ML20198F997

Marked-up Discussion of Vessel Head Drop for B&W 205 Fuel Assembly Reactor Vessel.Assumption & Methods Used by Applicant Acceptable

ML20198F997
Person / Time
Site:	Washington Public Power Supply System
Issue date:	05/11/1978
From:	Sihwell I Office of Nuclear Reactor Regulation
To:	Parr O Office of Nuclear Reactor Regulation
References
CON-WNP-1168 NUDOCS 8605290174
Download: ML20198F997 (2)

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.f th MEMOPRlDUM FOR:

0. D. Parr, Chief Light Water Reactors Branch No. 3 Division of Project Management FROM:

I. Sihweil, Chief Structural Engineering Branch Division of Systems Safety

SUBJECT:

VESSEL HEAD DROP FOR B f W's 205 FUEL ASSEMBLY REACTOR VESSEL FOR WPPSS NUCLEAR PROJECT UNITS 1 AND 4 (SED: //#J )

REFERENCES:

1) Letter, D. L. Renberger, HPPSS, to 0. D. Parr.

NRC, "yPPSS Nuclear Projects Nos. I and 4 Resnonse to NRC Ouestions Concerning RCP Coo $ng,CCWSRe and Guard Pipes,/ design, Pipe Break Criteria RV Head Drop Analysis, Five Cha Channel On-Site. Power Syste and RPV Support Analysis," dated March 7,1977.

2) Memorandum, Docket Nos. 50-460 and 50-513, J. Knight to Assistant Director for Light Water Reactors, dated J4}y 6,1976, " Review of Attachment C Seisnic f)ualifications of the Polar, Cask Handling and New Fuel Handling Cranes, etc."

3) Hemorandum, Docket No STN 50-561, O. D. Parr to V. Benaroya and I. Sihwell, dated April 14, 1978, " Vessel Head Drop for B 1. U's 205 Fuel Assembly Reactor Vessel."

4) Letter,D.L.Penberger,UPPSSfoJ.F.Stolz.

NRC, "WPPSS Nuclear Project Nof.14 4 Proposed Plant Design changes", dated April 23, 1976.

In accordance with your request contained in Reference 3, the Structural Engipwring Branch has reviewed the responses to SEB questions as provided in Reference 1 by the Wathington Public Power supply system. This infonnation was provide respons ur concerns on the original applicant's request to ange the PSAR s indicated in Reference 2.

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2 In the driginal PSAR the containment Polar crane is classified as non-seismic category I, but is required to be designed against failure in the event of an SSE. After a detailed review of the plant toyout and equipment arrangement, the applicant has found it unnecessary to comply with the above req 6irement. The applicant considers the failure of the pilar crane itself as highly inlikely. h However the drop of the henvist load carried bypetalF cranc n

considered. It was found that the most critical event involves the drop of the vessel head on the reactor vessel. Theough the use of the assumptions and methods as contained in Reference 4 and clarified in t

Reference 1, the applicant has made an analysis of such an event and has concluded that the loads resulting from a five foot drop are within the design limits of the reactor vessel and the RV supports.

We ahve reviewed the assumptions and methods used by the applicant and find them to be acceptable. We, therefore, concur with the applicant's conclusionsthet-th pesteleted ~ector vc:scl hcad J.ep will et 4-33

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DISTRIBUTIONS NRR READING FILE SEB READING FILE I. Sihwell, Chief SUBJECT Structural Engineering Branc)

Divis4cn of Systems Safety cc:

J. Knight D. Vassallo R. Tedesco K. Kniel V. Benaroya R. Bosank T. Cox W. Lefave H. Silver C. Hofmayer C. P. Tan D$1;SEB

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DJSkovholt Docket No. 50-51 AHMeltz Subject File JCPetersen l

Richard C. DeYoung, Acting Assistant Director for Light Water Reactors, PM i

WASHIllGTON PUBLIC POWER SUPPLY SYSTEM: WASHIt:GTON PAJCLEAR PROJECT UllIT fl0. 4 By order of Ju.ly 29, 1976, the ASLB directed the Staff to file an affidavit 'regarding the financial qualifications of Washington Public Power Supply System to design and construct the subject facility. This issue had been lef t open at the ASLB hearing in November,1975, due to uncompleted State environmental impact statements. Those statements i

have now been completed and the financial arrangements for WNP-4 have been finalized. The enclosed affidavit of Jim C. Petersen provides the updated financial information requested by the Board.

l Orkinal Signed 1 7 Donald J. hvhcit Donald J. Skovholt Assistant Director for Quality Assurance and Operations Division of Project Management

Enclosure:

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AFFIDAVIT OF NRC STAFF ON FINANCIAL QUALIFICATIONS FOR WNP-4 (DocketNo. 50-5131 by Jim C. Petersen 1

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

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WASHINGTON PUBLIC POWER SUPPLY SYSTEM Docket No. 50-513 (WPPSS Nuclear Project No. 4)

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AFFIDAVIT OF JIM C. PETERSEN I, Jim C. Petersen, having been duly sworn, state that:

I am the financial analyst assigned ta WNP-4. A copy of my professional qualifications is attached.

I.

BACKGROUND The evidentiary hearings on radiological health and safety issues were conducted on November 11-13, 1975. At that time, the Applicant, Washing-ton Public Power Supply System, ("WPPSS") requested that consideration of its financial qualifications to design and construct WPPSS Nuclear Project No. 4 ("WNP-4") be deferred to a later time.

(Applicant's l

Exhibit 17).

In the Matter of Washington Public Power Supply System (WPPSS Nuclear Projects No. 1 and No. 4),48P-75-72, NRCI-75/12, 922, 927.

At that time, the Applicant planned that the entire capability of WNP-4 l

would be purchased by publicly and cooperatively-owned utilities through the execution of Participants' Agreements.

Participants' Agreements are the second of a two step procedure under which participants comit to purchase a portion of the capability of WNP-4. The first step is the execution of option agreements under which potential participants obtain

. an option to purchase capability. The second step is the execution of Participants' Agreements under which participants commit to purchase capability. Option agreements for WNP-4 had been executed, but the execution of Participants' Agreements. was delayed pending completion of the secondary environmental impact statements, required by the Washington State Environmental Policy Act ("SEPA")

R. C. W. 5 43.21C.

(Tr. 825-29). NRCI-75/12, 922, 927, n. 10; 928.

The Applicant estimated that the secondary SEPA statements would be completed in approximately four-six months and that execution of the

{articipants'Agreementswouldfollowthereafterinduecourse.

NRCI-75/12,922, 928.

Although findings of fact and conclusions of law made by the Atomic Safety and Licensing Board (" Board") in its Initial Decision (NRCI-75/12. 922:

December 22,1975) related to both WPPSS Nuclear Project No.1 ("WNP-1")

and WNP-4, the findings and conclusions with respect to financial qualifi-cations related only to WNP-1. This result recognized the Applicant's request that consideration of its financial qualifications with' respect to WNP-4 be deferred. See n. 28, NRCI-75/12, 943.

In its Initial Decision (NRCI-75/12, 928), the Board stated that it wished to be kept informed on this matter and that it would receive additional evidence from the parties with a view toward supplementing its Initial Decision at a suitable tine with appropriste finiings relating to the n

. Applicaht's financial qualifications to design and construct WNP-4.

II. ANALYSIS AND CONCLUSION In Supplement No. 2 (dated August 8,1975) to its Safety Evaluation Report, the NRC Staff concluded that WPPSS was financially qualified to design and construct WNP-1 and WNP-4.

By letter of October 22, 1975, WPPSS informed the NRC Staff of a delay in the signing of Participants' Agreements (contracts to purchase a certain percentage of the capability of the facility) with the participants in WNP-4. As noted above, the Applicant indicated that the delay was due to the requirement for completion of secondary environmental impact statements pursuant to SEPA. The Ap-plicant estimated that tiie secondary SEPA statements would be completed in six (6) months, with execution of the Participants' Agreements to follow.

(Applicant's Exhibit 17.) This development did not affect the financing plan or the NRC Staff's conclusion regarding WNP-1, which is being financed independently of WNP-4.

The Staff modified its financial evaluation with regard to WNP-4 in its Supplemental Testimony presented at the hearing of the Atomic Safety and Licensing Board on November 11,1975 (Richard W. Cioni, following Tr. 746).

The NRC Staff stated that it could conclude that the" Applicant is financially qualified to design and construct WNP-4, if the Applicant obtained the signed Participants' Agreements.

(Tr. 841).

The following concluding paragraph of the NRC Staff's Supplemental Testi-many summarized the rationale underlying the Staff's modified position:

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" Based on the preceding analysis and a change in the original assumption that WNP-4 participation agreements would be signed by the time of the hearings, as reported by WPPSS in its May 1975 financial information submittal, we have determined that the applicant has not provided sufficient evi-dence at this time to demonstrate to the Comission their financial qualifications to carry out the design and con-struction activities for WNP-4 pursuant to 10 CFR 50.33(f). How-ever, the foundation for this evaluation is solely that the applicant failed to obtain signed participation agreements which are necessary to obtain pennanent financing for WNP-4 due to a recent interpretation of the Washington State En-vironmental Protection Act requiring WPPSS participants to file environmental impact statements. Over its long past history, WPPSS has issued revenue bonds, rated "AAA" by Moody's, based on similar contractual arrangements to permanently finance its other projects. When the applicant obtains the signed participation agreements, we feel submittal of such information will be sufficient for the Financial Analysis Staff to find the Applicant financially qualified to design and construct WNP-4."

(Cioni,followingTr.746,p.2.)

1 By letter of July 23, 1976, WPPSS informed the NR'C Staff that Par-ticipants' Agreements had been fully executed with 88 public and cooperative utilities for 100 percent of the output of WNP-4. This was the only condition remaining to be met prior to the issuance of 1

i a favorable NRC Staff conclusion with respect to WPPSS's financial qualifications.

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j By lette of July 19, 1976, WPPSS indicated that its updated estimate l

of the total cost of WNP-4 was $1,095.0 million. This compares with l

the Applicant's earlier estimate of $1,009.0 million, as presented in the August 1975 SER Supplement. The relative amount of the cost estimate increase is not unusual for this type of project and is rela-tively insignificant. Therefore, it does not affect our analysis or is,*-

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.. conclusion with respect to the Applicant's financial qualifications.

The above analysis is based on (1) the prior record, (2) the latter of July 19, 1976, submitted by WPPSS to the NRC staff, (3) the letter of July 23, 1976, submitted by WPPSS to the NRC Staff, and (4) the testimony of James T. Bobo filed on August 5,1976, with respect to Applicant's financial qualifications. We are aware of no other information which would affect our conclusion regarding the financial qualifications of WPPSS to design and construct WNP-4.

Accordingly,we conclude that based on WPPSS's project financing method, it has reasonable assurance of obtaining the funds necessary to design and construct WNP-4, and to cover related fuel cycle costs for WNP-4.

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im C. Petersen Subscribed and sworn to before

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JIM C. PETERSEN PROFESSIONAL OUALIFICATIONS OFFICE OF ASSISTANT DIRECTOR

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FOR QUALITY ASSURANCE AND OPERATIONS DIVISI0fl 0F PROJECT MANAGEMENT I am a Financial Analyst on the staff of the Division of Project Management, U. S. Nuclear Regulatory Commission.

I am responsible for reviewing and evaluating the financial qualifications of nuclear facility license applicants to pursue the proposed activities under the license, primarily the construction and operation of nuclear power plants.

In this regard, I have prepared financial qualifications analyses for inclusion in the Staff's Safety Evaluations and for presentation as evidence on the record of the Atomic Safety and Licensing Board's safety hearings.

I have served as a Staff witness before the Atomic Safety and Licensing Board in several proceedings. My work also involves keeping abreast of developments in the money and capital markets and the electric utility industry.

I received a Bachelor of Science in Business Administration degree (awarded cum laude) with a major in Accounting from the University of Denver in 1968.

I have continued my formal education through college and university courses in finance, math, economics and computer science-and through several intensive short courses.

I am a member of Beta Gamma Sigma, the national business administration honorary, and Beta Alpha Psi, the national accounting honorary. The latter organization presented me with its award for outstanding service.

Frcin 1968 through 1973, I was employed in a number of assignments on the staff of the Controller of the Atomic Energy Commission at German-town, Maryland. These assignments included reviewing, designing and implementing accounting systems and procedures for AEC offices and AEC contractors.

I also assisted in the financial review of nuclear facility license applicants during the period when that function was performed by independent staff members of the AEC Office of tM Controller. That function was subsequently transferred in its entirety to the NRC.

In January of 1974, I joined the regulatory staff and assumed responsibilities in the financial qualifications review of nuclear facility license applicants.

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Docket Nos.'s50-460 i

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H. Denton, Assistan't Director for Site Safety, Technical Review, L Thru:

V. A. Moore,' Assi4 tant Director for Light Water Reactors, Group 2, L i

USGS LETTER FOR WNP-1, 4' APPLICATION W

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l SAB input to the SER for WNP-1, 4 is due on 1/23/74. We recognize that the USGS letter evaluation is sometimes difficult to obtain on schedule.

I would like to suggest that st:eps be taken as soon as practicable to assure that the USGS offort on the WPPSS docket will be completed for submittal with the staff SER input.

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