ML20129H871
| ML20129H871 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/20/1985 |
| From: | Leonard J LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20129H857 | List: |
| References | |
| CLI-85-01, CLI-85-1, OL-4, NUDOCS 8506070680 | |
| Download: ML20129H871 (38) | |
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4 LILCO, May 13, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKETED' Before the Commission USNRC In the Matter of
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50-322VOL,3 LONG ISLAND LIGHTING COMPANY
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Docket No.
(Low Power)D0CdEithckdy',{
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(Shoreham Nuclear Power Station, )
BRAMCH Unit 1)
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AFFIDAVIT OF JOHN D.
LEONARD, JR.
John D. Leonard, Jr., being first sworn, deposes and says as follows:
1.
My name is John D. Leonard, Jr.
I am Vice President, Office of Nuclear Operations, Long Island Lighting Company (LILCO).
My work address is Shoreham Nuclear Power Station, North Country Road, Wading River, New York 11792.
2.
I received my bachelor's degree in physics from Duke University in 1953, and was President of Sigma Phi Sigma, the Physics Honorary Society.
In 1962, I received my master's de-gree in physics, with a minor in radiobiology from a nuclear engineering curriculum of the U.S. Naval Postgraduate School, Monteray, California.
I am a member of Sigma Xi and a regis-
-tered professional engineer in New York State.
I served in the United States Navy from 1954 to 1974, of which 12 years were DR A
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.o I was'the Commanding Officer of spent on nuclear submarines.
two nuclear submarines, The U.S.S. Abraham Lincoln (S.S.B.N.
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~602) and The U.S.S.- Beniamin Franklin (S.S.B.N. 640).
I ing my retirement from the Navy with the rank of Commander, went to work'for the Virginia Electric and Power Company from
-1974-through 1976;'there I was Corporate Supervisor of Opera-From 1976 through 1980, I was the tional Quality Assurance.
first Resident Manager of the James A. Fitzpatrick Nuclear i
Plant, a boiling water reactor.very similar to Shoreham, owned and operated _by the Power Authority of the State of New York (PASNY).
While I was at Fitzpatrick, in 1977, it was. judged by
'the NRC to be one of the 12 best-managed nuclear power plants in the. country from a safety standpoint.
In 1980, I was pro-moted to Vice President / Assistant Chief Engineer for Design'and with responsibility for the Fitzpatrick Analysis at PASNY, Plant as well as PASNY's interest in the Indian Point reactors.
that post until I came to work at LILCO as Vice
?
I. remained at President / Office of Nuclear Operations in May 1984.
My professional responsibilities at LILCO include 3.
overseeing the safety and operational aspects of the Shoreham
- Nuclear Power Station (Shoreham) and development of the plant.
s
.4.
This Affidavit addresses the Affidavit of Dale G.
Bridenbaugh and Gregory C. Minor in Response to Affidavit of John.D. Leonard, Jr., submitted by Suf folk County and New York State with their Petition for Reconsideration of CLI-85-1 on May 7, 1985.
Many of the statements in the Bridenbaugh/ Minor Affidavit are simply inaccurate.
Others are misleading.
Oth-ers involve opinions on matters about which Bridenbaugh and Minor have no expertise.
My earlier Affidavit of John D.
Leonard, submitted to the United States Court of Appeal for the District of Columbia Circuit in Mario M. Cuomo v. United States Nuclear Regulatory Commission, Docket No. 85-1042, and previ-ously filed with this Commission on March 4, 1985, describes the benefit of low power testing, the need to perform that testing promptly and the low additional incremental effects of
' Phase III and IV testing in great detail.
That earlier Affida-vit is attached as Exhibit A and all of its statements remain accurate and are incorporated here.
It is not the purpose of this Affidavit to repeat those details but simply to point out the errors, inaccuracies, and misleading statements in the Bridenbaugh/ Minor Affidavit.
, ~
Beneficial System Testing During Phases III'and IV 5,.
The'Bridenbaugh/ Minor Affidavit asserts that there
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will be minimal benefit in Phase III and IV testing.
This is
-wrong in many_ respects.
See Leonard Affidavit at 7-12, Tr. ff 152, (Gunther), 200-26, 828-30, 837 (Gunther).
6.-
Messrs. Bridenbaugh and Minor erroneously state that
.the turbine at Shoreham will not roll during Phases III and IV testing and that as a result, the turbine generator and turbine control portion of the EHC systems will not be operated.
(Af-fidavit 1 5).
Although a LILCO witness did apparently state on cross-examination that LILCO did not intend to roll the turbine during Phase III and IV testing, this was incorrect, as shown William by LILCO's other evidence in the low power record.
Gunther, the witness, had included with his testimony an Affi-davit by him and Jack A. Notaro in which it was clearly indi-cated that the turbine would be turned, since the turbine gen-turbine EHC-and turbine lube oil system would be placed
- erator, in service, operated and tested during Phases III and IV.
See Notaro/ Gunther Affidavit at 16, paragraph 24.
Additionally,
.the Chapter 15 safety analysis contemplated a turbine trip --
which can only occur if the turbine is spinning -- as a possi-ble event.
Tr. 320 (Rao, et al.)
In fact, the turbine will -
roll and the turbine lube oil system, generator seal-oil system and steam seal system will be tested during Phase III and IV Bridenbaugh and' Minor are further wrong in their as-testing.-
sertion that-Phase IV testing will produce insufficient steam to run'the' turbine (Affidavit 1 18); it will.
is in-Paragraph 6'of the Bridenbaugh/ Minor Affidavit 7.
the HPCI and Here,-Bridenbaugh and Minor state that correct.
RCIC' systems.can be. tested using recirculation pumps without
'the nuclear operation inherent in Phases III and IV.
In a boiling water reactor such as Shoreham, the HPCI and RCIC sys-Perhaps tem cannot be tested using recirculation pumps.
i which Bridenbaugh and Minor have confused Shoreham with a PWR, it is not.
The comments of Bridenbaugh and Minor in paragraph 7 8.
the tests
- of Ltheir Affidavit are misleading in asserting that listed there cannot be properly performed at low power levels.
LILCO will partially perform all of the listed tests In fact, except the local power range monitor. calibration, during low power operation'.
These include: (a) APRM/IRM calibration at
-overlap' point; (b) the' initial set of the APRM trip reference point at.55%; (c) initial APRM calibration; (d) turbine roll and balance at 1800 rpm; (e) generator exciter test; (f) L.
moisture separator-reheater and drains; and (g) extraction steam.
Performance of these tests during Phases III and IV will provide valuable information and will save substantial time in the ultimate ascention to full power, though these
-tests will continue to be performed as LILCO implements its power ascension program beyond 5%. rated power.
9.
Bridenbaugh and Minor are totally wrong in their as-sertion that there is relatively little benefit to be gained by system testing during Phases III and IV (Affidavit 1 8).
a.
Even if Bridenbaugh and Minor had correctly iden-tified tests which will not be performed -- and they have not -- the remaining testing to be performed, which includes thermal expansion testing of primary (reactor and recirculation) systems is important in and of.itself.
Such testing is time-consuming and often identifies hardware problems which LILCO could correct now if detected, without later disruption of power generation for LILCO's customers, b.
Based on my naval experience as a nuclear subma-rine commanding officer and my nuclear experience, I am convinced that there is no substitute for actual operation of the nuclear plant both when testing
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equipment and training personnel.
Isolated testing of isolated systems does not provide the'same opportunity
-to detect. problems, either with equipment or person-nel, as integrated operation.
Minimal Impact of Low Power Operation 10.:The incremental effects of' irradiating the fuel and reactor internals attributable to Phase III and IV operation are minimal.
See Leonard Affidavit at 20-24.
Bridenbaugh and Minor argue that there are adverse incremental impacts from op-erating the reactor in Phases III and IV.
They are simply wrong on their facts and demonstrate no expertise qualifying them to express the opinions contained in their~ Affidavit.
- 11. Bridenbaugh and Minor erroneously contend that addi-tional irradiation of the fuel to occur in Phases III and IV will be substantial and will reduce or eliminate its salvage value.
(Affidavit 11.10-12).
a.
It is unlikely that the Shoreham fuel would have any salvage value even if it had not been irradiated during Phase II.
See Leonard Affidavit at 21.
Nucle-ar reactor cores are custom designed for the type of reactor and its stage of life.
LILCO is not aware of,
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and believes _that there are-not, any other BWR Mark 4 reactors which have neither entered commercial op-eration,-nor had.their'first core already fabricated.
In order to' utilize Shoreham's core, another utility
. would have to have the_ core redesigned and refabricated.
The resale value, if any, would reflect' the cost of this costly and cumbersome process of re-moving, sorting and repacking the usable portion of some 10 million fuel pellets, a substantial percentage of which must be discarded due to the low enrichment characteristics of a first core.
It is likely that the last of such refabrication would exceed the cost of simply buying new fuel.
Bridenbaugh and Minor do not mention this problem.
As. importantly, since Shoreham's fuel was purchased, advances have been made in the design of fuel bundles.- Fuel now being pur-I chased by utilities employs these advanced designs.
It is unlikely that any utility would'want to purchase Shoreham's fuel, even if unirradiated, given its now-dated design and the substantial cost of fabrication.
b.
Even if the fuel initially had salvage value, that.value was destroyed in Phase II.
Bridenbaugh and Minor are. wrong in their_ assertion that the fuel would L
have a salvage value even after irradiation in Phase II.. Since Phase II initial criticality, however, the fuel must be treated as irradiated fuel for regulatory and commercial purposes.
Thus, the processes neces-sary to make the core usable at any other plant can no longer physically be performed.without shielding against radiation.
The necessity for shielding the fuel in accordance with NRC regulations would render
. salvage commercially infeasible, particularly in the current market, where neither raw uranium nor enrich-ment nor fabrication capacity are in short supply.
Substantial regulatory proceedings, a costly and time consuming process, may also be required to perform the salvage operations described by Bridenbaugh and Minor in their Affidavit.
As stated in my earlier affida-vit, therefore, since the completion of Phase II ct Shoreham, the salvage value of the Shoreham fuel for any reactor other than Shoreham is essentially zero.
There are no further costs associated with the fuel in Phases III and IV.
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- 12. Bridenbaugh and Minor are alsa wrong in paragraph 13
- of their affidavit where they discuss other components whose
' potential salvage value would allegedly be lost.
All of these
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components are'already irradiated at.least to.the same degree as the fuel, a.
While control rods could potentially be sal-
.vaged for use at other reactors, control rod drives are now inLconstant use.
Indeed, they are used virtually every day at Shoreham.
No other-facility would rationally use them without a major overhaul.
It is unlikely that any other facility would want to install used parts in its reactor.
Accordingly, control rod drives have no effective salvage value, b.
The 31 local power range monitors have no salvage value for all practical purposes.
There have been technological advances in local power range monitors which are employed in those now being marketed.
No other utility would want to use LILCO's irradiated local power range monitors which do not incorporate these technological ad-vances.
Bridenbaugh and Minor are also confused con-c.
cerning the irradiation of the-reactor sources, again reflecting a problem with their t
understanding about.the impact of the low power test program.
Neutron sources are irradiated when purchased.
They begin decaying immediately and have a half-life of approximately 60 days un-less the reactor reaches 5% of rated power.
Therefore, Phase III and IV' testing would not eliminate the~ salvage value of the source range monitors, but instead would increase their useful life for LILCO.
Even before Phase III testing, they have' no value to any other utility because sources cannot be irradiated except in a commer-cial reactor.
After initial irradiation in the test reactor, the source pins are machined such that they cannot be reinserted into the' test re-actor.
- 13. Bridenbaugh and Minor are also wrong in their asser-
. tion that there_will be costs of defueling, decommissioning and disposal of fuel associated with Phase III and IV testing.
.(Affidavit 11 14-15).
These costs will have to be incurred whether or not Phase III and IV testing goes forward.
They are
_now fixed costs and will~not be substantially affected by addi-tional testing.
As stated in my earlier affidavit, LILCO esti-
. mates the additional costs for decontamination and some E
additional costs for disposal of the fuel to be around $13 mil-lion, not " tens of millions of dollars" as hypothesized by Bridenbaugh and Minor.
- 14. The statement.of Bridenbaugh and Minor concerning worker exposure to radiation is misleading.
(Affidavit 1 16).
The level of-this exposure has been approved and is bounded by the Shoreham FSAR.
Most importantly, failure to proceed promptly to Phase III and IV testing may in fact increase the amount of exposure to workers.
This is because failure to reach 5% power will necessitate the changing of netron sources, which, in turn, will require entering the reactor vessel.
Changing of these sources may not be necessitated this summer if 5% power can be reached as described in my previous affida-vit.
Leonard Affidavit at 12-14.
- 15. It is not surprising that Bridenbaugh and Minor would make such erroneous statements since neither is qualified as a nuclear fuel specialist, nor has. extensive operational experi-ence in nuclear plants.
The evidentiary record discloses that Minor has never operated a nuclear power plant, has never been licensed to operate a nuclear power plant and has never been responsible for operating any power generation equipment.
(Tr.
s 2423-28)
Similarly, Bridenbaugh has never been licensed to L
operate a nuclear power plant.
(Tr. 2428).
Their partnership, MHB, spends 50-80% of its. time preparing.or giving testimony, rather than in actual practice of nuclear engineering.
(Tr.
24-26-27).
And, their Affidavit indicates no experience or special education concerning testing of nuclear power plants, marketing of nuclear fuel, radiation effects or any other mat-ter qualifying them to render opinions concerning the incre-mental effects of Phase.III and IV testing at Shoreham.
In my opinion, the qualifications offsuch professional witnesses can-not compare with experienced nuclear operators and engineers such as are employed at Shoreham who have determined the accu-racy of the statements in this and.my earlier affidavits.
Overall Benefit of Low Power Testina
- 16. The Bridenbaugh/ Minor Affidavit states that_there will Ebe no benefit from Phase III and IV testing at this time.
-(Af-fidavit 11 18-19).
Again, this is simply wrong.
Based on my extensive experience in the Navy and in the nuclear industry, in addition to the benefits discussed above and in my earlier affidavit, there is no substitute for actual operation of the
~ reactor to provide (a), advance warning of any potential prob-
. lems with the plant's systems and equipment, allowing them to be corrected now without jeopardizing or interrupting later u
generation'of electricity by Shoreham; (b) training of Shoreham's personnel under actual-operating conditions of the reactor; and (c) the welding of Shoreham's operators into a co-hesive and well-coordinated plant crew which is vitally impor-tant,to'the safe operation of a nuclear power plant.
For.these reasons, as well as the benefits of retaining experienced per-sonnel and. maintaining their morale as outlined in my earlier affidavit, there is immense benefit to conducting Phase III and IV testing as soon as possible.
4.
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John D.
Leonard, Jr.
STATE OF NEW YORK
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to-wit:
COUNTY OF SUFFOLK
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Subscribed and sworn to before me this JOE day of May, 8 "" "
MsE== ***U
' Notary Public "
J My commission expires:
3 0. \\ W (o
UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT
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MARIO M. CUOMO, GOVERNOR OF THE STATE OF NEW YORK and
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RCOUNTY OF SUFFOLK,
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Petitioners,
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Docket No. 85-1042 v.
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UNITED STATES NUCLEAR
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REGULATORY COMMISSION,
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Respondent,
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and
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LONG ISLAND LIGHTING COMPANY,
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Intervenor.
AFFIDAVIT OF JOHN D. LEONARD, JR.
John D. Leonard, Jr., being first duly sworn, deposes and says as follows:
1.
My name is John D. Leonard, Jr.
I am Vice President, Office of Nuclear Operations, Long Island Lighting Company (LILCO),
My work address is Shoreham Nuclear Power Station, North Country Road, Wading River, New York 11792.
I received my bachelor's degree in physics from Duke Uni-2.
versity in 1953, and.was President of Sigma Pi Sigma, the physics honorary society.
I received my master's degree in physics, with a minor in radiobiology, in 1962, from a nuclear engineering cur-riculum of the U.S. Naval Postgraduate School, Monterey, California.
I am a member of Sigma Xi and a registered profes-sional engineer in New York State.
I served in the U.S. Navy from
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1954 to 1974, of'which 12 years were spent on nuclear submarines.
I was the Commanding Officer of two nuclear submarines, the U.S.S.
Abraham Lincoln (SSBN-602) and the U.S.S. Beniamin Franklin (SSBN-640).
Following my retirement from the Navy with the rank of Com-mander, I went to work for the Virginia Electric and Power Company from 1974 through 1976; there I was corporate Supervisor of Opera-tional Quality Assurance.
From 1976 through 1980 I was the first Resident Manager of the James A. Fitzpatrick Nuclear Plant, a boiling water reactor very similar to Shoreham, owned and operated by the Power Authority of the State of New York (PASNY).
While I was at Fitzpatrick, in 1977, it was judged by the NRC to be one of the 12 best-managed nuclear power plants in the country from a safety standpoint.
In 1980 I was promoted to Vice President-Assistant Chief Engineer for Design and Analysis at PASNY, with responsibility for the Fitzpatrick plant as well as PASNY's interest in the Indian Point reactors.
I remained in that post until I came to work at LILCO as Vice President-Office of Nuclear Operations in May 1984.
3.
My professional responsibilities at LILCO include over-i seeing the safety and operational aspects of the Shoreham Nuclear Power Station (Shoreham) and development of the plant.
t I.
BACKGROUND 4.
Shoreham is a boiling water commercial reactor of approx-imately 810 MW net electrical capacity, owned by LILCO and located i
d e
s at Wading River, on the north shore of Long Island approximately 60 miles east of New York City.
I am familiar with the effects cf LILCO's being able to conduct low power operations up to 5% of rated power at Shoreham.
The purposes of this Affidavit are to provide background on the current posture of the Shoreham licens-ing proceeding, particularly as it relates to low power operation, to describe the benefits that will accrue from LILCO's conducting low power operation up to 5% of rated power as permitted by the license authorized on February 12, 1985 by the Nuclear Regulatory Commission in its decision CLI-85-01, and to indicate the harm that will occur if LILCO is delayed in conducting such testing.
5.
Low power testing is the first experience of a reactor and its crews with actual operation.
It is the foundation for the reactor's entire operating life.
A soundly designed and executed low power testing program accomplishes the necessary transition from unirradiated, no-power conditions to irradiated operation at commercial power levels and provides a final check on the physical functioning of reactor systems.
It also provides a baseline of training and experience that helps to set the tone for future op-erations.
Shoreham's low power testing program has been divided into four phases designed to emphasize training, deliberate proce-dural actions, thoroughness in operations, and mechanical sound-ness of equipment.
As a result, LILCO has built more testing and training into its low power testing program than is required or customary, and plant management is under operating instructions to
emphasize deliberatness using well-conceived procedures and thor-oughness over speed.
6.
On December 7, 1984 the Nuclear Regulatory Commission de-clared effective a September 5, 1984 Licensing Board Order author-izing issuance of a license permitting LILCO to load fuel (" Phase I" of low power testing) and conduct cold criticality testing
(" Phase II" of low power testing) at Shoreham.
Pursuant to Li-conse NPF-19, issued December 7, 1984, LILCO commenced loading fuel on December 21, 1984 and completed that process on January 19, 1985.
LILCO commenced cold criticality testing on February 15, 1985, and Shoreham achieved its first self-sustaining nuclear chain reaction at approximately 6:25 pm that day.
LILCO completed
-cold criticality testing on February 17, 1985 at approximately 6:00 am.
Shorehma is ready now to proceed to Phase III of low power testing.
7.
On February 12, IJ85, the Nuclear Regulatory Commission declared effective an October 29, 1984 Licensing Board Initial Decision authorizing issuance of a license permitting LILCO to conduct heatup and low power testing to rated temperature and pressure conditions (1% of rated power) (Phase III) and low power testing to 5% of rated power (Phase IV).
8.
This Affidavit is written in the context of a motion for a stay of the Commission's February 12, 1985 decision, pending later reviews on the merits.
Consequently, it does not attempt to quantify the monetary cost of delays beyond the time when Shoreham
could otherwise enter commercial service.
Rather, it focuses on the costs to LILCO of near-term delays and reviews the cost esti-mates prepared by Petitioners.
A summary of this Affidavit is as follows:
1.
Shoreham has a soundly designed, four-phase low power testing program.
Phases I and II are complete.
Fuel has been loaded into the reactor and it has "gone critical" -- it has had its first self-sustaining chain reaction.
The reactor's fuel and vessel internals are by now irretri.vably irradiated.
The plant is ready to embark now on Phases III and IV of low power testing.
2.
As presently planned, Phases III and IV could be com-plated in 42 days, or by about the end of March, if no complica-tions develop.
It would be unusual if at least minor complica-tions, extending the completion of Phases III and IV by several days to several weeks, do not arise.
3.
If any de'ay is imposed on Phases III and IV of low power testing, LILCO will incur, day-for-day, incremental out-of-pocket costs for expert technical advisors at a rate of between
$300,000 and $820,000 per month.
If LILCO is unable to undertake Phases III and IV by March 1, it will have to order new neutron sources for Shoreham at an out-of-pocket cost of $250,000.
If LILCO cannot undertake low power testing before July 1, it will have to replace the neutron sources.
This would mean an unavoid-f able 60 to 70 day further delay before low power testing can com-in addition to the time for low power testing (42 days plus
- mence, J
L
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o time for any complications), for a total delay of nearly four Thus if the start of low power testing is de-months at least.
it will be very un-layed, for any reason, beyond the end of June, likely that it can be completed before November; if the start were delayed until the end of July, testing could not readily be com-plated before December.
In addition, delays would disrupt what has been to date an orderly and successful plant startup, and would create the risk of damaging losses by attrition from three groups of expert technical advisors retained to assist in plant startup, from the 300-person Plant Staff, and from 300 persons in related support organizations.
4.
Petitioners overestimate by about a factor of ten the costs of undertaking Phases.II and IV of low power testing, The assuming Shoreham never subsequently operates commercially.
fuel in the reactor is already irradiated and not usable except at Shoreham; the incremental fuel cost of proceeding to Phases III and IV is not $120 million as Petitioners suggest, but zero.
The same is true of control rods and other reactor internals; the incremental cost of proceeding to Phases III and IV is not S1 to
$2 million, but zero.
The cost of defueling and decommissioning, put by Petitioners at unquantified " tens of millions" of dollars, has been estimated by LILCO at $13 million.
Thus if Shoreham com-the pletes low power testing but never operates commercially, incremental cost is approximately $13 million, not $120 million plus " tens of millions" more.
If Shoreham operates commercially, the incremental cost of proceeding to Phases III and IV is zero.
II.
THE SHOREMAM LOW POWER TESTING PROGRAM 9.
Conducting testing at up to 5% of rated power pursuant to the license for Phases III and IV authorized on February 12, 1985 will produce the following types of benefits, discussed in more detail in 11 10 below:
a.
Testing of the reactor and its components up to the turbines at rated temperature and pressure, during both Phases III and IV; b.
Testing steam operated reactor safety equipment such as the High Pressure Coolant Injection System (HPCI) turbine driven pump and the Reactor Core Injection Cooling System (RCIC) turbine driven pump; c.
Testing the main steam system up'to the turbine, including the main steam piping and steam drain sys-tem, the condenser under vacuum, and operating the steam driven main feed pump turbines; d.
Testing the off gas system including the catalytic recombiner, steam dilution and reheat systems; e.
Testing the rad waste systems and their associated steam driven concentrators; f.
Testing the steam reboller system, which utilizes re-actor steam to produce auxiliary steam from an
.. I enclosed pressure vessel in a separated loop, thus precluding radioactivity from the reactor from enter-ing certain auxiliary systems;
. Identifying and resolving unforeseeable equipment g.
malfunctions and other systems operability problems which can be detected only during startup testing; h.
Training of the reactor's crews and other station personnel; i.
Accelerating the date of commencement of full power operation.
- 10. LILco's division of low power testing into four steps was intended to permit accomplishment of discrete goals at each' step.
These were described in detail in the attached Affidavit of Jack A. Notaro and William E. Gunther, Jr., dated March 30, 1984, which accompanied LILCO's Supplemental Motion for Low Power Operating
-License, and the Testimony of William E. Gunther, Jr. during hear-(Tr. 152 ings leading to the Initial Decision now under appeal.
ff.).
Without repeating the details of that Affidavit, the fol-lowing will summarize the activities at each stage of low power testing:
A.
Phases I and II:
Fuel Loadino and Precriticality Testina (December 21, 1984 - January 19. 1985); and Cold criticality Testino (February 15-17. 1985) (Gunther-Notaro Affidavit. 11 6-11):
Phase I, now completed, involved placing
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1
-9 into the some 560 fuel bundles, each containing 62 fuel rods, It also involved installation reactor at predetermined locations.
and utilization of specially designed startup neutron sources and instrumentation to monitor the reactivity in the core and the functioning of reactivity control measures needed beginning with Control rod insertion drives, radiation monitoring, and Phase II.
During this phase the other systems and instruments were checked.
there was no self-sustaining plant was not critical -- 1 32, 2
nuclear chain reaction occurring in the reactor core.
involved withdrawal of control rods Phase II, also completed, from the reactor core to a predetermined extent and sequence so as a self-sustaining chain reaction to achieve criticality
-- 1 32, 2
-- at extremely low power levels (not above.001% of rated power).
The effectiveness of the 137 control rods in controlling reactiv-Plant operators were able to perform reactivity ity was measured.
install vessel instruments under operating control manipulations, constraints, and install instrumentation for later measurement of pipe expansion and vibration upon heatup.
Over 5000 man-hours of valuable training were accumulated itself did not become signifi-during Phases I and II.
The plant However, as is cantly radioactive outside the reactor core.
the reactor fuel itself became described more fully in 1 17 below, that it no longer has any sufficiently radioactive during Phase II commercial value at any plant other than Shoreham as a practical The same is true of reactor vessel if not theoretical matter.
internals (control rods, radiation monitors, etc.).
M
. 4 B.
Phases III and IV:
Heatuo and Low Power Testinc~to Rated Pressure /Temoerature Conditions (1% of Rated Power)
(Authorized but not yet commenced); and Low Power Testino (1% to 5% of Rated Power) (Authorized but not vet commenced)
(Notaro-Gunther Affidavit, 11 13-24):
Phase III involves plant heatup and pressurization in progressive steps to rated pressure and tem'perature at 1% of rated power.
Each of the six steps in this process includes the performance of a number of tests relat-ing to thermal expansion of piping and training of reactor crews in integrated systems operation under actual operating conditions.
In Phase IV, the reactor is taken initially to 5% of rated power at rated temperature and pressure, tested and then taken through its first cooldown to ambient conditions.
The plant is then heated up a second time to rated temperature and pressure; RCIC, HPCI and reactor feed pumps and associated balance-of-plant equipment are tested; and an endurance run on HPCI and RCIC is conducted.
The plant is then cooled again to ambient conditions.
Data are taken on nuclear steam supply system thermal expansion during each heatup and cooldown.
III.
HARM FROM DELAY
- 11. A delay in undertaking Phases III and IV, if brief, would delay their completion at least day for day.
A longer delay would l
have much longer than day-for-day consequences because of inevit-i able need to replace neutron calibration sources in the
. 4 Such a delay could also jeopardize permanent and reactor core.
temporary plant staffing and training.
Any delay imposes out-of-pocket costs.
in Comoletina Low Power Ooeration:
If plant
- 12. Delay startup were allowed to proceed now without any restraint and if no equipment malfunctions or administrative shortcomings are is conceivable that Phases III and IV could be com-detected, it However, a basic purpose plated in as short a period as 42 days.
of initial plant startup is to detect problems and correct them before the plant enters commercial operation at full power, and If a risks increase and shutdowns become extremely expensive.
problem is encountered with a safety-related system, correction can be very time-consuming because of the rigid substantive, docu-mentary and quality assurance requirements covering design, pro-While it is not curement and installation of such systems.
expected that problems requiring major delays in the ability to proceed between 5% and 100% of rated power will be encountered in It is con-Phases III and IV, the possibility cannot be ignored.
ceivable that a malfunction in a safety-related system, however unlikely, could require a year to assess, remedy, and receive For example, the failure approval for in the licensing process.
of the TDI emergency diesel generators, which gave rise to the ex-The emption proceeding now under review, occurred in July 1983.
results of the repairs to them are still being litigated over 18 While the likelihood of occurrence of this type of months later.
m,.
problem is, in my judgment, extremely low, other, smaller problems with a presently uncertain potential for delay ranging from sever-al days to several weeks will almost inevitably be detected.
In addition, a problem that would affect Shoreham's completion of low it could origi-power testing need not even originate at Shoreham; For nate at any other plant that was similar in relevant aspects.
example, the difficulties experienced at Shoreham with its TDI diesels affected other plants, including Mississippi Power & Light Company's Grand Gulf plant, then in low power testing, for months.
My policy as Vice President-Nuclear has been, and will remain, to detect problems early and correct them systematically and without unnecessary haste.
It is the purpose of plant startup to detect problems and correct them at the earliest possible time.
A stay of low power testing at Phases III and IV of low power testing would both impair LILCO's ability to execute this sound policy and would enhance the risk that low power testing could delay commercial operation.
- 13. Replacement of Calibration Sources:
Neutron sources of significant radioactivity must be in the reactor from initial fuel in l
loading on, at any time when there is fuel in the reactor, order to provide background levels of radiation in the core l
Five sets of against which to calibrate reactor instrumentation.
these sources were installed at Shoreham in late December 1984 as part of fuel loading.
These sources have a radioactive half-life of approximately 60 days, and will decay unless regenerated by i
m
1
- When the reactor attains 5% power, other activity in the reactor.
the level of radioactivity in the reactor core is sufficient to substantially delay further decay of the sources; at higher power levels (upwards of about 15%), the sources are regenerated by ac-If Shoreham does not start Phases III and IV tivity in the core.
by March, new power sources will have to be ordered at an out-of-because of the long lead time for their pocket cost of $250,000, fabrication and shipment.
If Shoreham is prevented from commenc-ing Phases III and IV by the end of June, the sources will have to least 60 This would mean an unavoidable delay of at be replaced.
This is because in to 70 days in commencing low power testing.
order to replace the sources the containment must be disassembled, the reactor vessel head unbolted and removed, and various fuel assemblies removed in order to access and replace the neutron New sources would have to be ordered, shipped and sources.
The reactor would then re-replaced, and the reactor reassembled.
quire hydrostatic and leak rate testing as well as repetition of other types of testing already performed once in Phases I and II.
l My staff has estimated that this work can be accomplished in 40 l
days, using 50% of the plant's maintenance force working 3 shifts around the clock seven days per week.
In the meantime, all of the ordinary maintenance these personnel would otherwise perform must Deferral of maintenance not only is bad practice; be set aside.
We have estimated an additional 20 to it has cumulative effects.
30 days to catch up on this work.
If unforeseeable complications
^
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4 develop (as can easily happen in round-the-clock work) further de-lays would result.
Replacement of the sources would thus entail a
~
delay in resuming. Phases III and IV of at least 60 to 70 days and in addition to the out-of-f major diversion of personnel resources, pocket monetary cost.
- 14. A stay which delayed the conduct of Phases III and IV of low power testing would also seriously impair the operational training of the Shoreham reactor crews and could even jeopardize I.
LILCO's ability to retain them, as well as forcing LILCO to incur out-of-pocket costs ranging between $300,000 and about $800,000 LILCO's per month, according to estimates prepared by my staff.
philosophy for low power operation has been to provide substan-tially more training of its reactor crews during Phases I-IV of low power testing than is minimally available or required in low l
power testing.
In Phases I and II the aggregate amount of i-training totaled about 5000 man-hours.
During Phases III and IV i
it is intended that training will total about 6000 man-hours.
This will include repeated startups and heatups to rated pressure and temperature in Phase IV to give gggh operating crew an oppor-l tunity to experience plant response.
Altogether in Phase IV, the Shoreham plant staff will be required to place in service, oper-
)
Notaro-Gunther Affida-ate, test and maintain 54 plant systems.
vit, 11 12, 24.
Delay in Phases III and IV would jeopardize LILCO's ability to see to this training and would force LILCO to j
make wasted out-of-pocket expenses, in three respects:
(A) i i
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retention of access to expert personnel from other organizations, in LILCO's low power and power now on site to advise and assist (B) out-of-pocket expenses to retain access to ascension program; the expert advisors; and (C) training and retention of plant staff and related personnel.
Pursuant to technical specifications in its low power A.
license from the NRC, LILCO has retained eight experienced advis-including employees of other utilities and independent con-
- ors, sultants, to act as shift operation advisors during low power testing anticipated to take place in early 1985 and in initial These shift advisors have sufficient expe-operation thereafter.
rience in operating nuclear reactors to assist LILCO in the low The cost to power testing program and to train LILCO's personnel.
LILCO averages approximately $100,000 per year per advisor, If comple-including the cost of their employment and training.
tion of Phases III and IV of the low power testing program is delayed, LILCO will incur out-of-pocket losses for their salaries at the rate of about $70,000 per month.
Four of these advisors are on loan from other utilities.
Each of the four has completed or is in the process of completing an eight-week-site-specific training program culminating in examinations to assure familarity with the Shoreham plant.
Because these advisors are on loan from other utilities, they can-LILCO has already been remain indefinitely at Shoreham.
not advised that at least one such advisor, on loan from Carolina m
I an-Power & Light Company, must. return to that utility in May.
ticipate that there will be similar requests from the other in order utilities if a delay is experienced in Phases III and IV, that these personnel can remain qualified at their "home" nuclear Each time LILCO needs facilities and advance their own careers.
it must to obtain a different advisor to assist in this process, conduct the eight-week site-specific training program before the Thus delay, in addition to new advisor can apply his knowledge.
being costly, induces turnovers which involve further delay.
Also at the Shoreham site are 28 experienced person-B.
nel furnished by General Electric Company and 30 furnished by Stone & Webster Engineering Corporation to assist LILCO with its startup and power ascension program assumed to commence in early The primary purpose of these personnel is to advise LILCO 1985.
personnel during the low power testing and startup program based on these organizations' previous operating experience at other nuclear facilities.
Twenty-five of these personnel are scheduled to leave at the completion of Phase IV low power testing; the re-maining 33 are scheduled to remain through various stages of power ascension.
Delay in completion of low power testing imposes two
,i out-of-pocket costs, and risk of loss of direct costs on LILCO:
access.
These contractor personnel are charged to LILCO at a rate For the approximately equivalent to about $12,000 per man-month.
25 of these personnel who are scheduled to depart after the
. a repre-conclusion of low power testing, delay in its commencement sents a direct out-of-pocket cost to LILCO of approximately For the other 33 or so whose contracts run
$300,000 per month.
full attribution of their through the end of power ascension, costs (about $396,000 per month) directly to delay in Phases III and IV is less clear-cut than with those scheduled to leave at t is real.
end of low power testing, but the cost involves access to valuable experts.
The second type of cost When no testing is taking place, these personnel are relegated It has been my experience that unless primarily to paperwork.
such personnel are actively engaged in supervisory activities for which they were employed, their principals soon transfer them to other jobs where progress is being made and where the personnel Accordingly, I anticipate that LILCO can employ their skills.
will lose the benefit of these personnel if low power testing is While such personnel may ultimately be able to return to delayed.
Shoreham, scheduling difficulties make it likely that delays in the power ascension program would be necessitated.
C.
Shoreham's Plant Staff, including reactor crews, su-would be adversely affected pervisory personnel and staff support, These personnel, who number about 300, are highly by a stay.
While trained and much in demand throughout the nuclear industry.
individually and collectively, highly motivated and i
they are, loyal to LILCO, they cannot be expected to ignore their own self-Shoreham's completion and operation have been interest.
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18-The plant staff delayed time and again for a variety of reasons.
n the past year, a reduction in force and pay have endured, just i cuts brought about by LILCO's financial difficulties, and a to operate the strike.
They are at Shoreham for one purpose:
Delays and attendant frustration have cost LILCO. valuable plant.
With the heightened frustration of being un-people in the past.
able to operate a plant which is physically complete and has been I fear the loss of knowledgeable, licensed by the NRC to operate, Based on my naval experience valuable, hard-to-replace personnel.
as a nuclear submarine commanding officer and as the New York State Power Authority's first resident manager of the Fitzpatrick I am convinced that personnel who have gone Nuclear Power Plant, through the construction period of a plant or ship and the associ-ated preoperational test programs have esperience that directly It is common knowledge among influences safe reactor operation.
naval commanding officers that the commissioning crew will proba-bly be the most knowledgeable crew the ship ever has.
In addition to the Shoreham Plant Staff, there are D.
approximately 300 additional employees, most of them professional i
or technical, who work in areas totally or primarily devoted to the the Nuclear Engineering Department, the support of Shoreham:
l Nuclear Operations Support Division, and the Nuclear Quality f
Like the Plant Staff, these employees are Assurance Department.
highly trained and motivated; like the Plant Staff, they are I
like the Plant Staff, they highly sought after and highly mobile; i
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I fear their loss by have endured economic and other privations.
attrition if startup is delayed.
- 15. The effect of delay in the conduct of Phases III and IV of low power testing, whether from the stay requested here or other causes, cannot be stated precisely for all circumstances.
First, the out-of-pocket However, the following things are clear.
cost of expert utility and contractor personnel now onsite for low in some cases, power ascension, is over power testing and,
$820,000 per month.
At least $300,000 per month is directly at-Sec-tributable, day for day, to any delay in Phases III and IV.
l if we cannot predict ond, purely from an operational standpoint, before the end of June that low power testing will be complete by September 1, we will have to install new neutron sources, at an After that, the low additional delay of at least 60 to 70 days.
power testing which could not be completed before September 1 will In have to be done again, covering another 42 days or more.
a delay preventing the undertaking of Phases III and IV of
- short, in all likelihood, delay low power testing beyond early June will, completion of that testing until about_the start of November, even A delay beyond that time would retard com-if all goes smoothly.
least 110 to 120 days beyond pletion of low power testing by at the end of the initial delay.
If personnel -- advisors, plant staff or supporting personnel -- were affected in the meantime, the effect of delay would be increased by an unquantifiable but potentially long period.
- 16. Delay of Phases III and IV of low power testing would also lead to delays in LILCO's ability to generate power to its LILCO has designed its grid once a full power license is issued.
ascension test program so that about 60% of the testing activities will be completed by the end of Phases III and IV of low power This is a significantly larger amount of the overall testing.
progr'am than is usually completed by the end of testing at 5%
As a result, when a full power license is issued, LILCO power.
will be in a position quickly to generate power directly to the Nor-grid, beginning at approximately 15 to 20% of rated power.
mally, the power ascension program requires the plant to fre-its quently cease power generation to the grid in order to test LILCO will test Shoreham's reac-reaction to various transients.
tion to the maximum possible number of these transients during Phases III and IV of low power testing, a time when no power gen-Accordingly, there will be a eration to the grid will take place.
its power generation to the considerably reduced need to interrupt L
grid once a full power license is issued.
AND IV INCREMENTAL EFFECTS OF PROCEEDING TO PMASES III IV.
I Affidavit of Messrs. Bridenbaugh
- 17. The February 12, 1985 and Minor compares various costs of permitting Phases III and IV of low power operation (assuming that Shoreham never enters com-r with those of halting operation after Phases I mercial operation),
$120 million for Their principal estimated cost element, and-II.
l t
o.
The actual initial cost to in all respects.
fuel, is incorrect LILCO of Shoreham's core was approximately $40 million, and its value for any plant other than Shoreham was effectively reduced to Thus the incremental zero when it was irradiated in Phase II.
fuel-related cost of proceeding to Phases III and IV is not $120 This and the other, smaller cost million but essentially zero.
elements estimated by Messrs. Bridenbaugh and Minor are discussed more specifically below.
The Bridenbaugh-Minor Affidavit over-A.
Nuclear Fuel:
estimates the value of Shoreham's core, before irradiation, to any The $120 million cost estimated by Messrs.
other reactor.
Bridenbaugh tad Minor to purchase the fuel in the Shoreham reactor the actual figure paid was approximately $40 mil-is incorrect; lion, though it would be somewhat higher (on the order of $60 to its resale value for any reactor
$65 million) now.
- However, initial other than Shoreham, even before irradiation in Phase II criticality, would have been substantially lower than its value to Nuclear Shoreham since there is no ready market for the core.
the type of reactor cores are custom-designed specifically for (1) and (2) its stage of life (in reactor (in this case, a BWR Mark 4)
LILCO is not aware of, and believes this case, the first core).
any other BWR Mark 4 reactors which have nei-s that there are not, ther entered commercial operation yet nor had their first core l
l Thus in order to be utilized economically and already fabricated.
f safely in any other reactor, Shoreham's core would have to be i
f
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Each of.the nearly 35,000 fuel rods redesigned and refabricated.
in Shoreham's core would have to be separated individually from Virtually every, if not every, the others within its fuel bundle.
rod would have to be opened and its nearly 300 individual fuel and fuel pellets (of varying degrees of uranium enrichment) in spacing devices removed, evaluated and repacked, rod by rod, different configurations, on the basis of engineering calculations The resale value -- more accu-performed for the other core.
d rately, salvage value -- of Shoreham's core, unieradiated, woul reflect the cost of this costly and cumbersome process of remov-ing, sorting and repacking the usable portion of some 10 million fuel pellets.
The Bridenbaugh-Minor Affidavit claims that the re-B.
sale value of the fuel in the Shoreham reactor will not stantially affected by irradiation before operation at Phases III and IV, with the implication that proceeding to Phases III and IV (Affidavit, 1 20, esp. 1 20(b)).
will incur a $120 million cost whatever it is, was al-That assertion is simply wrong; the cost, ready incurred in Phase II, when the fuel was initially irradi-Though the degree of irradiation is not as high as at full l
l ated.
power (or even 54) operation, the fuel must now be treated for Thus the regulatory and commercial. purposes as irradiated fuel.
processes necessary to make this core usable at any other plant cannot physically be performed anymore without shielding against In addition, the core could not be removed from the radiation.
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reactor or shipped without shielding in accordance with NRC and The amount of shielding required for its han-DOT regulations.
It dling would not render such operations technically impossible.
in would, however, render them commercially infeasible, especially the current market, where neither raw uranium nor enrichment nor Thus as of completion fabrication capacity are in short supply.
of Phase II activities, the salvage value of the Shoreham fuel for There are no any reactor'other than Shoreham is essentially zero.
further costs associated with the fuel in Phases III and IV.
i Petitioners claim that proceeding to Phases III and C.
IV will result in other areas of contamination which would not to control rods, radiation mon-have occurred at Phases I and II:
(See Affidavit, 1 20(c)).
They itors and other reactor interals.
This assertion evaluate this cost at between $1 and $2 million.
These components are as radioactive as Shoreham's is also wrong.
fuel and whatever costs may be-associated with their irradiation are already sunk.
Petitioners also claim that proceeding to Phases III D.
later commercial operation, would entail a cost and IV, without for defueling, decontamination, decommissioning and disposal which they do not quantify but which, they assert, could be " tens of millions of dollars."
(Affidavit, 1 20(d)).
LILCO has estimated at about $13 million.
this cost Even if one assumes that Shoreham never reaches com-E.
mercial operation, the incremental cost of proceeding to Phases
4,
III and IV is only $13 million, not the $120 million plus $2 mil-lion plus uncounted " tens of millions" as postulated by Messrs.
If Shoreham is assumed to ultimately reach Bridenbaugh and Minor.
the incremental cost of proceeding to Phases commercial operation, III and IV is zero.
State of New York to-wit:
County of Suffolk
._dA D.
Leonard, Jr Subscribed to and sworn before me this 80 day of February, 1985.
seeraar Yv*etdie.1".*e,
u commm. s
.a k'" %
I Notary PuBi b My Commission expires:
td 30 (?Pl.
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