ML20083P721

Statement of Matl Facts in Dispute on Eddleman Contention 15AA

ML20083P721
Person / Time
Site:	Harris
Issue date:	04/16/1984
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20083P695	List: ML20083P691 ML20083P721 ML20083P736
References
NUDOCS 8404200132
Download: ML20083P721 (4)

Text

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. .a STATEMENT OF MATERIAL PACTS IN DISPUTE ON EDDLEMAN CONTENTION 15AA

1. Historical performance of all Westinghouse PWRs in the US is a most inappropriate estimator of Harris l's performance.

2. Westinghouse units smaller than about 700 MWe have such i

a disfferent distribution of capacity factors than do larger units (including units more similar to Harris 1) that the smaller-than-700-MWe units are a statistically distinct population to above 99.8%

confidence level.

3 CP&L itself has stated that Beaver Valley 1 and North Anna

1 and 2 are uni += - w lar to Harris. This was stated in anplying for a certificate of convenience and necessity to construct Harris, before the NC Utilities Conanission in Docket E-2 sub 203 CP&L admits as much upon discovery. See responses to Interrogatories 15AA-18(e)(f) and (g), 11-17-83 at 1k-15. These units are in fact the most similar to Harris, since they were designed and pronosed at about the same time.

4 It is appropriate to estimate Harris operating capacity factor based in part on the perfomance of North Anna 1 and 2 and Beaver Valley 1, the 3 units CP&L originally identified as similar to Harris. There is no way to exclude similar performance by Harris 1.

5. The alleged Harris design improvements include not using

phosphates and not being cooled with seawater. It is hard to see why CP&L would have considered cooling a plant so far inland with i

sea water. Still, North Anna 1 and 2 and Beaver Valley 1 are not r cooled with sea water, and at least the North Anna units have always un i

[

r used AVT water treatment, the same that is planned for Harris. See Eddleman 6-28-82 amendments, pages 10 and following.

6. Harris 1 has Westinghouse model D steam generators. Such steam generators are associated with lowered capacity factors in initial operation. There is no way to assure that long-term performance of these steam generators will be better, or as good, as other S.G.s

.- s.

nor that they will no further adversely impact Harris operating C.F.

7, Despite claimed improvements in CP&L's Koppe affidavit, pp 10-12, relating to lowering length of outages, CP&L estimates Harris refueling outages will take 15 weeks initially (1st 2 cycles) and 13 weeks'(3 months) each, thereafster. 11-17-84 response at 8, ints 17(a) and (b). This is longer than tynical nuclear refueling outages scheduled at other plants operating now.

Westinghouse 8 3-lopp PWRS are associated with an approximate 11.5 to 11.8%

reduction in capacity factor. Komanoff affidavit, item 12, p.2.

Harris is a 3-lopp Westinghouse PWR.

9. Koppe says that CFs should draw closer to the average the longer PWRs (or other nuclear plants) overate, affidavidt at 15-16.

Yet Beaver Valley 1 is the longest-operating of the 3 plants most similar to Ham is, and its CF has dronped from 38.5% to 37.7% at IP-31-83 It is sure]y not drawing closer to the average. There is not evidence to suoport Koppe's assertions in this regard, and he presents no studies of CF vs. age to s upport it.

10. Greater CP&L involvement in densigning and building a nuclear plant is associated with a significant drop in performance.

The Brunswick plants have a 9 to 11 percent lower C.F. (p 9 to 11 points lower) which is unique to them and statistically significant At the 95%

to 99.5% confidence levels. Komanoff affidavit, item 7. This is true after controlling for the effect of salt water (brackish) cooling.

See Komanoff statistical analysis accompanying letter to Edelman.

11. CP&L is more involved in designing and building Harris than it was in Brunswick.

12. CP&L has twice been p aliged by the NC Utilities Commission fo= mismanagement resulting in outag e of 70 plus days (each) at Brunswick. Outages, of course, reduc . capacity factor. One such an aNo Ed nC&[$e$ngfnM h$k0 y C$'

! \: -

< a 13 NRC Staff does no checking on how well its past projections SeeobjectiontoInterrogatories37etctoI.(gp -

of capacity factor have panned out. The Staff estimated 80 percent ) ,g ,

at the CP stage (11-10-83 response to interrogatory #126, p.11 of t

filing). NRC Staff overestinaged the capacity of McGuire 1 and on information and belief a has consistently overestimated operating nuclear capacity factors ofj plants licensed to operate in the US.

14 NRC Staff uses statistical bases (NUREG-00PO) that exclude reactors permaniently shut-down or long-term stud shut-down, e.g.

TMI 1 and 2. This baiases their averages higher. TMI 1 and 2 are in the same simze ran6e as Harris.

. The actual capacity factor over a 25 or 30 year operating life can be next to zero for a nuclear plant. Consider TMI-2 on this basis. It ran at 90% CF for 3 months and will never run again.

The equivalent 25-year C.F. for it is thus under 1% (less than one percent). Therefore, much lower performance than 55% by a new nuclear plant cannot be excluded.

16. There is no basis for concluding that Harris will perform at a 55% or higher cauacity factor in commercial operation. CP&L's record of mismanagenent, lower C.F. 's (on average) for similar plants, the NRC's use of statistics that exclude plants inoperable (including PWRs in Harris l's size range) which baiases NRC statistics to the high side, and other matters referred to above show that this is a matter in controversy and not an open-and-shut- case as CP&L claims.

16 April 19814 dW Wells Eddleman I

1 i

s s EXHIBIT Q Qualifications of Wells Eddleman NC Public Interest Research Group, Staff Scientist 1979- ; Pt!11 ties Project Director 1980 .. Work includes investigation, assisting student researchers, and informing the nublic about issues in energy conservation, toxic wastes, nuclear energy, radioactive waste, and other fields. I advised DI9G in an ene*gy survey of Elon College and in similar work tG General Fnergy Consult $ng,uild rd Coll. f#3e.nendent energy and ro13utson 197f-control consultant with industrial, comnercial, residential and ihstitut*.nnal clients. Exnerience ranges from insulating water heaters and buildings, through designing and installing ene*gy-caving control systens, to studies of regional ene=gy neads end the costs and means of achieving them, with emphasis on electric nower syste,c and neeting end uses now met by electricity and oil thrnugh renewable energies instesd. I have designed, built and tested solcr ecuinnent.

Carolina Friends School, Energy Manager 1977-81; Teacher and Ene"F7 Donsultant 1977- . We achieved a 65% reductinn in electricity use and a peak demand reduction of 25%, both adjusted for weathe*,

during the h yects I was Energy Manager. The demand reductior continues at the same level, though the energy sevingr are only about 50% to 55% in 1981-82. Man Connunity Integrated Enevgy Systens grant which seved 15% on electricity and nuch hecting fuel, 70 clients.

Main speaker on econonics of coal, nuclear and solar ene gv, UNC-Chapel Hill Ene*gy Synnosiun 1981. Guest lecturer of energy and nuclear issues at Duke University, NC Central Unive*sitv, and UNCoCE classes. Presented paper "The Market Environment for Energy Alternatives : Potential and Actual" to 1983 UNC Fnvironnental Affairs Conf.

Expert witness before NC Utilities Comnission: Docket Fo. E-100 sub LO

(load forecast,1981), E-100 sub h1 (Avoided Cost rates), E-7 sub 31b and sub 338 (Dake Power General 9ete Increases); E-? sub h16 and E-2 sub hbh (Coal General Rate Increasec); E-2 sub h36 and E-bl (nuclent newer niant sale); E-7 sub 303 (Duke nuclear niant sale); E-7 sub 3b3 and E-2 sub h52 (fuel adjustment clause). Ficids of ere gv con serva tion and energy systens (or sone continat'on thereof, however nemed).

Other testimony duly nref' lad and given in E-103 sub 35 (load forecast 1979) in which I stated unon cross-exa9*.nat'nn that I was testir-ing as 9n exrert; E-100 sub 36 (PURSA standa-ds for eneag -seving, ate);

E-100 sub 37 (forming an Alternative Energ Cornoratinn): E-100 sub h1 avoided-cost setting hearin6 of 1980-81. I an testifv'n6 P8 FD espett in NCUC Docket No. E-100 sub h7 (fuel inw rulencking) 1965 With the heln of NC PIRG staff, I produced a 120-nage renort for the E-100 sub h0 load forecast hear'n6 in 1981. Expert testimony also in NCUC Dockets E-100 sub h8 (198h), E-100 sub h6(1983 load forecast)

E-7 sub 358 and E-2 sub h61 (electric general rate cases ), E-100 sub h1 1982 proceeding on avoided cost rates.

Educatien: S.B., MIT, 1971, ?hysical Sciences, concentrating on systens, including physicc, ccmpute" science, menngement and educction M. Ed., Policy Studies, University of Illinois Urbana-Chamonigr 1977.

Additional coursework ir nanagement and educational administ=ation Research on va'idity of stetistical techniques ir educatienal and ability test'ng.

Diniona in Welding, Gaston ColleEe, Dallas NC 1975 Additional course work at other universities including lic Satate U.