewed at each location. These individuals were chosen because of their know-ledge of local tourian and recreational activities. The interview was structured to: develop infonnation cn recreaticn and tourism activity arri trerris in the vicinity of the plant; draw out information which might indicate impact, positive or negative, of the plant cn tourism arxl recreation; arri finally elicit the respondents' personal opinion concerning plant impacts. This study was updated with followup interviews during May/ June 1978. (Staff's Testimcny, Pages 8 and 9) .

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I 386. The ten nuclear power plant locations investigated try the Staff wre Brunswick (Units 1 and 2), Ccok (Units 1 and 2), Itahm Neck, Indian Point (Units 1, 2 and 3), Milne Yankee, Millstone (Units 1 and 2), St. Lucie, San Onofre, Three Mile Island (Units 1 and 2) and Zicm (Units 1 an! 2) (Staff's Testinmy, Pages 9 and 10) .

• I 386.1 The Staff analysis of the impact of tne accident at Three Mile Island shows that while there were niinor, short-term inqncts, there have been no lasting impacts on either the regional tourist trade or recreational fishing in the Susquehanna River. (Staff Updatal Testirony, passim) .

387. Nurwrous officials interviewed by the Staff at each of the tcn plant locations said that the nuclear plant (s) in their areas had no discernible impact cn tourism or recreatioral activity in their vicinity. In most cases there has been a continuing growth in surtner populations and tourism in these areas. Many officials interviewed by the Staff felt the nuclear plants' visitor's centers positively influenced their tourism industry. (bok and Ftiine Yankee, for in-I stance, are advertisal in local tourist pamphlets and officials credit tien with drawing nore visitors to the vicinity. (Staff's Teatimony, Pages 10-32).

I 387.1 The Staff did rot undertake post-TMI studies in the other nine plant regions previously surveyal (Staff Updated Testinony,

p. 6). Ilowever, the Staff concitxled that the avoidance reaction in the vicinity of Three Mile Island wuld be greater tinn the avoidance I

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I reacticn at nom distant locations. Thus, it is reasoned, the avoid-ance maction at Three Mile Island bounds the reaction at the other nine sites (Staff Updated Testintny, page 6 and Tr. 7542-7546) . The Staff also testified that there has been to evidence of a mI-related avoidanm reacticn at other plant locations incitr31rg, for example,-

St. Imcle (a Florida coastal locaticn) for 4tich a licensing review is in progress (Tr. 7551-7553). The Staff testified that mI does not alter the conclusions put forth in their original testimony (Staff Updated Testintny, p. 6; Tr. 7543-7544) .

388. The Staff contracted with the Florida State University for the services of Drs. Earl J. Baker and Stephen G. West, and a research team under their direction, to apply survey research tech-niques and theory, drawn frcm several areas of the behavioral sciences, to the question of potential tourist behavior in the vicinity of FNP's (Staff's Testintny, Page 33) .

389. Using the estimates of net tourist avoidance developed by the Baker & West study, the Staff conputed the impact cn the local econany. These conpitations were made with the assistance of the regional econonic and dmographic forecastirg capability of the U. S.

Departnent of 0:mmerce. Baseline econonic forecasts were first adjusted to account for the contributicn of plant operaticn to the local econcmy. This forecast was then adjusted to account for the loss in tourian activity. The net calculated impact cn total earnirgs I of each area fran siting an ENP at the mid-pcint along each beach was I

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8 found by the Staff to be less than cne percent. (Staff's Testinmy, Page 64).

I 390. Using what the Staff miders to be very conservative asstznptions, the potential ignet of an WP cn a local econcmy was-found to be very small and well within the year to year fluctuations in local emnonic activity as well as within the band of meacurenent error (Staff's Testinmy, Page 64) .

I 391. An investigation was by the Applicant made to determine the impact of the presence of nuclear weapons testirg at the Nevada Test Site cn the resort ecorany of nearby Las Vegas, Nevada (Appli-cant's Testbimy, Page 1) . The presence of nearby nuclear operations to a resort area make Las Vegas, Nevada analogous to a resort can-munity havity a nuclear plant nearby (Tr. 6256 and 6410) .

I 392. Since 1951, the federal cpverrinent has been conducting nuclear weapons tests at the Nevada Test Site about 65 miles northwest of Ias Vegas, Nevada. As of the date of the testimcny, a total of 473 announccd tests had been moducted arrl tests are continuirg. Prior to 1%3, 84 of these tests were surface detonaticns. The flash frcm sone of these surface detonations was visible in Las Vegas. Since 1963,-

all tests have been conducted underground. The shock waves fran the larger undergrourrl tests are felt in Las Vegas. ( Applicant's Testi-nmy, Page 8) .

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l 393. Since the inception of nuclear weapons testing in the late 1940's, considerable local and national controversy concerning I its hazardo ins been reported in the media. Between 1%6 and 1970, the late floward !!ughes raised serious oppositicn to conductirg nuclear weapons testing near Ias Vegas and expended considerable money to wage" a canpaign against the Nevada Test Site operations. (Applicant's Testimony, Page 9) .

394. Despite the presence of nuclear weapons testing near Ias Vegas, its resort econoy has flourished.90 ( Applicant's Testimony, Pages 9 and 10).

I 395. Dr. Marshall E. Ievine testified on behalf of Intervenor Atlantic County cn this Contenticn. Dr. Levine utilized a newspaper advertisment along with followup personal interviews and letters in an attcznpt to exanine the fears held by the citizens of Atlantic County concerning the proposed siting of an ENP off the a3ast of 9h number of visitors to Las Vegas increased fran about 6.8 million in 1970 to 9.8 millicn in 1976, at an annual average rate of about one-half million visitors. The number of persons cmployed in the resort industry increased fran about 12,000 in 1958 to about 44,000 I in 1974 an average annual growth rate of about 8.5 percent. The number of hotel roons in Ias Vegas increased fran about 4,800 in 1954 to about 18,000 in 1974, an average annual growth rate of about I 9 percent. The number of motel roany increased frcm about 3,700 in 1954 to about 14,000 in 1974, an average annual growth rate of about 5.8 percent. Gross gantity revenuer. (calculated in 1%7 dollars) increased fran about $69 million in 1954 to about $465 million in 1974, an average annual growth rate of about 10.8 percent. (Appl-icant's Testimony, Page 9) .

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I Brigantine, New Jersey. (Atlantic County's Testimony, Page 1). During cross examination of Dr. Irvine, the Applicant established that his sttrly had no external validity ani questionable internal validity.

(Tr. 6%7 and 6%9) .

3%. External validity refers to the extent to which findings can be generalized beyond the particular people studied to a broader group of people (i.e., extrapolated fran the sample to the total populatial) (Tr. 6967) . Dr. Irvine testified that his survey had ro external validity (Tr. 6057) . His sample was biased because it only reached members of the county who real the newspaper and because the people who responded to the newspaper advertisenent decided if they would be includo3 or excluded in Dr. Levine's sttx3y rather than him select.ing then (i.e., the sample was self-selected) . In addition, Dr.

Levine did not krru if one persal or one group sent in nore than one respanse. (Tr. 6858-6861) . Accordingly, the findings in Dr. Irvine's sttxty cannot be generalized beyorri the particular people who responded to the survey.

I 397. Internal validity refers to the extent that a particular survey provides answers to that which the researcher desires to measure concerning the sample surveyed. If a study lacks internal validity, there is to basis to conclude that what tFe study is trying to measure has in fact been measured, d no basis to know what has been measured at all. (Tr. 6869-6872 and 6%9-6972) . Dr. Levine's survey has questionable internal validity (Tr. 6%9) . Dr. Levine I

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l adntitted that he did rot establish internal validity for his study (Tr. 6871). Acmrtlingly the Board concludes that there is no way of knowing that what Dr. Mvine was trying to measure with respect to the sanple surveyal was in fact measured, arri there was ro way to krow what Dr. Irvine measured at all. -

I 398. Dr. Invine also testified that the assumptions drawn in his written testimony, that lorg time regular vacationers and pcople frcm Atlantic County and other cxrmunities who are considering rroving to or vacationiry in Atlantic County would go elsewhere, have no statistical validity and that he could rot make a statement that they are trte (Tr. 6922 arri Atlantic County's Testimcny, Page 6) . In addition, Dr. Irvine testified that the sample obtained frcm his survey has to statistical significance (Tr. 6832) .

399. The Board finds that the eccncray of resort-oriented calmunities near coastal opersting nuclear power plants has not been adversely affected by the presence of nuclear plants. The econany of these areas has hai sustainect growth and, in saae cases, has shown dramatic improvanent The Ibard further ands that the accident at Three Mile Island at most generatcd only transient effects on the econcmies of resort-oriented cxmmunities in the plant vicinity. The Board concludes that the accident at Three Mile Island will not adversely impact the econcny of resort-oriented cxmmunities which are nearby to an ENP.

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l 400. The Board finds the potential impact of siting an ENP on a resort econany which is characterized by the presence of tourists aM leisure seekers is very trnall and well within the year to year fluctuations in the local emnonic activity of the coastal resort area. -

I R. ENTENTICti XVIII - NET ENERGY YIELD, CDST-BENEFIT BAIL \NG I ACCC Contention II:

"The EES Part II cost-benefit analysis underestimates the total direct aM indirect cost of the ENP's and grasly overstates the benefits because of (1) the axelusior. that I ENP's will produce a net energy yield (positive), without regard to the energy impact if less than eight are con-structal aM sold or if the ENP's, due in part to the I unique stresses of the alien marine environment, fail to operate for their planned useful life, (2) the failure to consider cast of decomtissioning the breakwater as a po-tential cost, (3) the failure to conpute the cost impact if I the ENP's are required to use coolng towers at inshore sites, (4) the failure to consider the various direct and indirect costs resulting fran the foreclosure of alterna-I tive uses of coastline, aM because of (5) the fact that the costs were based upon 1972 costs whereas the benefits are 1988 benefits "

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I E 91 Adntitted as interpreted by Board Order dated August 1,1977, pp.4,5.

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I 401. On this contention, both Applicant and Staff presented writtm and oral testimcny.92 None of the intervenors presented witnesses, testimony or other information. Ilearing sessims with regard to this contention were held cn July 12 and 13, 1978 ard the

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testimony appears at Transcript pages 7067-7076 and 7103-7130.

I Net Energy Yield 402. The Applicant performed an analysis of the net energy yield for the FNP. This analysis was performed cn a per-plant basis, assuming the manufacture of both me and four R@s , taking into account the energy required to build the tranufacturing facility as well as an assumed breakwater. Utilizing the methodology unployed by the Staff, Applicant's analysis shows that the therrrJ. energy required to build and operate an FNP is approximately 6.1 percent of the I

I 92 The Applicant's written testintny, Exhibit No. OPS-49, entitled

" Applicant's Testimony Regarding XVIII. Net Energy Yield, Cost-I Benefit Balance" was almitted at Tr. 7069 (7/12/78). The witnesses sponsorin3 this testintny were Dr. John Nutant, Measrs. P. Blair IIaga, William F. Trappen and Thcznas A. Mantia (Professional Qualif-I ications adnitted at Tr. 609,1024, 7055 and 609 respectively) . The Staff's written testimony entitled " Supplemental Testinrmy of hPC Staff in ACCG Contention II," by Dr. Paul C. Fine and Messrs. Fred I J. Clark, Nonnan E. Ilinkle and Fred G. Taylor was admitted at Tr.

7110. Mr. Taylor was unavailable for the hearing and was represented by Dr. Glenn W. Suter. (Professional Qualifications of Dr. Fine, Messrs. Clark and Hinkle, and Dr. Suter were adnitted at Tr. 7060, 637, 637 and 7106 respectively.)

93 Applicant ard Staff witnesses were examined by the Board.

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I thennal energy output for one plant, asstmirg only one WP is manu-factured and its operating life is 30 years. Asstriing four MPs are manufactured, the corresIxnling figure is approximately 5.9 percent.

(Applicant's Testimony, Page 2) . Applicant's results were conparable to the results of the analyses reported by the Staff (FES-II, Section-12.10.4 at page 12-71).

403. Assuming eight MPs are built, the crossover point at whidt the positive energy yield begins is at 3.7 nonths of operating time for an WP. If cnly +wo WPs are built instead of eight, the crossover point would increase fran 3.7 to 3.9 months, an insignif-icant change cnnpared to the assumed 30 year operating life. (Staff's Testinoly, Pages 3 and 4) .

I Breakwater Decnnnissicning I 404. Deccmnissioning the breakwater is discussed in Section 9.5.3 (page 9-12, et seq.) of FES II. Ikkliticnally, there is a discussicn regardity the alteration of the breakwater as a prerequis-ite to noving the MPs out of the breakwater enclosure, should that be included in tln overall deccmnissionirg plan. There exist a number of alternative w* 'vd s for dt h.ssioning the breakvater: perpetual care, alterna use, ard removal. The ES II contains an adequate discussion of major consideraticns of cost and benefit for the various deccr,tnissicning options. (Staff's Testimcny, Page 6) .

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I Cost of Cooling Towers 405. The oost impact for closed-cycle croling systens for FNPs located at inshore sites is discussed in Secticn 10.1.1 (Page l 10-5) of the EES II. The cost impact is given in Tables 10.1.7 (Page-10-16), 11.2.2 (Page 11-3) and 11.2.3 (Page 11-4) .

406. Table 10.1.7 of EES II presents wsts for an offshore ENP, inshore ENP with and without coolirg towers, and a land-based I plant with once-through cooling. Generally, the capital cost of inshore-sited FNPs with coolirg towers canpares favorably with the upper end of the range of costs likely for land-based nuclear stations without cooliry towers in the coastal zone of the Atlantic and Gulf coasts (Staff's Testimcny, Page 17) .

I Foreclosure of Alternate Uses of Coastline 407. Sections 9.4 (cmmencing p. 9-5) awl 12.8.1 (otmnencing

p. 12-62) of the FES II discuss conflicting uses of the continental shelf including the mastline. Potential conflicts are site dependent arrl will be evaluated cn a site-specific basis durirg an owner's construction permit process. Ikuever, the effects of such Intential conflicts are judgal to be of minor significance or avoidable.

(A{plicant's Testinony, Page 3) .

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408. ENPs at inshore sites will have no more effect on land use than land-bas <xi power stations. Offshore siting will involve even less cnmtitmmt of land. The small arTount of land actually disturbed will M much less than for other types of irxtustrial facilities.

(Staff's Testinony, Page 35) . -

I Alleged use of 1972 Cost Estimates and 1988 Benefits I

409. The costs for an ENP are discussed in Section 10.1.1 (p.

I 10-1) and suntnarized in Section 11.2 (cxmnencing p. 11-3) of the EES II. The costs are not " based upon 1972 costs." The costs were cal-culated using a 1973 base mst . Escalation and interest during constructicn were then added to arrive at a conpleted cont in

" current" dollars up to the time of cxrmercial operation. Two analyses were performed, asstming comerical operation ccnnencirg in 1981 arxl in 1985, respectively. Operating cx)sts for the entire life of the plant were discounted back to the ccrmercial operaticn date for each amlysis. ( Applicant's Testinmy, Page 4) .

I 410. The benefits for an ENP are set forth in Section 11.1 (Page 11-1, et seq.) of the EES II. The benefits are not "1988 bene-fits." The direct benefit fran an ENP is the electricity generated.

This direct benefit for each plant will begin when the ENP ccrmences operaticn arx1 is set forth in the EES II in terms of kilowatt-hours of electricity proluced. The value of th kilowatt-hours will be dependent uptn applicable rates dtifiry the period of plant operaticn.

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I (Applicant's Testimaty, Page 4). Indirect benefits, such as taxes and 1

anployment, also are discussed in the EES II (Sections 11.1.3 and

)

I 11.1.4, connencing Page 11-1) . I I .

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I 411. The Board previously has concluded that adequate consideration has been given to the marine environment (See Section IV.C Contential III - MARINE HIVIRCIIMENP, supra. ) . We further find that the net energy yield fran an RIP has not been overstated due to the failure to consider the unique stresses of the marine envirorrnent on the planned operating life of an ENP. In fact, a positive energy yield would occur within four nonths of initial operation of an ENP.

I 412. The cost benefit analpsis in the EES properly considers the various options for decomiissioning and the attendant costs for each option.

I 413. The cost benefit analysis in the EES properly considers the costs associated with cooling towers at inshore RIP sites.

I 414. Proper consideration is given in the EES to potential foreclosure of alternative uses of the coastal area and shoreline needed for eight ENPs. Such pxential foreclosure is jtriged to be of minor significance and does not alter the overall cost-benefit balance.

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, sb I 415. The costs and benefits in the EES were properly assessed usirg appropriate time frames for their calculaticn.

I 416. Accordingly, the Board finds that the EES II cost--

benefit analysis does not underestimate the total direct and indirect costs of the RTPs and does not overstate the benefits.

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I S. (INrafrION XIX - SPECIAL HIERGY REGERD4HirS Dmni Retained Issue (Originally Brigantine Contenticn I.4):

"Section 12.10.4 of Part II of the FES is inadequate in I that it dom not take into account the special energy re-quirements needed to procure breakwater material, to construct the breakwater, to tow plants to the site and to -

provide shore to barge tabilicals."94 417. On this contenticn, both Applicant and Staff presented I written and oral testimcny. None of the intervenors presented witnesses, testinony or other informaticn. IIearirg sessions with regard to this cnntention were held cn July 12 and 13, 1978, and the testimony appears at Transcript pages 7053-7058, 7059-7067 and 7087-7103.

I 94 Brigantine OJntention I.4 was originally admitted by the Board at the May 20, 1977 argtsnent, see Board Order dated Atgust 1, 1977, p.2. Upon the withdrawal of Brigantine as a party the Board retained this contenticn as an issm (Bcmtl Order dated August 1,1977, pp.

12-13).

The Applicant's writte.. testimcny, Exhibit No. OPS-50, entitled

" Applicant's Testinony Reganling XLX. Issue Retained by the Dcurd" I was admitted at Tr. 705G (7/12/78). The witnesses sponsoring this testintny were Dr. John A. Nutant, Messrd, P. Blair IIaga, Thanas A.

Mantia, and William F. Trappen (Professional Qualifications admitted at Tr. 609, 1024, 609 arxl 7055 respectively) . The Staff's written testimony entitled " Staff Testimcny in Response to the Issue Re-tainal by the Doani Regardirg Special Energy Requirenents for I Flcuting Nuclear Power Plants" by Dr. Paul C. Fine and Mr. Clifford A. IIaupt was adnitted at Tr. 7062 (Professional Qualifications of Dr. Fine and Mr. Ilaupt were admitted at Tr. 7060 and 7011 respect.ively. )

I be Staff witnesses were examined by the Board.

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418. Special energy requirements needed to procure breakwater material, to construct the breakwater, to tow R4Ps to an owner's site and to provide shore-to-barge tznbilicals were calculated (Applicant's Testimony, Page 1) .

Breakwater Construction -

I 419 The calculations of the energy requironents for con-struction of a breakwater were based cn the two unit breakwater design describM in Section 3.1 (pages 3-1, et seq.) of FES II. (Applicant's Testimony, Page 1) .

I 420. The energy required for quarrying the stone for the breakwater was estimated to be 0.28 trillicn ETrU. Asstznirg the stone would be transported 200 miles to the site, the energy required to I transport the stone was estimatal to be 0.6 trillim BIU. (Applicant's Testimmy, Page 2) .

421. The energy required to manufacture the cenent required for the concrete in the caissons and dolosse was estimated to be 1.7 trillion Bru. The energy required for the other elements in the manufacture of concrete was considered negligible. (Applicant's Testimcny, Page 2) .

I 422. The energy required for actual construction of the breakwater was estimated to be 0.7 trillicn BIU. (Applicant's Testi-I many, Page 2) .

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I 423. The total energy required for the breakwater was estimatal to be 3.3 trillicn B1U per ENP. This arount represents less than 0.2 of one percent of the energy generated cuer a 30 year period of plant operaticn. (Applicant's Testimcny, Page 2) .

424. The total energy required for providing materials and for constructing an offshore breakwater was calculated by the Staff to be 8.1 trillion BIU. Sinm an offshore station was assumed to consist of two ENP units, the energy per unit is about 4.1 trillion BIU (Staff's Testinony, Page 4) .

I 425. The Staff's estimate of energy required for breakwater constructicn was higher than the Applicant's estimate due to the assumption by the Staff that cne-half of the concrete would be reinforced (Tr. 7089). The Staff estimate may be conservative in ht reinforconent of the cnnerete may rot be necessary, (Tr. 7095).

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427. Two electrical circuits are required to link an ENP with the owner's power grid (PDR, Page 8.1-1) . To calculate the energy required to mnufacture the mterial in the cables and to mnufacture-the cables, it was assuned that the distance frcm the shore to the plant is three miles (Applicant's Testimony, Page 3). The energy required was estimato3 to be 0.45 trillicn BIU. The energy to lay the cables was estimated to be 0.6 trillion BIU. Thus the total energy required to provide the ENP-to-shore circuits was estimated to be 1.06 trillion BIU. (Applicant's Testimony, Page 4). The Staff estimated the energy requirement to be 1.2 trillicn BIU per ENP (Staff's Testinony, Page ti) .

I (bnclusions I 428. The energy requironents needed to procure breakwater material, to construct the breakwater, to tow an ENP to the owner's site anl to provide ENP-to-shore circuits represent approximtely 0.3 of cne percent of the overall expected energy output of an ENP during an assumed 30 years of operaticn (Tr. 7091) . The Boani finds that these energy requirenents as vere taken into accotmt properly in the FES an1 are insignificant conpared to the expected energy output of an ENP during its gerating life.

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I T. GNTENTIQi XX - HEM' PWiPS AND SECCNDARY AND TERTIARY RECDVERY OF OIL I Board Questicn:

I The Applicant and the Staff are requested to present evidence cn the following Board questicn: "To what extent, if any, would the consideration of the utilization of heat -

pumps and of secondary and tertiary recovery frcm oil wells I serve to nodify the discussions and/or conclusions reached in Part II of the FES 7" I 429. On this Board question, both Applicant and Staff presented written and oral testinony. None of the intervenors presented witnesces, testi:rony or other information. Hearing sessicns with regard to this Board questicn were held cn July 12 and 13,1978 arvi the testimony appears at Transcript pages 7078-7083, 7131-7134 arx1 7134-7137.

I Heat Pumps i

430. A heat pmp is a device which uses an electric motor and fluid systems to bring in ambient low temperature energy fran the I This question ms raised by the Board in our Mmorandum and Order ,

Re: Motions to Amend arxl Expand Contentions, dated August 1, 1977, p.10.

I 90 The Applicant's written testirmy, Exhibit No. OPS-51, entitled

" Applicant's Testimtny Regarding XX. Board Questicn," was admitted I at Tr. 7080 (7/12/78). We witnesses sponsoring this testimony were Dr. John Nutant arri Mr. P. Blair Haga (Professional Qualifications admitted at Tr. 609 and 1024 respectively). We staff's written I testinmy entitled "Testinmy of NEC Staff in Response to Board Question" by Norman Hinkle was admitted at Tr. 7133. (Professional Qualifications of Mr. Hinkle were admitted at Tr. 637).

99 Applicanc witnesses were examined by the Board.

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natural envirornnent and elevate it to useful tanperatures for space heating. By reversirg the flow of the working fluid, heat pumps also provide space cooling. Heat pumps can be utilized in new construction and in the replacanent of existirg heatirg systens. ( Applicant's Testimcny, Page 1) . -

I 431. Using a heat pump in new constructim or as a replace-ment for existirg fossil fuel heatirg will require additional electric energy generation. Using a heat pump as a substitute for existirg electric resistance heatirg will result in a reduction in alectric energy oJnsumption. This will be offset, in part, by newly aeated danml for suntner space coolirg in hones currently without space cooling systems (Applicant's Testimony, Page 2).

I 432. In the Ford Foundaticn Study reported in A Time to Choose, Final Report by the Ehergy Iblicy Project of the Ebrd Foundaticm, Ballinger Publishire 00., Canbridge, Mass., 1974, esti-mates were mde of the increase in overall electric energy danand. In the lowest projecticn case (Zero Energy Growth scenario), it is esti-mated that electric energy demand will grow by 1.5 Omds (0) between 1975 and 1985 assunirg widespread use of heat p. nps in new construc-tion. In this projection, the conversion of one-third of the 7.5 millicn hones with electric resistance heatirg in 1975 to heat puup heating by 1985 would result in a reductim in electric energy danand of 0.1 O. If all of these 7.5 millicn hcmes were converted to heat pump heating, a maximun reduction in electric energy denand of 0.2 O E

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I l would be achieved beyond the reduction already included in the Zero Energy Growth scenario. Thus, even with the maxirun possible reduction by omversion to heat punps, the increase in electric energy demand in the Zero Energy Growth scenario will still be 1.3 Q. This is equiva-lent to the annual mergy output of sixty-two 1000 MWe power plants-operatirg at 70 percent capacity. (Applicant's Testimmy, Page 2) .

433. More recent studies project an increase in electric energy denarri that is significantly greater than the lowest projected I denand of the Ford Ebundation Study (Applicant's Testinony, Page 3).

I 434. The use of heat punps is not expected to raluce the overall growth in electric energy requirenents (Applicant's Testimony, Page 5; Staff's Testimmy, Page 6) .

Secondary And Tertiary Recovery of Oil 435. Since 1970, annual danestic producticn fran existirg oil fields lus fallen each year, with almost half of the current denand nude up by importal oil (Applicant's Testumny, Page 4) .

I 436. Since the total U.S. danestic production of oil by all methods of recovery is estinated to meet only about half of the dennd in 1985, secondary and tertiary we j of oil alone will rot be sufficient to eliminate the neal for oi.1 imports to make up the shortfall (Applicant's Testirony, Page 4).

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I 437. Secondary and tertiary methods cf recovery of oil are only expectal to maintain total overall danestic producticn and are not expected to significantly reduce the mquirenents for imported oil. Therefore, oil supplies are not expected to be available to meet the overall projected growth of electric energy demand (Applicant's-Testimony, Page 5; Staff's Testinmy, Page 4) .

Conclusicn I 438. The Board finds that conclusions reached in the FES are not changed or nodified by consideration of heat pumps and secondary and tertiary recovery of oil.

I U. IDARD QUESTICNS OF MARm 29, 1979 439. The Board's review of the Staff Liquid Pathway Generic Study (NURDG-0440) and M:S, Part III (tNREG-0502)100 resulted in a number of questions for which responses were sought fran the Applicant and/or the Staffl01 Bcard findings based cn responses provided by both the Applicant and the Staff as wil as other relevant evidence, are presented in Section IV.N, supra.

I I 100 Admitted at Tr. 7264.

101 Board letter, Sheldon J. Wlfe, Esq. to Barton Z. Cbwan, Esq., et al.,

March 29, 1979.

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I V. DOARD NIQiS OF BDVDMR 12, 1981 1

440. The Board's review of SER Supplements 3 and 4 102 i

resultal in a number of questions for which responses were sought fran the Applicant and/or the StafflO3. Board findings tased cn responses-provided by both the Applicant and the Staff, as well as other relevant evidence, are presented in Sections II.I, II.J and III, supra.

102 Admitted at Tr. 7522.

1 Board letter, Sheldon J. Vblfe, Esq. to Barton Z. Cowan, et al . ,

Novanber 12, 1981.

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r I l V. CI21CWSIO1S OF LAW j 441. The Board makes the fo.' lowing Omelusicms of Law based upm the entire record and all the evidence in this proceedirg, I including our mnsideration and evaluation of the A@licaticn for-Manufacturing License and supporting doctanents subnitted by Applicant; the Staff's Safety Lyaluation Report, as supplemented, and Final Erwirornental Statement, Parts I, II arri III; the written and oral testimcny of all of the witnesses; the exhibits admitted into evi-dence; the Atonic Energy Act of 1954, as amended; the National Envircrrnental Policy Act, as amended; the Rules and Regulations of the COTmission; and relevant NRC decisions and case law.

442. In accordance with the provisions of 10 CFR Part 50, Appendix M, paragraph 2, the Board firxis that the Applicaticn for a Manufacturing License meets all applicable requirenents of Sections 50.34(a)(1)-(9) and 50.34a(a) arri (b). Any required infctmaticn or analysis relating to site matters is predicated cn postulated site parameters which are specified in the Applicaticn. Further, the Application includes infonnation pertaining to design features of the proposal reactors that affect plans for copirg with energencies in the operation of the reactors.

443. In accordance with the provisions of 10 CFR Part 51 and 10 CFR Part 50, Appendix M, paragraph 3, the Board finds that the Applicant has subnitted with its Applicaticn an Environmental Rei: ort as required of applicants for construction permits, such report I -210-

directed to the manufacture of the reactors at the Blount Island manufacturing site; and, in general terms, at the construction and operaticn of the reactors at hypothetical sites havirg characteristics that fall within the postulated site parametesrs. The related draft and final detailed statements of environmental considersations-prepared by the Ommission's Regulatory Staff are similarly directed.

444. In accordance with the provisions of 10 GR Part 50, Appendix M, paragraph 4, I

the Applicant has canplied with the re-quirenents of 10 GR Part 50, Appendices E and H to the extent that the requirements these appendices involve facility design features.

445. In accordance with the provisions of 10 GR Part 50, Appendix M, paragraph 5:

(a) The Applicant has described the proposed design of, anl the site parameters postulated for, the reactors, includirg, but not limited to, the principal architectural and engineering criteria for the design, an1 has identified the major features or ccmponents incorporated therein for the protection of the health ard safety of I the public; (b) such further technical or design information as may be required tr couplete the Applicant's design report and which can reasonably be left for later consideration, will be supplied in a Supplanent to the design report;  ;

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I (c) Safety features or omponents, if any, which require research arxl developnent have been described by the Applicant anl the Applicant has identified, aryl there will be mnducted a research an1 developnent progran reasonably designed to resolve arry safety questions associated with such featues or omponents; and (d) On the basis of the foregoing, there is reasonable assurance that (1) such safety questions will be satisfactorily resolval before any of the proposal nuclear power reactors are renoved fran the mnufacturing site arxl (ii) taking into mnsideration the site criteria containul in 10 CER Part 100, the proposed reactors can be constructal arxl operatal at sites having characteristics that fall within the site parameters postulated for the design of the reactors without undue risk to the health and safety of the public.

,446. The Applicant is technically qualified to design arx1 mnufacture the proposal reactors.

447. The Applicant is financially qualified to design arx1 manufacture the proposal rmetors.

I 448. The issuance of a license for manufacture of the proposal ractors will not be inimical to the carrer defense arxl security or to the health arxl safety of the public.

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449. The applicable requirments of Section 102 (2) of NEPA, 10 GR Part 51 ( formerly 10 GR Part 50, Appendix D) and 10 GR Part 50, Appendix M, have been ocmplied with in this proceeding. In particular, the Board has independently considered the benefits and costs of the proposcx1 reactor nunufacture and concludes that the -

benefits to be derived frcm such manufacture outweigh their costs.

450. The Board finds cn the basis of the evaluations ard analyses of the envirormental effects of the proposed action required by 10 GR Part 51 and 10 GR Part 50, Appendix M, paragraph 3, that the acticn called for is the issuance of the manufacturing license.

451. The Ibard concludes that the Q2mtission should issue a manufacturing license to Offshore Power Systems authorizing the manufacture by the end of 1999 cf eight standardized floating nuclear plants at its manufacturity facility located (m Blount Islard in Jacksonville, Florida.

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I APPINDIX A LISTING OF APPLICATICN AND STAFF REVIN DOCLMNTS I A. Application Documents I Exhibit Nunter Title Date Almission Into Evidence 20 Application for Minufac- tby, 1973 Tr. 1031 turing License and Sup-plemental Information 20A Application for Novmber 10, 1981 Tr. 7533 Manufacturing License General Informatico, I Revision 2 (Amendnent No. 29 to Application) 21 Plant Design Report (PDR), January, 1973 Tr. 1031 As amended through Amenhent No. 22 21A PDR Amendment No. 23 Septater 10, 1976 Tr. 2978 210 Pm Amenbent No. 24 August 31, 1977 Tr. 7532 21C PDR Amendment No. 24, Errata October 20, 1977 Tr. 7532 .

21D Pm Amendment No. 25 June 20, 1978 Tr. 7532 21E PDR Amerdment No. 26 January 3, 1979 Tr. 7532 21F Pm Amendment No. 27 April 30, 1979 Tr. 7532 21G PDR Amenlment No. 27, Errata April 30, 1979 Tr. 7532 2 111 Pm Amendment No. 28 July 15,1981 Tr. 7532 21I PDR Amendment No. 30 Novmber 17, 1981 Tr. 7532 4 Envirornental Report [Part I] May, 1973 Tr. 614 Supplment to bbnufac-turirr3 License Application 5 Supplment No. I to October 8, 1973 Tr. 614 Envirorrnental Report [Part I]

I Supp1 ment to tbnufac-turin3 License Application l I 6 Supplment No. 2 to Envirorinental Report [Part I]

Supp1 ment to Fbnufac-January, 1974 Tr. 614 l turing License Application I

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I Exhibit I Ntriber Title Date Ahtission Into Evidence 7 Supplement No. 3 to June 7,1974 Tr. 614 I Envirorrnental Report [Part 13 Supplement to Manufacturing License Application 8 Supplement No. 4 to August 6, 1974 Tr. 614 Envirorinental Report [Part I] ~

Supplement to Manufac-turirn License Application 9 Supplement No. 5 to January 30, 1975 Tr. 614 I Envirorinental Report [Part I]

Supplanent to Manufac-turity License Appli-caticn l 10 OPS Letter re Environ- January 23, 1975 Tr. 614

! mental Report to Mr.

Gordon K. Dicker of the Staff I 57 Enviromental Report, Part II, Supplanent to M1nufacturing June, 1973 Tr. 6786

! License Application 58 Environmental Report, June, 1973 Tr. 6790 Part II, Apperrlices, I Supplement to Manufac-turing Licenne Appli-cation

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l 59 Suppleme.t No. I to March, 1974 Tr. 6790 Enviroimental Report, Part II, Supplement to Rinufacturing License Application I 60 Supplement No. 2 to Envirorinental Report, Part II, Supplement May, 1974 Tr. 6790 I to Rinufacturing License Application 61 Supplanent No. 3 to Dece ber 3,1974 Tr. 6790 Envirorinental Report, Part II, Supplement to Manufacturity3 License Amlicaticn I

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Exhibit hinission Into Ntuber Title Date Evidence 62 Supplcraent No. 4 to Septenber 19,1975 Tr. 6790 Envircrrnental Report, Part II, Supplanent to Manufacturing License Application 63 Supplanent No. 5 to May, 1976 Tr. 6790 Envirorrnental Report, I Part II, Supplanent to Manufacturing License Application 64 Supplement No. 6 to June, 1977 Tr. 6790 Environnental Report, I

Part II, sur %nent to Manufacturing License Applicatico I

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I Publication Mmission Into Title Number Date Evidence Safety Evaluation NUREG-75/100 9/30/75 Tr. 1043 Report Relatal to Offshore Powr Systans Floatirg Nuclear Plants (1-8) -

I supplanent No. I to Safety Evaluation Report Related to t m D M O54 3/16/76 Tr. 1043 Operaticn of Offshore I Power Systems Float-iro Nuclear Plants (1-8)

Supplanent No. 2 to NURH3-0054 10/8/76 Tr. 7388 Safety Evaluation Report Related to Operaticn of Offshore Power Systans Floating Nuclear Plants (1-8)

I Supplement No. 3 to NURD3-0054 2/90 Tr. 7522 Safety Evaluation I

f Report Related to Offshore Power Systens Floating Nuclear Plants (1-8)

Supplanent No. 4 to NUREG-0054 9/81 Tr. 7522 Safety Evaluatier I Report related to Offshore PoWr Systuns Floating Nuclear Plants (1-8)

Final Envirornnental NURDG-75/091 10/75 Tr. 642 I Statenent Related to Manufacture of Float-irn Nuclear Power Plants by Offshore Ibwer Systans I

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I publicaticn Admission Into Title Number Date Evidence Firni Environmental NURDG-0056 9/76 Tr. 3626 I Statunent Related to Manufacture of Floatirg Nuclear I Power Plants by Offshore Pcwer Systens, Part II ~

(Staff Exhibit I)

Final Addendtzn to NUR M-0056 6/78 Tr. 7014 Final Envirormental I Statunent Re. lated to Manufacture of Float-ing Nuclear Power Plants by Offshore I Powr Systems,Part II Final Environmental NUREG-0502 12/78 Tr. 7264 I Statanent Related to Manufacture of Float-iry Nuclear Power I Plants by Offshore Power Systans, Part III I

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I APPDIDIX B LISrniG CF CIITralTIQiS AD4ITTED AS ISSUES Di COTTIOVERSY RID OTHER PCTTERS OF IDARD DICUIRY A. D4ERCDICY IDWER (01TfDTTIQi I )

Brigantine Amended Contention 3 -

I " Motion by Intervenor City of Brigantine to Amend and Expand Its contentions" (hereinafter " Brigantine Motion") (10/21/75), page 2.

I Admitted, " Fourth Prehearing Conference Order and Ruling on Motions" (hereinafter " Fourth Prehearing Conference Order")

(12/29/75), page 4.

B. UIDEINATER ELECTRICAL TRANSMISSIQ4 LDIES (GITTDTTIQi II)

ACCCE Contention 4b

" Atlantic (bunty Citizens Council cn Environnent's Petition to Intervene in the Above-Cited Matter; Contentions Therefor" (here-inafter "ACDCE Petition") (4/15/74), page 3.

.I Admitted, as interpreted by the Atcmic Safety and Licensing Board, "Second Prehearing Conference Order" (5/21/74), page 7.

C. MARINE DNIIniMDTP (CJtTrHTPIQi III)

Brigantine Amended Contention 6 Brigantine Motion (10/21/75), page 3.

Admitted, " Fourth Prehearing Conference Order" (12/29/75), page 5.

AQJCE Contention 2 ACCCE Petition (4/15/74), page 2.

I Admitted, as interpreted by the Atcmic Safety and Licensing Board, "Second Prehearing Conference Order " (5/21/74), page 4.

I I This listing reflects the consolidation of related contentions for hearing and utilizes the Rcman numeral numbering sequence and

.I subject matter designations anployed by Applicant in its various motions to esablish schedule.

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D. CHTTRAL CIT 170L FOOM (ONTHIPIOT IV)

ACCCE Contention 9 ACXE Petition (4/15/74), page 4.

Ahnitted, as interpreted by the Atanic Safety and Licensing Board, "Second Prehearing Conference Order" (5/21/74), page 10.

E. TRRISIMPATIOi (CITrHirIGI V)

Atlantic County Contention 3 ,

Atlantic County Letter (2/7/74), page 2.

I hinittal, "First Prehearing Conference Order" (4/15/74), page 9.

ACDCE Contention 5 ACCG Petition (4/15/74), page 3.

Ahnitted, "Second Prehearing Conference Order" (5/21/74), page 2.

Brigantine Original Contenticn Kenneth B. Walton Letter (12/13/73)

Alnitted, "Seccnd Prehearing Conference Order" (5/21/74), page 2.

Kenneth B. Walton Contention Kenneth B. Walton Letter (12/13/73) htnitted, "Panorandtzn and Ordez" (5/8/75), page 2.

F. SITE ENVEIDPE DNTA (CNTH7PIQi VI)

Brigantine Amended Contention 1 Brigantine Motion (10/21/75), page 2.

I hinitted, as interpreted by the Atanic Safety and Licensing Board,

" Fourth Prehearing Conference Order" (12/29/75), page 4.

G. RADIOIDGICAL IMPACP Of SWIBMERS AND IDATERS (CNTETTIOT VII)

ACOCE Contention 3d ACCCE Petition (4/15/74), page 3.

hinitted, "Seccnd Prehearing Conference Order" (5/21/74), page 6.

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!!. AIRCRAFT (MDRIOT VIII)

Atlantic County Contention 2 Atlantic County Ietter (2/7/74), page 2.

hinitted, as stated by the Atanic Safety and Licensing Board, "First Prehearing Conference Order" (4/15/74), page 9.

Brigantine Amended Contention 4 Brigantine Motion (10/21/75), page 4.

Admitted, " Fourth Prehearing Conference Order" (12/29/75), page 4.

ACCCE Contention 6 ACOCE Petition (4/15/74), page 4.

Admitted, as interpreted by the Atanic Safety and Licensing Board, "Second Prehearirg Cbnference Order" (5/21/74), page 8.

I. SilIP WILISICN (QJNTDRIOT IX)

Brigantine Amended Contention 5

" Motion by Intervenor City of Brigantine to Amend and Expand Its Contentions" (10/21/75), page 4.

Admitted, " Fourth Prehearing Conference Order" (12/29/75), page 4.

A00CE Contention 6

" Atlantic County Citizens Oauncil cn Environment's Petition to In-I tervene in the Above-Cited Matter; Contentions Therefor" (here-inafter "ATCE Petition") (4/15/74), page 4.

I Adtnitted, as interpreted by the Atanic Safety and Licensing Board, "Second Prehearing Conference Order" (5/29/74), page 8.

J. IC MAINMINT (02EDRIOT X)

I ACOCE Contention 7 AOCG Petition (4/15/74), page 4.

Admitted, as revised by the Atonic Safety and Licensing Board, I "Manorandtsn and Order" (7/10/74) .

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I K. TURBETE-CHIERAIOR MAITERS (03rresrw ISSUE XI )

On June 15, 1976, Mr. Ernst J. Effenberger made a limited appear-ance statenent concerning turbine-generator matters (Tr. 999-I 1010). The Doard requested the Applicant and Staff to address the matters raised by Mr. Effenbertjer (Tr.1011).

L. EFFI:Cr Of BICTTA (CITrDEIOi XII)

ACCCE Contention 3a ACOCE Petition (4/15/74), pages 2-3.

Admitted, "Secmd Prehearing Conference Order" (5/21/74), page 5.

M. EUTCPIGIAL DESIGi OF DISOIARGE OUTFAIL (C11THEIOT XIII)

ACOCE Contention 3b ACCCE Petition (4/15/74), page 3.

Admitted, "Seccnd Prehearing Conference Order" (5/21/74), page 5.

N. EDOD OIAIN (CIEDRIOT XIV)

ACCCE Contention 3c ACCCE Petition (4/15/74), page 3.

Admitted, "Secorxl Prehearing Conference Order" (5/21/74), pages 5-6.

O. DREDGING (ERE HEIOT XV)

ACTE Contention 3f AOJCE Petition (4/15/74), page 3.

Admitted, "Second Prehearirx3 Conference Order" (5/21/74), page 6 I

2 I In the Board's "Second Prehearing Conference Order" (5/21/74) ACECE Contention 4a pertainirr3 to breakwater stability (AO.'G Petition (4/

15/74), page 3) was admitted as an issue in controversy. In the I

early stages cf the hearing this issue was referred to as Cbntention I XI. However, ACCCE Q3ntention 4a was dismissed as an issue in controversy by Boari Order dated April 20, 1977.  ;

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I P. IMPACF Of RES3RF E01XJMICS (GICHITIGI XVI)

Atlantic County Contention 1 Atlantic Cbunty Letter (2/7/74), pages 1-2.

hhitted, "First Prehearirrj Conference Order" (4/15/74), page 8 O. Pf0GRNMirIC ENVIRIIMHTTAL STATH4HR (GNTHEIOT XVII)

NRDC Contention I " Petition for Ieave to Intervene" dated January 9, 1974 and

" Amendment of NRDC's Petiticn for Leave to Intervene" dated February 2G, 1974.

Admitted, "First Prehearing (bnference Order" (4/15/74), pages 2-3.

R. NET HIERGY YIELD, CDSP-BENEFIT BAIANCE (RIrrHRIOT XVIII)

ACCCE/ Atlantic County Contention II

" Motion to Amend and Expand Contentions" dated Novanber 19, 1976.

Admitted, "Manorandtzn and Order Re: Motions to Amend and Expand Contenticna" dated August 1, 1977 (hereinafter " August 1, 1977 Order), pages 4-5.

S. ISSJE RETAINED IW THE DOARD - SPECIAL HIERGY REQUIRD4H4TS (RIRENTIOT XIX)

Identified, August 1, 1977 Order, pages 12-13.

T. 'DARD QUESTIO4 - It6d PUMPS, ETC. (017FESTED ISSUE XX)

Identified, August 1, 1977 Order, page 10.

U. EDARD QUESTIQ1S OF MARGI 29, 1979 V. EDARD QUESTIQ4S OF NOVEMBER 12, 1981 I

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I APPDIDIX C LISTD3G OF APPLICRTf'S EXHIBITS I Exhibit Number 1

Description Admission Into Evidence Date of Admission 4 Envircrriental Report [Part I] Tr. 614 3/23/76 Supplanent to Manufacturing License Application I 5 Supplement No. I to Environnental Report [Part I]

Supplement to bbnufacturing Tr. 614 3/23/76 License Applicatico G Supplement No. 2 to Tr. 614 3/23/76 Environnental Report [Part I]

S+plement to bhriufacturing License Application I 7 Supplement No. 3 to Environnental Report [Part I]

Supplement to Manufacturing Tr. 614 3/23/76 License Applicaticn 8 Supplement No. 4 to Tr. 614 3/23/76 Envircrraental Report [Part I]

I Supplement to bbnufacturing License Application I 9 Supplanent No. 5 to Environnental Report [Part I]

Supplement to Manufacturing Tr. 614 3/23/76 License Application I 10 OPS Letter RE: Envirorrnental Report Tr. 614 3/23/76 I to Mr. Gordon K. Dicker of the Staff (12/23/74) 20 Application for ohnufacturing Tr. 1031 6/15/76 I License and Supplanental Information I 1 Exhibit Nos. 1-3 and other sequential Exhibit Nos. through 67 not included I cn this Listing were used to identify the professional qualifications of Applicant's witnesses. These professional qualifications were incorporated into the transcript as if read ard thus did not becane separate exhibits.

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,Wtissim Into Number Description Evidence Adnission 20A Applicatim for Manufacturing Tr. 7533 12/4/81 I License, General Information, Revision 2 I 21 Plant Design Report (beltrilrg all PIE traendnents through Tr. 1031 6/15/76

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Amerdnent No. 22) 21A PDR Amendment No. 23 Tr. 2978 9/20/76 21B PIR Icendnent No. 24 Tr. 7532 12/4/81 21C PIE Amendment No. 24 Errata Tr. 7532 12/4/81 21D PIR Amenduent No. 25 Tr. 7532 12/4/81 21E PDR Anendment No. 26 Tr. 7532 12/4/81 21F PIR Amendnent No. 27 Tr. 7532 12/4/81 21G PDR Amendment No. 27 Errata Tr. 7532 12/4/81 21H PIR Amendment No. 28 Tr. 7532 12/4/81 21I PDR Amendment No. 30 Tr. 7532 12/4/81 22 Applicant's Testimmy Regarding Tr. 1052 6/15/76 I. Dnergency Power 23 Applicant's Testimony Regarding Tr. 1715 7/6/76 III. Marine Environnent 24 Applicant's Testimmy Regarding Tr. 2164 7/9/76 Central Control Rom I

IV.

25 Applicant's Testimmy Regarding Tr. 1331 6/16/76 VI. Site Envelope Data 26 Applicant's Testimmy Regarding Tr. 3421 9/23/76 VIII. Aircraft 27 Applicant's Testimmy Regarding Tr. 9884 7/30/76 IX. Ship Collisim I 33 Applicant's Testimmy Regarding II. Underwater Electrical Transmission Lines Tr. 3787 9/29/76

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Ahtission Into I Exhibit Number Description Evidence Date of Admission 34 Applicant's Testinony Regarrling Tr. 3864 11/3/76 V. Transportaten 35 Applicant's Testimony Regarding Tr. 3834 11/3/76 VII. Radiological Impact cn I Swinmers and Boaters .

2 37 OPS Ictter ( A. R. (bilier) - -

Re: Fuel Cask Drop Doses to Mr. Knighton of the Staff (6/2/76) 38 Applicant's Testimmy hagarding Tr. 5095 3/1/77 I Turbine-Generator Mitters I 42 Applicant' Testimony Regarding X. Ice Contairment Tr. 6009 5/13/77 44 Applicant's Testinony Regarding Tr. 6242 5/17/77 XVI. Impact on Resort Econonics 47 Applicant's Testimony Regarding Tr. 6988 7/12/78 I XIII. Functional Design of Discharge Outfall 48 Applicant's Testimony Regarding I XV. Dredging Tr. 7025 7/12/78 49 Applicant's Testinony Regarding Tr. 7069 7/12/78 I XVIII. Net Energy Yield, Cost-Benefit Balance I 50 Applicant's Testimony Regarding XIX. Issue Retainal by the Board (Special Energy Requirements)

Tr. 7058 7/12/78 51 Applicant's Testinony Regarding Tr. 7080 7/12/78 XX. Board Question (Heat Pumps aryl Secondary and Tertiary Recovery of oil) 57 Environnental Report, Part II, Tr. 6786 7/10/78 Supplanent to Manufacturity I License Application 58 Environnental Report, Part II, Tr. 6790 7/10/78 I Apperrlices, Supplanent to Manufacturing License Application I 2 Exhibit No. 37 was marked for identification cnly at Tr. 3906 (11/3/76).

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Exhibit Muissicn Into Date of Nirnber Description Evidence Adnission 59 Supplanent No. I to Tr. 6790 7/10/78 I Environnental Report, Part II, Supplanent to Manufacturing License Application 60 Supplesnent No. 2 to Tr. 6790 7/10/78 Environnental Report, Part II, -

Supplanent to Manufacturirn License Application 61 Supplement No. 3 to Tr. 6790 7/10/78 Environnental Report, Part II, I Supplement to thnufacturing License Application 62 Supplernent No. 4 to Tr. 6790 7.'10/78 Envirorrnental Report, Part II, supplement to thnufacturing License Application 63 Supplement No. 5 to Tr. 6790 7/10/78 Envircrznental Report, Part II, I Supplement to Funufacturing License Applicaticn 64 Supplernent No. 6 to Tr. 6790 7/10/78 Environnental Report, Part II, Supplement to thnufacturing License Applicaticn 65 OPS Liquid Pathway Tr. 7266 4/4/79 Generic Sttdy, Topical I Report No. 22A60 (June, 1977)

G6 Professional Qualifications Tr. 7266 4/4/79 of Dr. Thamas W. Philbin 68 Amlicant's Mditional Tr. 7601 12/4/81 I Testintny Regartling XI. Turbine-Generator butters 69 Applicant's Testintny in Response Tr. 7692 12/4/81 to the Novanber 12, 1981 Board I Question Nos. 4-7 70-99 Not used - -

100 Figure 3 fran the Tr. 4812 12/17/76 I S.11. Bush Report, p.1%

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I Exhibit Date of I Number Description khissicn Into Evidence Adnission 101 Figure 5 fran "A Method of Tr. 4813 12/17/76 Calculatirn Turbine Missile Strike and Dawje Probabilities" by S. W. 9wan and M. Meleis, Nuclear Safety,1975, p. 449

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102 OPS Figure 3-1 entitled - -

" Actual Plant. Configuration, I Plan View 103 OPS Identification of Tr. 5121 3/1/77 I Secticn Cuts et al.

(Three sheet drawing)

I 104 ENP Turbine control Drain Tubirg Arrargenent Tr. 5106 3/1/77 105 Not used - -

106 OPS Letter (P. B. Haga) Tr. 5641 5/10/77 Re: Turbine-Generator Information to Mr. Karl Kneil of the Staff I (9/8/76)

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I I UIITED STATES OF ATRICA NUCIEAR Pf]GUIATORY CDbf4ISSICU BEFORE TIIE A'IOMIC SAFETY RID LICDISING IDARD I

In the Matter of )

OFFSIDRE IWER SYSTDiS ) Irrket No. SIN 50--437 (Manufacturing License for Floating )

Nuclear Power Plants) )

I CERTIFICATE OF SERVICE I

I I hereby certify that copies of " Applicant's Proposed Findings of Fact and Conclusions of Iirs in the Fonn of a Proposed Initial Decision" were served by deposit in the United States Mail (First Class), Instage prepaid, upon I the persons listed ai attachment to this Certificate of service this lith day of Decernber 1981.

3 L .1 rL J R. Kenrick I sel for Offshore Power Systens i

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I OPS SER/ ICE LIsr Sheldon J. ib1fe, Esquire, Chairman Docketing and Service Section h hinistrative Judge Office of the Secretary I' Atanic Safety and Licensing Board U. S. Nuclear Regulatory Chmtission U. S. Nuclear Regulatory Chmiission Washirgton, D. C. 20555 Washington, D. C. 20555 i Stephen M. Schinki, Esquire Dr. David R. Schink Office of the Executive Legal -

h hinistrative Judge Director I Atanic Safety and Licensing Doard Department of Ocearography Texas A & M University U. S. Nuclear Regulatory (bmtission Washirgton, D. C. 20555 I

College Station, Texas 77840 Barton Z. Cowan, Esquire John R. Kenrick, Esquire Dr. George A. Ferguson Eckert, Seanans, Cherin & Mellott hhinistrative Judge Forty-secorrl Floor I Atanic Safety and Licensing Board School of Ergineering Ikward University 600 Grant Street Pittsburgh, Pennsylvania 15219 2300 5th Street, N.W. Thcmas M. Daugherty, Esquire I Washingtcn, D. C. 20059 Offshore Power systens 8000 Arlirgton Expressway Dr. David L. Hetrick I Alternate Mtsnber Atcmic Safety and Licensing Boartl P. O. Box 8000 Jacksonville, Florida 32211 Professor of Nuclear Engineering Carl Valore, Jr., Esquire I The University of Arizona Tucson, Arizona 85721 Valore, McAllister, DeBrier, Arcn & Westmoreland P. O. Box 175 lE Alan S. Rosenthal, Esquire, Northfield, New Jersey 08225

! Chairman .

lE Atanic Safety and Licensing S. Jacob Scherr, Esquire il l

j EB Appeal Board Panel U. S. Nuclear Regulatory Cbmtission Washirgton, D. C. 20555 Natural Resources Defense Council, Inc.

1725 I Street, N.W. , Suite 600 Washington, D. C. 20006 iEg Alternate c> airman Atcmic Safety and Licensing Sandra Ayres, Esquire Appeal Board Assistant Deputy Public Advocate lg U. S. Nuclear Regulatory (bmtission State of New Jersey lg Washington, D. C. 20555 P. O. Box 141 Trenton, New Jersey 08625 j Chief Ilearing Omnsel

! Office of the Executive Legal Mr. George B. Ward Director Nuclear Power Plant (bmtittee U. S. Nuclear Regulatory (bmtission City Hall

'g Washirgton, D. C. 20555 Brigantine, New Jersey 08203 ig

!!arold R. Denton, Director Office of Nuclear Reactor Regulation i U. S. Nuclear Regulatory Chmiission Washirgton, D. C. 20555 I i

I Dr. Willard W. Rosenberg, Chairman I Energy Ommittee Atlantic County Citizens (buncil on Envircrment 8 North Rumscn Avenue i Margate, New Jersey 08402 Mr. John H. Williamson Energy Ccrmittee Atlantic (bunty Citizens Cbuncil -

on Environnent I

i 211 Ebrest Drive '

Linwood, New Jersey 08221 I

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