ML17346A938

Radiological Environ Monitoring Rept,Jan-June 1983. W/850829 Ltr

ML17346A938
Person / Time
Site:	Turkey Point
Issue date:	06/30/1983
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
L-83-464, NUDOCS 8504100398
Download: ML17346A938 (157)

Text

RAD I OLOG ICAL ENVIRONE NTAL NONITORI NG RE. URT TURKEY POINT UNITS 3 & 4 DOCKET NOS. 50-250, 251 DADE COUNTY, FLORIDA 1-1-83 TO 6-30-83 PREPARED AUGUST 1983 8504100398 880&~&

PDR ADOCK 05000250 R PDR

1. 1NTRODUCT10N This report is submitted pursuant to Section 6.9 of tne Turkey Point Plant Units 3 5 4 Technical Specifications.

Radiological envirorrnental surveillance for tne Turkey Point Plant. is conducted in accordance with Section 4.12 of the plant's Technical Specifications. A summary of the samples collected and analyses performed during the period January 1, 1983 through June 30, 1983 is provided in Table 1.

2. THE NDNJTOR1NG PROGRAN Period Covered: This report covers the p riod frcm January 1, 1983 through June 30, 1983.

Analytical Responsibility: Envirormental radiological monitoring for tne Turkey Point Plant is conducted by tne State of Florida, Department of Health and Rehabilitative Services {DHRS). Samples are collected and analyzed by DHRS personnel.

Number of Samples: During the- period, a total of 707 samples were collected from 35 different locations to be analyzed for radioactivity.

Table 1 summarizes the highest, lowest and mean results for all sample locations, and where applicable the highest, lowest and mean results for the sample locations which yielded the highest mean levels. The. values in Table 1 are based upon only those analyses which yielded detectable measurements.

5"'. i=-Sample: During the period januarv 1, 19B3 - june 30, }983, ir, addition to the samples identified in Table 1, }1 samples w.re collected for canparative analysis by the DOE in accordance with the DHRS/DOE split-s am pl i ng pr ogr am.

3. Yi}S SING DATA Due to the length of time required to porform the analyses, several 8gSr, gOSr results were not available for this report. Wnen completed, tnese l

results will be provided in a supplemental report. Based on past experience, the missing data is not expected to alter any of the conclusions of this report.

A description and explanation for missing data is contained in Table 1.

4. D I SCUSS10N AND }NTERPRETAT10N 0" DATA Air Monitoring: Continous.air sampling was conducted at 8 di fferent locations surrounding the Turkey Point Plant. Samples were collected and analyzed by Florida DHRS for gross radioactivity and radioiodines (1-131) on a weekly basis. All samples from this reporting period were within the normal range of background measurements. Table 1 provides a summary of these results.

Direct Radiation Nonitoring: Continuous monitoring of ambient radiation exposure rate was provided routinely at eleven different sample locations surrounding the Turkey point pl ant. Sampl es are co11ected and analyzea oy Florida DHRS on a monthly basis. Results are based upon the average readings of two dosimeters at epch location. All results fran this reporting period were within the normal range of background measurements. Table 1 provides a summary of these results.

Other Samples: In addition to the samples described aoove, several otner envirormental samples are routinely collected fran areas around the Turkey Point Nuclear Plant. These samples include precipitation, surface water, drinking water, sediment, fish, crustacea, food crops, vegetation, milk, soil and other terrestrial biota. Table 1 provides a summary of the results of these samples fran January,1, 19S3 through June 30, 1983.

As in the past, tritium has remained the predominant radionuclide measured around the Turkey Point Plant, wi th the highest concentration (7000 pCi/1) found in mter samples collected fro~ the closed cooling canal. Tnis concentration is approximately 0.23 of the concentration which woul a be permitted continously in unrestricted area waters. In addition to the waterborne tritium, radionuclides of cobalt, cesium and cerium were detected in sediment and fish samples extracted from the closed cooling canal. The reported levels of these radionuclides are very low, and are consistent with past measurements, with no evidence of continued buildup.

In addi tion, the concentrations of 137Cs and 144Ce in these samples are within the range of values which wre obtained from simi'1ar samples during the preoperational surveillance program, and in samples which have been collected elsewhere within the State of Florida.

The results of radiological m asureaents for other media and other loca:ions surrounding tne Turkey Point Plant do not yield evidence of buil dup in the enviroment when canpared to past measurements, incluain",

samples collected during the preoperational surveillance program, and elsewhere within the State of Florida.

5. CONCL US I ONS The concentration of al 1 radionuclides reported in Table 1 is mucn less than that permitted for release to unrestricted areas as specified in 10 CFR 20, Appendix B, Table II. The Radiological Envirornental t~onitorinc Program establishes that radioactivity released as a result o operation of the Turkey Point Plant Units 3 8, 4 is not contributing significantly to the radiation exposure of any individual or population group.

TAULF. I ENVIRON(<NIAL RNJIULOG ICAL M(JNI TUNING PNONAM

SUMMARY

NAME OF FACILITY TURKEY PUINf PLANI UNITS 3 (( 4 UUCKET NU. 5U-ZbU, Z51 L(KATIUH OF FAcILITY UADE COUNTY Fl.UNIUA REPORTING ('L((IU(J JANUARY I, 1903 - JUN(. Ju, 1903 Vdige I vl l u Al I Indicator Location 4th I((ghost Mean ~

Cuntro(Z> ((d. Of Number of Loca t lons Locdt(on nonruu c I ne Medium or Path~ay a lysis Gamp e Locat on Ii KdVurted Sam Ied Un It for Sl tes Sam les Analyses Mean ) NaPJe Ul stance 6 Ulrect ion Mean Na e 1 Mean I K d ll/e

,(1 Measurvnent~

1.1 AIR

1. Particulates pCI /m Gross 8 Z08 208 .016 .U(J5- (56:Pr lnceton Subs tat(u( .0 16 . U I 0- .0IG .IJ(0-(ZUN/ZUU .030 (0 mlles - NNN) (Zb/Z(1 .UZ4 (Zb/CbJ . oc'/

2. Radioiodine /m 1311 208 208 NU pCl 1.2 0 IRECT RAO IATIOH I ~ TLO uRem/h Exposure 11 131 ) 2.3-6.6 T64: Natoma Substatlun 5. (i 5./ 5. (-

Rate (66/66) (ZZ mlles - H) (6/6) b.6 IG/6) G.b 1.3 PRECI PI TAT ION

1. Ral(n(a ter pCI/I Gross 8-DS 24 2.7 I. 3-4.9 T52: Florida C(tg bub- 4.5 Z.G l 5-(1/24) statlon (1 mlles - (() p( icdo Ie

TnttLC I KtIYIROttt'I:tITN. RN)IOLUG ICAL MOttllURIHG PRUGIIAM

SUMMARY

HAMS OF FACILITY IUIILLY POIHr PLAHr IIHITS 3 r, n IIUcKL'I tlu. 50-250, 251 LOCATION OF FACILITY OAOE COUNTY I'LURIOA RFVURTltlG I'LRIOO JNIUARY I, 1903 - JUHL JU, 1903 r~ip: 2 ut IV All Indicator location with Hlgnest Mean Cuntrul nu. ut Number ur Loca t lons Loca t lun Ku(II vut toe Medium or Pathway An a lys I s bamp e ucat on Kel~rteu Sam led Un I t for Sites Sam les Analyses Meanl) Katx el) Olstance II Olrectlon Mean > Ka e I Mean I Kan>~ I > neasurenents 2.1 SURFACE MATTERS

1. Estuarine 10 20 (Surface Mater) pC I/I Tr I t lum 5ZU IUI: Card Sound 520

( I/20) (6 mlles - 5] (I/2) 89Sr 10') HU HA tIA HA gOSr 10')

Y eml t ting ZO I sotopes Z. Closed Cooling 12 Canal (Surface Mater) pCI/I Tr I t lorn 12 5100 3900- TUn! Cl osed Cool I ng SZOO nOOO-(12/12) 7IIUU Canal (Unslte- SM) (b/b) 1IIOU egS 03) NO HA tIA I

'OSr 03) 1.3 tIA 104: Closed L'oollng 1.3 Hn (I/O) Lanai (Onslte - SK) '(I/n )

Y emlttlng" 12 tie tIA Hn ltn Isotopes OS - Dissolved Solids UDS - Undl sso I ved Sot lds Hll - Not Octectable tlA Hut ntlpl Icaule

IAULI. I EttVIRUINEIIIAL lthOIOLOG ICAL tlutll IOlt I tl0 PROI7IAH SINrlhRY HNIE OF FACILITY TURKEY POltll'Lhtll UtlITS 3 6 4 OOCKLI tlU. 50-250, 251 I.DCATIOH FACILI TY 'DADE COUHTY fLURIOA tfEIUttrlrtl; I'Lttlutt JAHUARY 1. 1903 - aunt. 30, 1903 I'auu 3 ut IU

'vntro OF All Indicator Locatlvn with Highest A.an ld) tiv. vt Humbcr of Locations Location Hunrvut lne Hedlum or Pathway Analysis anp c l.ocatlvn Nvttul tvu Sampl ed Unl t for Sl tes Samples Analyses t<canI ) Range I ) Distance 6 Direction tleanl ) el) Hean>> Raiqv I I riedsuronunts

3. Fresh Mater Drainage Canals (Surface llater) pCI/1 Tr I t lum 12 390 2)0- T15 - Florida City 390 210- ttn tth (5/12) 600 Canal (2 mlles - MHM) (5/6) 600 HR tlh Gross B-DS 12 166.9 3.0- T15: Florida l.ity 300 200-(11/Iz) '310 Canal (Z mlles - MHM) (6/6) 370 Gross 0-UDS IZ tlO Hh Hh Z.Z IIELLS

1. Potable Mell Mater (Drinking Mater) pCI/I Tr I t lorn IIO ttR N

Gross B-DS 6.5 4.Z-10.9 T57: Dolan's Farm 0' 6.6- HI'l HIL (6/6) (4 mlles - HM) (z/2> 10.9 Gross B-UOS 1.5 Hh T51: Dolan's Farm 1.5 HA rtn (I/6) (n mlles - HM) I I/Z)

2. Ground Mater

~ Mel ls IZ (Ground Mater) pCI/I Tr I tlum IZ n00 ZZO-090 TUU-Groundwater Mc1 I 090 (n/Iz) E-ln (5 tttlcs - S) I I/2) 89Sr 12. ttO Hh tlh tin 9DSr 12 llh Y enlttlng4 IZ HU HI\ llh Isotopes DS - Dissolved Solids UOS - Un(ll sso I vcd So I lds HO - tlot Octcctahlc tlh - tlut Rtltlt ICdv I v

fhUI L I EIIYIROttte tt I AL RAUIULOG ICAL wtt I I URI tlG PIIUWAII surirIARY HNE OF FACILITY IUIIKEY POIHf ILNIT Util IS 3 f, 4 UVCXET Hu. >U-Z50, Z51 LOCATION OF FACILITY OADE CUVHfY ILOI\IUA HEI'Ultl IHG I'L'lll00 JINUAHY I, 1903 - JVrlt 30, 19N Pave 4 vt 10 hl I Indicator Location KIth IllgiICSt llcan l.'vntrol~> IIV. Vt NuIItIcr of Locatlvns Lvc a 't I v n nonrovt Inc edium or PathKay Analysis Satrrp e Locat on IICPvr CCIt Sampled Un i t for Sites Samples Analyses ttca nI ) Range Ol stance 5 Ul rect ion rlcan ) ila e ) dean ) Kong' I)

~

IICdSUreflentS 3.0 BOTTCti SED INENTS

1. Closed Cooling Canal (Sediment) pCI/kg 09Sr HD IN N 9OSr tth a Y enf tting I sotopes I. 6OCo 330 ZZl -400 I 04-Closed Coul I ng 3/lt ZIIV-40 (4/4) Canal (Vnsl te - SK) iz/z)

Z. SUCo 60 tlh IV4: Closed Cooling 6U IN

( I /4 ) Canal (Unslte - SK) (1/C) 144Ce ZZU 705: Closed Cvullng zzv. IIn . IN IN

( I /4) Canal (Unslte - SKI I I/Z>

C, 51 f04: I;l used tooling ,SI IN (I/4) Lanai (Unsltc - SK) I I /z)

5. Others ttO Hh lih IN

2. Estuarine (Sediment) pCI/kg 69Sr tl0 tlh N 9OSr . HU Hh Y eml ttlng IS isotopes OS - Di ssol ved Solids UOS - Undl sso I ved Solids ri0 - tlv t Oe tee tab Ie Iln rivi. Appl lcalr te

TAULI. I FIIVIIIORN:NTN R)6IULOiilCAL NNIIIUNIIIG I'RVQIAM SUNHAIIY IIA)IL OF FACILITY TURKEY PO IIII PLA)IT UNI IS 3 II 4 DOCKET t)0. 50-Z50, 251 LOCATION OF FACILITY DADE COUNTY FLORIDA REPUNIIHG I'L'RIVD JAIIUARY I, IgN - JU)It; 30, IgN I'age 5 vt lu hi I Ind I ca to r Location with Illgnest )lean Control I nu. vt llumbcr of Loca t I vns Local.lvn ttunrwt Inc

)Tedium or Pathway Anal ys I s S@np e Locat on Nc)erteu Sampled Unl t for Sites Samples Analyses )lean ) Range Distance II Direction canl ) Nange nean ) Nan7e neasuronent~

1. Crustacea (Blue Crab) pC I /kg B9Sr 43) HD 90Sr 43) 62 Tg I 'PUlhjfkln Key Un nn (I/4) (B mlles - SSI;)

y eml ttlng t<D IIA W'L Hn I sotopes Z. Fish, Carnivore (Hlxed Species) pCI/kg Sr 63) HV i)h 90Sr 63) IIO IIA >o'I NA Y eml t ting isotopes

1. Cs 77 TU4 - Closed Cooling 77 IN

( I/O) Canal (Vnslte - SM] (I/2) 137Cs 240 150- TU4:Closed Cooling 240 )50- IN (Z/8) 32U Canal (Unslte - SH) (2/I) 380 DS - Dissolved Solids UDS - Undl s sv I ved So I I ds IIV - )lot octcctanle Iih - UV t np pl eau)e

fhULL I EHVIIN)larL'ttfhL RAUIULUGICnL Nurll IUHItlG I'rrUGrtnrr SUrrl<nttY NINE OF FACILITY IUIIKFY I'Ultlf I'Lhttf UHI f5 3 II 4 UUCKET HU. 50-250,,251 LOCATION OF FACILITY OAOE COUNtY FLURIUA 'IEIUlrfirrG I'LrtlUU JnHUnHY I, 1003 - writ JU. IUOJ I'd eJ1! b u t I u All Indicator Location <<ith llignest I<can r.'un t ru I 2 I lru ~ u I tlumber of Locations Loca t 'Ion lrdnl out lne edlum or Pathway Analysis Sample Location lrln r1d r t e1t Sampled Un I t for Sl tes Samples Analyses rreanI ) lhl neJ ee Uistance rI Uirectlon rrudnI ) ~kan e<1 n en~i nedsurellents

3. Fish, llerblvore (Nullet) pCI/kg ee 095r 905r 53) 53)

HO HO Hh'N rrn IIA nn Y on I tt I ng4) 6 IN Nh rvr Isotopes

4. Turtle Grass

. (Turtle Grass) pCI/kg 095r 53) HO rvl ee 90Sr 53) HU IVi 1m Yeml t t lng4) 6 isotopes

l. >>'Cs 250 frll: Card Sound 250 ra'l (I/6). (6 mlles - S) I I/1)

2. Others HU Hh tlh IVL

5. Sponges Y emitting Hll IN rvl (Sponge) pCf /kg Isotopes OS - Ol ssolved Solids UOS - Undl ssu1 ved Sol lds NU - Not Uetectdole trn - trvt nllpl icdule

TADLE 1 EtIYIRUIIti.'IITALRADlOLOU ICAL Wltl 1UIIIIIU I'IIUGHAII SUrlHARY NAIIE OF FAClLITY lURVEY lolttl ILAHI UHllS 3 Il 4 UDLKEI HU. 5V-25U, 251 LDCATlON OF FAClLI TY OAOE COUNTY FLORIDA HEPOIITIHO PUIIUO JAIIUAHY 1, 1903 - duttt SU, 1983 Vdgc I vt lv All indicator Lvcatlon with lliiyicst rtcan Cvntrv I~ I lid. vt Number ut Locations Lvcattvn 1ldnl vu c Inc Nedlum or Pathway Analysis Smnp e Lvcdt ton ncpdl Sam ed Unit for Sites Samples Analyses Hcanl) Range 1) Distance Il Direction IIeant > Han cl> cteani > IId lid c ted'1cdsdl Cents 5.0 TERRESTR{AL

l. Small Animal (Racoon) pC1/kg 89Sr HD IN N 90Sr ~

IN rtn 7 emitting 4) HU IN rtn isotopes Z. Food Crops (Nalanga, pCl/kg 895 23) IN IN Potatoes) H 905r 23) IID tN HA I la Y emitting 3 isotopes 1 131Cs 152: Florida I:1 ty. UU Hn

{ 1/3) Substdt tvn {7 mlles-H) I I/I) 2 . Othe r tN IN IIA

- Dissolved Sol ids UDS - Until s su I vcd Sul I ds tIU - tlvt Uct,CCtab le HA - Itvt APPI Icdu I c DS

lnltLL 1 LIIVIIIOIII1LIIIALIIN)IULO(ilCAI. HUNI llIIIlnd PtIUIaIAI1 SUt1t1AIIT HNIE OF FACILITY lukxky POIIII I'LAIIT UIII15 3 a 4 UUCKLT Od. 5U-Z5U, 251 LocliTIOH OF FACILI TT Onor. CUUklv rLUIIIUA 'ILIUkilIII;I tkiUU dnIIUAIIT l. IUU3 -'dultt su, 19U3 I'due U vt IU nil indicator Location with Illgttest Ilean Cutltf U I i'. ul IIutnber of Locations LOCII t lot I t nt I I fuu t I tle edium or path~ay hna 1ys I s Smnp e Locat ton kutrvrteo led Unit for Sites Samples Analyses Heanl) kange Ulstance 5 Dlrecl,ion I1eanl > kan ) ttean I I Iteasurenents Sam e koranu

3. Hllk (Goat Hllk) pCI/I "9Sr II 90Sr Tgg:I'anti ly Tree Farm 1,4 1.4 tIA IIA (1/1) (11 mlles - IIk) . (I/I)

'f emitting I so tope s.

1 1311 IIA tot 1

R.Other. IIO ttn IItI tlA

4. Vegetatton (Hangrove leaves) pCI/kg 89Sr no

. 'OSr 7.4 158: Lntrance IIUad /.4 IIU ttn (I/7) (Unsite - Ihl) 1I/I)

Y emitting ) HO NI IIA IIA I1U tIA Isotopes OS - Ol sso lved Sol lds UUS - Uodl sso I ved So I lds IIU - Ilot Uetectab le Hh - ttvt nttkl l eau le

fhI)LI: I f t(VIROta(Ltlfhl. RAOIOI.OGICAI. HUI(l fUI\It(O PRU(Rht(-SWt)ARY HAH'F FAClLIIY 1URKI Y POINT PLht(l Ut(115 3 I( 0 DUCK(.f t(U. 50-250, Zbl

'RFPO)(1lNO PFRIOO dht(DARY I, IOU3 - dUNL 30, 19()3 I'a Je 9 ut I 0 LOCATION DF FACll.lfY DADE COONIY FLORIDA hli indicator Location with lllgoest Hean CuntrolZ) ut tlumher of Locations Locatiun Nunruu t inc Hedium or Pathway Analysis Sanp e Locat on ei) heanf )

ji~L'u. Ke)~rteu Sam led Un I t for Sites Sam les Anal ses Hean1) Range Distance h Olrectlun (canl ) Ran Ral HeaSurumants

5. Soll 89Sr t(h (Soll ) pCI/kg 7 gosr 7 IN Y emitting 7 isotopes c, 350 ZUO- f56: Princeton Suhstatlo 5UU (2/7) 500 (0 mlles - NNM) ( I/1 J 2 137Cs 100 az- f56: Princeton Suustatiot 260 (5/7) 260 (0 mlles - NNW) (1/1) t(h (N 3.Other .IIO

- Undissolved Sol lds - Nut Uetectaule Nn - t(ut nppl icaulu DS - Dissolved Solids ODS NO

Page 10 of 10 TABLE 1 HOTES

1) Mean and Range values based upon data with detectable results only.

( / ) Indicates the number of analyses with detectable results canpared to the numer of analyses performed

2) Control location - T64, Florida Power 8 Light Caopany -'atoma Substation (22 Miles - H).

3) Missing Data 89Sr 90Sr Analyses for 9Sr and 90Sr for the following samples (Date/Media/Location" ) were not ccmplete at the time of tnis re port.

2-16-83/Crustacea/T66 3-09-83/Food Crop/T52 5-10-83/Fi sh, Herbivore/781 5-11-83/Estuarine Water/766 5-11-83/Estua rine Water/78 5-11-83/Cooling Canal Water/T84 5-11-83/Cooling Canal Water/T97 5-11-83/Turtl e Gr ass/T81 5-26-83/Fi sh, Carnivore/T81 5-27-83/Crustacea/T81 6-14-83/Cooling Canal Water/T84 6-14-83/Cool i ng Canal Wate r/T97

b. Direct Radiation The TLD results fran location T64 (control location) on 2/9/83 are based upon the results fran one dosimeter. An abnormally high result was obtained on one of the two dosimeters recovered from this location. Ho explanation could be found for the high reading. The results frao the second dosimeter were normal and vere used to represent the reading at this location for February 1983.

4) Excluding Potassium - 40 (40K), Radon - 226 (226Ra) and Thorium - 232

(

~

Th) which are naturally occurring radioisotopes canmonly found in many environmental specimens.

• Key to sample locations is provided in Turkey Point Units 3 5 4 Technical Specifications.

P Q. BQX l4000, Jdtvo B ACh, F L 33408 J .

pl F'RlDA PQ!'. == a 'e-'7 Col.'> '. ~

August 29, 1983 L-83-464 Hr. James P. O'Reil ly Regional Administrator, Region II J.S. ")uciear Regulatory Commission 101 Harie..a Street, Suite 2900 Atl anta, Georgi a 30303 0ear i'ir. O'Reilly:

Re: Turkey Point Units 3 5 Hos. 50-250 and 50-251

-'ocket Radiological Envirornlental monitoring Report Please find attached tne Radiological cnv'.rornental i')onit0rin", ?epor= r tile period January 1, 1983, to June 30, 1983, as required oy Tecnnica',

Spe i f i c ation 6.9.4.6.

Ve ry t rul y yours, Robert;. Uhrig Vice President Advanced Systems 5 Technology REU/PLP/mpc At tachme nt cc: Harold F. Reis, ~squire DESIGNATED ORIGINAL "~

~n~

Ce- tifie5 By

~EuG'> i PEQPLE, . SERVlNG PEQPLE

Comments to Draf't Environmental Statement Turkey Point Steam. Generator Repairs by Marlr. P. Oncavage, Intervenor February 26, 1981

I'I

~

I ~ ~

f4 ll I I 1

0 '~ ..j> Fj

~~

h h

COMMENTS Purpose of this r.nvironmental Statement

Background

History of Steam Generator Operation Staff Environmental Review Radiological Assessment 13 Economic Costs of Steam Generator Repair 19 t

Nonradiological- Environmental Assessment 26 k

Envirobmental Impacts of Postulated. Accidents 29 Impacts of Alternatives 32 Conclusions 33 Appendix 38

b 0

I

~Pur ose of this ovnvironmental Statement

1. The Nucle'ar Regulatory Commission (NRC) finds itself in the untenable position of being forced to make an important management recommendation, for a privately owned nuclear utility.

The recommendation contained in the Draft- Environmental Impact

/

Statement (DEIS) will have great bearing on the outcome of the forthcoming hearings before the Atomic Safety and Licensing Board (ASLB) ~ The DEIS recommendation should be based on health impacts, safety impacts, economic impacts, and recurrence probabilities, but the NRC has limited itself'nly to safety considerations for recommending the repairs in the DEIS. At best, the NRC is incapable of making an honest evaluation of the.

repair proposal. By publishing the DE1S, the NRC has violated 40 CFR 8 1501.6.

The contributions the NRC can make to an honest study would be in the areas of',accident risk assessment and recurrance assessment, but these areas alone are inadequate under 40 I

CFH 8 1501.'-

The NRC should disqualify itself as being the sole agency writing the DEIS and should recuest involvement of the i:nvironmental Protection Agency (EPA) in assessing environmental and health impacts, and the Florida Public Service Commission (PSC) in assessing economic and social impacts. This division of interests would provide the necessary interdisciplinary approach as mandated by NEPA.

2. The DZXS is not an inhouse NRC document. j:t has been published f'r public comment and the public deserves to have the technical terms defined and, 'even more so, have the special significance given to some terms, fully explained. 40 CFR I 1502.8 requires that the DZIS be written in plain language as to be readily understood by the public. A glossary must be provided to include, but not be limited to, full explanations of the 'following terms:

1. steam generator 2. sodium phosphate secondary water

3. lower assembly chemistry treatment

4. all volatile treatment 5. full flow condensate

6. U tube desigh demineralizer

7. plugged tubes 8. wastage

9. three loop PYK's 10. caustic stress corrosion L

11. secondary coolant cracking

12. radial deformation 13. "denting"

14. rectangular flow slots 15. support plate deformation

16. tube wall thinning 17. support plate flow slot

18. plate ligament cracking hourglassing

19. power derating 20. channel cut method

21. ALARA considerations 22. SA 240 type 405 ferritic

23. inconel 600 heat exchanger stainless.-steel tubes 24. broached hole pattern

25. quatrefoil design 26.. drilled flow holes

27. corrosion products 28. shell

29. special storage facility 30. long term layup

31. reactor vessel head 32. fuel cooling "

33. fuel removal 34. spent fuel storage

35. HZPA filter 36. biological shield wall

~

WI j 37. moisture separator 38. manway

~ < 39. feedwater inlet 40. swirl vane

41. wrapper 42. transition cone

~

lf I~

43. tubesheet 44. channel head l

45. RCS hot leg 46. 75 mr/hr (contact)

47. hydrostatic testing 48. moisture carryover

49. pipe cut method 50. radiological assessment

51. conservatisms 52. occupational dose

53. person rem 54. exposure rate values

' 55. source to receiver 56. dose reducing activities distance 57. whole body dose

58. remote tools 59. 10 CFR part 20 limits

~ I

60. NASH 1400 61. 10 person years

~ I

62. environmental pathways 63. 6 mrem

64. regulatory position 65. 16 mrem thyroid

66. Regulatory Guide 67. environmentally significant

68. 270 curies 69. 2300 m

70. noble gases 71. mixed fission and activation

72. halogens products

73. gamma activity 74. particulates i 75. tritium 76. primary side i 77. radioactive decay 78. nearest site boundary

4

79. Co-60 80. natural background radiation

81. heat transfer surface 82. nuclear peaking factor F Q

83. neutron flux 84. fuel burnup

85. .038/kw hr 86. 9 25/BBL

87. 0.855 capacity factor 88. 6.1 x 10 BTU/BBL

89. permanent storage 90. turbidity

91. condensate system 92. dredge spoils

93. sound pressure levels 94. ionic species

95. mixed bed ion exchange 96. backflush receiver tank resin 97. maximum resin loading

98. backwashed resin slurry.- 99. supernatant liquid 100. 1 umho/cm 101. 100 mg/1 instantaneous max 102. turbulent mixing 103. biological oxygen, demand 104. total organic carbon 105. biological assessment 106. limiting potential 107. corrosion inhibitors receptor 108. chemical decontamination 109. grit blast 110. state of art internals 111. in place refurbishment 112. tube sleeving 113. licensed burial facility 114. facility decommissioning 115. 2200 dpm/100 square cm 116. tare weight 117. beta radiation 118. transitiors cone end 119. gamma radiation

3. The DPIS has failed to study the 169 mile cooling canal system to gather information on the many species of marine life

that have.all ready died out from the system. Studies have not been described (or performed) that would demonstrate whether the effects of, the repair will initiate or hasten the extinction of the remaining species in the cooling canals.

Unnatural tamperings with natural s'ystems or critical habitats can drastically effect the food supply for endangered and threatened species. The'-DEIS has,even failed to list the endangered and threatened s'pecies and their critical habitats living in the Turkey Point area. This lack of attention violates not only the National Environmental Policy ~ct, but also the Endangered Species Act.

4. The legacy of the Three Mile Island accident will be years of complex lawsuits in the attempt to hang the financial responsibility for the accident, cleanup, and loss of power costs on various parties. In the case of the Turkey Point repairs, r

questions of financial responsibility for accidents, cleanup, and loss of power need to be answered before the repairs are authorized and explained in the DEIS.

1. What measure of responsibility does the NRC accept for permitting the repair on the basis that the new designs will prevent the occurance of corrosion mechanisms observed to date, when in fact, they may not  ?

2. In case of unacceptable contamination of public or private resources or injury, what 'would be the NRC's responsibility since it would have approved and licensed the activities that caused the contamination or injury '?

3. '<'/hat measure of responsibility does the IJRC accept for not enforcing license requirements if'he nonenforcement of'icense requirements leads to contamination or injury 7

4. 'hfhat measure of responsibility does the NRC accept for a failure to identify and remedy the conditions that lead to contamination or injury ?

i'xamples of accident conditions that lead to contamination or injury are numerous: release of 50,000 gallons of undecontaminated primary coolant to the environment, fires in radioactive areas, construction accidents, damage to the operating reactor's components or controls whereby a design basis or lesser accident occurs, and inadequate storage of radioactive materials during hurricanes, floods, or tornadoes.

At this late date, two years after the accident, the contamination at Three Mile Island has still not been cleaned up. The DZIS is deficient because the questions of responsibility have not been answered and litigating these questions after an accident can prevent a timely and thorough cleanup if accidental contamination were to occur.

5. The NRC has intentionally avoided public input into the DEIS writing process in direct violation of 40 CFR s 1501.7.

Starting in February 1979, two years ago, I initiated hearings and requested an IS concerning the Turkey Point repairs.

Sudsequently, I have filed numerous briefs identifying issues that have been ignored by the NRC staff in the scoping of the DZIS. In addition, numerous editorials and news stories appearing locally have also outlined public concerns about the repairs. Some of the publications that printed unaddressed issues, which the IJRC closely monitors, are Miami I~".agazine, Miami News, Iiiami 1ierald, Southwest Monitor, and the South Dade News Leader. See Appendices I and II.

The NRC has ignored federal rules for seeking input, even adversary input, for the scoping of the DZIS. The genuine concerns of the citizens of South Florida have been ignored and a DEIS skewed in favor of the nuclear industry has been written. The citizens of South Florida deserve a much better effort than the shoddy effort that has been given thus far.

6. The DZIS has failed to recount the record of (Yestinghouse's poor engineering designs prior to the Surry and Turkey Point

4

,)

"N%

plants. The early westinghouse steam generatoz s, installed in Yankee Rowe, Selni, and Sena, had stainless steel tubes and used a sodium phosphate water treatment. This combination proved to be a poor engineering choice since it led to caustic stress corrosion creacking of'he stainless steel tubes. The next combination was tried at San Onofre in 1967. The. choice of inconel 600 tubes and sodium phosphate treated water resulted

'in wastage, fretting, denting, and tube leaks. The next poor engineering decision was tried at Beznau ¹l, in 1969. Inconel

-600.tubes and a zero solids water treatment produced intergranular cracks and tube leaks.

In 1973, westinghouse went back to inconel 600 and sodium phosphate at Turkey.;Point and Surry. Wastage and stress corrosion cracking of tubes forced a change to the all volatile treatment. The changeover demonstrated classic engineering incompetence. The combination of the two water chemistries, sodium phosphate and all volatile treatment, produced rampant denting at a rapid unprecedented rate. This sordid history of poor engineering choices has made the steam generators unfit for operation and has necessitated the repairs.

As a result, the Licensee, Florida Power and Light Co. is suing Y<estinghouse for selling negligently designed steam generators,. See,Appendix III. The history of engineering failures in Y/estinghouse's steam generators cast serious doubt

'on the new experimental models proposed for Turkey Point.

0 t'

The DZIS provides no positive operating experience data for the new'design of the steam generators. The estimates f'r success of the new design are baseless and highly suspect Staff Environmental Review

7. The NRC has accepted the Licensee's data without the least question and has written this data into the DEIS. FP%L, the Licensee, has demonstrated a poor record for estimating the negative costs of the repa'irs. Originally the man-rem f'r the repairs was estimated to be 1301, then it jumped to 2948 for the same repair. The time estimate which was 180 days has now become 270 days. Costs were to have been 8 102,000,000 but now the, Licensee doesn't even total the costs. Could the estimate be as high as @ 730,000,000 now '? Low level radioactive solid waste was estimated by the Licensee was estimated to be 26,000 cu. ft but now has jumped to 38,000 cu. ft. while the generic estimate is 82,000 cu. ft. per unit.

The NHC has available consultants from outside laboratories (Hattelle PNL) on this project that appear to be objective. The consultants have no obvious reason to skew estimates, yet these apparently objective estimates are rejected out of hand in the DEIS and are replaced with the apparently skewed estimates of the Licensee. The advantage the Licensee may perceive for presenting apparently skewed estimates is the notion that it will have an easier time winning approval for the repairs in the forthcoming hearings before the ASLB. Overestimating

benefits and underestimating costs can make the repairs appear beneficial in the licensing process. It is apparent that the

. NRC has done very little independant investigation into the Turkey Point repairs. This mode of operation abandons 40 CFR 8 1601.2 for preparing a DAIS. The NRC has merely accepted all of the Licensee's dubious estimates. The DAIS is hardly an objective document.

8. The NBC has failed to examine the tube degradation I

experiences in nuclear plants using Powdex demineralizers. In the DAIS, on page 4-17 are the statements: "It is anticipated that the removal of suspended solids and ionic species from the

'condensate water will reduce corrosion related phenomena.

The demineralizers will employ a mixed-bed ion exchange resin (Powdex) in a'series of vessels."

Qn January 26, 1981, during a meeting with the NRC staff, FP8cL) Dade County, and the Intervenor, Norman Coll, a spokesman f'r FP8L stated that the Powdex demineralizer design is like the Trojan and North Anna units.

The DEIS fails to state that both plants are suffering tube degradation from corrosion related phenomena. In NUREG- 1 0523 published in January, .1979, Table 1 states: "Trojan and D.C. Cook have had indications of limited degradation in recent inspections."

North Anna el has suffered catastrophic resin spills

from their Powdex demineralizer. On 5 separate occasions concentrated corrosive accountings, up to 300 lbs. of it were dumped back into the steam generators thereby initiating tube degradation. A letter to NRC Commissioner Bradford from June Allen of the North Anna 'vironmental Coalition states that the North Anna el demineralizer has,been placed in a bypass mode, shut off. Recent inspections of North Anna el show that 35% of the tubes inspected are experiencing degradation problems, also all tubes in the innermost row of all three steam generators have been plugged.

Mr. Gene Smith, on page 451 of'he transcript from the 248th ACRS meeting states: "Y/estinghouse believes that resin discharges from the Powdex condensate polisher into the feedwater are responsible for the observed accelerated corrosion."

Further information about Powdex demineralizers can be found in the Director's Decision by Harold Qenton, June 20, 1980.

It is likely that the Powdex.demineralizer to be installed at Turkey point will either be a model that has been proven defective, like the unit at North Anna el or it will be an experimental model with no operating experience data.

The NRC has disregarded, completely, the historical, negative aspects of demineralizer operation and has delivered instead, a theoretical unproven wish that the addition of a

\

demineralizer may be beneficial. This DEIS is a travesty perpetrated on the unsuspecting citizens of South Florida.

12

9. The DEIS fails to,examine all the degrading corrosion mechanisms that can occur within a newly designed steam generator.

N One mechanism that wasn't studied is galvani'c action.

Steam generators can be likened to a wet cell battery.

Dissimilar metals, on various levels of the galvanic scale, will send a flow of electrons from one metal to another, through an electrolyte such as water. The metals losing their electrons will erode,and lose their structural integrity. Recurrance of crippling steam generator tube corrosion through mechanisms such as galvanic action remains a strong likelihood and diminishes the potential benefit of the repair proposal. The DEIS fails to mention galvanic action as a problem and it has not offered any claims or proof that the problem can or will be solved. The DAIS seems to have omitted all information which is not favorable to the repair proposal.

Another mechanism, though poorly understood, is the strange behavior of metals in. contact with demineralized water. Dr.

Robert Anderson, I-'rofessor of Materials at San Jose State University has suggested that metals in contact with demineralized water actually give up their ions to replace ions which would be found in normal water but are missing from demineralized water.. This phenomenon must be studied and understood before such a vast- commitment of public and private resources takes place. Once again, the DAIS fails its intended I

function.

0 13

10. A negative aspect of the performance of the newly designed steam generators that has been overlooked by the DEIS is cracking of inconel 600 tubes at the apex of the curve. Poor performance of the new components would greatly lessen the anticipated benefits and would actually make what were lesser alternatives, superior in reality. The new ouatrefoil support plates appear to have dramatically more flex than the drilled I

hole design. No parameters for measuring flex have been stated.

There are no design features to limit or control the flex. The mechanisms, for distorting or'lexing the tube support plates are numerous: chemical corrosion, fretting, cyclical vibrations, uneven expansion due to uneven heating and cooling, corrosion of the carbon steel wrapper and shell, engineering defects, manufacturing defects, and human error. The DEIS has not guaranteed that the repaired steam system will operate adequately, without major repairs, until the year 2012. The DEIS has not conclusively stated what the benefits of the repair will be nor has it stated the length of time for which the repaired, steam generators will safely operate. These are 0

serious deficiencies in the DEIS.

~d'1 '*1

11. The DEIS fails to assess the postulated number of nonfatal cancers that will be contracted as a result of the repair effort. This failure violates 40 CFR 5 1502.1 since

14 nonfatal cancer is a direct impact on the human environment.

'I

~

The classifications of study sho'uld be the workforce and plant personnel from external dose, the workforce and plant personnel from internal dose, and the public living in the general area.

12. The DAIS has completely ignored the negative health impacts and potential fatalities that will be suffered by the workforce due to internal dose from ingested radioactivity. Eighteen months of repair activity will generate copious amounts of radioactive construction dust, fumes, smoke, aerosols, and particulates. Kissing from the DEIS is an'inventory of all the possible airborne isotopes, the number of potentially affected persons, the severity of. the contamination, the critical organs, and the size of'he area that may contain airborne activity.

13. There is no data in the DZIS that pertains to the costs of mating mismatched components. The economic costs would be increased field costs, delay of entire operation, and additional fuel replacement costs to consumers. Fnvironmental costs would be increased direct radiation, increased ingested radioactivity, increased airborne activity, and increased liquid and solid radioactive waste.

The old upper assemblies have been subject to nine years of an aggressive and strenuous environment. (:orrosion, sagging

high temperatures, high pressures, transients, vibration, unequal heating and cooling, scrams, and metal f'atigue could cause critical distortions f'rom'he design geometry.

The new lower assemblies have been subject to manuf'acturing rigors, transporter and barge travel, numerous lifts by cranes, and long term laydown at the Turkey point site. In addition, due to the changes in Revision 7, the new lower assemblies will have to be cut below the tubesheet to implement the channel cut method.

It is rumored that Surry ¹2 had terrible alignment problems during the installation of their new lower assembly.

14. The DL'IS states on page 4-10, that f'rom 1975 to 1977, each nuclear unit generated about 575 cubic meters (20,297 cu. f't.)

of'ow level radioactive waste (LLRN) annually. The sources f'r,a year of'epair starting Oct. 1, 1981 and ending of'LRW Sept. 30, 1982, must be examined. Unit ¹3 will be in operation and .will generate about 20,297 cu. f't. of'LRY/- The three I

old steam generators removed f'rom the containment building will add about 10,000 cu. f't. of'LRH. Three months of'peration after the repair of'nit ¹ 4 will add another 5074 cu. f't.

There are three estimates f'r the amount of'LR)Y to of'LRY(.

be produced by a unit's repair; FP8:L's at 38,830 cu. ft, Surry's at 56,480 cu. f't., and NRC generic at 81,190 cu. f't. Qonsider that the Surry LLRN estimate was made bef'ore the repair was completed.

I 16 The total LLHN estimates range from 74,201 cu. ft.

to 116,563, cu. ft. Unfortunately, there is no proposal for II post repair testing and inspections, so the LLRW estimates for this phase have not been determined.

Page A-10 in the DZIS gives the volume limitation for the burial of LLRN, from Turkey Point, at the licensed burial facility in Barnwell, .South Carolina. Starting October 1981 and each month thereafter, only 2,000 cu. ft. of LLRW will be accepted for burial. By totaling the site sources and the various estimates for the .repair LLRW and by subtracting the burial allotment, there will be estimated excesses of 50,201 cu. ft. to 92,561 cu. ft. of LLRN that will not be accepted by Barnwell. During the following year, starting Oct. 1, 1982, another repair will take place and the amount of LLRN not acceptable to Barnwell will double. The excess LLRN at Turkey Point will be 100,400 cu. ft. to 185,000 cu. ft.

and these estimates still- do not include the LLRW projections for the post repair testings and inspections.

Other than meekly saying that Barnwell may grant an additional allotment, the DEXS offers no studies or solutions for the storage of excess LLRW. This situation is exacerbated by the Licensee who has not requested an additional allotment from Barnwell, South Carolina. See Appendix V.

Will there be mountains of LLRN sitting on site 7 What happens to excess LLRW during hurricanes, floods, and tornadoes 7 What about leakage and leachates contamunating

17 Biscayne Bay and the Bisca yne'Aquifer '? How badly will the LLRW containers corrode from salt spray and weathering '?

Who will be liable for accidental contamination 7 Y/ill the excess LLRN be shipped'o some other storage or burial site 7 If so, what are the costs 7 Will there be a new LLRW site in Florida 7 What environmental and human costs are involved '?

How much leakage from LLRW is tolerable 7 The DEIS has not answered these questions.

Looking past the repairs, the prospects. for landfill disposal of excess LLRW from Turkey Point seem poor. The nuclear units may continue to generate 20,297 cu. ft. of LLRW a year. But since the backvrash effluent from the new demineralizers must be solidified and disposed, it is possible that the amount of LLRW will increase above historical levels.

A gradual reduction of accumulated LLRW over the years is unrealistic. lk years after the repairs have concluded, St. Lucie no. 2 is expected to come on line. If there is no provision for the LLRW from St. Lucie no. 2 up to Garnwell, any reduction of accumulated LLRW at Turkey Point may be permanently ha3% d.

The DEIS studies no volume reducing techniques. What percentage of the repair wastes will be compactable 7

. What volume reductions can be obtained from compacting wastes '? Y/hat are the additional costs '? What are the

18 additional man rem commitments '? Is incineration being considered '? )Vhat are the incineration costs, effluents, and dangers 7 The DElS is totally deficient in addressing the impacts

-of LLRYf management, such as postulated leakage, postulated accidents, contamination of food chains, immediate cancers, delayed cancers, nonfatal cancers, mutagenic and teratogenic effects. The DEIS clearly violates 40 CFR 5 1502.1.

15. Turkey Point sits atop the Biscayne Aquifer. It is a rock formation that is porous and permeable and is reputed to be the finest aquifer in the country. If the hydrologic gradient slopes towards the East, the water will flow east.

If the gradient slopes toward the",/est, the water will flow west. A potentially serious condition can occur when the hydrologic gradient reverses and radioactive water from Turkey Point's low level radioactive liquid dump gets transported toward the main part of the Biscayne Aquifer.

The hydrologic reversal is due to drainage of the wetlands west of Turkey Point usually for commercial enterprises. The high water table must be lowered to drain the land. Canalp are dug and water flows into the bay faster than normal and drains the land. The bay, whose level doesn't change, except for the semidiurnal tides becomes the higher hydrologic level and pushes the water from Turkey Point further and further inland.

I 19 Private wells used to irrigate food crops and public wells used to provide drinking water to Homestead, Florida and the Florida Keys Aqueduct Authority (FKAA) are being threatened by the westward movement of underground water from the Turkey Point plant. The Licensee has instituted an "Interceptor Ditch Pumping Program"- to mitigate the situation the plant has created, but the interceptor ditch is only and the aquifer is 97'eep at the plant site. The 20'eep pumping can scarcely be expected to affect the full depth of the aquifer when the hydrologic'gradient slopes west.

The hydrologic gradient normally slopes westward during the times of peak drought, but this situation will be considerably worsening as the wetlands continue to be drained. At last report, water contaminated with salt, in the vicinity of Turkey Point, was about five miles from the cones of depression caused by the Homestead and FKAA wellfields. The DEIS has completely f'ailed to study the short and long term effects on the groundwater as a result of radioactivity from the repairs being added to the radioactivity from plant operations. The DZIS must study cumulative effects.

7conomic Cost.s of Steam 'Generator ~Re air 16- The DEIS fails to study the effects that will occur due to the large amounts:of capital that will be gathered .and spent on steam generator repairs. The Licensee can generate

'"Ya>>; '+ I 7

20 capital by going into debt (selling bonds) or selling off ownership in the company (selling stocks). Presently, the Licensee is trying to sell l,750,000 shares of stock and the value of the stock in the market i's dropping. The Licensee and consequently the consumers will suffer from the extraordinary high costs of generating capital in today' market. This sale of stock and other problems will force the Licensee to seek rate hikes before the Florida PSC. This situation is presently occuring.

There is a double negative effect concerned with raising

'capital for steam generator repairs. The Licensee will be forced to pay premium rates for this capital and once commWed, there will be 'much less capital available to convert oil burning facilities to coal and to implement useful conservation strategies. Increasing costs will cause rates to go up.. There will be a ripple effect through the economy.

Conversion to coal and conservation will be delayed or forgotten and this will place additional burdens on the consumer.

The consumer sector will suffer the problems that the "Licensee faces and it will also be hit with the excessive fuel replacement costs no longer charged to the Licensee.

The massive withdrawal. of monies from the consumer sector will seriously impair the conservation strategies that would have been implemented by the individual consumers. The Licensee will suffer, the consumers will suffer, conservation

'6 will suffer, but Bechtel and Ylestinghouse will prosper. Money will be unavailable just when it's needed the most. The vast amounts of money reauired to repair Turkey point will not be available to save energy. The DEIS fails to consider the full impacts of making this irreversible decision.

17. The use of 3 535,000 a day, differential fuel replacement cost makes the DEIS grossly inadequate as a study document.

Much more sobering and realistic is NUREG-0685 published in August, 1980, and which can be used as a planning document for future reactor outages. NURZG-0685 states that the projected fuel replacement cost for unit no. 3 or unit no 4, as of January, 1981, is Q 20,000,000 a month. This number divided by the number of days in January gives a daily fuel replacement cost of' 645,000 a day. Although this document does not predict future oil prices, it states that the price of'il has doubled in the past two years. Since the Licensee exclusively uses OPZG oil, it is likely that this pricing scenario will continue in the future as it has in the past.

In July 1981, the daily replacement fuel cost may be + 806,250 (beginning of the third quarter). In January 1982, the cost may be 9 967,500; in July 1982, 9 1,128,750; and in January, 1983 (repairs still in progress), 0 1,290,000. If the price of oil doubles every two years, the fuel replacement costs for the repair project will be 3 587,917,500. This fuel replacement cost figure is dependant on the ability of the

22 Licensee to complete the repairs within the 270 day time frame. If the repairs go past June of 1983, the costs can 1

be expected to escalate.

Most recently, President Reagan has lifted pricing controls from domestic oil supplies. Although not directly tied to OPEC pricing, decontrol can be expected to put upward pressure on OPEC oil pricing.

The DZIS incredulously assumes that the price of oil will not rise between October 1980 and June 1983. Such skewed cost analysis violates the. entire spirit of NEPA and specifically violates 40 CFR 8 1502.22 and 8 1502.23.

See Appendix VI and VII.

18.'he DZIS presents a completely deficient argument in justifying the repairs on an economic basis. The mistakes published in the DEIS makes it unfit for public comment. The economic errors prevent any alternative economic model from being eaual or superior if the model utilizes DEIS information as being accurate information. The DEIS must be withdrawn, corrected, and resubmitted as a DEIS.

The total cost estimate fails to consider that outages of 270 days will occur twice not once, as the LEIS has calculated.

Other mistakes are more sly. Intervenor's comment 417, assumes the cost of oil will continue to rise (whereas the DEIS does not).

The total likely cost of replacement fuel will be 9 587,917,500.

Added to the fuel replacement costs are: capital repair costs,

I l

23 8 119,000,000; I

new demineralizer, > 9,000,000; condensor retubing, .8 8,000,000; startup of Cutler plant, 0 2,300,000; storage building, ~ 3,000,000; and offsite ship'ment of lower assemblies, 9 2,500,000. In a meeting on January 26, '1981, with the NRC, the Licensee, Dade County, and the Intervenor, a spokesman -for the Licensee stated that both options for

.lower assembly disposal are being pursued simultaneously.

The storage site has been elevated to 17.5'nd the barge for transport to Barnwell is being built. Consequently, the Licensee will accrue both costs. The total cost estimate for the repairs thus far are 5 731,717,500 but still all costs are not yet counted.

Not addressed by the DZIS are the additional costs of borrowing money, selling stock, NRC licensing fees, engineering studies, repair administration, environmental studies, lawyers fees, obsolete plans and studies, health physics efforts, public relations, lobbying, operations, maintenence, inflation, and the inevitable cost overruns. The DEIS must be withdrawn, corrected, and .resubmitted as a DEIS.

19. The DEIS ignores the economic impact of the repairs on the Fpg;L consumer. Never is it mentioned that the total repair cost will not result in any new generating capacity, other than what is on line right now. Simply stated, the costs of the repairs will result in pure inflation to the customers of, FP8:L.

Vast monies will be spent with no appreciable gain. The cost of the repair to the average customer will be 5 332 (8 731,717,500 divided by 2,200,000 customers) It is devastatingly significant to extract this much money from the Florida economy with no apparent gain. To make matters worse, the costs will come, entirely, from the consumers disposable income.

Some sectors of'he economy can pass on these additional costs and others cannot. Commercial enterprises pass costs on to the consumer, but the consumer must absorb his own plus all the commercially, passed on costs.

Within the consumer sector, cost impacts will vary. Rich and middle class consumers will survive, but the poor consumers living at the very edge of survival will suffer greatly.

Consider the poor, black, fatherless families living on welfare in riot tom Liberty City, the aged retirees living on meager ,fixed social security allowances, on South Beach, and the terribly poor migrant families of South Dade County devastated by the Wiidwest droughts and the lack of'ork from the 1981 vegetable freeze. They all will be required to pay premium electric rates because of the incompetant engineering at '(estinghouse and FPEcL. The DEIS has failed these people.

Sadly, even in a DEIS, corporate profits will overshadow human desperation.

A secondary impact will be the delayed investment of private

25 energy conservation strategies in Florida due to the loss of Q 731,000,000 in disposable income. As electric rates skyrocket and some conservation does take place, only the rich and some of'he middle class consumers will be able to invest and benefit from conservation strategies. Unfortunately, the poor, who need to be the most energy efficient of all the classes, will not be able to make the necessary investments.

The DEIS has failed-to examine any energy conservation strategy as an alternate to steam generator repairs. Effective conservation investments will benefit the -consumer, the business sector, and the Licensee, but above all, it will greatly benefit the poor people of Florida-On a national scale; the repairs will require a vast amount of OPEC oil. The impacts of the repair will worsen America's balance of payments to OPEC nations, increase the demand for oil which usually drives prices up, and increase the consumption of'il, an irreplaceable resource. The logical direction in which to turn is conservation, the saving of energy which otherwise-would be wasted. The DEIS fails again.

Assuming that the repairs are made, Turkey Point has historically worked at only a 65 5 DER capacity level. This level is not unusual, it is the average level of all reactors in the country. See Appendix VI. Little more capacity can b' expected from Turkey Point since it is an old reactor and it will continue to be plagued with component problems associated

0 26 with advancing age. The argument f'r conservation is made stronger. An added benefit will be the conservation,.of'lectricity usually provided by the burning of'PEC oil for the 35 5 of capacity that Turkey Point fails to produce.

Conservation can replace 100 5 of Turkey Points DER capacity.

By ignoring conservation, the NRC has violated '40 CFR 8 1502 '4 which is the very heart of the HIS process under NEPA.

20. The DEIS has not considered the negative economical impacts of tPe Licensee putting the capital costs of the repairs into the rate base of'he utility. The customers of FPEcL are all ready paying f'r the building of the Turkey Point plant. Now, due to some incompetent engineering decisions along with the h NRC's consent on those decisions, the'onsumers must now pay for the repairs which will be 3 times the cost of constructing the plant. The repair costs in the rate base will have a long lasting negative effect on the Florida economy and the DEIS has failed to address that effect.

Nonradiolo ical -nvironment Assessment

21. The DEIS fails to study the effects of'he reopening of'he Cutler plant in Dade County in response to the closing of units 3 and 4 for repairs. Cutler operations entail increased oil barge traffic, auto traffic, air pollution, noise =pollution,

27 thermal pollution to I;;iddle Biscayne Bay,, Chemical effluents to the bay, 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> disturbances to area residents, raw sewage to Biscayne Bay, and .the likely lack of a valid NPD 3 Permits The surrounding residential area has grown considerably in the years the Cutler plant has= been shut down. Increased auto traffic will add to.rush hour congestion, increased noise levels 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day,. increased traffic accidents, especially among the area resident's children.

The short stacks on the Cutler plant are known to the area residents as "loopers"- The turbulence created by wind passing around the plant, drives the effluent from the short stacks it h

down to ground level where concentrates and damages the surrounding area. Fumes containing a sulfer smell h'ave damaged paints on houses, cars, furnishings, and have caused corrosion of acid sensitive materials. Obviously the value of the housing in the nearby area will decline sharply as the negative impacts appear. Local vegetation and landscaping representing substantial investment, will ail and die due to the noxious fumes. There is a strong likelihood that 7P8:L will burn an oil with a higher sulfer content than has been burned at that plant previously.

The DAIS has failed to consider the 8 2,300,000 cost of starting up Cutler as a consequence of the Turkey 1"oint repairs.

Another cost, unknown as of now, will be the operating and maintenence expenses, which have not been included in the'uel

28 replacement cost estimates for the repairs. All Cutler costs will negatively affect the consumers.

The design of the Cutler plant is poor because there is no containing building. The mechanical sounds deluge the local residents and carry very far at night when ambient noise levels are low. Cutler will have to undergo substantial and expensive modifications before its operations can be made tolerable.

See Appendix VIII.

Cutler is notorious for its thermal impacts on I3iscayne Bay. Ig. immediate danger is thallasia (turtle grass) in the vicinity of the plant. Thallasia is vital for keeping Biscayne Bay alive. Its importance is. shown by the initiation of thallasia planting projects in the 'Say, taking place where thallasia has been destroyed. The opening of the cutler plant and the scorching of the, bay bottom are important negative impacts ignored by the DZIS.

22.'The,'3)PXS..'discounts the...effects='.of 'la'undry.waste water in the cooling canals. 22,000 gallons x 270 days x 2 units ecuals 11,880,000 gallons of wastes. The unit that is'not being repaired is still generating its usual amounts of waste and the cumulative effect of both units is ignored in the DAIS.

The DAIS patently states that nonphosphate detergents will be used, but it never states precisely what are the detergent compounds that will be used.

29 The estuarine environment in South Florida is delicate and fragile. Nowhere else in Florida are raw laundry wastes allowed to be discharged directly into canals. Is there a valid NPDi:S Permit f in place that allows the increased dumping oX'his sewage 7 None of'he pollutants have been identif'ied.

)That will the laundry waste pH be 7 If'he detergent is

,biodegradable, what is the biological oxygen demand 7 )'Ihat eff'ect will an increased BOD have on the environment 7 Sill the radionuclides bind. with organic compounds and contaminate f'ood chains ? What eff'ects will laundry wastes have on each of'he endangered species living in the area 7 All legitimate questions concerning direct ef'f'ects, indirect ei'f'ects, synegistic and cumulative ef'f'ects on endangered species and critical habitats have been discounted by the D~IS on a wholesale basis.

nvironmental ~Im acts of'ostulated Accidents

23. The DAIS has approved a radioactive waste storage building that is compliance with few, if'ny saf'ety codes. South Florida may soon have 1200 tons of'adioactive waste sitting in an experimental building atop a small manmade hill. any sizeable hurricane can wash out the fill, since its only 1300 ft. f'rom the shoreline, and send the splintered building and the radioactive wastes crashing into the floodwaters below.

30 The Licensee has stated that its storage building complies with the South Florida Building Code. ']fas this code devised to keep radioactive wastes isolated from the environment or was it dev'ised to protect people '? Xn South Florida, buildings and residences located near the edge of the water are traditionally evacuated at the approach of each hurricane.

i(ill the Licensee evacuate the radioactive steam generators at the approach of each hurricane '?

Zach hurricane contains all the mechanisms needed to release large amounts of radioactivity'rom the storage building.

large waves will erode the limestone fill and undercut the concrete foundation. Concrete walls and roof will come crashing down on the steam generators breaking open the protective caps.

The steam generators will go tumbling down the 18 ft.

embankment and the floodwaters will flow through the units, washing out all the radioactive crud that has broken loose by

.the tremendous mechanical shocks. At this point Biscayne Hay is contaminated with high levels of radioactivity, including transuranics, and decontamination is impossible.

The NRC apparently has no safety codes to assure that this accident won'0 happen. This building will be an experimental model and will be located in the worst place in the country, hydrologically and geologically to isolate radioactive wastes from the environment. Hurricane Camille came ashore in mississippi packing winds in excess of 200 mph, yet, the building

is only designed to withstand winds of'20 mph. The DEIS has failed to assess the extent of contamination that will occur if' 200 mph hurricane h'its the site.

24. One of 4he alternatives to steam generator repair discussed in the DEIS is continued operation in the present or derated mode. Continued operation may be a part of an alternative strategy if other generating capability or effective conservation strategies would:be implemented. The DFIS fails to st'udy the lack of'ccurate inormation in determining the extent by corrosion to the degraded steam generators.

of'amage NURilG/CR-0718 written by Battelle PNL studies the accuracy of single frequency- eddp current testing, used to measure degradation in corroded tubes. Unlike field condition measurements taken in a hostile radioactive environment, Qattelle performed the experiments in near perfect laboratory conditions using new tubes with intentionally machined defects.

The results of this study discredit this commonly used measurement device. On page 119 of NUR"G/CH-0718, is a summary of the attempts to measure groove defects by single frequency eddy current testing. Orily 14 5 of the measurements were accurate to within 5 5 of the actual defect. 17 % of the measurements overestimated the damage, 41 $ underestimated the damage, and 31 5 of'he measurements failed to detect any damage when the damage was present.

Qn page 129, an experiment showed that 34 5 of the results of'ddy current testing on tubes with denting and elliptical wastage, were uninterpretable., These grossly innaccurate

~

measurement systems demonstrate that the NHC has not been able

/

to determine the actual amount of danger to the public when dealing with reactors that have degraded steam generators.

The DFIS was to have addressed dangers to the human environment, but has failed in its purpose and has violated 40 CFR I 1502.1.

~Im acts of Alternatives

25. The DZIS considers continued operation of units 3 and 4 possibly in a derated mode, as an alternative to repairs.

Derating does not require the vast resources (g 730,000,000) i or the generating of large volumes of waste. If a committment of'll the resources required for the repair was made towards implementing conservation strategies, derating would become a beneficial interim strategy, unless the derated operation of Turkey Point is an unsafe alternative.

The DZIS fails to examine the dangers of operating Turkey Point in a derated condition. Unexplained references, such as

" not enough heat transfer surface" leave the D:"IS reader uncomfortable and uninformed- In NUR~G-0523, appendix 9, safety questions are asked but not answered. The DAIS has failed to examine the safety issues raised by NUB'G-0523 as it

33 pertains to the present and possibly future operation of Turkey Point.

What are the failure probabilities of degraded tubes 7

.What is the justification for continued safe operation with degraded steam generators '? What are the real consequences of LQCAs and 1'JlSLBs for reactors with degraded tubes '? What are acceptable primary to secondary leakage rates in relation to FCCS ability '? What effect will degraded tubes have on the radiological dose during postulated accidents '? Do degraded tubes increase the probability of a design basis accident 7 13y how much '? Will accidents be caused or exacerbated by degraded tubes 7 How many tube failures can be tolerated is an accident scenario '? Yfhat are the effects of plugged tubes during accidents 7 Clearly, the DZXS is a total failure in this area and clearly, a design basis accident is a catastrophic threat to the human environment.

Conclusions

26. The DPIS fails to address the other serious impairments that the Turkey Point plant will face in its remaining operating life. These impairments must be calculated as negative costs in the cost/benefit analysis. Problems such as cracked containment walls, cracked feedwater piping, cracked

34 borated water piping, cracked primary coolant piping, cracked supports, pump failures, cracked reactor head and vessel, or the buildup of excessive radioactive crud (such as at Dresden) can totally negate any benefit that repaired steam generators may offer. The D "IS is deficient for not considering all the I

likely, disabling impairments that can shorten the life of'he Turkey Point reactors.,

27. The D'IS is noncommittal about the 100,000 gallons decontaminated primary. coolant that may or may not of'artially be discharged into the cooling canals.-'The D "IS is deficient f'r not considering the dumping as as environmental impact.

See Appendix IX.

28. The DEIS fails to conclude precisely who is the beneficiary of'he steam generator repairs. If it were to identify the beneficiary, it would be the Licensee, the Florida Power and Light Company. The citizens of Florida will pay the costs and be hurt by the repairs. FP8:L has made this decision as it has made many other decisions. It was based on the maximization of'rofits so it can continue to attract investment capital. Certain obligations for maintaing the franchised monopoly will be made, such as the availability of'lectricity, but, the greatest benefits will go to the corporation and the stockholders.

The Dl:IS has forgotten the public. The "business as usual" approach by the NHC in their daily routine matters may be acceptable government practice, but this lack of objectivity and disregard of the public must not be allowed to permeate a , NEPA mandated Znvironmental Impact Statement. Nuclear profits must not be promoted at the expense of the public good. The concept that "electricity is good", is not enough reason to dismiss public costs, public health risks, and the public's desire for a clean and healthful environment.

The public is definitely being served by increased rates, skyrocketing fuel adjustment charges, contamination of ground water and coastal waters, new local radioactive waste sites, increased cancers among'orkers, poor component designs, and the strong possibility that disabling tube degradation problems will recurr. In light of the advantages of a strong effective conservation program, the most beneficial plan will be to phase out the operations at Turkey Point with all of its technical problems and commit the resources to an ever expanding conservation of electricity program.

Unfortunately, the NRC is still promoting nuclear power.

Conservation programs, which are the most viable and desirable energy plans, both locally and nationally, were totally ignored by the DPIS.

29. The DAIS has failed to consider the-most appropriate

0 Jg

36 alternati've to the steam generator repairs. The alternative is conservation of electricity. The advantages of conservation are many:

Less economic burden Fewer health and environmental hazards Iio new local nuclear waste dumps Reduction in the usage of imported oil, and The recurrance of tube degradation becomes unimportant.

Two recent documents submitted to the Florida PSC by FPRL prove the clear cut economic advantage of conservation over the repair option. They are "Energy Management Plan for the 80's", Nov. 1, 1980 and the "Petition For Approval Of Revised Energy Management Plan", Dec. 30, 1980. Zxhibit ¹8 of the "Petition For Approval..." contains a detailed cost benefit analysis f'r electricity conservation strategies. The conservation strategies in Target Areas 1, XI, and IXX will P

reduce present demand by 1,871 Itic capacity. The cost the conservation strategies will be Q 712,116,000of'mplementing (1980 dollars) for a calculated cost of 3 380/kw.

Turkey Point units Q and 4 are rated at 666 Md each.

FPkL hopes to be able to get up to 85 9> capacity for awhile, so the actual generating capacity is 666 I".'~7 x 2 x 85 5 equaling 1,132,200 kw. The .actual costs attributable to the repair and fuel replacement cost will depend 1arge1y on the

37 rates by which oil prices increase, but based on the historical data presented in NUREG-0685, the costs for the repairs will be 3 731,717,500 for a calculated cost of'46/kw.

Conservation will provide .a cost advantage of' 266/kw.

The dollar advanta e for not re airin Turne Point is 0 301 165 200. . Another advantage is that the conservation strategies will provide an'ddit'ional 738.8 MW capacity while still below the repair costs. These conservation strateg'ies can easily be expanded to reap greater economic benefits while suffering fewer health and environmental costs.

The complete cost benefit analysis for this conservation program is in Appendix X.

The DZXS is tragically faulted and is mistaken in its conclusion that the repairs is the most desirable of all options. Documents produced by Florida Power and Light have

.conclusively proven that the most desirable option is conservation. The DZIS must be amended to recommend that the re airs not be made.

5 05 I'he Miami News Wednesday, July 30. 1980 Turkey point repairs everybody's business Both the people and the government of Dade County are t ne ongoing problems with the nuclear units, the fact affected in almost every way imaginable by what happens at that all 20 of the Westinghouse-designed steam generators in Turkey Point's nuclear generators. Yet Florida Power & the country are leaking and corroded, the cost of temporary Light Co. has the authority to make most of the decisions repair and the time-consuming and very probably dangerous pertaining to the nuclear units, decisions which can have a nature of the replacement process all raise the inevitable radical impact on Biscayne Bay, on the area's water supply, question about the safety and the financial efficacy of on air quality, on the employes at Turkey Point, and on all nuclear power.

the people who live here and who pay commercial and It is true that Miami schoolteacher Mark Oncavage, residential power bills. acting as a private citizen, has petititioned the NRC for the So the Metro Commission was wise in agreeing to right to question FP&L about the impact of the repairs. But intervene in two legal proceedings involving Turkey Point: everyone who lives or works in Dade has a stake in the the hearing before the Nuclear Regulatory Commission on repair process. and therefore has the right to be represented the environmental impact of FP&L's proposed replacement in some manner at the NRC hearing on the environmental of the nuclear unit steam generators, and the lawsuit in impact of the removal and disposition of the damaged which FP&L seeks damages from Westinghouse, alleging nuclear generators.

that it was negligent in the design and manufacture of the It is only proper that Metro make its technical expertise generators. available during the process of reviewing that potential Quite apart from the halo of health and safety problems impact, proper because Metro would be involved should the surrounding the proposed removal and storage of the repair process result in polluting the air with radioactivity, damaged generators, Metro government and Dade residents or have an adverse effect on the bay, the water supply, even have a significant financial stake in the outcome of the two the FP&L employes doing the work.

actions. Commissioners deserve credit for becoming involved in Every time the nuclear units are shut down so FP&L what may be the most significant issue Dade County has can plug the corrosion-caused leaks which have appeared ever confronted. Their decision to intervene in a regularly since the generators were installed, the county and non-adversary position makes it evident that the the business and residential users pay an added surcharge. commissioners are concerned with questions more complex Metro Commissioner Harvey Ruvin, who introduced the and long-term than next year's budget or the next motion to intervene. estimates that the county government referendum. And although FP& I.'s intense lobbying has paid $ 9 million in fuel surcharges since l976. some $ 2 predictably has resulted in the call for a possible million of which was necessitated by repairs to the leaking reconsideration of tlie vote when the commission meets generators. If damages are recovered from Westinghouse, again in September. the commissioners should not consider the county, by participating in the lawsuit, might be in a backing away from one of the most responsible and position to get some of that money back. progressive stands the commission has ever taken.

" A' dl ll

Appendix Ig Ejjc ~immi KetaQ JOHN S. KNIGHT, Ehtor Emeritus JAMES L KNIGHT. Chairman LEE HILLS, Editorial Chrm.'LVAH H. CHAPMAN Jr. Pres. JOHN McMULLAN,Exec. Editor BEVERLY CARTER. Gen. My'.

~

JIM HAMPTON, Editor ROBERT O. INGLE, Managing Editor OON SHOEMAKER. Senior Editcr 6-A r oooo Tuesday, September 2, 1980 EDITORIALS Metro: Intervene in FPL Cases ETRO commissioners were correct money, back from either company.

in July when. they decided that the FPL Officials insist that they are both county attorne'y should participate able and eager to defend their custom-in two "complex legal proceedings in- ers, Metro included. But higher charges volving the Turkey Point nuclear-power, to Metro government'alone as a result of plant. When they reconsider the ques- the problems at Turkey Point is estimat-tion today, the commissioners should ed by the coUnty to be more than $ 1. mil-stick with their'original'course. . lion; The'commissioners should look out ~

That's not to say that. there necessari- for their own interests rather than pas-ly is anything wrong with the handling sively depending on FPL to do so.

of the Florida Power 8c Light (FPL) Tur-'ey In addition to the civil suit between Point plant. But very large sums of Westinghouse and FPL, the county also money are involved an estimated should join in the FPL application to the

$ 120 million to repair the plant's steam 'Nuclear Regulatory Commission (iNRC) generators, plus another $ 300 million for 'for permission to repair the steam gener-fuel oil that wouldn't have been needed ators. This repair work is no backyard if the nuclear plant were operating prop- welding job. It is massive, and it in-erly. Further, there's obvious potential volves potentially hazardous work con-for environmental and health dangers ditions and possibilities for the escape of from the repair process and from the radiation into the air and into Biscayne proposed storage at the site of radioac- Bay.

tive materials. The repairs should be done. But Metro Certainly Metro Dade has every right, should participate in all environmental-both as a major customer itself and as impact reports, health-and-safety plan-the representative of all Dade residents, ning, and other aspects'of the NRC ap-to participate in the two cases. In plication process. The county can partic-is suing Westinghouse'Corp., one'ase,.FPL ipate actively as a concerned but disin-which produced Turkey Point's steam terested party. It need not, and should generators. That equipment has deterio- not, oppose the company's application.

rated and now requires extensive repairs and replacement after eight years of use. Lay citizens can hardly reach sound If Westinghouse sold defective equip- conclusions about the cost-effectiveness the utility and its custom- or safety of a particular power plant.

ment to FPL, are entitled to refunds. If, on the Nor can rivate volunteer groups such ers other hand, the courts determine that as Floridians United for Safe h,nerg oe the fault is in FPL's maintenance, the ex ected indefinite y to carry the heavy consumers should look to the electric burden ot re resenting t e pu ics in-terest. That's what government is for.

company for their refunds. There should be no opportunity for a private settle- Metro is the government involved.

ment that might make it difficult, if not The commission ought to proceed with impossible, .for consumers to get their its planned intervention in both

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cases.'et's Keep Florida Safe!

CONTRIBUTE TO FUSE 7210 Red Rd.

rm 208 Miami, 33 143 please make tax deductible donations payable to: Community Action@ Research, lnc. N.S.p. iNuclear Safety Proiect).

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Appendix III UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FLORIDA POWER & LIGHT COMPANY, 8-1896 ) g a Florida corporation, Plaintiff, vs ~

) COMPLAINT FOR DAMAGES WESTINGHOUSE ELECTRIC CORPORA-TION~ a Pennsylvania corpora-tion qualified to do business in Florida,

'78 l.o Defendant. HhY FLORIDA POWER & LIGHT COMPANY ("FPL" or "Plaintiff")

sues WESTINGHOUSE ELECTRIC CORPORATION (" Westinghouse" or "Defendant" )

and says:

1. This is an action for damages in an amount which exceeds the sum of ten thousand dollars ($ 10,000.00), exclusive of interest and costs.

2. FPL is a corporation, incorporated un'der the laws of the State of Florida, having 'its principal place of business in the State of Florida. At all material times, it is and has been a public utility engaged in generating, transmitting, and distributing electricity to the public in the State of Florida.

3. Westinghouse is a corporation, incorporated under the laws of the State of Pennsylvania, having its principal place of business in a State other than Florida. At all material times, it has been qualified to do business in Florida and doing business in Florida, having agents or other representatives in Dade County, Florida.

4. FPL and Westinghouse entered into a Plant Equipment Contract effective November 15, 1965 (Contract).

4 h

5. Under the contract, Westinghouse was obligated to design, manufacture and furnish to FPL the nuclear steam supply systems, (Plant Equipment) including six steam generators, for FPL's Turkey Point Unit. No. 3 and Unit No. 4 nuclear generating plants in Dade County, Florida.

6. At the time, Westinghouse entered into the Contract, it knew or should have known that:

(a) The operation of Turkey Point Units 3 and 4 by FPL would be dependent upon the satisfactory operation of the Plant Equipment to be supplied by Westinghouse; (b) Any inadequate Plant Equipment supplied by Westinghouse pursuant to the Contract would have to be repaired, replaced or revised; (c) Inadequate operating instructions supplied to FPL by Westinghouse would lead to damage and injury to Turkey Point Units 3 and 4; (d) Upon completion, Turkey Point Units 3 and 4 would supply a significant part of the power required by FPL to ful-fill its comm'tments to its customers; (e) If Turkey Point Units 3 and 4 were to be in-operative for any period, FPL would be required, during that period, to produce substitute power at its other facilities and to purchase substitute power from other sources at much greater cost than it could produce power from Turkey Point Units 3 and 4.

7. In August 1974, Plaintiff first discovered substantial leaks in certain tubes comprising an an integral part oz the steam generators designed, manufactured, and supplied by Westinghouse pursuant to the Contract for Turkey Point Unit 4.

8. In September 1974, Plaintiff first discovered substan-tial leaks in certain tubes comprising an integral part of the steam generators designed, manufactured, and supplied by West'nghouse pursuant to the Contract for Turkey Point Unit 3.

STEEL HECTOR

• DAVIS, MIAMI, FLORIDA

I Ail P'I

9. In April 1975, FPL first discovered that a large number of tubes comprising an integral part of the steam generators'esigned, manufactured, and supplied by Westinghouse pursuant to the Contract for Turkey Point Unit 4 were performing little or none of their intended function because corrosion within the tube assem-blies had dented, partially closed and cracked the tubes and tube support plates.

10. In October 1975, FPL first discovered that a large number of tubes comprising an integral part of the steam generators designed, manufactured, and supplied by Westinghouse pursuant to the Contract for Turkey Point Unit 3 were performing little or none of their intended function because corrosion within the tube assem-blies had dented, partially closed and cracked the tubes and tube support plates.

ll. The aforesaid defects have rendered the steam genera-tors totally unfit for their intended purposes, and reasonable efforts to render them fit or suitable have been unsuccessful.

12. Despite FPL's requests and demands that Westinghouse correct these defects, Westinghouse has failed and refused to do so.

13. FPL has fully performed all of its obligations under the Contract, including payment of the Contract price, and all conditions precedent have been performed or have occurred.

COUNT I

14. Plaintiff incorporates by reference and iealleges Paragraphs 1 through 13 above.

15. Westinghouse expressly warranted and guaranteed that the equipment it furnished under the Contract would produce stated guaranteed outputs.

16. Westinghouse breached such express warranty and guarantee by supplying Plant Equipment, which, because of the defects described above, has failed to produce the stated guaranteed outputs.

17. FPL furnished Westinghouse reasonable, timely and adequate notice of the above-described breaches of Westinghouse's express warranty and guarantee.

SVeCI. AIF.~. ~ DAVIS, MIAMI, F I.OR IDA

18. As a direct result of Westinghouse's breaches of such express warranties and guarantees ot'he Contract, FPL has been and continues to be required to make major repairs, revisions and inspections of the Plant Equipment furnished by Westinghouse, to take Turkey Point Units 3 and 4 out of operation for extended periods of time for repair, revision and inspection, to produce substitute power at its other facilities and to purchase substitute power from other sources at much greater cost than it could produce power from Turkey Point Units 3 and 4. As a direct result of the foregoing, Plaintiff has sufferend and will continue to suffer damages, the exact amount of which is still undetermined.

COUNT II

19. Plaintiff incorporates by reference and realleges Paragraphs 1 through 13 above.

20. Under the Contract, Westinghouse expressly warranted that the work, and 'all parts thereof, furnished by it would be free from defects in workmanship and material and be suitable for the use intended, and further agreed that it would, without cost to FPL, promptly correct any defects.

21. Westinghouse breached such express warranties and provisions of the Contract:

(a) By supplying Plaintiff with steam generators for Turkey Point Units 3 and 4 which were:

l. not free from defects in workmanship and material; and

2. not suitable or fit for the use intended (b) By failing to promptly or successfully correct the defects in the steam generators for Turkey Point Units 3 and 4 without cost to FPL.

22. FPL furnished Westinghouse reasonable, timely and adequate notice of the above-described breaches of the express warran-ties and other provisions of the Contract.

23. As a direct result of Westinghouse's breaches of such express warranties, Plaintiff has been and continues to be required to make major repairs, revisions and inspections of the Plant Equip-STCCL I R 6 DAVIS, MIAMI. FLORIDA

lt l ment furnished by Westinghouse, to take Turkey Point Units 3 and, 4 out of operation for extended periods of time for repair, revision I

and inspection, to produce substitute power at its other facilities and to purchase substitute power from other sources at much greater costs than it could produce power from Turkey Point Units 3 and 4.

As a direct result of the foregoing, Plaintiff has suffered and will continue to suffer substantial damages, the exact amount of which is still undetermined.

COUNT III

24. Plaintiff incorporates by reference and realleges Paragraphs 1 through 13 above.

25. Westinghouse is and was at the time of the Contract in the business of designing, manufacturing, selling, installing and furnishing nuclear steam supply systems, auxiliary equipment and auxiliary systems, including steam generators.

26. Westinghouse impliedly warranted that the steam generators designed, manufactured, furnished and sold by it to FPL pursuant to the Contract were of merchantable quality and that they were free from defects.

27. Westinghouse breached the above-described implied warranties by supplying Plaintiff steam generators pursuant to the Contract which were not of merchantable quality, and were not fit for the production of steam and which contained defects in the design, materials and workmanship.

28. FPL furnished Westinghouse reasonable, timely and adequate notice of the above-described breaches of Westinghouse's implied warranty of merchantability.

29. As a direct result of Westinghouse's breaches of such implied warranties, FPL has been and continues to be required to make major repairs, revisions and inspections of the Plant Equipment furnished by Westinghouse, to take Turkey Point Units 3 and 4 out of operation for extended periods of time for repair, revision and inspection, to produce substitute power at its other facilities and to purchase substitute power from other sources at much greater cost than it could produce power from Turkey Point srr.ea. ~ec~ DAVkS, MIAN QRIOA

k Ik

Units 3 and 4. As a direct result of the foregoing, PPL has suffered and will continue to suffer substantial damages, the exact amount of which is still undetermined.

COUNT XV

30. Plaintiff incorporates by reference and realleges Paragraphs 1 through 13 above.

31. At the time Westinghouse entered into the Contract with FPL, it knew that the Plant Equipment it was contracting to supply to Plaintiff was intended to be included in Turkey Point Units 3 and 4, and that Plaintiff was relying on Defendant's skill and judgment to supply Plant Equipment fit for the aforementioned purposes. Westinghouse impliedly warranted that the Plant Equip-ment it was to supply pursuant to the Contract would be fit for the aforementioned purposes.

I

32. Westinghouse breached such implied warranty by fit J

supplying Plant Equipment which was not for its intended pur-poses, was not fit for the production of steam and which contained defects in design, materials and workmanship.

33. As a direct result of Westinghouse's breach of such

,implied warranties, Plaintiff has been and continues to be required to make major repairs, revisions and inspections of the Plant Equipment furnished by Westinghouse, to take Turkey Point Units 3 and 4 out of operation for extended periods of time for repair, revision and inspection, to produce substitute power at its other facilities and to purchase substitute power from other sources at much greater cost than it could produce power from Turkey Point Units 3 and 4. As a direct result of the foregoing, FPL has suffered and will continue to suffer substantial damages, the exact amount of which is still undetermined.

,COUNT V

34. Plaintiff incorporates by reference and realleges Paragraphs 1 through 13 above.

'I l'

~

35. Defendant owed Plaintiff a duty to exercise reason-able care in the d esign, manufacture, and furnishing of the steam generators for Turkey Point Units 3 and 4 and in furnishing Plain-tiff with operating instructions and assistance.

36. Defendant breached its duty to exercise reasonable care in the following particulars:

(a) The steam generators for Turkey Point Units 3 and 4 were negligently designed and manufactured such that certain tubes comprising an integral part leaked substantially, impairing their effectiveness; (b) The steam generators for Turkey Point Units 3 and 4 were negligently designed and manufactured with improper materials which were not corrosion resistant, causing the tubes and tube support plates to dent, partially close and crack.

(c) The steam generators for Turkey Point Units 3 and 4 were negligently designed and manufactured so as to facilitate corrosion which caused the tubes and tube support plates to dent, partially close and crack.

(d) The operating instructions provided by Defen-dant negligently specified the introduction of chemicals or substan-ces into the liquid transported around the tubes which facilitated the corrosion of the tubes and tube support plates; (e) Although Defendant was aware of similar prob-lems with steam generators of the same type sold to other utility customers, Defendant failed to warn Plaintiff of the possibility or likelihood of such problems occurring in the steam generators for Turkey Point Units 3 and 4.

37. As a direct and proximate result of the Defendant's negligence, Plaintiff has been and continues to be required to make major repairs, revisions and inspections of the Plant Equipmentf furnished by Westinghouse, to take Turkey Point Units 3 and 4 out of operation for extended periods of time for repair, revision and inspection, to produce substitute power at its other facilities and to purchase substitute power from other sources at much greater cost than it could produce power from the Turkey Point Units 3 and TCCL HCCTOst 6 DAVIS, MIAMI, FLORIDA

I

~ ~ f

4. The foregoing has caused Plaintif f to suf fer substantial and continuing damages, the exact amount of which is still undetermined.

WHEREFORE by reason of Counts I through V above, and each of them, Plaintiff demands judgment for damages in excess of ten thousand dollars ($ 10,000.00), together with interest, costs, and further demands trial by jury.

STEEL HECTOR 6 DAVIS Attorneys for Plaintiff.

1400 Southeast First National Bank Building Miami, Florida 33131 Phone: (305) 77-28 BY:

THOMAS E. CAPPS STCC l. DAVIS, MIAMI, FLOE;i

C

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Appendix ZV

'QIRTH AMMAEHVIIRGMMIEMTAIL Charlottesville, Virginia Mailing JLddreosg 4M CGAILIITIIGH

~no Drive February 18, 1980 Eantovillea Mab~ SM0l

{205) 5~678 Commissioner Peter Bradford'.

S. Nuclear Regulatory Comnission Washington, D. C. 20555 Re: Defective demineralizer design Related corrosion and cracking in Steam Generators & turbine discs In the Hatter of Virginia ELectric and Power'ompany North Anna Power Station, Units 1 and 2 Docket Nos..50-338 and 50-339 OL Surry Nuclear Power Station, Units 1 and 2 Dock t No 50-280 50-281

Dear Commissioner Bradford:

NAEC commends the decision of the Commission to require an Environmental Impact Statement (EIS) on the experimental replacement of steam generators at the Surry Power Station.

After so many months had passed since Mr. Denton's 2-1-79 denial to NAEC of both a public hearing and an EIS, we had virtuaUy abandoned hope. We would like to think that our letters of 3-4-79, 5-5-79, and 8-14-79 were of some use to you in your deliberations, and are grateful for your decision to review.

Our letter 'today would again ask your prudent action in the light of recent disturbing developments.'

Westinghouse (W) admission oi gurbine ~di c ~cr ~kin Discovered at both Surry reactors Potential at both North Anna reactors, already under Appeal Board review for turbine missi1c ~roblemy Defective Powdex demineralizer design, leading to Five (5) ~r~in ~Q;l~ at North Anna g., the largest of 200-300 pounds occurring on February 27, 1979 (the same date "liquid discharge from Unit 42 VCT entered an unrestricted area in //2...Iodine 131 was 310 times value specified in 10 CFR Part 20...");

others occurring 7-19-79, 9-10-79, 9-12-79, and 9-15-79

~Simon l~ g~hmi ~ ~oboe~ from the foregoing spills leading to gor~oion and ~cr ckin in steam generator support plates and tubes as weU. as in turbine disc kcyways leading to poss'ible disc bursts

NAEC would call the attention of the Commission to

,the striking inter-rel e s and the irony of the fore-going problems.

Surry VEPCO's severe problems with Westinghouse steam gen-Conditions erators at Surry vere to be avoided at North Anna by the at presence of fresh water, by the absence of chloride, and North Anna by the use of the Powdex deminoralirer or polisher. Yet

~ *'e ins in o the t ener tor t North Ann actu cr e Su -like orrosion onditions d he be innin of s r corrosion an cr kin in 35 of the ube .

Chemotherapy One NRC engineer likens the corrosion to a "malignant tumor," all of whose cells must bo removed.if No th Ann ~s ene to e o re in he h. Nevertheless, the NRC has permitted the installation of a ene o 1W1, second re-fueling at North Anna g..

Defective According to NRC Atlanta, the damaging resin spills t Demineralixer Design function with Povdex v ve insufficiencies re uirin r de~i . Thus North Anna jjl is currently operating without demineralisation.

Redesign IronicaUy, such a Powdex demineralixer has just been at installed in Surry g2, dovn for over a year for steam generator Surry A replacement (a difficulty some NRC engineers thought demineral-ixers might have prevented). 0 0 h m e es i re d S vent t rt

'on ub en re in U. v h ould be in Sur gs 3 mi team ner tor re ir roubl new.

Secondary As noted earlier, in s ill ffects u n the s Chemistry Affects in the steam generators, but also in the ~turbine.. Since Turbines the turbine bvildin at North Ann i ettlin -abno the risk to turbine integrity is enhanced;-"periodic shim-ming has already been necessary.

oth S x un' the u ines r known to be Surry'urbine

~r ~ke , vith NRC staff listing Surry Unit g. in Category AA Hissile' and Surry Unit g2 in Category A. Although unlike North Anna, Risks the Surry units are not now under revicv by an Appeal Board concerned vith turbin mi ile ri k, that risk vould seem to be even greater under current Surry conditions and thus de-serves the direct attention of the Commission'.

En the light of the complexity and n'innber of unsolved problems at North Anna and Surry'including condenser neglect described in detail 5-5-79, a leak problem. at North Anna now),

i ion h r b k h Commis ion r fo o-

~

he Co o in ction in the fir in since NRC staff approval of

~

VEPCO~s continued operation with malfunctioning steam generators is a matter of record:

F! "  !!I!!

mlgLQMI ~

restart pending adequate spiU.-proof test results.

2. Continue licensing moratorium on North Anna @,

requiring the same inspection and repairs as those for North Anna, g..

(NAEC would also, request that the licensing moratorium be continued for Scquoyah since this reactor alsolas a Vestinghouse turbine.)

3. Keep Surry g. closed, pending its steam generator replacement, as unsafe to operate vith its*multiple related problems: plugged steam generator tubes in excess of 25$ , cracked turbine, and questionable seismic resistance.

4. Maintain Surry g2 shutdovn pending repair of cracked turbines, redesign and repair of Povdex demineralirer, installation of seismic reinforcements, and stringent testiag of nev steam generator and condenser tubing.

the follovtng related matters:

a. Vhy did VEPCO make no 2/79 report. of the significant and damaging 200-300 pouad resin spill ia the North Anna steam generator of 2-27-79?

b. Why did the NRC require no report?

c. Why did the North Anna plant coatinue in operation-after the spill as opposed to closing for clean-up of the resins from the steam generators?

d. Why did the NRC on-site inspector not know of the spill until months after it had taken place?

e. Was the NRC informed before the four (4) succeeding spills? If so, what action was taken?

f., Was the major resin spil1 of 2-27-79 related to the volume control tank dischaqp and Iodine-131 at 310 times specified value reported on 2-27-79 or to the "uncontrolled release to the storm drain" of 2-28-79?

(See April and May OUSR's of 1979)

g. What are the implications of the three September 1979 spills on the 10th, 12th, and 15th, followed by the radiation release accident of September 25?

h. Have resin-spiU, effect warnings been sent to other licensees with Powdex demineralirers and Westinghouse steam generators?

i. Was NRC~s first notice of V turbine disc cracking and missile problems the anonymous letter of November 5, 1979 suggesting a "flagrant, Westinghouse violation"?

The Coalition believes thLt Commission investigation of the foregoing has safety significance beyond Virginia reactors. Thank you for your professional consideration.

Sincerely, June AU.en President, NAEC P, S. In terms of reportability, NAEC is pu2;sled as to why the 3-28-79 reactor scram at Browns Ferry g. was not a reportable event since it was "due to false high pressure and low water level signals generated when concrete that was dislodged during a floor drilling operation struck a local panel."

Today we are concerned with the implications of disgruntl'ed employees at Browns Ferry cutting the cords and removing the mouthpieces of "between 65 and 70 inplant telephones" this past weokend. What does this event say of worker responsibility or worker comprehension of the safety necessity of inplant communication? Will there be an NRC investigation?

0

~

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~

going through all the other permitting limit placed on low level radioactive TIIE STATE Columbia, 4>>

~

Q-.H o S.C., Saturday, Feb. 7, 1981 they would need frown the Nuclear waste disposal.

Regulatory Commission. the Coast The limit, under a program in-Anti-Nuclear Group Claims Guard, the Corps of Engineers and the Highway Department," he said.

"We have received no formal re-itiated by the governor, would allow no more than l'.2 million cubic feet. per year by October of this year. The two.

quest. and we don't know when, or if, year plan is aligned at gradually reduc-

%'aside-Dumping Deal we will get an application from FP& L.

If we do get one, we will judge it as we do others on an individual ing the amount of waste received from a high of 2.4 million cubic feet.

Lowe said the disposal of the units basis." is "approximately equal to the annual average waste volume and three times kn" Works Wilson said that the situation has changed since the volume limit went the annual curie content of waste shipped for disposal from the Turkey

!nto effect. Now the states have au- Point station.

thority to enter into regional compacts "Unless a specific exemption is for the disposal of low level atomic obtained from thc state of South Caro-wastes. If a SoutheasL compact were lina. the licensee would use up his By P]IKE. I.IVINGSTON formed. and approved by Congress. allocation.- he said.

Go>ernmes<sl hnalrs $ <au presumably the volume limit would be But ltick Wilson. an attorney for

~ ~ An anti-nuclear group charged Fri-lifted. the DepartmenL of Heatlh and En-day that private negotiations are going on to allow nuclear waste from Flori- "Presumably, under a regional vironmental Control. said (.'hem-Nu-da to be buried in South Carolina in compact, we would envision Florida "clear officials have only been making

.violation of volume limits, but the being in our region. They are in a DHEC aware of FP&L's problem. and state's health agency said the. different spot because of their geogra- that there have been no "private" phy they don't have a site suitable negotiations.

talks'ere open information sessions and no deal has been made. for a low level waste burial ground," "What is all this 'secret'alk Michael I.owe, a member of the said Wilson. "They musL rely on some- abouL? We have just talked to Chem-I'almetto Alliance, said Florida one else for their disposal." Nuclear about the problem..All the I'ower and Light Co. wants to replace The 1,200 tons of steam generators stuff tliey (Palmetto Alliance) have six 200-ton steam generators from the been putting out is stuff we gave would have to be moved up the Savan-Turkey Point nuclear units 3 and 4 them." said Wilson.

nah Itiver by barge and then taken by "The problem is that if FP&l. were near Miami and bury the old ones at trurk to the Barnwell County site.

Chem-Nuclear Systems in Barnwell to ship the material today they would "We would>>'L see this as a prece- be within their limiL. But because of County.

Lowe said that for the generators dent for any other power companies," the volume reduction over the coming said Wilson. "And we haven't seen monlhs amt the fact that it will take to be buried at Chem.Nuclear. the Fl'&L's studies and showings and-state would have to waive the volume then) until 1%2 to remove and ship the they will have to do that. Until we get units-will mean that by then their tin>it that,-and a forrnal application. we are would have slid too loiv.

reluctant to make any kind of indica- "They are anticipating this and arc tion about what will happen." asking us abouL thc situation before

APPENDIX VI NUREG-0685 Envfronlrlenkal Assessment fol Erf"ective Changes to 10 CFR Part 60 and Appendix E to 1Q CFR Paft 50; Ernergei>cy Planning Requirements for l~iuciear Power Plants tManuscript Completed: July 1980 Date, Published: August 1980 W. f<. Ott Division of Siting, Health and Safeguards Standards Office of Standards Development U.S.'uclear Regulatory Commission Washington, D.C. 20555 0

APPENOIX A REPLACEMENT POMER COSTS OF SHUTTING DOMN OPERATING NUCLEAR POMER PLANTS, 1981 If a nuclear plant is ordered shut down, the power that would have .been generated by the plant will be generated by another plant if the capacity is available. A cost estimate was prepared and is shown in the accompanying Table A-1 for replacement'ower for one month. The list of operating plants for 1981 was taken from the forecast in NUREG-0380, October 19, 1979,. excluding Indian Point 1 and TMI 2. It was assumed that each utility would replace the power with coal-fired and oil-fired capacity at the-ratio'the State where the plant is located currently uses these fuels for steam-electric plants. It was assumed that no replacement hydrogenerating capacity would be available because it would already be fully used. In addi tion, the availability of hydroelectric V

capacity is highly weather dependent. Supplies of coal and oil, particularly oil, are highly uncertain for next year. Thus, these fuel mixes may be altered considerably. Similarly, coal supplies could be changed substantially by strikes and severe weather.

Coal and oil costs were based 'on January 1979 prices from the Oepartment of Energy. Coal costs for 1981 were increased by 15%%u'. Oil costs (residual) were doubled over January 1979'rices. This estimate is conservative since the present price (January 1980) has already exceeded twice the January 1979 price. Neither of these assumptions are likely to be near the prices actually prevailing in 1981. ,(Oil prices in particular are highly uncertain. ) It does l reasonable however, to assume that oil prices in January will be seem 1981 no iower, than current levels. "Also, if oil prices continue rising, past experience indicates that coal prices will follow.

12

The weighted cost of fuel for each plant was adjusted downward by 6 mills/

kWh, which is the approximate savings of nuclear fuel costs by not operating

\

the nuclear plant. No adjustment for non-fuel operating and maintenance costs was made, although average operating and maintenance costs for nuclear plants k

are lower than those for fossil fuel plants, especially those that would be brought into operation to replace the nuclear capacity.

It was assumed that the nuclear plants operate at an annual average capacity factor. will likely be higher i n the early months of 65'ercent This 1981 as utilities will be experiencing their winter peak demand for elec-tricity. The average capacity factor wi 11 likely be lower in the spring when nuclear plants are typically shut down for refueling. The above patterns will be repeated for the summer and,fall.

Given these uncertainties especially i n fuel prices, the monthly replace-ment costs shown in the Table A-1 should be taken only as indicators. What is clearly shown is that oil-dependent areas are quite vulnerable to substantial cost i ncreases. These are California, the enti re Northeast Power Coordinating Council plus New Jersey, Florida, and Arkansas.

TABLE A"1 SHORT-TERN REPLACEHENT POWER COSTS FOR NUCLEAR UTILITIES Ratio of Coal Fuel Cost'eightede Het Fuel Replacement Power Reliability HWe to Oil Use 4/106 Btu Ave. Fuel Cost Costs3 Costs $ lx)0e Council Plant ~DER

• Coal Oil Coal Oil Hills/kWh Hills/kWh ~ Per Ho.4 NPCC H.Y.-Fitzpatrick 821 134 218 46.8 40. 8 15.9.

H.Y.-Ginna 470 4 134 218 46. 8 40. 8 9.1 Conn.-Haddam Neck 575 oil 245 60. 4 54. 4 14. 9 H.Y.-Indian Point 2 873 134 218 46. 8 40. 8 16. 9 N.Y.-Indian Point 3 965 4 134 218 46. 8 40. 8 18. 7 Haine-Haine Yankee 825 oil 182 44. 8 38. 8 15. 1 Conn. -Nil 1 stone 1 660 oil 245 60. 4 54. 4 17. 1 Conn.-Nil 1 stone 2 870 oil 245 60.4 54.4 22. 5 N.Y.-Nine Nile Point 1 620 4 134 218 46. 8 40.8 12. 0 Hass.-Pilgrim 1 655 oil 201 49.4 43.4 13. 5 Vt.-Vermont Yankee 1 514 oil 201 49.4 43.4 10. 6 Hass.-Yankee-Rowe 175 oil 201 49.4 43. 4 3.5 H.Y.-Shoreham 854 4 134 218 46. 8 40. 8 19. 8 SERC Ala.-Browns Ferry 1 1065 coal 146 20. 7 14. 7 7.5 Ala.-Browns Ferry 2 1065 coal 146 20. 7 14. 7 7.5 Ala.-Browns Ferry 3 1065 coal 146 20. 7 14.'7 7.5 N.C.-Brunswick 1 821 coal 143 20.,3 14. 3 5.6 N.C.-Brunswick 2 821 coal 143 20. 3 14. 3 5.6 Fla.-Crystal River 3 825 1 132 336 66.7 60.'7 23. 8 Ala.-Farley 1 829 coal )46 20. 7 14.7 5.9 Ga.-Hatch ) 786 coal 132 18. 7 12.7 4.7 Ga.-Hatch 2 786 coal 132 18. 7 12.7 4.7 Va.-North Anna 1 907 2 161 203 39.2 33.9 14.4 S.C.-Oconee 1 887 4 147 186 25.8 19.8 8.4 S.C.-Oconee 2 887 147 186 25.8 19. 8 8.4 S.C.-Oconee 3 887 4 147 186 25.8 19. 8 8.4 S.C.-Robinson 2 700 4 147 186 25.8 19.8 6.6 Fla.-St. Lucie 1 802 1 132 336 66. 7 60. 7 23. 1 Va.-Surry 1 822 2 161 203 39. 2 '33.2 12. 9 Va.-Surry 2 822 2 161 203 39. 2 33. 2 12. 9 Fla.-Turkey Point 3 693 1 132 336 66. 7 60.7 20.0 Fla.-Turkey Point 4 693 1 132 336 66. 7 60. 7 20.0 Ala.-Farley 2 829 coal 146 20. 7 14.7 5.9

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9 i r Florida Power & Light Co. again, will be allowed to raise elec-tricity rates, beginning in March. The Public Service Commission

"; ";:;:-.,':;:-':,-': i;;~", Tuesday granted the company its second fuel-adjustment increase withm two months'ime.

The'action translates to'an increase of $ 6.30 or 12.4 per cent for the average FPL customer. The average bill for the "

/VV

, company's 1.5 million subscribers in South Florida and along the Florida East Coast will be $ 57.09.

• stment ch~~ge from .32 cent~ pe kilowatt hour to I.95 cents. That in-creases each customer's bill bP:6~ g< V "i.cents for every kilowatt hour used.... Assistant Public Counsel charged 'with representing Roger'Howe,

,.-> '-"Normally, Florida power compa-',

"nies make fuel-cost adjustments in '9 .the public interest in such matters,

.-" their rates only every six months. ~t.ltt said the rate-hike request was not But FPL said dramatic, unexpected opposed by his office. "We'e put in hikes in the cost of oil had again an awkward position," he said. "If 9 ~ 9 shattered its original October-to- we oppose the increase and the March projections. A similar in- company's projections come ji"..'~r crease was tacked on to electric through, then, the consumer has to ~ ~

bills in December. pay'for not only the increased cost Vt but also for the interest on the dif-PSC Chairman Joseph Cresse said no one could dispute the rising cost "I ference."

of oil. "The price of oil has gone up Howe said that if the company's 222 per cent in the last two years latest estimates fall short of the ac-

~ 99 - for reasons I don't understand," he tual fuel costs for the six-month pe-riod, FPL must then pay the cus- ~ \*

said.

The increase, however, was less ";/ tomers back the overcharge with

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• than the company had requested.. interest. "It cuts both ways," Howe

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FPL petitioned the Public Service 9

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said.

Commission to begin the new fuel- FPL is sc heduled to return to th e 9 adjustment charges on the upcom- Public Service Commission again in ing bill for January usage, April with its regularly scheduled The commissioners, however, April-to-September fuel-adjustment 9

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said it would be unfair to charge customers an increased rate for electricity already consumed. Com t missioner'Gerald Qunter added that;,.;

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projections.

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'I i I MIKE TONER HOIIIO Sci ~ IICt WrutI' Florida Power and Light 'The "major noise off-again Cutler power proble>>1 before ivas Co.'s'on-again,

,.", plant, mothballed in 1976 because It

>~I was Inefficient.,will soon bc back. apl)are>>tly a>> exhatist

'n again.

Company officials said Wednes-stAck al thc l)la>>l. l hc 0'ay that they plan to reactivate the ttolutioii lo tllal f)I'oble>>1

'1-year-old plant that was once the is c>>rl'ctltly in the object of a lawsuit by neighbors

~ t'ho complained that it "incessantly (l('slg>> 'IstQgc I>>

t,,i whined. hissed. belched, tlirobbed. olll'n<<iilecri>><<(lc

~ ~ ~ ."- ~"....".. v, howled, groaned, rumbled and

'::t,:: .,".-> burped" and snorted smoke over

~

"." ...-."the FPL spokesman Tony Hruns

)At'l>>lcnl.'hem prime residential area around rI Coral Reef Drive and Ludlam Road.

FPL savs this time the power;. -.

plant shoiild be a batter neighbor.,; state of "cold shutdown." lt has The company is spending $ 2.3 mil- been maintained by a skeleton crew lion to refurbish two oil-fired gen- of about 20 workers.

erators, muffle them, and bring A though the company once con-into compliance with today sI sidered selling the aging generators L I ~

air pollutionstandards. "

to some South American country FPL spokesman Tony Bruns said more despcratc for electricity, it de-I ' ~

Ip that reactivation of the power plant. cided to keep the plant intact for is necessary to meet the anticipated possible use in some unforeseen shortage of electrical reserves that emergency.

will occur wlicn FPL's Turkey THE tEMERGENCy the compa

• tI'I point nuclear power Plant Is shut down for a major overhaul, starting ny now sees, Is a shortage of ade-in October 1981. '

quate generating capacity in South Florida created by the shutdown of I, ~ I

.~.

BRUNS SAID the Cutler pls t o

'ts two nuclear reactors at Turkey One or the other of the reactors is backin'opcrationbynlld-1982.

ac in opera ion ymi - .

'xPectcd to be oilt of service from late 1981 until i983 for replace-

~ ~

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ready" sroon as we can gear up for it "

"The major noise problem before

'y he said, -Work will start as which liavc been plaglled for years cracks and corrosion; The reactivation of the Cutler was apparently an exphaust stack at P ant rcPresents a relatively small, the plant. The solution to that prob- but new, addition to the ultiniaie lem is currently in thc design stage cost of those repairs now esti'-

in oilr englileerii)g dcpartnicnt." mated to cost the coml)aliy and its The company will also hsve to customers a total of $ 136 niillion.

t t d f d I st d ds f r costan additional $ 500,000a day.

new power plants.

~ ~ ~ ~ ~

In the four years since I'Pi. ~. I'~t:~" " .'.

placed thc controversial plant In a ~.'" ".',),'.',t

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~TLATIOiTtf Appendix IX jr I1 FLORIDA INTERNATIONALUNIVERSITY TAMIAMI CAMPUS ~ 'IAMI. FLORIDA 33199 ~ (305) 552-220T COLLEGE OF ARTS & SCIENCES DEPARTMENT OF BIOLOGICALSCIENCES 8.anuary 39, 1981 Nr. Vark P. Gncavage 12200 S.W. 110 E.venue iTiami, Florida 33176

Dear I;r. Oncavage:

In a letter which was .sent to you on June 4, 1979 I expressed my concern for the ultimate fate of liquid wastes generated by FXorida Power and Light Company's proposed steam generator repairs. I noted particularly that confusing, ambiguous and conflicting statements were made concerning disposal or possible re-use of the drained reactor coolant.

I have nov reviewed the btuclear Regulatory Commission's Draft, Environmental Statement dated December, 1980 and find it not only leaves my questions of one and a half years ago unanswered, but ignores them completely.

I do not consider the fate of nearly 50,000 gallons of highly radioactive waste a trivial matter to either those who vill perform the operations of drainage or to organ-it isms who may have to swim in later on. Will the liquid be stored and re-useQ?

be made for such storage.

If so, what safety provisions will v?ill it be treated and then discharged? If so, some documentation for the decontam-ination figures should be provided and radiological data concerning plants and animals now living in the cooling canals should be maQe available. I am disappo'nted with the completeness of the latest document and hope that succeeding drafts will eventually address themselves to these issues.

Yours sincerely, Walter Goldberg, Ph.D.

Zssociate Professor KG:ms THE STATE UNIVERSITY SYSTEM OF FLORIDA

Appendix X ~ ~

Exhibit 8 FPL COST BENEPIT ANALYSIS FPL Energy Mgt. Plan Revised 12/29/80 Docket No. 800662-EG (MC) '

0 FPL Energy Manageme4. Plan Revised 12/29/80 Docket No. 800662-EG (I4C)

NAME OF UTILI'I'Y- FLOIIH)A POIUER 6I', LIGHT COMPANY

SUMMARY

OF COST-BENEFIT ANAI.YSIS TITI E OF E6>fIMATED TOTAL ES'I'IMATED TOTAL COMPANY COST/BENEFIT PROGRAM COMPANY EXPENDITORES TOTAL REDUCTIONS BENEFITS (1981-1999) ANAI,YSIS Construc- Bene- Imple-tion Fuel Net fit menta-PV of Per Customer System Cost Purchase PV of Benefits /Cost tion Total Total .1981-1999 Savings Savings Mntc. Pers. Total Total (Costs) Ratio Dates Target Equip.

$ (000)

Mtnc. Pers.

eratin Adv.

$ (000) $ (000) $ (000) 0

$ (000) $ (000) KIU KIUH MIU GIUH $ (000) $ (000) 05kM

$ (000) $ (000) $ (000) $ (000) $ (000)

Area I

iUater Heater insulation Program 27 V66 793 506 0.04 2>400 6 350 S,ZZ1 18,521 2,057 29>349 13>IVS 12>672 26.0 1982 Reflective lUindow Film Program 50 18>511 18>561 11>390 0 17 7>000 20, 820 29>408 43>281 4>935 77 ~ 624 34>V&5 23>395 3 1 1981 Residential .

Ceiling Insulation Program 52,541 6,005 58>546 33>186 0 ~3 ll>500 32 1>250 4Z>V21 65>016 8>471 121>208 50>940 1Z>V54 1 5 1981 Appliance Efficiency Program 60 160>881 160>941 94 504 0 3 13>440 607 25>090 903>224 1>320>6SO 160>502 2 384>406 I ~ 030>563 936>059 10 ~ 9 1982 Efficient Home Credit 391" 40,898 41 >2&9 25 ~ 428 0~6 24 000 319 12 ~ V&0 474 >V63 673 >093 81 >781 1 >229 637 532 > 102 506 >674 20 9 1981 Program >

'1 Comm. dc Industrial Energy Analysis Program 12,517 12>538 V>578 0 7 43>330 67 4>390 99 185 232>826 26>528 358 > 539 157 >262 149 >6&4 20 8 1981 Street 2 Outdoor Light Conversion Program 44,731 V35 45>466 32>620 0 5>540 0 l>910 0 298,764 0 298>V64 115>69V 83>077 3 ~6 19&1 Cumulative 90! 10101 97,821 240,313 338,134 205,212 N/A N/A ~7057 46 590 1.563.072 2 652 181 284 274 4 499 527 1 934 527 1 729 315 N/A

S 0

tor mr 2

FPL Energy Management Plan Revised 12/29/80 Docket No. 800662-EG (MC)

NAME OF UTILITY- FLORIDA POIUER 40r LIGHT COMPANY

SUMMARY

OF COST-BENEFIT ANALYSIS TITLE OF ESTIMATED TOTAL ESTIMATED TOTAL COMPANY COST/BEN EF IT PROGRAM COMPANY EXPENDITURES TOTAL REDUCTIONS BENEFITS (1981-1999) ANALYSIS Construc-tion Fuel Net fit menta-PV of Per Customer System Cost Purchase PV of Benefits /Cost tion Equip. Mtnc. Pers. Adv. Total Total 1981-1999 Savings Savings. Mntc. Pers. Total Total Ratio Dates Target

$ (000) eratin

$ (000) $ (000) $ (000) 0

$ (000) $ (000) KW KWH MIU G 'iU H $ (000) $ (000)

$ (000) $ (000)

OitrM

$ (000) $ (000)

(Costs)

$ (000)

Area rl Res. Pool Pump Program S,973 5>978 4>249 0 Z 3>650 117 642 87>587 35>248 3>330 126>165 62>276 58>02Z 14 ~ 7 1981 Res. I,oad Control Program 54,137 46,091 100>228 529063 0 5 0 154 0 238,315 0 238,31S 110>770 58,707 2.1 1981 Res. dr Gen. Svc.

T-0-U Rate Program 122,844 29,630 152,474 75,909 0.8 6,920 193 1>370 297>511 67>006 10>913 375>430 1639305 87 ~ 396 2~2 1987 u

Comm. dr Industrial T-0-U Rate Program 39,912 11,733 51>645 28>812 2 8 36>660 166 2>120 2389381 109>001 13>033 360>415 172 068 1439256 6~0 1982 Comm. 47r Industrial Curtailable Rate Program 1 60 363 60 364 35 343 850 0 190 272 437 0 272 437 130,120 102 777 3.9 1982 Cumulative Subtotal 216 899 153 700 370 689 196 376 N/A N/A 820 276 570 861 794 211 255 27 276 1 372 762 646 539 450 163 N/A Target Area III Capacitor Dank Replacement Program 3 293 0 3 293 2 532 4.0 210 240 3 180 25 542 9 850 711 36 163 18 604 76 072 7.3 1982 Cumulative Subtotal 3 293 0 3 293 2 532 N/A N/A 3 180 25.542 9 850 771 36 163 18,604 16 072 7.3 Cumulative rap>rr 4I

.0 FPL Energy Management Plan Revised l2/29/80 NAME OF UTILITY- FLORIDA POIUFR Zk LIGHT COMPANY Docket No. 800662-EG (MC)

TITI.E OF PROGltAM: Water Heater Insulation Program BRIEF DESCRIPTION OF PROGRAM: FPL will sell water heater insulation kits at market price (about $ 20). FPL will instaU the kit for free with an onwlte Energy Analysis. Kits will be offered as part of Customer-Assisted Energy Analysis services.

PRIMARY PURPOSE OF PROGRAM: Have water heater insulation kits installed on electric resistance water heaters in residential dwellings.

COSl'-BENEFIT ANALYSIS YEAR ESTIMATED COMPANY EXPENDITURES REDUCTIONS ESTlhlATED COMPANY BENEFITS 2 3 4 5 8 9 10 '11 12 13 14 15 16 Construc-tion Fuel PV of Per Cost Purchase PV of Mtnc. Adv. Total Total Cu'stomer System Savings Savings Mtnc. Pers. Total Total Equip.

$ (000) $ (000) 0 Pers.

$ (000) eratin $ (000) $ (000) $ (000) K iU KIUH M'iU GIUH $ (ooo) $ (aoo) -

OaM

$ (ooo) $ (ooo) $ (ooo) $ (ooo) 1981 27 95 122 111 0 0 0 0 0 0 0 0 1982 0 65 65 54 0.04 240 5 0 285 0 285 235 1983 0 70 70 53 0.04 240 10 0 650 0 650 4SS 1984 0 75 75 51 0.'04 240 15 0 1>110 0 1,110 V58 1985 0 80 80 50 0.04 240 20 0 1,680 ~

0 1,680 1>043 1986 0 86 86 49 0.04 240 25" 0 2,400 0 2,400 1,354 1987 0 92 92 47 0.04 -

240 29 V,095 899 162 8,156 4,1S4 1988 0 98 98 46 0.04 240 32 0 1,088 192 1,280 598 1989 0 105 105 45 0.04 240 35 1,676 1,295 '24 3,195 1,355 1990 0 0 0 0 0.04 240 35 0 1,400 242 1,642 634 1991 0 0 0 0 0.04 240 35 0 1,540 259 1,V99 630 1992 0 a 0 0 D.04 0 30 0 1,440 237 1>677 535 1993 0 0 0 0 0.04 0 25 0 1,300 210 1,510 43&

1994 -0 0 0 0 0.04 0 20 0 1>140 180 1,320 347 1995 0 0 0 0 0.04 0 15 0 930 146 1,076 257 1996 0 0 0 D 0.04 0 10 0 680 103 783 171 1997 0 a 0 0 0.04 0 6 0 444 67 511 101 1998 0 0 0 0 0.04 0 3 0 240 35 2VS 50 1999 0 0 0 0 004 0 0 0 0 0 0 0 Cumulative Total 27 766 293 506 0.04 2 400 6 350 8 TT1 10 521 2 05T 29,349 13 118 Net Benefits $ (000)

From Cumulative Totals Col 16 - Col 6 1'2 6Z2 Benefit/Cost Ratio From Cumulative Totals Col 16 -. Col 6 26.0 METIIOD AND JUSTIFICATION USED TO DETERMINE'I'HE COST EFFECTIVENESS OF THIS PltOGRAM: (Attach additional sheets if necessary)

I I

FPL Energy Hanagement Plan Revised 12/29/80 Docket No. &00662-EG (MC)

NAME OF UTILITY- FLORIDA POWER 4k LIGHT COMPANY TITLE OF PROGRAh1: Reflective Window Film Program BRIEF DESCltlPTION OF PROGRAhl: FPI, will pay labor cost (about $75) for having refiective window film installed in residences when it is cost-effective. FPL wIII develop a list of approved contractors. FPL will find homes and notify owners through Energy Analyses services.

PRlhiARY PURPOSE OF PROGRAM: Have reflective window film installed, where cost-effective, in residential dwellings that utilize some type of electric air conditioning.

COST-BEN EFIT ANALYSIS YEAR ESTlhlATED COhi PANY EXPENDITURES REDUCTIONS ESTlhiATED COMPANY BENEFITS 4 5 11 12 13 14 15 16 Construc-tion Fuel PV of Per Cost Purchase PV of 1981 Equip.

$ (000) 50 Mtnc.

$ (000) 0 Pers.

$ (000) .

eratin 66V Adv.

$ (000)

Total

$ (000)

V17 Total

$ (000) 652 KW Customer 0.17

'KWH VOO MW System 0

GWH 1

Savings'a'vings

$ (000) 0

$ (000) 50 hitnc.

04kM

$ (000)

Pars.

$ (000) 0 Total

$ (000) 50 Total

$ (000) 45 1982 0 1,799 1>V99 1>486 0.17 700 2 8 0 456 0 456 377 1983 0 2,128 2,128 1,598 0.17 700 5 20 0 1,300 0 1,300 976 1984 0 2>491 2>491 1,V01 0.17 700 8 33 0 2,442 D 2,442 1,668 1985 0 2,441 2,441 1>516 0.1V VOO 11 45 0 3>780 0 3,VSD 2,34Z 1986 0 2,367 2,36Z 1,335 0.17 VOO 14 57 0 5,4Z2 0 5,472 3,086 1987 0 2,250 2,250 1,154 0.1V VOO 16 66 22,704 2,046 370 25,120 12>887 1988 0 2>211 2,211 1>033 0.17 700 18 75 0 2,550 450 3,000 1>401 1989 0 '2, 157 2,15V 915 0.1V 700 20 82 6,704 3,034 525 10,263 4>352 1990 0 0 0 0 0.17 700 20 82 0 3,280 566 3,846 1,485 1991 0 0 0 0 0.17 0 20 81 0 3,564 599 4>163 1,45Z 1992 0 0 0 ~ 0 0.17 0 20 74 0 3>552 585 4>137 1,320 1993 0 0 D 0 0.17 0 20 62 0 3;224 521 3,745 1,086 1994 0 0 0 0 0.1V 0 20 49 0 2,793 441 3,234 S51 1995 0 0 0 0 0.17 0 20 37 0 2,294 359 2,653 634 1996 0 0 0 0 0.17 0 20 25 0 1,ZOO 258 1,958 427 1997 0 0 0 0 0.17 0 20 16 0 1,184 178 1,362 270 1998 0 0 0 0 0.17 0 20 7 0 560 83 643 116 1999 0 0 0 0 0.17 0 . 20 0 0 0 0 0 0 Cuinulative Total 50 18 611 18 061 11 390 0.17 7,000 90 080 89 408 43 88 1 4 930 77 694 34 780 Net Benefits $ (000)

From Cumulative Totals Col 16 - Col 6 83 390 Benefit/Cost Ratio From Cumulative Totals Col 16-. Col 6 3.1 ML'TIIOD AND JUSTII>ICATION USED TO DETERhHNE THE COST EFFECTIVENESS OF THIS PROGRAM: (Attach additional sheets if necessary)

I

-0

8 41~ =. ~ = 5 ~ ~ 4. 4 > 4 ~ ~J4LQh, 6 W(~ ~84044 ~

r.-

~ 8, FPL Energy Management Plan Revised 12/29/80 Docket No. 800662-EG NAME OF UTILITY- FLORIDA POWER lk LIGIITCOMPANY (MC)

TITLE OF P ROG R A hl: Residential Ceiling Insulation Program BRIEF DESCRIPTION OF PROGRAM: FPL will pay $ 300 toward the installation cost of ceiling insulation with a rating of R-19 or higher in homes with electric air conditioning and/or heating, provided that the homo previously had no ceiling insulation. FPL will develop a list of approved contractors. FPI will find qualifying homes through Energy Analyses services and neighborhood (area) surveys and inspections.

PRIMARY PURPOSE OF PROGRAhl: Ilave ceiling insulation of R-19 installed in residential dwellings that have no ceiling insulation but are equipped with some type of electric air conditioning and/or electric heating.

COST-BENEFIT ANALYSIS YEAR ESTIhlATED COhlPANY EXPENDITURES REDUCTIONS ESTIMATED COhlPANY BENEFITS 2 3 10 11 12 13 14 15 16 Construc-tion Fuel PV of Per Cost Purchase PV of 1981 Equip.

$ (000) 612 ht tnc.

$ (000) 0 Pers.

$ (000) eratin 151 Adv.

(000)

Total

$ (000)

V63 Total

$ (000) 694

. KW Customer 0.3 KWH 1>150 MW System 0

GWII 0

Savings

$ (ooo)

.'0 Savings

$ (ooo) 0 h'ltnc.

$ (ooo) 04kh1 Pers.

$ (ooo) 0 Total

$ (000) 0 Total

$ (000) 0 1982 ,1,9Z8 315 2,293 l>S94 0.3 1,150 1 5 0 285 0 285 235 1983 2,576 398 2,974 2,234 0.3 1, 150 3 13 0 845 0 845 635 1984 6,753 864 7,617 =5,202 0.3 1,150 7 27 0 1,998 0 1,998 1,365 1985 V,V30 924 8,654 5>374 0.3 1,150. 12 47 0 3,948 0 3,948 2,452 1986 Z,919 989 8,90S 5,024 0.3 1,150 18 68 0 6,52S 0 6,528 3,682 1987 8,055 V35 8,790 4,509 0.3 1,150 23 87 32>637. 2,697 487 35,821 18,376 1988 8,325 V87 9,112 4,255 0.3 1,150 28 106 0 3,604 636 4,240 1,980 1989 8,593 842 9,435 4,000 0.3 1,150 32 125 15,0S4 4,625 800 20,509 8,696 1990 0 0 0 0 0.3 1,150 32 125 0 5,000 862 5>862 2,263 1991 0 0 0 0 0.3 0 32 125 0 5,500 925 6,425 2,249 1992 0 0 0 0 0.3 0 32 120 0 S,Z60 948 6,70S 2>140 1993 0 0 0 0 0.3 0 32 112 0 5>824 941 6,765 1,962 1994 0 0 0 0 0.3 0 32 98 0 5,358 882 6,240 1,641 1995 0 0 0 0 0.3 0 32 78 0 4>836 VSV 5,593 1,33Z 1996 0 0 0 0 0.3 0 32 57 0 3,876 587 4,463 973 1997 0 0 ~ 0 0 0.3 0 32 38 0 2,812 422 3,234 640 1998 0 0 0 0 0.3 0 32 19 0 1,520 224 1,Z44 314 1999 0 0 0 0 0.3 0 32 0 0 0 0 0 0 Cumulative 2'4447 52 541 6 865 58 546 33 186 8.3 11 568 32 1 256 47 721 65 816 8 471. 121 268 58 848 Net Benefits $ (000)

From Cumulative Totals Col 16 - Col 6 17 754 Benefit/Cost Ratio From Cumulative Totals Col16-. Colo 1.5 METIIOD AND JUSTIFICATION, USED TO DETERMINE TIIE COST EFFECTIVENESS OF TIIIS PROGRAM: (Attach additional sheets if necessaty)

(,

II',

II 0

0

FPL Energy Manager p1an Revised 12/29/80 NAh1E OF UTILITY- FI,OItIDA POIUEII 4t; LIGHT COMPANY Docket No. 800662-EG (htC)

TITLE OF FROG RAh1: Appliance Efficiency Program BRIEF DESCRIPTION OF PROGRAM: FPL will give rebates to established customers I'or replacement purchases of very efficient appliances for cooling, heating, and water heating. FPL will develop a list of specific appliances and rebate amounts. FPL will notify customers through Energy Analyses services. FPI, will promote the merits of efficient appliances through mass media and dealer advertising techniques.

PRIMARY PURPOSE OF PROGRAM: improve the average efficiency of new and replacement appliances used by residential customers by 15 percent.

COST-BENEFIT ANALYSIS ESTIMATED COMPANY EXPENDITURES R EDUCTIONS ESTIMATED COMPANY BENEFITS 2 3 4 5 6 8 9 10 11 12 13 14 15 16 Construc-tion Fuel PV of Per Cost Purchase of eratin PV Equip. Mtnc. Pers. Adv. Total Total Customer System Savings Savings hltnc. Pers. Total Total

$ (000) $ (000) 0

$ (000) $ (000) $ (ODD) $ (000) II W IfIVH MIV GNH $ (DDD) $ {000) 04kM

$ {000) $ {000) $ {DDD) $ (000) 1981 19 328 347 315 D 0 D 0 0 0 0 0 0 1982 41 15,812 15,853 13,095 0.3 1,344 40 166 0 9,462 0 9,462 V,&16 1983 0 16,&16 16,&16 12)629 0.3 1)344 121 500 0 32,500 0 32>500 24,40S 1984 0 17,883 1Z,SS3 12,214 0.3 1,344 2D2 &34 0 61,716 0 61,716 42,152 1985 0 19)136 19,136 11,883 0.3 1,344 282 1,169 0 98,196 0 9S>196 60,980 1986 0 20,474 20,474 11,54V 0.3 1,344 363 1,503 0 144,288 0 144,288 81,378 198? D 21,9DS 21,908 11,239 0.3 1,344 444 1,838 630,036 56>978 10,293 69Z,307 35Z,718 1988 0 23,441 23,441 10,947 0.3 1,344 525 2,1V3 0 73,882 13,03S -86,920 40,592 1989 0 25,083 25>083 10,635 0.3 1,344 607 2,509 273,188 92,&33 16,058 382,079 162>001 199D 0 0 0 0 0.3 1,344 60Z 2,509 0 100,360 1V,312 llV>6Z2 45,421 1991 0 0 0 0 0.3 P,344 60Z 2,509 0 110,396 18,56V 128>963 45,137 1992 0 0 0 0 0.3 0 607 2,343 0 112,464 18>510 130,974 41,781 1993 0 0 0 0 0.3 0 60Z 2,009 0 104)468 16>876 121,344 35,190 1994 0 0 0 0 0.3 0 607 1,6Z5 0 95,4ZS 15)075 110,550 29,075 1995 0 0 0 0 0.3 0 607 1,340 0 83,080 12,998 96,078 22)963 1996 0 0 0 0 0.3 0 60Z 1,006 0 68,408 10,362 78,410 17)093 1997 0 0 0 0 0.3 0 607 671 0 49,654 V,448 SV,I02 ~ 11>306 1998 0 0 0 0 0.3 0 607 336 0 26,880 3,965 30,845 5,552 1999 0 0 0 0 0.3 0 607 0 0 0 0 0 0 Cuniutative Total 60 160,881 160,941 94 304 0.3 13,440 601 26 09D 003,224 1 320 680 160,602 2 304,406 1 03D 603 Net Benefits $ (000)

From Cumulative Totals Col 16- Col 6 936 069 Benefit/Cost Ratio From Cumulative Totals Col16; Col6 10.9 METHOD AND JUSTIFICATION USED TO DETERMINE THE COST EFFECTIVENESS OF THIS PROGRAM: (Attach additional sheets if necessary)

1 0

FPL Energy Hanagement Plan Revised l2/29/80 NAhlE OP UTILITY"FLORIDA POWER d( I IGIIT COhlPAH Y Docket No. 800662-EG (HC)

TITLE OP PROGRAM: Efficient Home Credit Program BRIEF DESCRIP'f ION OF PROGRAhl: FPL will propose to the PPSC that, beginning in 1982, customers whose new homes and appliances meet revised Watt-Wise standards (25% more efficient than new state building code) receive and "efficient home credit". FPL will develop cost support data for a charge on all new homes and for the efficient home credit. If adopted, FPL will notify potential purchasers through Energy Information Services and tin ough horne builders and developers, appliance dealers and suppliers.

PRIMARY PURPOSE OP PROGRAM: Achieve the use of energy-efficient design and equipment in new homes.

COST-BENEFIT ANALYSIS ESTIMATED COhlPANY EXPEHDI'fURES lt EDUCTIOHS ESTIMATED. COMPANY BENEPITS 1 2 8 9 ll 12 13 14 15 16 Construc-tion Fuel PV of Per Cost Purchase PVof 1981 Equip.

$ (000) 391 Mtnc.

$ (000) 0 Pers.

$ (000) eratin 3,414 Adv.

(000)

Total

$ (000) 3,805 Total

$ (000) 3>459 KW Customer 0.6 K WII 2,400 hlW System GWII 5

Savings

$ (000) 0 Savings

$ (000) 250 .

hltnc.

05kM

$ (000)

Pers.

$ (000) 0 Total

$ (DDD) 250 Total

$ (000) 227 1982 1983 0

0 3,653 3,909 3>653 3,909 3,017 2>936 0.6 0.6 2,400 2>400 23,91 1

64 256 0

0 5,18Z 16,640 0

0 5,187 16>640 4,284 12,497 1984 0 4,1S3 4,183 2,857 0.6 2,400 106 424 0 31,376 0 31>376 21>430

. 1985 0 4,476 4,476 2,V&0 0.6 2>400 . 148 592 0 49,728 0 49,V28 30,881 1986 0 4,789 4,V&9 2,Z01 0.6 2,400 190 V61 0 V3,056 0 V3,056 41,204 1987 0 5> 124 5,124 2,629 0,6 2,400 233 932 330,62Z . '28,892 5,219 364>738 187,111 1988 0 5,'4&3 5,483 2,561 0.6 2,400 276 1,104 0 37,536 6,624 44,16D 20,623 1989 0 5,&6V 5,86V 2,488 0.6 2,400 319 1,'2VS 144,136 4'7,286 8,179 199,601 84,631 1990 0 0 0 0 0.6 2,400 319 1,278 0 51,120 8,818 59,938 23,136 1991 D 0 0 0 0.6 0 319 1,273 0 56,012 9,420 65,432 22,901 1992 0 0 . 0 0 0.6 0 319 1>187 0 56,976 9,37V 66,353 21,167 1993 0 0 0 0 0.6 0 319 1,022 ,

0 53>144 8,585 61,Z29 17>901 1994 0 0 0 0 0.6 0 319 &54 0 48,6VS V,686 56,364 14,824 1995 0 0 0 0 0.6 0 319 686 0 42>532 6,654 49,186 11,755 1996 0 0 0 0 0.6 0 319 51V 0 35,156 5,325 40,481 S,S25 1997 0 0 0 0 0.6 0 319 346 0 25,604 3,&41 29,445 5,830 199S 0 0 0 0 0.6 0 319 174 0 13,920 2,053 15>973 2,875 1999 0 0 0 0 0.6 0 319 0 0 0 0 0 0 Cumulative Total 391 40 898 41,289 25 426 0.6 24 000 319 12 780 474 763 673 0113 81 701 1 229 637 532 102 Net Benefits $ (000)

From Cumulative Totals Col 16-Col 6 506 674 Benefit/Cost Ratio From Cumulative Totals Col 16-. Col 6 '20. 9 METIIOD AHD JUSTIFICATION USED 'fO DETERhllHE TIIL'OS'f EFFECTIVENESS OP TIIIS PROGRAhl: (Attach additional sheets if necessary)

0

PPL Energy Hanagement Plan Revs,sed 12/29/80 NAhlE OF UTILITY- FLOltlDA POIVER 4 LIGIITCOhlPANY Docket Ho. 800662-EG (NC)

TITLE OF PROGRAhl: Com'mercial and Industrial Energy Analysis Program BRIEP DESCRIPTION OF PROGRAhl: FPL representatives, in conjunction with business managers, will make thorough analyses of commercial and industrial customers with usage under 20K'lV. FPL will also provide consultation and arrange for an engineering consultant to conduct energy analyses of large businesses, local municipalities, and other governmental agencies that are FPL customers. Analyses will also encompass outdoor lighting usage. FPI, will notify customers of availability through Energy Information Services (including the South Flotida Energy Partnership).

PRIMARY PURPOSE OF PROGRAhi: Assist commercial and industrial customers in making their facilitics more energy efficient through. the installation of certain conservation measures and through the implementation of certain conservation practices.

COST-BENEFIT ANALYSIS YEAR ESTlh'IATED COhlPANY EXPENDITURES REDUCTIONS ESTIhIATED COMPANY BENEFITS 2 3 4 5 9 10 11 12 13 14 15 . 16 Construc-tion Fuel PV of Per Cost Purchase PV of 1981 Equip.

$ (000) 21 eratin Mtnc.

$ (000) 0 Pers.

$ (000) 689 Adv.

'(000)

Total

$ (000) 710 Total

$ (000) 645 Customer K IV 0.7 K\VII.

4,330 MiV System 3

G'iVII 18 Savings

'(000) 0 Savings

$ (000) 900 hitnc.

5(000)

Okhi Pers.

$ (OOO) 0 Total

$ (000) 900 Total

$ (000) 818 1982 0 1,153 1>153 952 O.V 4,330 11 VO 0 3,990 0 3,990 3,296 1983 0 1,234 1,234 927 O.V 4,330 19 122 0 V,930 0 7,930 5,955 1984 0 1,320 1,320 902 0.7 4,330 27 175 0 12,950 0 12,950 8,845 1985 0 1,412 1,412 877 0.7 4,330 35 228 0 19,152 0 19,152 11,893 1986 0 1,511 1,511 852 0.7 4,330 43 281 0 26,970 0 26>976 15,214 19&7 0 1,617 1,61V 830 O.V 4,330 51 333 72,369 10,323 1,865 84,557 43,3Z8 198& 0 1,730 1,730 808 0.7 4,330 59 386 0 13,124 2>316 15,440 Z,210 1989 0 1>851 1,851 785 O.V 4,330 6Z 439 26,816 16,243 2,810 45,869 19,448 1990 0 0 0 0 0.7 4,330 67 439 0 17,560 3,029 20,589 Z,94Z 1991 0 0 0 0 0.7 0 67 421 ,0 18,524 3,115 21,639 7,574 1992 0 0 0 0 0.7 0 67 369 0 17,Z12 2,915 20,62V 6,580 1993 0 0 0 0 0.7 0 67 31V 0 16,484 2,663 19,147 5,553 1994 0 0 0 0 O.V 0 67 264 0 15,048 2,3Z6 1Z,424 4,583 1995 0 a 0 0 O.V 0 67 211 0 13,082 2,047 15,129 3,616 1996 0 0 0 0 0.7 0 67 158 0 10>V44 1,627 12,371 2,697 1997 0 0 0 0 0.7 0 67 106 0 V,&44 l,lZZ 9>021 1,786 1998 0 0 0 0 0.'7 0 67 53 0 4,240 588 4,S28 869 1999 0 0 0 0 0.7 0 67 0 0 0 0 0 0 Cunrula tive Total 21 12,51V 12,538 V,578 0.7 43,330 67 4,390 99,185 232,826 26,528 358,539 '157,262 Net BenefitS $ (000)

From Cumulative Totals Col 16 - Col 6 149 684 Benefit/Cost Ratio Fro>n Cumulative Totals Col l6-. Col 6 20.8 Mh",I'IIOD AND JUS'I'IFICATION USED TO DETERhlINE TIIE COST EFFECTIVENESS OF TIIIS PROGRAhl: (Attach additional sheets if necessary)

I U

0 I

FPL Energy Hanagem~ plan NAME OF UTILITY- FLOIIIDA POIUER 4k LIGIITCOMPANY Revised 12/29/80 Docket No. 800662-EG (Hc)

TITLE OF PROGRAhl: Street and Outdoor Light Cohv8":rsion I'rogrum BRIEF DESCRIPTION OF PltOGRAM: FPI will (a) convert Companymwned incandescent and mercury vapor street lights and outdoor lights to high-pressure sodium vapor; (b) encourage conversion of customer-owned lighting systems to hlgh~ressure sodium vapor; and (c) close the mercury vapor street light and outdoor lighting rate schedules. In addition, a public awateness campaign will be conducted to facilitate thc acceptance of this program and encourage customer-induced conversions.

PRlhlAltY PURPOSE OF PROGRAhl: Reduce energy consumption for street lighting and outdoor lighting while maintaining existing illumination levels.

COST-BENEFIT ANALYSIS YEAR ESTIMATED COMPANY EXPENDITUIIES RL'DUCTIONS ESTIMATED COhIPANY BENEFITS 2 3 4 5 6 8 9 10 11 12 13 14 15 16 PV of Per Construc-tion Cost

'uel Purchase PV of 19&1 Equip.

$ (000) 3>824 hltnc.

$ (000) 0 Pers.

$ (000) eratin 278 Adv.

$ (000)

Total

$ (000) 4,102 Total

$ (000),

3,Z29 KW Customer K'IUH 554 M\U System 0

GIUII 7.

Savings

$ (000) 0 Savings

$ (000) 350 hltnc.

M

$ (000)

O)k Pers.

$ (000) 0 Total

$ (000) 350 Total

$ (000) 318 1982 8>555 103 8658 7,152 554 0 3& 0 2,166 0 2,166 11'789 1983 9,151 110 9,261 6,955 554 0 V2 0 4,680 0 4,680 3,515 1984 9,792 118 9,910 6,769 554 0 103 0 Z,622 0 7>622 5,206 19&5 10,4'?7 126 10>603 6,584 554 0 14) 0 11,844 0 )1,844 V>355 1986 660 0 660 372 554 0 162 0 15,552 0 15,552 S,VZl 1987 V07 0 707 363 554 0 172 0 18,920 0 18%920 9,V06 1988 756 0 V56 353 554 0 181 0 22,444 0 22)444 10,481 1989 809 0 &09 343 554 0 191 0 27 >122 0 27,122 11,500 1990 0 0 0 0 554 0 191 0 30,751 0 30,751 11,&ZO 1991 0 0 0 0 0 0 184 0 34,040 0 34,040 11,914 1992 0 0 0 0 0 0 153 0 32,2&3 0 32,283 10,298 1993 0 0 0 0 0 0 . 119 0 28,560 0 28,560 8,282 1994 0 0 0 0 0 0 88 0 24>112 0 24,112 ~ 6)341 1995 0 0 0 0 0 0 50 0 15,650 0 15,650 3>740 1996 0 0 0 0 0 0 29 0 10,324 0 10,324 2)251 1997 0 0 0 0 0 0 19 0 V,714 0 7,714 1,527 1998 0 0 0 0 0 0 10 0 4>630 0 4,630 833 1999 0 0 0 0 0 0 0 0 0 0 0 0 Cumulative Total 44 731 735 45 466 32 620 0 5 540 0 1,910 0 298 764 0 298 764 ll5 697 Net Benefits $ (000)

Prom Cun)ulative Totals Col 16- Col 6 83 077 Benefit/Cost Ratio From Cumulative Totals Col 16-. Col 6 3.6 METHOD AND JUSTIFICATION USED TO DETERMINE TIIE COST EFFECTIVENESS OF TIIIS PROGRAhl: (Attach additional sheets if necessary)

T> ~ ',4 aa ~ '4= 4 J " - \ " ~ 4 T>a r - e ~ w 0 ~

0

9 FPL Energy Nanag t Plan Revised 12/29/80 NAh1E OF UTILITY- FLORIDA POIUER 4k LIG>HT COh1PANY Docket No. 800662-EG (MC)

TITI,E OF PIIOG RAM: Residential Pool Pump Program BRIEF DESCIIIPTION OF PROGRAhl: FPL will install clips on residential swimming pool pump timers. FPL, in conjunction with pool builders and maintenance organizations, will determine recommended filtering system operating time. FPL will find homes and notify and remind owners through Energy Information Services, coupled with meter reader surveys.

, PRIMARY PURPOSE OF PROGRAM: Eliminate the use of residential swimming pool pumps at times of system peak and reduce overall operation of pool pumps when applicable.

COST-BENEFIT ANALYSIS YEAR ESTIMATED COMPANY EXPENDITURES REDUCTIONS ESTIhlATED COMPANY BENEFITS 2 3 4 5 8 9 10 11 12 13 14 15 16 Construc-tion Fuel PV of Pcr Cost Purchase of PV Equip. Mtnc. Pers. Adv. Total Total Customer System Savings Savings Mtnc. Pers. Total Total

$ (000) $ (000) 0

$ (000) eratin $ (000) $ (000) $ (000) KIU KIUH hliU GlUH $ (000) $ (000)

M

$ (000) 04k

$ (000) $ (000) $ (000) 1981 5 888 893 812 O.V 365 10 5 0 250 0 250 227 1982 0 950 950 V85 O.V 365 31 16 0 912 0 912 753 1983 0 1,017 1,017 764 O.V 365 52 2Z 0 1,Z55 0 1,Z55 1,318 1984 0 1,088 1,088 V43 0.7 365 73 38 0 2,812 0 2,812 1,921 1985 0 1,164 1,164 723 O.V 365 94 49 0 4,116 0 4,116 2,556 1986 0 195 195 110 0.7 365 107 56 0 5,376 0 5,376 3,032 1987 0 209 209 107 0.7 365 110 57 80,883 1,767 319 82>969 42>563 1988 0 223'39 223 104 0.7 365 114 59 0 2,006 354 2,360 1,102 1989 0 239 101 0.7 365 11V 61 6>704 2>25Z 390 9,351 3,965 1990 0 0 0 0 0.7 365 11V 61 0 2,440 421 2,861 1,104 1991 0 0 0 0 0.7 0 llV 56 0 2,464 414 2,8ZS 1>007 1992 0 0 0 0 O.V 0 117 45 0 2,160 356 2,516 802 1993 0 0 0 0 0.7 0 117 34 0 1,768 286 2,054 596 1994 0 0 0 0 0.7 0 117 23 0 1,311 207 1,518 399 1995 0 0 0 0 O.V 0 117 16 0 992 155 1,14Z 274 1996 0 0 0 0 O.V 0 117 15 0 1,020 154 l>174 256 1997 0 0 0 0 0.7 0 1IV 13 0 962 144 1,106 219 1998 0 0 0 0 0.7 0 117 11 0 880 130 1,010 182 1999 0 0 0 0 0.7 0 117 0 0 0 0 0 0 Cu mule t I v e Total 5 973 5 979 4 249 0.7 ~3 650 117 642 87 587 35 248 ~3 330 126 165 62 276 Net Benefits $ (000)

From Cumulative Totals Col 16- Col 6 58 027 Benefit/Cost Ratio From Cumulative Totals Col 16 ". Col 6 14.V METIIOD AND JUSTIFICATION USED TO DETERhllNE 'I'IIE COST EFFECTIVENESS OF TIIIS PIIOGRAM: (Attach additional sheets if necessary) 9

li FPL Ener9Y Nanar3ement p1an Revised 12/29/80 NAh1E OF UTII.ITY - FI.OIIIDA PO'lUER tk LIGIITCOMPANY Docket No. 800662-. EG (NC)

TITLE OF PROGIIAM: Residential Load Control Program BRIEF DESCRIPTION OF PROGItAM: FPL will propose to the FPSC that, beginning in 1985, all residential customers who allow their electric central air conditioning, strip heating, and water heating use to be cycled (controlled) will receive a rate incentive. FPL will develop cost support data for the proposal. FPL will provide for the installation of appropriate communication and load control equipment. If adopted, FPL will notify potential customers of the load control offer through Energy Information services.

0 PRlhiARY PURPOSE OF PitOGRAhi: Reduce the usc of home appliances at times of FPL syst'm peak, thereby reducing peak demand.

COST-BEN EFIT ANALYSIS YEAR ESTlhtATED COM PAN Y EXPENDITURES REDUCTIONS ESTlhlATED COhiPANY BENEFITS 2 3 4 5 .9 10 11 12 13 14 15 16 Constr uc-tion Fuel PV of Per Cost Purchase PV of 1981 Equip.

$ (ooo) 2 hi tnc.

$ (000) 0 Pers.

$ (000) eratin 68 Adv.

$ (000)

Total

$ (000) 70 Total

$ (000) 64 Customer KIU 0.5 KIUH MlU System 0

GiUH 0

Savings

$ (000) 0 Savings

$ (000) 0 hitnc.

Otkht

$ (000)

Pers.

$ (000) 0 Total

$ (000) 0 Total

$ (000) 0 149 123 0.5 0 0 . 0 0 0 0 0 1982 2 14Z 1983 2>909 157 3,066 2,303 0.5 0 .0 0 0 0 0 0 1984 6,228 207 6,435 4,395 0.5 0 0 0 0 0 0 0 1985 7,890 2,264 10,154 6,306 0.5, 0 0 0 0 0 0 0 1986 9,695 5,18& 14,883 8,394 0.5 38 0 0 0 0 0 0 1987 10,373 8,694 19,067 9,781 0.5 77 0 109,263 0 0 1901263 56,052 1988 11,100 12>665 23,765 11,098 0.5 115 0 0 0 0 0 0 1989 5>938 16,701 22,039 9,599 0.5 154 0 129,052 0 0 129,052 54,718 1990 0 0 0 0 0.5 154 0 0 0 0 0 0 1991 0 0 0 0 0.5 154 0 0 0 0 0 0 1992 0 0 0 0 0.5 154 0 0 0 0 0 0 1993 0 0 0 0 0.5 154 0 0 6 0 0 0 1994 0 0 0 0 0.5 154 0 0 0 0 0 0 1995 0 0 0 0 0.5 154 0 0 0- 0 0 0 1996 0 0 0 0 0.5 154 0 0 0 0 0 0 199Z 0 0 0 0 0.5 154 0 0 0 0 0 0 1998 0 0 0 0 0.5 154 0 O 0 0 0 0 1999 0 0 0 0 0.5 154 0 0 0 0 0 0 Cumulative Total 54 137 40 001 100 220 52 003 0.5 0 154 0 230 315 0 230 315 110 770 Nct Benefits $ (000)

From Cumulative Totals Col 16 - Col 6 50 707 Benefit/Cost Ratio From Cumulative Totals Col 16-. Col 6 2.1 htETHOD AND JUSTIFICATION USED TO DETERMINE T)iE COST EFFECTIVENESS OF THIS PROGRAM: (Attach additional sheets if necessary)

0 TITLE OF PROGRAhi:

NAh'IE OF UTILITY- FLORIDA POIUER Residential and General Service Timewf-Usc Rate Program Vk LIGHT COhtPANY

'PL Energy Management Plan Revised 12/29/80 Docket No. 800662-,EG (MC)

BRIEF DESCRIPTION OF PROCIIAhl: FPL will propose to the FPSC that, beginning in 1987, large residential customers be offered a choice of load control or a mandatory seasonal Timewf-Usc (T-0-U) rate. PPL will develop appropriate cost support date for the proposal. FPL will provide for the Installation of appropriate metering and communication equipment. If adopted, FPL will notify potential customers of the mandatory seasonal T-0-U rate and the Load Control option through Energy Information services.

PRIMARY PURPOSE OF PROGRAhl: , Reduce demand of high-use residential and general service customers at times of FPI system peak.

COST-BENEFIT ANALYSIS YEAR ESTlhlATED COMPANY EXPENDITUltES 2 3 4 5 REDUCTIONS 9 10 '1 Construc-ESTIMATED COMPANY BENEFITS 12 13 14 15 16 tion Fuel PV of Per Cost Purchase PV of 1981 Equip.

$ (000) 0 Mtnc.

$ (000) 0 Pers.

$ (000) eratin 0

Adv.

(000)

Total

$ (000) 0 Total

$ (000) 'IU Customer .

0 KIUH 0

MIU System 0

G1UH 0

Savings

$ (000) 0 Savings

$ (000) 0 hitnc.

04khI

$ (000)

Pers..

$ (000) 0 Total

$ (000) 0 Total

$ (000) 0 1982 0 0 0 0 0 0 0 0 0 0 0 0 1983 0 0 0 0 0 0 0 0 0 0 0 0 1984 0 0 0 0 0 0 0 0 0 0 0 0 1985 8,635 2,898 11,533 0 0 0 0 0 0 0 0 0 1986 26,899 4,260 31>159 0 0 0 0 0 0 0 0 0, 1987 28,216 5,786 34,002 0.8 692 . 101 90 143,319 2,Z90 504 146,613 V5>212 1988 29>744 7,442 3Z,186 0.8 692 187 133 0 4,522 V98 5,320 2,484 1989 29>350 9,244 38,594 0:8 692 193 13V 154,192 5,069 877 160,138 67,899 1990 0 0 0 0.8 692 193 137 0 5,480 945 6,425 2,480 1991 0 0 0 0.8 692 193 137 0 6,028 1,014 . Z,042 2,465 1992 0 0 0 0.8- 692 193 137 0 6;576 1,082 7,658 2,443 1993 0 0 0 0.8 692 193 137 0 V,124 1,151 8,2ZS 2,400 1994 0 0 0 0.8 692 193 137 0 7,809 1,233 9,042 2,3ZS 1995 0 0 0 0.8 692 193 137 0 8,494 1,329 9,823 2,348 1996 0 0 0 0.8 692 193 137 0 9,316 1,411 '0,727 2,338 1997 0 0 0 0.8 0 193 47 0 3,4Z8 522 4,000 V92 1998 0 0 0 0.8 0 193 4 0 320 4Z 367 66 1999 0 0 0 0.8 0 193 0 0 0 0 0 0 Cumulative 74141 122 844 29,630 152,474 75 909 0.8 6 9 ZO 1'93 1 3V0 29V 511 67 006 10 913 3V5 430 163 305 Net Benefits $ (000),

From Cumulative Totals Col 16 - Col 6 87 396 Benefit/Cost Ratio From Cumulative Totals Col 16 -. Col 6 2.2 METHOD AND JUSI'll>ICA I1ON USED TO DI3I'ERhIINETIIECOST EFFL'CTIVENESS OF TIIIS PROCRAhl: (Attach additional sheets if necessary)

0 0

'C."

FPL Energy I4anage plan Revised 12/29/80 NAhIE OF UTILITY- FLORIDA I)O'lVER R LIGIITCOMPANY Docket No. 800662-EG (NC) 7 TITLE OF PROGRAM: Commercial and Industrial Time-of-Use Rate Program BRIEF DESCRIP'I'ION OF PROGRAM: FPL will propose to the FPSC that, beginning in 1981, commercial and industrial customers be placed on a phased-in, mandatory seasonal Time-of-Use (T-O-U) rate. FPL wiR provide for the installation of appropriate metering and communication equipment.

FPL will develop appropriate cost support data for the proposaL If adopted, FPL will notify customers of the mandatory seasonal T-0-U rate through Energy Information Services.

PRlhIARY PURPOSE OF PROGIIAM: Reduce demand of large commercial and industrial customers at times of FPL system peak.

COST-BENEFIT ANALYSIS YEAR ESTIMATED COhlPANY EXPENDITURE REDUCTIONS ESTIMATED COhIPANY BENEFITS 2 3 4 5 8 9 10 11 12 13 14 15 16 Construc-tion Fuel PV of Per Cost Purchase PV of 1981 Equip.

$ (000) 36, hltnc.

$ (000) 0 Pars.

$ (000) eratin 160 Adv.

(000)

Total

$ (000) 196 Total

$ (000) 178 KW Customer 0

K IVH 0

hI1U System 0

GNH 0

Savings

$ (000) 0 Savings

$ (000) 0 hltnc.

OtkM

$ (000)

Pers.

$ (000) 0 Total

$ (000) 0 Total

$ (000) 0 1982 495 182 6V'7 559 2.8 3,660 14 20 0 1,140 0 11140 1,036 1983 20 195 215 161 2.8 3,660 4Z 62 0 4,030 0 4,030 3,329 1984 21 210 231 158 2.8 3,660 49 65 0 4,810 0 4,810 3,612 1985 7 >VZ2 1,389 9,161 5,6&9 2.8 3,660 51 67 0 5,628 0 5,628 3,495 1986 27,340 2>123 29,463 16>617 2.8 3,660 119 156 0 14,9Z6 0 14,976 ~

8,446 1987 1,315 2,298 3,613 1,853 2.8 3,660 155 200 219>945 6,200 1,120 22Z,265 116,587 1988 1,407 2,486 3,&93 1,818 2.8 3,660 161 206 0 V>004 1,236 8,240 3,848 1989 1>506 21690 4,196 1>779 2.8 3>660 166 212 18,436 7,844 1,35V 2Z,63Z 11>718 1990 0 0 0 0 2.8 3,660 166 212 0 8,480 1,463 9,943 31838 1991 0 0 0 0 2.8 3,660 166 212 0 9,328 1,569 10,897 3,814 1992 0 0 0 0 2.8 0 166 192 0 9,216 1,517 10>V33 3,424 1993 0 0 0 0 2.8 =

0 166 150 0 7,800 1,260 9,060 2,627 1994 0 0 0 .0 2.8 0 166 147 0 8,379 1,323 9,702 2,552 1995 0 0 0 "0 2.8 0 166 145 0 8,990 1,40Z 10>39'7 . 2>485 1996 0 0 0 .0 2.8 0 166 56 0 3,808 577 4,385 956 1997 0 0 0 0 2.8 0 166 12 0 888 133 11021 202 1998 0 0 0 0 2.8 0 166 6 0 480 71 551 99 1999 0 0 0 0 2.8 0 166 0 0 0 0 0 0 Cumulative Total 39 912 ll 733 51,645 20 012 2.8 36 660 166 2 120 230.301 109 001 13 033 360 415 172 060 Net Benefits $ (000)

From Cumulative Totals Col 16 - Col 6 443 256 Benefit/Cost Ratio From Cumulative Totals Col 16 . Col 6 6.0 hlETIIOD AND JUSTIFICATION USED TO DETERMINE TIIE COST EFFECTIVENESS OF TIIIS PROGRAM: (Attach additional sheets if necessary) 4, ) N 4 <<4 4 ~

4,'4 ~ ~ 4 a ' a a 4 9' 14 a )\ 9 ~ p 9; 4

~

(~ PPL Energy Hanagi~nt Plan Revised 12/29/80 NAME OF UTII.ITY - FI.ORIDA POIVER 4k LIGHT COMPANY Docket No. 800662-EG (HC)

TITLE OF PROGRAhl: Commercial and hidustrinl F

Curtailable Rate Program BRIEF DESCRIPTION OF PROGRAhl: FPL will propose to the FPSC that, beginning in 1981, commercial and industrial customers who allow their usage to be curtailed for a specified number of occurrences and hours will receive a rate incentive. This will be a revision to the current rate schedule.

FPI, will provide for installation of approprinte metering and communication equipment. FPL will develop appropriate cost support data for the proposal. If adopted, FPI will notify potential customers of the offer through Energy Information Services.

PRIMARY PU RPOSE OF PROG RAhl: Reduce firm demand of large commercial and industrial customers at times of FPL system'peak.

COS'I'-BENEFIT ANALYSIS YEAR ESTlh1ATED COhlPAN Y EXPENDITURES REDUCTIONS ESTlhlATED COMPANY BENEFITS 2 3 4 5 8 9 10 "

11 , 12 13 14 -

15 16 Construc-tion Fuel PV of Per Cost Purchase PV of 1981 Equip.

$ (000) 1 eratin hltnc.

$ (000) 0 Pers.

$ (000) 1,544 Adv.

$ (000)

Total

$ (000) 1,545 Total

$ (000) 1,404 Customer K 17 0

K1UH 0

ii117 System 0

GWH 0

Savings

$ (000) 0 Savings

$ (000) 0 h1tnc.

M

$ (000) 07k Pars.

$ (000) 0 Total

$ (000) 0 Total

$ (000) 0 1982 0 5,048 5,048 4,1ZO 850 0 151 0 0 0 0 0 0 1983 0 5,5Z9 5,579 4,190 850 0 156 0 0 0 0 0 0 1984 0 6>159 6,159 4,207 850 0 161 0 0 0 0 0 0 1985 0 6,835 6,835 4,245 850 0 167 0 0 0 0 0 0 1986 0 V,574 Z,SZ4 4,272 850 0 1V3 0 0 0 0 0 0 19&Z 0 8,384 8,384 4>301 850 0 179 0 254,001 0 0 254>001 130,303 1988 0 9,220 9,220 4,306 850 0 184 0 0 0 0 0 0 1989 0 10,020 10,020 4>248 850 0 190 0 18,436 0 0. 18,436 7,81Z 1990 0 0 0 0 850 0 190 0 0 0 0 0 0 1991 1992 0

0 0

0 0"

0 0

0 0

850 85D 850" 0

0 '90 190 0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

1993 0 0 0 0 19D 1994 0 0 0 0 &50 0 190 0 0 0 0 0 0 1995 0 0 0 0 850 =0 190 0 0 0 0 0 0 1996 0 0 0 0 850 0 190 0 0 0 0 0 0 1997 0 0 0 0 850 0 190 0 0 0 0 0 0 1998 0 0 0 0 850 0 190 0 0 0 0 0 0 1999 0 0 0 0 850 0 190 0 0 0 0 0 0 Cumulative Total 1 60 363 60 364 35 343 850 0 190 0 272 437 0 272 437 138 120 Net Benefits $ (000)

Prom Cumulative Totals Col 16- Co) 6 102 '177 Benefit/Cost Ratio Prom Cumulative Totals Col 16 . Col 6 3.9 h1E'I'IIOD AND JUSTIFICATION USED TO DETERhiINE THE COST EFFECTIVENESS OF THIS PROGRAM: (Attach additional sheets if necessary)

0

.0

FPL Energy Management Plan Revised I 2/29/80 Docket Ho. 800662-EG NAME OF UTILITY- FLORIDA POIUER tk LIGIITCOhlPANY (MC)

TITLE OF PROGRAM: Capacitor Bank Replacement Program BRIEF DESCltlPTIOH OF PROGRAhl: FPL will replace all high loss distribution capacitors on the system. Field locations of these older capacitors will be identified during seasonal switching of capacitors.

PRlhlARY PURPOSE OF PROGRAM: Reduce system losses in both demand and energy by replacing high loss capacitors.

COST-BENEFIT ANAI.YSIS YEAR ESTlhlATED COhIPANY EXPENDITURES REDUCTIONS ESTIMATED COMPANY BENEFITS 3 4 5 6 8 9 10 II, 12 13 14 15 16 Construc-tion Fuel PVof Per Cost Purchase PV of 1981 Equip.

$ (000) 413 hltnc.

$ (000) 0 Pers.

$ (000) eratin Adv.

$ (000)

Total

$ (000) 413 Total

$ (000) 375 Customer KW 0

KIUH 0

MW System 0

GIVII 1

Savings

$ (000) 0 Savings

$ (000) 50 Mtnc.

04kM

$ (000)

Pers.

$ (000) 0 Total

$ (000) 50 Total

$ (000) 45 1982 883 883 'l29 4.0 21,024 1 5 0 285 0 285 235 1983 944 944 V09 4.0 21,024 2 10 0 650 0 650 488 1984 1,053 19053 719 4.0 21,024 3 "15 0 1,110 0 1,110 758 1985 0 0 0 4.0 21,024 3 18 0 1,512 0 1,512 939 1986 0 0 0 4.0 21,024 3 18 0 1, '728 0 11728 975

.198V 0 0 0 4 ' 21,024 3 18 25,54'2 558 101 26,201 13,441 1988 0 0 0 4.0 21,024 3 18 0 612 108 V20 336 1989 0 0 0 4.0 21,024 3 18 0 666 115 781 331 1990 0 0 0 4.0 21,024 3 18 0 720 124 844= 326 1991 0 0 .0 4.0 213024 3 1V 0 74S 126 874 306 1992 0 0 0 4.0 . 0 3 13 ~

0 624 103 727 232 1993 0 0 0 4.0 0 3 8 0 416 67 483 140 1994 0 0 0 40 0 3 3 0 171 27 198 52 1995 0 0 0 4.0 0 3 0 0 0 0 0 0 1996 0 0 0 4.0 0 3 0 0 0 0 0 0 1997 0 0 0 4.0 0 3 0 0 0 0 0 0 1998 0 0- 0 4.0 0 3 0 0 0 0 0 0 1999 0 0 0 4.0 0 3 0 0 0 0 0 0 Cumulative 24464 3 293 3,293 2,532 4.0 210 240 3 190 25 542 9 950 V71 36 163 10 604 Net Benefits $ (000)

From Cumulative Totals Col 16- Col 6 '6 012 Benefit/Cost Ratio From Cumulative Totals Col 16 . Col 6 hiETIIOD AND JUS'I'IFICATION USED TO DETERMINE TII E COST EFFECTIVENESS OF TIIIS PROGRAhl: (Attach additional sheets if necessary)