ML19281B515

Statement of Matl Facts Which Are Not in Dispute.Applicant Not Able to Build Eight Plants by 1985.Statement Filed in Opposition to NRDC Statement of Matl Facts

ML19281B515
Person / Time
Site:	Atlantic Nuclear Power Plant
Issue date:	03/08/1979
From:	Haga P, Nutant J OFFSHORE POWER SYSTEMS (SUBS. OF WESTINGHOUSE ELECTRI
To:
References
NUDOCS 7905250313
Download: ML19281B515 (7)

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NRC PUEL:C C;. L. 200M 91

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a r UNITED STATES OF AMERICA 3 ;. - Rj NUCLEAR REGULATORY COMMISSION \ MM 43

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'- , ~ i'[. e 3 In the Matter of  :

OFFSHORE POWER SYSTEMS  : Docket No. STN 50-437

(Manufacturing License fo Floating Nuclear Power Plants)  :

APPLICANT'S STATEMENT OF MATERIAL FACTS WHICH ARE NOT IN DISPUTE AND APPLICANT'S COUNTER-STATEMENT OF MATERIAL FACTS OPPOSING NATURAL RESOURCES DEFENSE COUNCIL, INC.'S STATEMENT OF MATERIAL FACTS AFFIDAVIT OF P. BLAIR HAGA, DIRECTOR, PLANT ANALYSIS AND LICENSING, AND DR. JOHN A. NUTANT, MANAGER, PRODUCT ASSURANCF AND I

ENVIRONMENTAL PROGRAMS t

STATE OF FLORIDA  :

ss.

COUNT'l OF DUVAL  :

1 We, P. BLAIR HAGA and JOHN A. NUTANT, being first duly sworn, do hereby depose and say:

1 The Professional Qualifications of P. Blair Haga are incor-porated in the hearing transcript following p. 1024. The Professional Qualifications of John A. Nutant are incorporated in the hearing transcript following p. 609.

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I. Applicant's Statement of haterial Facts Which Are Not in Dispute.

1. The Applicant, Offshore Power Systems (" OPS"),

filed an Application to Manufacture Eight Floating Nmviear Plants in January, 1973. This Application was docketed by the Atomic Energy Commission (the predecessor to the Nuclear Regulatory Commissioni in July, 1973 under Commission regula-tions set forth in 10 CFR Part 50, Appendix M. From the time of original filing until the present date, the Applicant has continually sought authorization to manufacture only eight floating nuclear plants. Each such floating nuclear plant is capable of supplying electric energy to a utility system grid.

II. Applicant's Counter-Statement of Material Facts Opposing Natural Resources Defense Council, Inc.'s Statement of Material Facts.

2. The Blount Island manufacturing facility of the Applicant located in Jacksonville, Florida, construction of which is incomplete, is presently designed to produce one floating nuclear plant per year. The facility design is such that it could be expanded to produce more than one per year, up to a maximum of four floating nuclear plants per year should

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market conditions and orders for ficating nuclear plants warrant such expansion.

3. Applicant from time to time has assessed its market for floating nuclear plants based on utility projec-tions of electric power demand. While Applicant was opti-mistic of the potential market for floating nuclear plants prior to the Arab Oil Emtargo of 1973-74, substantial ,arket changes have occurred since that time. As a consecuence, it is physically impossible to build as many as eight floating nuclear plants prior to 1985 in Applicant's manufacturing facility. Further, Applicant has no current plans to seek authority to manufacture more than the eight floating nuclear plants, license for which is currently pending.

Should market conditions improve and should the eight float-ing nuclear plants which are the subject of the current application be both licensed and sold, Applicant thereafter will assess its potential for participation in the then cur-rent m.rket, and based on such an assessment may apply for authority to manufacture additional floating nuclear plants.

4. The floating nuclear plant is an application of proven technology. It employs the Westinghouse nuclear steam supply system and the Westinghouse ice condenser con-tainment, both of which have been previously licensed and

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are operating. The proposed floating nuclear plants, even with some novel features, do not represent basic new tech-nology but are based on many years of experience with many

'ower reactors and numerous harbors, ocean-going tankers and ocean oil drilling rigs. (See 42 Fed. Reg. 25782-84; May 19, 1977.)

5. The design provision on the floating nu: lear plant proposed by the NRC Staff in the Final Environmental Statement, Part III (NUREG-0502), p. xv, respecting the replacement of the concrete pad beneath the reactor vessel is a design provision which addresses the release of radio-active material to the liquid pathway. Therefore, the risk addressed by this design provision is solely that associated with releases to the liquid pathway and not the airborne pathway which must be included in assessing total risk.

6. Any special consideration of riverine, estua-rine or barrier island siting of floating nuclear plants with respect to environmental review will await the filing of a construction permit application by a utility / owner of a floating nuclear plant. The NRC Staff's requirements set forth in the Final Environmental Statement, Part III (NUREG-0502), p. xv, under Siting Requirements at paragraph 1, address the contents of environmental reports that may be

filed by utility / owners of a floating nuclear plant at the time of an application for a construction permit and are not required "in advance of any specific siting pro-posal . . . ."

7. The licensing regime for the floating nuclear plant is set forth in 10 CFR Part 50, Appendix M. Appendix M authorizes the manufacture of a floating nuclear plant but prohibits shipment to a utility / owner until the award of a construction permit. Therefore, no siting of a floating nuclear plant is authorized under Appendix M and no siting of a floating nuclear plant will be authorized until a utility / owner has filed an application for a construction permit which under Commission regulations must include an environmental assessment of the siting of the floating nuclear plant. Under the tenets of Appendix M, the environ-mental review of the preparation of the site and the opera-tion of a flocting nuclear plant at that site are deferred until an application for a construction permit has been filed. Further, as a practical matter, no floating nuclear plant will be manufactured by the Applicant unless and until it has been contracted for delivery by a utility / owner. Since a license application for only eight floating nuclear plants has been filed under Appendix M, the " total environmental f

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consequences of the siting of a substantial number of (floating nuclear plants] . . . " await future actions"by utility / owners which may or may not occur.

8. The eight floating nuclear plants sought to be manufactured can be dep: ayed along the Eastern, seaboard and Gulf Coast of the United States. The shoreline along which such siting could occur exceeds some two thousand statute miles. Typically, the siting of the floating nu-clear plants will occur in pairs resulting under this license in fo such pairs. Since such a typical installa-tion would involve less than one statute mile of shoreline

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deployment, eight floating nuclear plants can be sited along only four statute miles of more than two thousand such miles of shoreline available. Thus, the NRC Staff ha-3 determined that:

"although this action could cause conflicts in the use of the zone that could possibly be significant, tne effects would be local-ized and confined to a few relatively small areas along the coastline." (Final Environ-mental Statement, Part II (NUREG-0056, Volume 1), at p. 9-5)

Any such conflict will be addressed at the time'of environ-rental review for the siting of floating nuclear plants by a utility / owner in its application for a construction permit.

The floating nuclear plant is capable of flexibility in siting

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such that one method of resolving localized conflicts would be to change the siting locale of the floating nuclear plant.

9. Research for the commercial utilization of solar power is cont"nuing. The Applicant is familiar with many of these programs, including ongoing pilot projects, some of which are being conducted by Applicant's parent com-pany, Westinghouse Electric Corporation. None of the pro-grams of which Applicant is aware will demonstrate economic practicality or be available for wide-scale application by the 1990s. Therefore, in assessing solar alternatives to the floating nuclear plant, the time frame during which these alternatives may prove economically feasible and may be available for wide-scale commercial deployment is an essential fact which has been properly addressed by the NRC Staff in the Final Environmental Statement, Part II (NUR2G-0 0 5 6, Volume 1) , at pp. 10-22 and 10-23.

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j/,e P. Blair Haga, girector Plant AnalysisVand Licensing a /-

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g/chn A. Nutadt, Manager V Product Assurance and Environmental Programs Sworn to and subscribed before me this /hday ~

of March, 1979.

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