ML20117A411

Affidavit of DG Bridenbaugh & Gc Minor in Response to Affidavit of Jd Leonard.Certificate of Svc Encl

ML20117A411
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/06/1985
From:	Bridenbaugh D, George Minor MHB TECHNICAL ASSOCIATES, SUFFOLK COUNTY, NY
To:
Shared Package
ML20117A379	List: ML20117A375 ML20117A391 ML20117A411
References
ALAB-800, CLI-85-01, CLI-85-1, OL-4, NUDOCS 8505080219
Download: ML20117A411 (15)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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00LMETED UO Be fore the Commission 15 MY -7 P3 :20 In the Matter of ) 0Fi . i 3b.u.

GCC.R TING & der < v .

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LONG ISLAND LIGHTING COMPANY, ) Dockethh"S0-322-OL-4

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(Shoreham Nuclear Power Station, Unit 1)) (Low Power)

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AFFIDAVIT OF DALE G. BRIDENBAUGH AND GREGORY C. MINOR IN RESPONSE TO AFFIDAVIT OF JOHN D. LEONARD, JR.

1. My name is Dale G. Bridenbaugh. I am president of MHB Technical Associates ("MHB"), a technical consulting firm

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specializing in nuclear power plant safety and licensing mat-ters, located at 1723 Hamilton Avenue, Suite K, San Jose, California 95125. I received a Bachelor of Science degree in mechanical engineering from South Dakota School of Mines and Technology in 1953 and am a licensed professional nuclear engi-neer. I have more than 30 years experience in the engineering field, primarily in power plant analysis, construction, mainte-nance and operations. Since 1976, I have been emplo;1d by MHB and have acted as a consultant to domestic and foreign govern-ment agencies and other groups on nuclear power plant safety and licensing matters. Between 1966 and 1976, I was employed by the Nuclear Energy Division of General Electric Company

("GE") in various managerial capacities relating to the sale, G

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service and product improvement of nuclear power reactors manufactured by that company. Between 1955 and 1966, I was employed in various engineering capacities working with gas and steam turbines for GE. I have written numerous technical papers and articles on the subject of nuclear power equipment and nuclear power plant safety and have given testimony on those subjects.

2. My name is Gregory C. Minor. I am vice president of MHB. My education background is in electrical engineering (with a power systems option) in which I received Bachelor of Science (University of California, Berkeley, 1960) and Master of Science (Stanford, 1966 ) degrees. I have over 24 years of experience in the nuclear industry, including design and testing of systems for use in nuclear power plants. Since 1976, I have been employed by MHB and have acted as a consul-tant to domestic and foreign government agencies and other groups on nuclear power plant safety and licensing matters.

Between 1965 and 1976, I was employed by the GE Nuclear Energy Division as a design engineer and manager of engineering design organizations. My responsibilities included the design, testing, qualification and pre-operation testing of safety equipment and control rooms for use in nuclear power plants.

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3. Our experience with the Shoreham plant started when we were employed by GE. At that time we were involved with the I design of reactor system components for Shoreham and imple-mentation and resolution of problems related to that design.

After leaving GE, we have been involved with the Shoreham case on a virtually continuous basis since 1977, when we were origi-nally retained as consultants to Suffolk County. As consul-tants on the Shoreham plant, we have performed diverse assign-ments, focusing primarily on technical reviews of safety and cost issues. Over the course of the Shoreham proceedings, we have visited the plant on numerous occasions and have testified -

on diverse issues before the NRC's Atomic Safety and Licensing Board ("ASLB") and the State of New York Public Service Commis-sion ("NYPUC"). In August 1984, we testified on behalf of Suffolk County in the ASLB's Shoreham exemption hearings where the question of low power operation without nuclear qualified emergency diesel power sources was addressed.

4. In this Affidavit, we address certain statements made by John D. Leonard, Jr. in an affidavit filed by LILCO to sup-i port its Petition for Review of ALAD-800.

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SYSTEM TESTING DURING LILCO'S PROPOSED PHASES III AND IV IS VERY LIMITED

5. LILCO asserts that 54 systems will be required to be in service, operated and tested during Phases III and IV testing (Notaro and Gunther Affidavit at 16, cited in Leonard Affidavit at 10). This is misleading since 41 of those systems are already operational and have been checked out as part of Phase I and Phase II testing (Notaro and Gunther Aff. at 8 and 9). Thus, according to LILCO, Phases III and IV provide the opportunity to check out only 13 additional systems. However, this number is also overstated because LILCO. witnesses testified in the exemption hearings that LILCO will not roll the turbine during Phase III and IV testing (Tr. at 776).

Therefore, the Turbine Generator and the turbine control por-tion of the EHC systems will not be operated in Phases III and

~IV, contrary to LILCO's recent suggestion. (Notaro and Gunther Aff. at 16). In addition, the support systems, consisting of the Turbine Lube Oil System, Generator Seal Oil Systems, and Steam Seal System, will not be finally checked out until the turbine generator is actually run. Thus, only 8 additional systems could be checked out during Phase III and IV testing.

6. Among the systems listed by LILCO to be checked during Phase III and IV testing are the HPCI and RCIC systems which rely on steam driven turbines. Contrary to LILCO's suggestion, however, it is possible to test these systems without the nu-clear operation inherent in Phases III and IV. The closed re-actor system can be heated to normal operating temperature and pressure by running the two large (5600 HP) recirculation pumps. This would permit sufficient steam to be directed to the RCIC turbine and HPCI turbine for testing. Thus, if LILCO were serious about its intent to find any problems as early as possible, the RCIC and HPCI systems could be operationally "de-bugged" without going critical and without having to irra-diate the reactor fuel and reactor components at the 5% power. _

level.

7. In addition, there are several tests which cannot be properly performed at low power levels (5% or less). These in-cluder

. APRM/IRM calibration at overlap point

. Set APRM trip reference point at 55%

. APRM calibration (inaccurate at very low readings and would have to be repeated at higher pow levels)

. Turbine roll and balance at 1800 RPM

. Generator exciter test

. Moisture separator-reheater and drains (dynamic test)

. Extraction steam (dynamic test)

. Local power range monitor calibration

8. Considering that Phases III and IV would only add a few systems to those already checked out, other systems can be tested without nuclear operation, and still other systems re-quire higher power levels for testing, there is relatively lit-tle benefit to be gained by pursuing Phase III and IV operation for the purpose of system testing.

ADVERSE IMPACTS OF LOW POWER OPERATION

9. Low power testing necessarily causes irreversible changes to a nuclear reactor and its supporting systems. We discuss below these changes with specific reference to the Shoreham plant.

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10. There is necessarily significant irradiation of the nuclear fuel as a result of low power testing. This irradiation results in the build-up of quantities of fission products within the fuel which requires that the fuel subse-quently be handled, transported, and treated as irradiated fuel. Such irradiation necessarily increases the risk of worker exposure to harmful radiation.

11. In its non-irradiated condition, the fuel loaded into the Shoreham core probably had a recovery (or salvage) value nearly equal to the original purchase value for that fuel.

This fuel, if not irradiated, likely could have been sold to

other nuclear plants to use as is, or, if necessary, to have it reconfigured for a different reactor. (For example, some bun-4 dies might have required manual disassembly and rod rear-rangement or reconfiguration of the pellets for the necessary pattern of enrichment.) The fuel still has a salvage value even after the light irradiation involved in Phases I and II.

However, once the fuel is substantially irradiated and there is a substantial build-up of fission products (even though rela-i tively small compared to what would be built up after long term full power operation), as would occur during Phases III and IV,

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it makes' fuel reconfiguration, and therefore most opportunities j for reuse of the fuel, more complicated and costly and there-fore far less likely to be implemented. The result is that the cost of the fuel is not recoverable and therefore it is a po-tential cost of the decision to conduct low power testing.

According to LILCO, the Shoreham fuel is worth approximately

$65 million.

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12. LILCO takes the position that once the Shoreham fuel has been through Phase II criticality (to a power level of from 0.0001% to 0.001%), it is by definition " irradiated" and is to-tally without salvageable value. We agree that the achievement of the extremely low power criticality of Phase II for a brief period of time does irradiate the fuel to a measureable level i

and that care in handling is subsequently necessary, and some i

reduction in resale value would occur. There is, however, a factor of 500 to 5000 difference between the Phase II power level and the 5% level planned for Fhase IV of the Shoreham low l power testing program. In addition, operation at 5% power is projected to last for a much longer time than the brief period at criticality involved in Phase II. We believe that substan-tial positive salvage value could be realized from the fuel in its post-Phase II condition, although not as much as if the fuel were not irradiated at all. There would be no such value if the fuel were used at the 5% power level, however. The NRC Staff apparently shares our view in this matter and believes that after a decay period of about 6-12 months, the post-Phase II fuel could be shipped in its original shipping containers if further irradiation is not undertaken. (See Affidavit of Edward F. Goodwin, dated February 20, 1985, filed by NRC in U.S. Court of Appeals, at 9.)

13. During low power testing other components of the Shoreham plant would also be irradiated to the extent that sig-nificant potential salvage value would be lost. These include the 137 control rods and control rod drives, the 31 local power range monitors, and a number of source and intermediate range neutron monitors. We estimate the replacement value of these

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components to be at least $2-6 million. These components are virtually identical in all BWRs and are periodically replaced.

Thus, a resale market for them should exist unless they are heavily irradiated. The NRC Staff appears to agree with our opinion. (Goodwin Affidavit cited above, at 10). LILCO has asserted that after Phase II of low power testing, these compo-nents would be "as radioactive" as the fuel and thus have no salvage value. We disagree. The radiation levels present after Phase II operation would not, in our opinion, preclude altogether their transfer and installation in other reactors, although it would be more difficult and complicated than if -

they were not irradiated at all. Additional irradiation during Phases III and IV would reduce their marketability to practi-cally nothing.

14. Additional costs resulting from a decision to perform low power testing are the costs of defueling, decontaminating, and decommissioning, and disposal of the fuel as well as por-tions of the primary reactor system following a low power testing period in the event that a full power license is not obtained. Low power testing creates an inventory of radioac-tive fission products within the fuel. Sustained operation at power levels up to 5% will irreversibly irradiate the 137 con-trol rods, the 31 local power range monitors, startup sources L- 1

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1 and instrumentation monitors, and portions of the reactor l

internals and structures (in addition to the fuel). It can 1

also contaminate other reactor components, equipment, and piping, and if contaminated, special care would be required in handling these items. The cost of necessary removal /-

disposal / decontamination efforts could be tens of millions of dollars, depending on the specific disposal requirements, and 1

such efforts carry with them the potential for worker radiation l exposure.

15. We disagree with LILCO's previously stated $13 mil-lion estimate of-the costs of decontaminating, decommissioning and disposal following low power testing. First, our estimated cost (tens of millions) -- but apparently not LILCO's -- in-cludes the cost of disposal of the irradiated fuel as high level radioactive waste. LILCO agrees that the Shoreham fuel, when irradiated at 5% power levels, must be treated for regula-tory and commercial purposes as irradiated fuel. The U.S. De-partment of Energy has published expected costs for the receipt and ultimate disposal of irradiated fuel. The costs are cur-  ;

rently being collected at a rate of $.001/ kwhr of generation for fuel exposed now to be disposed of by DOE in the future.

For fuel with a design exposure of 15,000 MWD (t)/ ton this cost is equivalent to approximately $120,000 per ton. The potential l

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cost for disposal by DOE of the 100+ tons at Shoreham is therefore approximately $12,000,000, not counting transporta-tion or possible cost increases. In addition, no disposal fa-cility is planned nor expected before about the year 2000, some 15 years in the future. LILCO would therefore be required to store and safeguard the spent fuel on site until that time.

Assuming an operational and security staff of at least 10-15 people for this core, an annual cost of $500,000 to $1,000,000 is not unreasonable and is probably low. The cost of spent fuel disposal alone thus becomes a $20 to 30 million obliga-tion. Reactor component removal, handling and disposal would-be additionally required. We conclude that LILCO's $13 million figure is greatly understated.

16. The conduct of low power testing of necessity re-quires some worker exposure during the course of the testing.

This may not be large and probably would not exceed allowable limits, unless errors were made. However, it is an additional environmental impact which results from low power testing.

17. During Phases I and II of LILCO's Shoreham low power testing program, some irradiation of the fuel and contamination of reactor internals and components, with the resulting econom-ic costs, occurred. The amount of irradiation and

contamination, and resulting economic costs involved in Phases III and IV of the low power testing are substantially greater.

18. The essential purpose of a low power license is to test reactor systems which cannot be effectively tested in non-critical conditions. It is necessary to conduct such testing prior to operating the plant at higher power levels (i.e., greater than 5% power). However, during the testing, the Shoreham reactor would never be put in the "run" mode and the turbine would not be operated because sufficient steam will not be produced. Therefore there would be no electric power supplied to the grid as a result of the testing, and there would be no displaced oil or fuel cost savings. Instead, power from the grid would be required to run the plant during the tests. Thus, none of the benefits assumed in the NRC's 1977 EIS for Shoreham would be achieved by low power testing; howev-er, as noted, low power operation would result in environmental impacts, such as plant contamination with radioactive material, the likely loss of the resale value of the fuel and other com-ponents once they become irradiated, the cost of decontamination, decommissioning and disposal, and worker expo-sure.

19. Because low power testing standing alone produces no benefits but does have serious adverse effects, it is our i

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opinion that there is no reason to conduct low power testing just for its sake alone. Rather, low power testing can be ra-tionally justified only in circumstances where there is no sub-stantial doubt the.t the plant subsequently will operate at higher power levels so that its benefits (i.e., generation of

. electricity) will be available to offset the adverse effects (fuel irradiation, radioactive contamination, potential worker exposure) which cannot be avoided. In our technical opinion, the optimum time for performing low power testing of any nucle-ar reactor is shortly before full power operation is reliably anticipated to begin. -

DALE G. BRIDENBAUGH GREGORY [. NOR Subscribed and sworn to before me on this 6th day of May, 1985.

C ~$d/l Catherine Citriano-Nncric NOTARY PUBLIC My Commission expires g,gg$

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_- My Comm tapan New IS. lHS {

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission 00thET Err USNRC

)

In the Matter of ) 15 MY -7 P3:21

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LONG ISLAND LIGHTING COMPANY ) Docket No. 5 0-3 2 2-OL-4

) bbb)d;' 'N" (Shoreham Nuclear Power Station, ) -

SRANCH Unit 1) )

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CERTIFICATE OF SERVICE I hereby certify that copies of Suffolk County and State of New York Petition for Reconsideration of CLI-85-1 and Affidavit ~

of Dale G. Bridenbaugh and Gregory C. Minor in Response to Affidavit of John D. Leonard, Jr., have been served on the following this 7th day of May 1985, by U.S. mail, first class, except as otherwise noted.

James L. Kelle.y, Chairman

• Edward M. Barrett, Esq.

Atomic Safety and Licensing Board Long Island Lighting Company U.S. Nuclear Regulatory Commission 250 Old Country Road Washington, D.C. 20555 Mineola, New York 11501 Judge Glenn O. Bright

• Honorable Peter Cohalan Atomic Safety and Licensing Board Suffolk County Executive U.S. Nuclear Regulatory Commission H. Lee Dennison Building Washington, D.C. 20555 Veterans Memorial Highway Hauppauge, New York 11788 l I

Judge Elizabeth B. Johnson #

Oak Ridge National Laboratory Fabian Palomino, Esq.#

P.O. Box X, Building 3500 Special Counsel to the Oak Ridge, Tennessee 37830 Governor Executive Chamber, Room 229 Atomic Safety and Licensing State Capitol Appeal Board Albany, New York 12224 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 W. Taylor Reveley, III, Esq.*

Anthony F. Earley, Jr., Esq.

Robert G. Perlis, Esq.* Robert M. Rolfe, Esq.

Edwin J. Reis, Esc. Hunton a Williams Office of Exec. Legal Director 707 East Main Street U.S. Nuclear Regulatory Commission Richmond, Virginia 23212 Washington, D.C. 20555

2-Mr. Martin Suubert James Dougherty, Esq.

c/o Cong. William Carney 3045 Porter Street, N.W.

1113 Longworth House Office . Washington, D.C. 20008 Building Washington, D.C. 20515 Mr. L. F. Britt Long Island Lighting Company Martin Bradley Ashare, Esq. Shoreham Nuclear Power Sta.

Suffolk County Attorney . P.O. Box 628 H. Lee Dennison Building North Country Road Veterans Memorial Highway Wading River, New York 11792 Hauppauge, New York 11788 Jay Dunkleberger, Esq.

Docketing and Service Branch New York State Energy Office Office of the Secretary '

Agency Building 2 U.S. Nuclear Regulatory Commission Empire State Plaza Washington, D.C. 20555 Albany, New York 12223 Nunzio J. Palladino, Chairman

• Comm. Frederick M. Bernthal* 1 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm.

Room 1114

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Room 1156

1717 H Street, N.W. 1717 H Street, N.W. -

Washington, D.C. 20555 Washington, D.C. 20555 l ,

Commissioner Lando W. Zech, Jr.* Comm. 'i'homas M. Roberts

• U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm.

Room 1113 Room 1103 1717 H Street, N.W. 1717 H Street, N.W.

. Washington, D.C. 20555 Washington, D.C. 20555 Commissioner James K. Asselstine* Stephen B. Latham, Esq.

U.S. Nuclear Regulatory Commission John F. Shea, Esq.

Room 1136 Twomey, Latham and Shea .

1717 H Street, N.W.' 33 West Second Street Washington, D.C. 20555 Riverhead, New York 11901 Allen S. Rosenthal, Chairman * . Mr. Howard A. Wilber* ,

Atomic Safety and Licensing Appeal Atomic Safety and Licensing Board Board -

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Gary L. Edles*

Atomic Safe,ty and Licensing Appeal Board p j U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Kar$ a J. Letsche KIRKPATRICK & L HART

• By Hand 1900 M Street, N.W. - Suite 800 Washington, D.C. 20036

% By Federal Express ,

Dated: May 7, 1985 1

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