ML20072K715

Submission of Contention 15-AA That Operating Capacity Factor of 55% in Des Overestimated.Contention Submitted Per ASLB 830527 Order

ML20072K715
Person / Time
Site:	Harris
Issue date:	06/30/1983
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20072K706	List: ML20072K704 ML20072K715 ML20072K726 ML20072K756 ML20072K767
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8307060386
Download: ML20072K715 (2)

Text

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r 2 {h UNITED STATES OF AMERICA June 30, 1983 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of J Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )

Units i and 2) ) ASLBP No. 82-h68-01

} OL Contention 15-AA : Staff Overestimation of Harris Capacity Factor, by Wells Eddleman Under the Soard's order of 5/27/83, pare 8 footnote 8,

' dells Eddlenan hereby files the following contention that the Staff's 55% capacity factor in the DEIS is too high:

Contentien 15-AA: The Staff has overestinated the enerating capacity factor of the Harris nuclear clants .in its draft environ-mental innact statement, thus exaggerating the benefits of this tower being produced by nuclear enenrgy, an d distorting the NrPA cost-benefit balance at the onerating license stage. The Staff also calculated the output at 55% too high even for the design rating.

3_ ASIS : Many presently operating nuclear plan ts have lifetine capacity factors below 555. McGuire 1, wi th Westinghouse model D

! - stean generators (similar to Harris' s tean generators ) had a 38.5%

ogg apa ity factor as of 12-31-82 (NU??Ge00PO " Gray Book" January 1983) .

nea 88 Earris will be subject to more stringent regulations and recuirenents 88o mg than nost plants nov onerating (see,c.c. Board Exhibit 8 of the i

gg 40 Harris 1979 construction pernit remand hearings, re " site strfngency" R4 or strictness of requirenents. ) The Brunswick nlant, which C"&L 85 mao played a considerable role in building (see record of sane renand i

-2,-

I hearings)(testinony of J.A. Jones of CP&L, et al), has the lovest two capacity factors of any 3WRs in the United States as of 12-31-82. {

(NUREG-0020, Jan 1983: Brunswick 2 is worst at h0.9% of design rating; Brunswick 1 is next lowest at about 50%; Browns Fer:=7 1 at $2.3% (including the effects of the 197F fire) is next lonwest, I believe). (CP&L's Robinson clant, by cortrast, was a turnkey job, i.e. CP&L had no role in building it. Also, Robinson has the lowest site stringency (safety /bnerating requirement a) of anv nuclear plant 'n TRC Region II according to Board Fxhibit 8 and the test'.nony in the Harris renand hearing or 1979, NRC Dockets 50-h00 thru ho3. )

In addition, CP&L's record of nisnanagement of nlants, and of plant problems (sec , e.g., testimony of A. Ronald Jacobstein, with exhibits, NC Utilities Connission 3ocket E-2 sub hhh, where the NC Commission penalized CP&L fer its rcle in causirg/ extend'rg a turbine cutage a t Brunswick -- sabotage is susnected; testinony and exhibits cf Thonas Lan, NCUC Pub 13c Staff (officic1 c onsurer a dvoca te), Docket E-2 sub h61 (1983) re Co&L's f ailure to nerform tests, lead'nr to extensive outages in the summer of 1982 at Brunsvick; NoC nronosed fine of $600 Ldocumeuted,000 tc CP&L IM Gt ttach forC<failure mo)is +o A, toherforn requived tests;rtWs numbers of other lerge fines by NoC to CP&L in the nast; Board Exhibit 8 of the 1979 renand hearings on Enrais (anonyncus PDC insnectors' opninions that Rob'ncon nstagement nut newer preduction ahead of safety, did only what URC recuired); record of Ro binson deratinEs and cutages in recent years due to stean genevator degradation) indicates that CP&L nay not get as good results as other nuclear plcnt onerators, at least not withcut comronising safety (vide NRC FCIA82-P61 where CP6.L un'ts hold 3 of the highest 5 ratings in the USA for 1981 in risk of neltdown trecuxrsors hannening at those plants in that review). Harris DER rating is 1800 MW x h818 hrs

($$%) is only 8.67 billion KWH a year , not 9 billion as Staff clains.

No CP&L nuke has an operating MDC ecuni to its DER, so 8.67 is too high. j m