ML20082F849

Supplemental Answers to Interrogatories on Contention 15AA. Related Correspondence

ML20082F849
Person / Time
Site:	Harris
Issue date:	11/23/1983
From:	Hollar D CAROLINA POWER & LIGHT CO.
To:	Eddleman W EDDLEMAN, W.
Shared Package
ML20082F852	List: ML20082F849 ML20082F854
References
ISSUANCES-OL, NUDOCS 8311290263
Download: ML20082F849 (8)

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USNRC November 23,1983 . _

13 NOV 28 A10:32 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION (hj-f/h((.,"

;,c.o BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL

)

(Shearon Harris Nuclear Power Plant, )

Units 1 & 2) )

APPLICAN'IE' SUPPLEMENTAL ANSWERS TO WELLS EDDLEMAN'S INTERROGATORIES ON EDDLEMAN CONTENTION 15AA Since providing answers on September 16, 1983, to Wells Eccleman's initial interrogatories on Contention 15AA, Applicants have retrieved a copy of the transcript of proceedings in North Carolina Utilities Commission Docket No. E-2, Sub 203 from storage in CP&L's documents wirehouse. Therefore, Applicants' original answer to Interrogatory No. 5 is revised to read as follows:

ANSWER: Mr. Morgan supported the projected 80 percent capacity factor on cross-examination as set forth on pages 38-43 of the transcript in NCUC Docket No. E-2, Sub 203. Mr. Morgan's redirect testimony on the subject of capacity factors is set forth on transcript pages 5*.-58.

With respect to Applicants' November 17, 1983 Response to Mr. Eddleman's second set of interrogatories on Contention 15AA, Applicants' answer to Interrogatory 15AA-(2d)-18(t)(ii)is revised to read as follows:

83112902o3 831123 PDR ADDCK 05000 G gs/n

(ii): EFOR data are not routinely calculated and maintained by Applicants. However, Applicants did calculate the Robinson Unit 2 EFOR to be 22.08 percent for 1982.

In the November 17, 1983 Response, Applicants indicated that answers to Interrogatories 15AA-(2d)-17(q),17(w),17(y),18(j),18(k),18(m),18(n) and 18(o) would be provided by a supplemental filing. The provision of answers to these interrogatories is not to be deemed a representation that Applicants consider the information sought to be relevant to the issues to be heard in this proceeding. These answers are provided as follows:

INTERROGATORY NO. 15 AA-(2d)-17(q) Exactly what information conceming planned maintenance did you use from the Robinson Plant (Robinson Unit 2) (see your 9-16-83 response to my interrogatory #25 on 15AA) in making estimates of planned maintenance for Harris? Please include in your answer (but do not limit it to) exactly what experience data was used, and exactly how it was used, including all relevant calculations or computations; exactly what projections were used, who made them, how each was made, when it was made, what calculations were made in making each such projection, what data was used in the calculations (and in each such calculation), where the data used came from (including identity of all documents containing it), and any other opinions or information you relied on making these projections, stating such data for each such projection. Please provide sufficient data and statement of calculations that the results of the calculations can be checked from the original data and calculational procedures given.

ANSWER: The referenced data on planned maintenance were obtained from the Company's PURPA Section 133 filing of June 30,1982, At that time, the estimated end of operating cycle outage duration on a yearly basis at Robinson Unit 2, which was used for planning purposes, was 8 weeks per year. The end of operating cycle outage includes iefueling operations and planned maintenance and inspection.

The estimated outage duration was established by the CP&L Nuclear Operations Departrnent by first considering a critical path schedule for the refueling activities.

Planned maintenance and inspection requirements were also considered to determine if additional outage time was required. A primary basis of this estimate was an average of 2 -

t

the Robinson Unit 2 historical end of operating cycle outage durations on a yearly basis from 1973 through 1981. These historical outage durations are provided in Applicants' answer to Interrogatory 15AA-(2d)-18(t)(i). There were no end of cycle outages for the years 1977 and 1981; therefore, zeros were included in the average for these years to obtain an average on a yearly basis. The Robinson Unit 2 historical outage durations were obtained from CP&L's operating records for the unit.

(w) Did CP&L take into accomit NRC-ordered shutdowns in estimating (i) capacity factor (ii) planned equivalent maintenance availability, (iii) forced outage rates (iv) EFORs (v) availability (vi) for Harris?

ANSWER:

Applicants currently estimate capacity factor and planned maintenance, but do not routinely estimate forced outage rates, availability, or equivalent availability in projecting the performance of Harris. As indicated in Applicants' answers to Interrogatories 15 AA-(2d)-17(v), 18(s), 18(t) and 18(u), Applicants do not routinely estimate or use EFOR data for their nuclear units. In some cases, however, Applicants do use EFOR factors as necessary to define capacity factors, which as stated in Applicants' answer to Interrogatory 15AA-(2d)-17(n) are the most valid measure of base load nuclear unit performance. It should be noted that these EFOR factors are not equivalent to the stanoard EFOR as defined by NERC or EEI, but are modified factors which are actually based on operating capacity factors (OCF). These modified EFOR factors are derived from the following formula: EFOR = 1 - OCF. Applicants did develop a composite estimate of the EFOR of commercial reactors in one instance, as -

discusseo in answer to Interrogatory 15AA-(2d)-17(y) below. These capacity factor, planned maintenance and EFOR estimates generally take into account past NRC-ordered shutdowns.

(y) Please give each estimate for which your answer to any part of (w) or (x) above (or to all of (x)) is affirmative, and please state who made it, when, for what purpose (if known), and all significant bases of said estimate which you know.

ANSWER: In February,1983, CP&L's Nuclear Staff Support Section of the Nuclear

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Generation Group estimated the capacity factor and planned maintenance of Harris Unit I for general planning purposes. Also, to provide general verification for the capacity factor estimates, CP&L's Planning and Coordination Department developed a composite estimate of the EFOR of commercial nuclear reactors. The operating capacity factor for liarris after the unit is placed in commercial operation and between refueling outages was projected to be 65 percent for the first cycle, 75 percent for the second cycle, ana 80 percent for the third and subsequent cycles. The capacity factor and EFOR estimates were based upon a combination of CP&L's nuclear operating experience .ind the experience of other utilities with nuclear units. The planned maintenance estimate is discussed in the answer to Interrogatories 15AA-(2 dbl 7(b),(c), and (u). It is based on CP&L's nuclear operating experience.

INTERROGATORY NO. 15 AA-(2 dbl 8(j) Does CP&L know what the average capacity factor of (i) Westinghouse nuclear plants of 800 MWe and up(lifetime, DER basis), (ii) Westinghouse nuclear plants of 900 MWe and up (lifetime, DER bas.;)is? If so, please state these averages and the data at which they are computed (e.g. as of 6-30-83).

ANSWER: No. CP&L has not calculated capacity factors for these categories of nuclear plants. Basic data needed to perform such a calculation is available in NUREG 0020 which is published monthl; by the NRC. See also NRR Monthly Technical Report for September 1983 attached to NRC Staff Response to Interrogatories, etc.

(November 14, 1983).

(k) Does CP&L have any opinion as to why its Brunswick units have the lowest lifetime DER capacity factors of any two commercial electricity generating BWRS over 300 MWe (design capacity)in the US?

ANSWER: Y es.

(1) If answer to (k) is affirmative, what is that opinion? Please state all facts you rely on to support that opinion.

ANSWER: The performance of the Brunswick unit has been affected since early 1979 by the need to modify the units to correct generic design problems, improve plant reliability, and comply with regulatory directives. Many of these modifications could I

only be performed with the units shut down. Thus outages for modifications, maintenance, and refueling have been longer than are normally required. In addition, generic equipment problems, such as recirculation. pump seal failures, snubber failures, and inadvertent operation of relief valves, and specific operational problems, such as condenser tube leaks and pipe corrosion, have had a negative impact on overall plant performance. These modifications and problems are discussed further in answer to

~

Interrogatory No.15AA-(2d)-18(n) below.

Since the Brunswick units were declared commercial, CP&L has made a number of modifications to improve reliability, correct generic design problems, and comply with regulatory directives. in the area of reliability and efficiency improvements, the Company has completed over 150 separate modifications since the units began commercial operation. For example, new seal packages were installed on the reactor recirculation pumps in 1980 (Unit 2) and 1983 (Unit 1). Snubbers were rebuilt in 1981 (Unit 1) and 1982 (Unit 2). This rebuilding effort incorporated an improved poppet valve design which climinated a major cause of snubber failures and repairs. In 1983, the Unit I condenser was retubed with titanium tubes to provide greater tube corrosion resistance and integral-grooved tube sheets were installed to minimize the potenthl for tube-to-tube sheet leaks. A similar modification is planned for Unit 2 during the next major outage.

(m) Does CP&L believe there are reasons for the poor performance of the Brunswick nuclear units it co-owns and operates that relate to (i) construction (ii) design (iii) operation (iv) management (v) NRC regulations (v) CP&L non compliance with NRC regulations?

OBJECTION: Applicants object to subpart (iv) of this Interrogatory on the basis that it exceeds the proper bounds of discovery on the capacity factor issue by delving into the area of management capability. In admitting Contention 15AA, the Board stated that

"[o]ur admission of this contention is not to be construed as reopening discovery' on the subject of management capability. Memorancum and Order on Wells Eddleman's

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l Contentions on the Staff Draft Environmental Statement at 7 (August 18, 1983).

, With,rspect to the remaining subparts, Applicants recognize that the listed factors have had an impact on the performance of Brunswick as they do for any other commercial, reactor.

(n) If Answer to any part of (m) above is affirmative, please state for each such part, each reasons CP&L believes the matter inquired about in that part has contributed to lower or poor performance of the Brunswick nuclear units, in terms of capacity factor 1 over their operating lifetimes.

ANSWER: The factors identified in Interrogatory 15AA-(2d)-18(m) above are interrelated. Thus, no single factor can be specifically addressed independent of other f ac tors.

With respect to design and construction, the performance of the units has been affected by equipment and design problems such as those associated with recirculation i

pump seals, snubbbrs, relief valves, main steam isolation valves, reactor water clean-up system, circulating water system, corrosion and condenser tube leaks. Some of these problems have been generic problems within the industry and some have been specific to Brunswick -(i.e'. corrosion and condenser tube leaks due to the estuarine environment). In all cases, however,,CP&L has diligently pursued resolution of these problems in a timely manner.

Problems such as those listed above obviously create operating difficulties, such as more frequent outages or, operation at reduced capacity for various periods of time, which lower a plant's capacity factor. One of the more significant impacts in this regara .

has been load reductions and outages required to plug condenser tube leaks.

NRC regulations have also had an impact on performance. For example, the need to make modifications to the torus, reanalyze and m,odify seismic supports, and install add:tional fire protection equipment has resulted in longer than normal refueling, maintenance, and modification outages.

In addition, escalating and changing regulatory requirements have frequently lead to

the need to modify procedures, test and inspection programs, and operating limits, which has contributed to the length of outages. The modifications and changes required due to regulatory criteria have of necessity received priority attention, thus diverting resources from, or delaying, some of the design and operational improvements that had been .

planned.

(o) If answer to any part of (m) above is other than affirmative, please state all  ;

basis for each such belief.

ANSWER: Not applicable.

Dated: November 23,1983.

Objections submitted by:

w & -

Dale E. Ilollar, Esq.

Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 Attorneys for Applicants:

Thomas A. Baxter, P.C.

John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 Richard E. Jones Samantha Francis Flynn Carolina Power & Light Company Post Office Box 1551

. Raleigh. North Carolina 27602 t (919) 836-6517

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g I-I DOCKETED UNITED STATES OF AMERICA USHF.C NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA 1h 19 28 AIO G2 In the Matte,r of ) CFFICE OF SEc6t 4 h 00C4ETitlG & SE?v.. .

) BhANCH CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY )

) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ) 50-401 OL Units 1 & 2) )

AFFIDAVIT OF B. M. WILLIAMS County of Wake )

)

State of North Carolina )

B. M. Williams, being duly sworn according to law, deposes and says that he is Director of Staff Services - Planning and Coordination Department of Carolina Power &

Light Company; that the answers to Interrogatories on Eddleman Contention 15AA contained in " Applicants' Supplemental Answers to Wells Eddleman's Interrogatories on Eddleman Contention 15AA' are true and correct to the best of his information, knowledge and belief; and that the sources of his information are officers, employees, agents and contractors of Carolina Power & Light Company.

I * ,.

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- . I L i '., B. M. Williams Sworn to and subscribed before me this 23rd day of November,1983. ^

a Notary Public -

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My commission expires: 011 k /7 ff U j '

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