ML20093J348
| ML20093J348 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/24/1984 |
| From: | Bridenbaugh D MHB TECHNICAL ASSOCIATES |
| To: | |
| Shared Package | |
| ML20093J320 | List: |
| References | |
| OL, NUDOCS 8407300053 | |
| Download: ML20093J348 (5) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the-Matter of
)
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PACIFIC GAS AND ELECTRIC COMPANY )
DOCKET Nos. 50-275 O.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
' Plant, Unit Nos. 1 and 2)
)
)
AFFIDAVIT OF DALE G. BRIDENBAUGH DALE G. BRIDENBAUGH, being first duly sworn, state under oath as follows:
'-jj 1.
In 1981 I, Dale G. Bridenbaugh,coauthored an affidavit with Richard B. Hubbard regarding the risks surrounding operation of Diablo Canyon, Units 1 and 2 at low power.
This affidavit, entitled Affidavit of Dale G.
Bridenbaugh and Richard B. Hubbard, was dated August 11, 1981, and was submitted to the Nuclear Regulatory Commission.
A copy is attached.
2.
Paragraphs 11 and 12 of the 8/11/81 affidavit address the potential hazards resulting from a release of built up fission products as a result of an accident during 5% power operation.
It also discusses the radioactive contamination and irradiation of plant systems and components that would occur as a result of the 5% power operation.
3.
It is my understanding that PG&E is now seeking approval for a full power license for Diablo Canyon Unit 1.
The granting of such full power approval is potentially 8407000053 840725 PDR ADCCK 03000275 0
r hazardous and needs to be carefully considered.
The risks outlined in the above paragraphs of the 8/11/81 affidavit are still present and would be increased by a significant factor by operation at full power.
It is therefore of even greater importance that the plant has been adequately designed and constructed and that PG&E is properly qualified to operate it than was the case for low power operation.
Accordingly, the risks described in paragraphs 11 and 12 of the 8/11/81 affidavit continue to be of concern.
I have read the foregoing and swear' that it is true and accurate to the best of my knowledge.
A
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DALE G.
BRIDENBAUGH Subscribed and sworn to before me on thisc2 Y# ay of sc[y d
1984.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
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-In the Matter of
)
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PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos.'50-275 0.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
Plant, Unit Nos. 1 and 2)
)
)
AFFIDAVIT OF DALE G. BRIDENBAUGH AND RICHARD B. HUBBARD DALE G. BRIDENBAUGH and RICHARD B. HUBBARD; being first duly sworn, state under oath as follows:
1.-
In preparing this affidavit, affiant Richard B.
Hubbard reviewed PG4E's proposed special low power test pro-gram as set forth in the low power license application and as further described in PGGE's safety analysis report provided to the NRC Staff on February 6, 1981.
He also attended, as a consultant to Governor Brown's counsel, all sessions of the recent low power test proceecings which were held in San Luis r
Obispo from May 19 to May 22, 1981.
Thus, he is familiar with the duration of the low power tests as postulated by PGSE and Staff witnesses.
Further, he has reviewed the actual schedule for fuel loading, initial criticality and zero power testing, and low power testing of large'PWR's which have occurred in the
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post-TMI period,'particularly North Anna-2, Salem-2, and Se-Y, quoyah-1.. In addition, on. July 10,.1981, Hubbard accompan-
-ied Commissioner Gilinsky on his tour of the Diablo Canyon facility.
A recent statement of Hubbard's professional qualifications and experience is set forth in Exhibit 16 of
" Opposition of Governor Edmund G. Brown, Jr. to the NRC Staff and Pacific Gas and Electric Company Motions for Reconsidera-tion and Summary Disposition," dated April 24, 1981.
2.
' Affiant Dale G. Bridenbaugh is a Professional Nu-
- clear Engineer,atechnical consultant, co-founder and president of MHB Technical Associates, technical consultants on energy and environment, with offices at 1723 Hamilton Avenue, Suite K, San Jose, California..He has participated as an expert witness in licensing proceedings before the U.S. Nuclear Regulatory Commission (NRC); has served as a consultant to the NRC; has testified at the request of the Advisory Committee on Reactor Safeguards; has appeared before various committees of the U.S.
Congress and testified in various state licensing and regulatory proceedings.
Additional details of Bridenbaugh's experience and qualifications are set forth in Attachment A, which is at-tached hereto.
3.
The purpose of this affidsvit is twofold:
First, to estimate the elapsed time.which is likely to be required after issuance of a low power operating license to load fuel and to
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ec complete the special low power tests at or below 5% of Rated
' Thermal Power as Pacific Gas and Electric Company has proposed
'for Diablo Canyon Unit 1; second, to identify the technical i
difficulties and increased costs associated with modifying the structures, systemf,~ and components of the plant should further. modifications be required after fuel has been loaded
.an'd operation commenced.
The results of our review are sum-marized in the following paragraphs.
4.
During Commissioner Gilinsky's tour of the Diablo Canyon facil'.ty,-both NRC and PBGE personnel emphasized PGGE's
~ readiness to load fuel.
The necessary fuel is presently onsite em in a building immediately. adjacent to the Containment Building.
Further, due to the duration of the licensing process, PGGE has had sufficient time to conduct, and in some cases reconduct,
'its pre-operational tests as set forth in Section 14.1 of the Final Safety Analysis Report.
Thus, we conclude that Diablo Canyon-Unit 1 equipment is in an advanced state of readiness to load fuel, and that virtually all preliminary testing (see FSAR Table 14.1-1) possible prior to fuel loading has been completed. /
Further, we conclude that PGGE should be able to promptly load fuel once such authorization is received from the NRC.
5.
We estimate that the fuel loading task should be com-pleted in less than one week elapsed time.
For example, at
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A rec 6nt Nuciconics Week article indicates that all steps
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prior to fuel load will be completed by approximately August 12, 1981 (p. 4, Nucleonics Week, July 23, 1981).
In general, all pre-operational testing will be completed before fuel loading (FSAR, p. 14.1-8). -
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-Salem-2, a Westinghouse-designed PWR similar in design and rat-
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'ing to Diablo Canyon, fuel loading began on May 23, 1980 and wasLeompleted on May'27, 1980.
More specifically, a PGGE 1 spokesman recently estimated that preparation and fuel loading of Diablo Canyon Unit 1 could be completed in about one month
.after issuance of a low power license (see July 18, 1981 ar-ticle from.the' San Francisco Chronicle, which is attached here-to as Attachment B).< -Therefore, we conclude that it is reason-
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E able to. expect that fuel loading of Diablo Canyon could be com-pletedlin one to two weeks and certainly no more than 30 days
'after the issuance of a low power test license.I/
- 6. ;The next phase of'startup-and testing includes initial criticality and low power testing, FSAR Table 14.1-2 summar-izes the normal tests which will be performed.
In addition,
'the scope and duration of-the special low power tests were des-cribed in' detail during the recent low power proceedings in San r1 Luid Obispo.- The Board, in the partial Initial Decision dated July 17, 1981, noted at page 24, paragraph 61, that PGGE has
- proposed a series of eight special low power tests.
The propos-ed tests would probably last for no more than one month end'in actuality, as cited by the Board, would perhaps take only about eighteen days (Tr. 10,726-10,728).
Other references to the "re-latively few days" encot. passed by the proposed low power test
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It has been reported that PGGE expects fuel loading to take no longer than two weeks (p.' 4, Nucleonics Week, July 23, 1981)..
program are set forth in the recent decision by the Board at page 25 (paragraph 65), page 32 (paragraph 82), and page 33 (paragraph 83).
Therefore, we believe that it is reasonable to expect that, absent major problems, initial criticality and
. low power testing can be conducted in an elapsed time of less than 30 days. 'Thus, assuming a 30-day period to complete fuel loading (which we believe to be very conservative), the entire fuel load and testing program can easily be completed in no more than 60 days.
7.
The reasonableness of a 60-day cycle from license is-suance.to completion of the special low power tests was further confirmed during Commissioner Gilinsky's tour of the Diablo Can-yon facility.
In response to a question, the Diablo Canyon Plant Manager, Robert C. Thorn terry, stated in Hubbard's pre-sence that PGGE's current schedules forecast that fuel loading, zero power testing, and the special low power test program will be completed approximately 58 days after receipt of a low power license.
Mr. Thornberry added that the schedule might need to be increased.if major unanticipated problems were encountered during the test program.
8.
In order to be conservative, we believe it may be ap-propriate to add 15 to 30 days to the fue] loading and low pow-er testing schedule to allow time for resolution of any routine unanticipated events.
In reaching the preceding conclusions,
.m
_ we have assumed a routine startup during which no major acci-dent, such'as a seismically induced LOCA, occurs.
Thus, we are not_ stating any conclusion on either the risk potential during low power testing or the probability of accidents oc-curring during such1 testing.
Our sole purpose is to express the. view that absent unforseen events, the PGGE startup and low power testing program should require no more than 30 days to complete after fuel is loaded.
9.
The post-TMI experience and the current schedules for startup testing lend further support to the preceding conclu-sions.
The first plant granted an operating license in the post-TMI period was Sequoyah-1, which received a low power license on February 29,-1980.
Fuel loading commenced on March
'2, 1980_and was completed on March 8, 1980.
Two major prob-lems thereafter seriously delayed the initial criticality of I
Sequoyah-1.
First, in response to IGE Bull. 79-14, TVA re-quired approximately 60 days to inspect and rework pipe hangers and-supports.
Second, in parallel with the hanger reinspection, TVA conducted a base line inspection of the turbine blades.
The' turbine reinspection required 4-5 weeks of elapsed time.
Routine maintenance problems and pre-operational testing re-sulted in further delays.
Initial criticality was achieved on July _5, 1980.
Following zero power testing, the special low power testing program began on July 12 and was completed on,
1 i
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July 18, 1980.
10.
The second plant to receive a post-TMI license to load fuel and conduct special low power tests was North Anna-2.
The authorization to load fuel was issued on April 11, 1980 and the low power testing was completed by July 1, 1980, an elapsed time of less than 80 days.
The Salem-2 low power li-cense was issued on April 18, 1980.
As set forth in paragraph 5, fuel loading was completed on May 27, 1980.
Initial cri-ticality was achieved on August 2, 1980 and the special low power test program was completed on August 29, 1980.
The two months delay between fuel loading and initial criticality was 1crgely due to the need to conduct routine pre-operational maintenance testing and surveillance testing (such as valve operability) which could have been accomplished prior to fuel load.
As presented in paragraph 4, we believe that these pre-operational tests will be accomplished at Diablo Canyon prior to mid-August, 1981.
Thus, we conclude that the actual dura-tion of the Salem-2, North Anna-2, and Sequoyah-1 fuel loading and low power testing programs is not inconsistent with our conclusions for Diablo Canyon as set forth herein.
11.
Table I of the testimony of Applicant's witness, Dr. Brunot, in the low power test proceedings sets forth the fission product inventories which will be produced in the core during the proposed Diablo Canyon low power test program.
For.
example, the inventory of iodine-131, one of the radionuclides which is a significant contributor to the dominant exposure modes for accidents requiring off-site emergency preparedness, is estimated by Dr. Brunot as 4,500,000 curies (approximately 1/20th the full power value as set forth in FSAR Table 11.1-4).
In contrast, for the design basis LOCA addressed by the Appli-cant in the FSAR for full power operation, only 192 curies of iodine-131 were postulated to be released to the environment in the first two hours (FSAR Table 15.5-12).
Therefore, be-cause of the relatively rapid buildup (half-life of hours to days) of the radioactive isotopes listed in Table 3 of NUREG-
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0654 which dominate prompt health consequences resulting from postulated accidental releases, we conclude that even at 5%
power the fission products available for release pose a sig-nificant potential hazard.
12.
Operation at low power will not only cause a buildup of fission products within the reactor core, making it inac-cessibic for contact repair and/or modification but will also cause a spread of radioactive contaminants throughout the pri-mary portion of the steam supply system.
It will also contam-innte certain auxiliary systems such as the Chemical and Volume Control System, Equipment and Floor Drainage Systems, and the Liquid Radioactive Waste System.
If fuel failures and/or steam generator tube failures or leaks are experienced, a large number
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NUREG-0654, Rev. 1 (FEMA-REP-1), " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Pre-paredness in Support of Nuclear Power Plants," November, 1980.
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of other systems, including the turbine, condensate, and other components within the Steam and Power Conversion System could become contaminated.
Contamination and irradiation of such equipment greatly increases the care required and the time and cost of future modifications that could be required at the plant.
It is, therefore, important that power operation, in-cluding low power testing, not be permitted until reviews and evaluations that could lead to required plant modifications have been completed.
13.
Based on the foregoing, we conclude that fuel loading, initini criticality, and low power testing, including the spe-cial low power tests, can be accomplished at Diablo Canyon Unit 1 within approximately 60 days, with an outside maximum elapsed time of approximately 90 days, after issuance of the low power operating license.
We further conclude that the fuel loading portion of the startup schedule should be completed within less than 30 days following issuance of the low power license.
Final-ly, we conclude that operation at low power will contaminate some of the facility's components and systems.
This unnecessary com-mitment of resources creates technical difficulties and increased costs associated with modifying the reactor, should further modi-fication be required after fuel has been loaded and power opera-tion commenced.
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o I have read the foregoing and swear that it is true and accurate to the best of my knowledge, j
J2 DALE G. BRIDENBAUGli M
RICIIARD B. IlUBBARD i
// c4 Subscribed and sworn to before me this day of August, 1981.
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j UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'I BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD TA di 26 Pd :37 i
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)
In the Matter of
)
)
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PACIFIC GAS AND ELECTRIC COMPANY )
Doc ke t. Nos. 50-275 0.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
Plant, Units 1 and 2)
)
)
)
P CERTIFICATE OF SERVICE I hereby certify that on this 25th day of July, 1984, I have served copies of the foregoing JOINT INTERVENORS' APPLICATION FOR A STAY, mailing them through the U.S. mails, first class, postage prepaid, to the attached list.
MMWdt!cwGtw l
AMANDA VAHONA b
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I SERVICE LIST
- Nunzio Palladino, Chairman
- James Asselstine, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555
- Lando W. Zech, Jr. Commissioner
- Frederick Bernthal, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555
- Thomas Roberts, Commissioner
- Samuel J. Chilk, Secretary U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555
- Thomas S. Moore, Chairman
- Dr. W. Reed Johnson Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Com.nission Commission Washington, D.C.
20555 Washington, D.C.
20555
- Dr. John H. Buck
- Docket and Service Branch Atomic Safety & Licensing Office of the Secretary Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555
- Lawrence Chandler, Esq.
Office of the Executive Legal Director - BETH 042 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 David S. Fleischaker, Esq.
Post Office Box 1178 Oklahoma City, OK 73101
- Bruce Norton, Esq.
Norton, Burke, Berry & French 2002 E. Osborn Phoenix, AZ 85064
- Malcolm H. Furbush, Esq.
Vice President & General Counsel Philip A. Crane, Esq.
Pacific Gas and Electric Company 77 Beale Street San Francisco, CA 94106.
o John Van de Kamp, Attorney General Andrea Sheridan Ordin, Chief Attorney General Michael J. Strumwasser, Special Counsel to the Attorney General Office of the Attorney General State of California 3580 Wilshire Boulevard, Suite 800 Los Angeles, CA 90010 Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, CA 95125 Virginia and Gordon Bruno Pecho Ranch Post Office Box 6289 Los Osos, CA 93402 Sandra and Gordon Silver 1760 Alisal Street San Luis Obispo, CA 93401 Carl Neiburger Telegram Tribune Post Office Box 112 San Luis Obispo, CA 93402 Tom Devine Government Accountability Project 1901 Qde Street, N.W.
Washington, D.C.
20009 Eric Havian, Esq.
Heller, Ehrman, White & McAuliffe 44 Montgomery Street., 31st Floor San Francisco, CA 94104
- Via Express Mail --
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