ML20086T836

Statement of Matl Facts as to Which There Is No Genuine Issue

ML20086T836
Person / Time
Site:	Harris
Issue date:	02/28/1984
From:	Hollar D CAROLINA POWER & LIGHT CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20086T831	List: ML20086T829 ML20086T836 ML20086T839
References
OL, NUDOCS 8403070058
Download: ML20086T836 (3)

Text

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February 28,1984 4

UNITED STATE 584F EME1(ICO2 N i NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFET&AND LICENSING BOARD itnte In the Matter of )

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r CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY )

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

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO hHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON EDDLEMAN CONTENTION ISAA Pursuant to 10 C.F.R. 52.749(a), Applicants state, in support of their Motion for Summary Disposition 'of Eddleman Contention 15AA in this proceeding,' that there is no genuine issue to be heard with respect to the following material facts:

1. Eddleman Contention 15AA challenges the NRC Staff's estimate in the Draft Environmental Statement that the Harris Plant will operate at a 55 percent capacity factor for; purposes of evaluating its benefits in connection with the National Environmental Policy Act (NEPA) cost-benefit balance.

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2. Historical performance data demonstrates that the 28 nuclear units in the United E ' States with modern Westinghouse nuclear steam supply systems (NSSS) have an average capacity factor of 61.8 percent. Affidavit of Robert H. Koppe at 7.

3. The performance of these 28 Westinghouse units is an appropriate basis upon which to judge the likely capacity factor of the Harris Plant. M. at 8.

4. There has been no showing that Beaver Valley 1, McGuire 1 and North Anna 1 are any more similar to Harris than other Westinghouse NSSS units, nor would it be appropriate to project the capacity factor for the Harris Plant based exclusively on the performance of those three units. I_d. at 15-17.

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5. There have been numerous design improvements in the Harris Plant that should further increase its capacity factor over that of presently operating plants. M. at 10-13.

6. Among the design improvements in the Harris Plant are improvements in steam generator design; since the Harris Plant will not use phosphates for feedwater treatment and will not be cooled with sea water, even without steam generator improvements it would not be expected to have significant capacity factor lossas from steam generator problems. M. at 12.

7. There has been no showing that Carolina Power & Light Company's involvement in the design and construction of the Harris Plant will result in a lower capacity factor.

M. at 17-18. '

8. Even if it were assumed that the management of the Harris Plant would be below average, it is reasonable to project that the Plant will still achieve a 55 percent capacity factor. M. at 18.

9. For almost 13 years, Carolina Power & Light Company has operated H. B.

Robinson Unit 2-a three-loop Westinghouse PWR of a design generally similar to the Harris Plant-with a lifetime capacity factor of 62.4 percent. _I_d. at 18.

10. Considering all the available information, the NRC Staffs estimate of a 55 percent capacity factor is reasonable and provides a reasonable basis upon which to assess the benefits of the plant for purposes of the NEPA cost-benefit analysis.

This 28th day of February,1984.

Respectfully submitted, Dale E. Hollar, Esq.

Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 2-4

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Attorneys for Applicants:

Thomas A. Baxter, P.C.

John H. O'N eill, Jr., P.C.

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

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones, Esq.

Samantha Francis Flynn, Esq.

Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517

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