ML20206M992
| ML20206M992 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/22/1988 |
| From: | George Minor MHB TECHNICAL ASSOCIATES, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20206M964 | List: |
| References | |
| OL-6, NUDOCS 8812020123 | |
| Download: ML20206M992 (6) | |
Text
/'1 6
Y UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION Before the Atomic Satety and Licorsina Anpeal Board
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In the Matter of
)
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-6
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(25% Power)
(Shoreham Nuclear Power Station,
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Unit 1)
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AFFIDAVIT OF GREGORY C.
MINOR IN SUPPORT OF MOTION FOR S' FAY 1.
My name is Gregory C.
Minor.
I am vice-president of MHB Technical Associates ("KHB"), a technical consulting firm specializing in nuclear power plant safety and licensing matters, located at 1723 Mamilton Avenue, Suite K, San Jose, California 95125.
l I received a Bachelor of Science degree in Electrical Engineering from University of California, Berkeley in 1960 and a Masters Degree in Electrical Engincering from Stanford University in 1966.
I have more that 25 years experience in the nuclear industry related to engineering, design, development and testing l
of nuclear plant systems, and the analysis of construction, maintenance, scheduling and operation of nuclear power stations.
Since 1976, I have been employed by MHD and have acted as a consultant to domestic and foreign government agencies and other 8912O20123DBig"g3 PDR ADOCK 050 p
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e groups on nuclear power plant safety and licensing matters.
From 1960 to 1976 I was employed by the General Electric Nuclear Energy Division in fields related to nuclear plant components and
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systems.
I have beun involved in the review of technical issues pertaining to the design, construction, licensing and emergency plans for the Long Island Lighting Company's Shoreham Nuclear Power Station ("Shoreham") heard in various proceedings over the past ten years.
I have appeared as an expert witness presenting testimony on such matters before the US NRC's Licensing Board and before the New York Public Service commission.
1 2.
This Affidavit it submitted to support the Motion of New York, Suffolk county and the Town of Southampton to stay the Licensing Board's November 21 Order insofar as it authorized the issuance of a 25% power operating license for the Shoreham plant.
As described below, the operation of shoreham at power levels up to 25% rated power would cause a substantial change in the status l
of the plant, a large increase in the radioactive fission product 1
j build-up within the core, and an increase in the radiological consequence which may impact the public in the event of a serious accident at Shoreham.
I 3.
Low power (up to 5% power) testing of the Shoreham plant has occurred, under a license issued by the NRC in 1985.
That testing has involved operation of the plant at power levels I
no greater than 5% of rated power for a few months.
The rcports a
i t
I _
e available to MHB indicate that the plant has had no nuclear operation for more than one year.
Tais limited period of actual operation, often at extremely low power levels and not exceeding 5% power, has resulted in some irradiation of the nuclear fuel and some irradiation and contamination of certain plant components, but many of the short-lived radioactive products have now decayed to nearly insignificant quantities.
If there is ne further operation of Shoreham beyond that which already has occurred, the task of decontaminating and decommissioning the plant will present a finite task which should involve no serious technical obstacles.
However, sustained operation of the plant at power levels up to 2St rated power will result in a substantial increase in the irradiation of components and the build-up of radioactive contamination.
Irradiation of reactor components is essentially irreversiblet and, once plant components and equipment have been contaminated by substantial
(
quantities of long lived radioactive fission products, as would occur with sustained 25% power operation, decommissioning of the plant would be more difficult from a technical perspective and more expensive due to the added care that would be required in handling the more intenscly irradiated fuel and reactor components.
In addition, after sustained 25% power operation, i
the decommissioning task would involve an increased risk of worker exposure to harmful levels of radiation.
4.
The amount of component irradiation, contamination, and build-up of fission product inventory which would result from i.
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4 sustained operation of Shoreham at power leveln up to 25% would be substantially greater than that which oxists as a result of the intermittent testing at levels no greater than 5%, which has occurred at Shoreham to date.
The radioactive inventory in the form of fission products in the fuel, when operating at 25%
power, would be approximately 5 times greater than with the reactor operating at a sustained level of 5% power.
- However, because the average power level of Shoreham under its 5% power license is likely to be only a fraction of 1% power, the actual t
increase in fission product inventory at 25% power operation is l
even more significant than nerely a 5-folcl increase.
5.
The purpose of a license to operate Shoreham at up to 5% power was to permit the necessary low power testing to be performed.
Once this testing was conducted and the operator training completed, the plant sat idle for long periods of time (112 para. 3).
This is mainly because operation at 5% power does not permit reliable generation of power for use on LILco's grid.
I If LILCO obtained a license to operate at 25% power, the goal i
would be to cperate continually at or near the highest power
[
1evel permitted.
This would result in much greater irradiation of reactor components and a much greator build-up of fission
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products in the fuel.
The greater fission product inventory in f
the fuel would result in a potentially higher radioactive release
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l in +he event of an accident.
The higher irradiation of the reactor veshal and components would result in greater levels of l
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residual radioactivity and higher worker exposure in the event the plant were to be decommissioned after operation at 25% power.
6.
The NRC has concluded that during operation at 5%
power, the likelihood of an accident and the reduced consequences thereof are sufficiently low that substantially reduced offsite planning is all that is required (111 10 CFR 50.47(d)).
- However, at 25% power, the offsite consequences if an accident were to occur, can be more severe.
The NRC Staff's recent review or Lilco's 25% power proposal (Staff's Technice1 Evaluation of LILCO's Request to Operate the Shoreham Nuclear Power Station at Twenty-Five Percent Power, Oct.
6, 1988 ("Staff's Technical Review")) addresses this fact.
Thus, for instance:
1)
In the detailed reports underlying the Staff's 25%
power review of LILCO's PRA, the Staff acknowledges "the absolute distar.ce at which major reductions occur in the probability of exceeding a particular dose are dependent on modelling and input assumptions and are an area of remaining uncertainty." 1/
2)
In addition, the Staff acknowledges that while the probability of exceeding a five rem dose (the upper bound EPA PAG dose for whole body exposure) is also reduced at 25% power "significant reduction does not generally occur within the 10 mile EPZ."
2/
Thus, at 25% power, the probability of exceeding a five rem dose is not significantly reduced within the 10 mile EPZ.
Therefore, l
1 1/
Staff's Technical Review (Enclosure 2 at 46).
2/
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i at 25% power operation, there is still a need for an approved and implementable offaite emergency plan in the 10-mile EPZ.
-(jW/hh Gregorf C.' Minor Subscribed and sworn to before me this M A day of November 1948.
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(Notary Publip My cor. mission expires:
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