ML19289E963
| ML19289E963 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/20/1979 |
| From: | Sinclair M GREAT LAKES ENERGY ALLIANCE |
| To: | |
| References | |
| NUDOCS 7905290691 | |
| Download: ML19289E963 (19) | |
Text
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C */ h b a NRC PUBLIC DOCIDENT ROOM ,c7 g > r%
i e s.f Et UNITED STATES OF ASIERIC A g [+ #
NUCLEAR REGULATORY COSI311SSION BEFORE THE ATOAIIC SAFETY AND LICENSING BOARD / ;G In the SIatter of )
CONSUSIERS POWER COAIPANY Docket No.50-255SP
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(Palisades Nuclear Plant) )
GREAT LAKES ENERGY ALLIANCE RESPONSE TO CONSUSIERS POWER CO., NBC STAFF AND NRC LICENSING BOARD We wish to respond to the questions raised by the NRC Staff, Consumers Power Company and the NBC Licensing Board as to the validity of our position in petitioning to intervene in the hearing dealing with steam generator replacemc at at the Palisades Nuclear Plant.
The whole purpose of a hearing is to make sure that all of the facts of a particular action involving a nuclear facility are made known to the Licensing Board and ultimately the Nuclear Regulatory Commission.
We will provide documentary proof that the Licensing Board cannot depend on either the NRC Staff or Consumers Power Company to provide them with all the facts they need to have to make a determination.
This proof is the result of a number of licensing actious in the past in which the NBC Staff and Consumers Power Company have been involved in which only the citi::en intervenors brought into the record very important facts about which the NRC Licensing Board and the public needed to be informed.
The following is a chronicle of a series of these kinds of events that we are able to document:
- 1) In the suspension hearings of the TIidland Case in 1976-77, Consumers Power Company attorneys deliberately attempted to conceal important facts and new developments in the Slidland Case that were essential for the Board to consider.
7905290691 "'4 s j[M G M
As a consequence, the NRC Appeals Board has reopened the construction license pro-ceedings of the Midland Case to consider the reprehensible conduct of Consumers attorneys in that action which should, in fact, call for their disbarrment. (Notice of Pre-Hearing Conference, April 9,1979 - Bemand Proceeding - Docket Nos. 50-329 CP; 50-330)
In preparation for the suspension hearings in 1977, Consumers Power Company attempted to conceal the fact that the management of the Dow Chemical Company had serious misgivings about linking the operation of the SIidland Division of Dow to the Slidland n-plants which were being built by that utility. The threat of a $600 million law suit by Consumers Power Company against Dow Chemical Company was the major reason why Dow Chemical has stayed with the contract, according to the sworn testi-mony of Paul Oreffice, President of the Dow Chemical Company. The attorneys for Consumers Fower Company also asked to manipulate and edit the testimony of Joseph Temple, manager of the Michigan Division of Dow, to make it appear that he still favored the n-plant connection. The Appileant's attorneys also asked Dow to send witnesses to the hearings who did not know the changed attitude of Dow's top manage-ment toward the Midland n-plants. This Dow Chemical refused to do. They sent in their key management people, Joseph Temple and Paul Oreffice, to provide sworn testimony for Dow.
Furthermore, Consumers Power Company assumed that the Intervenors' attorney would not appear because of lack of funds, and that without cross-examination and discovery, Consumers Power would be able to " finesse" the Dow-Consumers dis-pute and prevent the Licensing Board from finding out about it. (These facts are described in attached Exhibit I.)
Joseph Temple had, as a matter of fact, decided that the n-plants would be
" disadvantageous" not only to the Midland Division of Dow, but to their employees and the community. (See Exhibit II.) The Company had secured a consultant's report indicating that for $350,000,000, Dow could build their own coal-fired plants that would supply all their needs for steam and power and meet all air pollution controls.
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It should be made clear that the NBC Staff was privy to all these developments prior to the suspension hearings through discovery, but made no effort to get the in-formation to the Licensing Board. Those attorneys should also be disbarred for fail-ing in their primary professional duty, to get all the important facts before the Board and on the public record.
- 2) In the Palisades construction hearing, the grave quality control defects Attorney for Intervenors, in the construction of that plant were brought out only by SIyron Cherry,/who introduced the log of Combustion Engineering, one of the contractors at the n-plant. In that log, Combustten Engineering detailed the short-cuts and sloppy work of Bechtel Corpora-tion in the construction of that plant. They did this to protect themselves. Palisades has had serious operational difficulties and has operated at only 44?o capacity since it began in 1972 All the contractors were subsequently sued for a huge sum ($300 million).
Consumers Power Company charged them with negligence and installing defective equip-ment. Consumers recently settled for a fraction of that amount. This is a fact that citizen ratepayers do not view as in their best interests since this money should have been remitted to ratepayers who are bearing the costs of poor quality control in the construction of Palisades and a substantial share of the costs of power that must be purchased.
- 3) In the 3Iidland Case, neither the NRC Staff nor Consumers Power company told the Licensing Board of the failure of the six pilot ECCS tests in Idaho in the win-ter of 1970-71. The record shows that Styron Cherry, Attorney for the Intervenors, made that fact known to the Board in his efforts to pursue the safety questions of the SIidland n-plants.
- 4) In 1972, whan the Palisades n-plant first went on line, Consumers Power Company could not make their rad waste holding tanks to work at all. They released the rad waste to the biosphere and continued operation. They not only did not disclose this to the NRC Regulatory Staff, but lied about it to them and claimed that they had always been able to stay within their licensing requirements. (Exhibit III.)
These facts show that the Licensing Board cannot rely on either Consumers Power Company or the NRC Staff to disclose the important facts that will be develop-n s' h
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k ing in the steam generator replacement at Palisades.
The NRC has called steam generator degradation' a serious, unresolved nuclear safety problem requiring the' highest priority effort for resolution. (Letter of March 2,1979, to S. Howell from D. G. Eisenhut.)
The people in the vicinity who are bearing the risks and who belong to groups that are a part of the coalition of the Great Lakes Enargy Alliance and.are deeply concerned about the safety problems at the Palisades n-plant include:
Catherine Benner Sharon Wilson 2800 S. Lake Shore Drive 1221 Lane Drive St. Joseph, Michigan 49085 ,
St. Joseph, Michigan 49085 Paul Gillespie Frank Lahr 407 North St. Dunham Ave.
St. Joseph, Michigan 49085 Stevensville, Mi::higan 49127 Joe & Marge Hartwig Elinor Morloch 1226 Riverwood Terrace 700 Rosehill Ed.
St. Joseph, Michigan 49085 Berrien Springs, Michigan 49103 We are deeply distressed that citizens whose lives and property are at risk have no funds to pursue issues of the magnitude that are clearly a part of nuclear power development. Our lack of funds for attorneys and expert witnesses will.make it I
difficult to provide the kind of record that the Licensing Board should have. But tvith-out citizen intervention, we have proved that the Licensing Board may not secure any of the pertinent facts that they should have, but b.ay,in fact,be provided with delibarately false information, as the previous actions of Consumers Power Company and the NRC Staff indicate in the instances we have described.
/
Respectfully submitted,
/ w d} i e Mary Sinclair, Vice President Great Lake / Energy Alliance Dated at Midland, Michigan April 20, 1979 anr1 3 i VJC 3's50
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, N UNITED STATES OF AMERICA j [' ,1 <7 6 g'\S,p g NUCLEAR R EGULATORY COSI3IISSION e,
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In the Matter of ) M'/g!
CONSUMERS POWER COMPANY Docket No.50-255SP
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(Palisades Nuclear Plant) j)
CERTIFICATE OF SERVICE y
I hekeby certify that copies of "GR EAT LAKES ENERGY ALLIANCE RESPONSE TO CONSUMERS POWER CO., NRC STAFF AND NRC LICENSING BOARD" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 20th day of April.,1970:
Charles Bechhoefer, Esq., Chairman Michael I. Miller, Esq.
Atomic Safety and Licensing Board Panel Martha E. Gibbs, Esq.
U.S. Nuclear Regulatory Commission Isham, Lincoln and Beale
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Washington, DC 20555 One First National Plaza Suite 4200 Chicago, Illinois 60603 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 MARY SINCTl\IR, Vice President, Great Lake 8 Energy Alliance p f'* % OC "
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@7- JJ oT 2 Nk/ Y MEETING 11ITH CONSITHERS P0i!EP., SEPTEM3ER 21,1976 AT 1:30 g i,e 0 Y Present Oh T ,x\h ; -
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Consu=ers: 1. Judd Bacor. Dow: 1. Lee Nute V f.W c.1
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Rex Renfro James Falahee 2.
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Jim Hanes Al Klocparen nO f */Y cq. ,
N Hearings called by Licensing Board. mi\ $
I. A. - Brief to be filed Sc.ptember 29. Brief shall be on the issue of suspension of the construction permit while all the remanded Midland issues are being concidered in an evidentia:y hearing. Parties shall include cc:ments on the timing of the hearing on the = aries, discovery and the length of time estimated for the hearing.
B. Hearing on issue of suspension pending hearing on =erits - October 6,
, nd 8 - issue being heard will be suspension of per=it pending resolution of substantive issues. Written direct testi=ony shall be filed prior to the hearing and witnesses shall be made availabla for cross-enamination.
Similar to MPSC proceedings.
Consumers said that the best way to explain the importance of the suspension hearing and the issues to be covered there was to talk first about the hearing on the substantive issues or " big neatg. .*
II. A. Issues to be covered at the substantive hearing (5).
- 1. ACRS issues - primarily e afety issues - so=e'have been resolved since 1972, others mest be provei up in hearing - there are 16 "other" matters to be considered, seme of which will require expert tes timony -
no " lightening rod" issues here that are currently being hotly contested in other hearings.
- 2. Enerdy conservation - not a big issue - se a Diablo Caey3 and Niacra Mohawk (AEC-NRC cases) - Consumers not overly concerned about this particular issue - claim they are loaded for ' sear - =ay ne ed so=a Dow input on electric conservation by Dow since 1972, which, although showing lessened demand, will still show need for electricity b; Dow -
(current contract 300 =egaaatts).
- 3. Chanced circumstances in contract trich Des; - won' t be an inquirf limited just to the contract change (1974) allevi:;g Dow to con:inue to
]l back to the original cost /benefi:runanalysis its pcwer houses afccr the nuclear plan: cc e:. on which :.ncluded shut:ing dot. t y Dov's power houses as one of :he factors in cos:/benefi: - have to talk about condi: ions between Dow and Consu=ers as : hey are today - Con::u=ers claims this can' t be covered by a Consucers -i: ness - has to be covered gaDowwitness-Dow (Hanes) asked if that meant. Dow's intent mnrn 9C7 VJC LJL r\f~ f GI)
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.W # J b] 1 or the current factual situation - Consumers replied "both" - Consu=ers asked what Dow planned to use for back-up (1,000,000 lbs. /hr.) - Dow really didn' t answer - Consumers said thi- too will be a part of the cost / benefit analysis, particularly if different than package boilers included in original cost / benefit analysis - Consumers said main issue is "Does Dow really need the steam."
- 4. Cost / benefit analysis - c:ostly covered above - Consumers said question is "Miat is Dow's position on steam? On electricity?" "b'ha t
- is Dow's current position?"' Consumers said a Dow witness will be needed to testify on this - Dow referred Consumers to the contract negotiations, including Temple's June 30 letter.
- 5. Other unaddressed fuel evele issues - transportation of radio-active vastes - also, site storage of nuclear wastes - these =ust be considered.
B. Factors to be considered in suspension hearing (5) - Consu=ers assumes Cherry will not appear because of lack of funds - Consu=crs says suspension hearing cost critical - they believe that since there is no discovery, and probably no intervenor cross-examination - vill be able to finesse ')ow-Consu=ers continuing dispute.
'l. Significant adverse effect in environment - Consu=ers believes interim rule will allow further licensing - neither interis rule nor final rule will affect Midland construction - Consu=ers must prepare two ~
Cases.
- a. Until interis rule comes out - impact of suspension or non-suspension.
b ', Until final rule comes out'- impact of suspension or non-suspension.
Must consider adverse environ = ental impact of either continuing construe:1on and halting construction.
- 2. Reasonable alternatives foreclosed.- will continued construction foreclose =odification of plan: that may be ordered as a result of the fpromulgation of interis rule - Consumers said one of alternatives that
'$ may be foreclosed by continued construction is Dow generating its own steam, and this would affect configuration of Unic #1 - =aybe now is only time Dow can put in new unit. (Note: don't really understand this oint.)
- 3. Effe.ct of delav electric - Consumers must put an entirely new "need for power" case to replace that done originally - vill discuss shut-off of Canadian crude :o Bay City power house and other factors af f ecting reserves - will also have to put on testimony as :o the 300 megaust:s Dow must take under current nuclear electric contract - Dew witness will have to testify as to Dow's turent to take 300 ccgswatts -
. ill discuss increased costs to Consumers - four =onth suspension will w
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result in eight month delay and increased construction costs of $130 million (doesn't include purchased puuer) - one year suspension =eans eighteen month delay - Consu=ers said didn't have cost figures yet on one year suspension.
- 4. Eff ect of delav steam, and cost / benefit analysis tilted - Dow ecumes very 6portant because here two issues (above) can co=e together -
Rex suggested that Dow witness might be sacecne fro: Dow Chemical U.S.A.
or Corporate area who is unaware of Midland Division reco=mendation to Oref fice - this person would testify as to ef fects of further delay upon Dow - if Dow accepts division reco==endation and takes that position in suspension hearing, then construction license will be suspended for at least one year - no doubt about it - Falahee added that Consumers may hose its construction per=it entirely - Consumers said that as long as M$ construction continues, Consumers has a lever and will drag feet in Q, earing on merits - if construction stopped, intervenors have lever and will drag feet in hearing on merits - Consu=ers further pointed out that final FES (environmental statement?) states that if construction permit for Midland is cancelled, Consumers will cancel one Unit and transfer e other to Palisades - this was one of basis for issuance of construction license - Consu=ers threat - Falahee brought up the point that Dow has an obligation (Bacon interjects "Section 3") under the Ceneral Agree =ent to support Consu=ers in the licensing proceeding. Falahee said "If Dow takes this posture, Consu=ers and Dow will have a helluva legal probles" -
(Note: strong i= plication that Consu=ers would regard us in breach if we went too far in our testimony) - Hanes replied that Dow's witness would tell the truth as he honestly believed it to be, whoever the Dow. -
witness - Falahee then made naked threat that if Dow testiconv not g poortive of Consu=ers (Note: no longer just if we go too far) and
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that results in suspension or cancellation of permit, then Consumers I
g file suit for breach and include as, da= ages cos,t_oti, delay,_cosg proj ect it canceued and all da= ages resulting tres cancellation of
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proj eTt'Ti~iMEsWirreoarEble'fiEa'Ecl's1 h3rElo "Consu=ey.,s__Qanldup.tcy) .
i ~Gote: pretty damn cicse to black = ail) /
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- 5. General ooliev cencern[- main case will be jobs - jobs at site, in Midland, and affect on econo =y of Michigan - Stan Arnold of AFL-CIO will testify for Consumers.
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Above issues discussed in Consu=ers' Septe=ber 7 brief - Rex said he wanted to know Dov's position before he files his brief on Septe=ber 29 -
Nute replied that they were inconsistent, threatening - a =assive lawsuit on one hand if Dow takes hasty position, 'yet dc=anding i==ediata state =ent of position on the other - Deu replied that it would state its position as soon as able, but =ay have to go before the 3 card of Directors - Rex said he wanted an outline of Dow vitness testi=eny to use as bacis for prepping uitness on October 4 and 's - no response fre: Dcw - Dow coc=itted to get back to Rex before Septe=ber 29, one way or other.
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,.. iou.u. :.=. ,m: .: ,m MICHICAU DIVISION Sep tember 8,1976 ENTERED IICO THE PUBLIC RECORD: CONSUMERS PC,lE3'S MIDLAND UNITS 1 and 2 "DOW CONFIDENTInL NRC REARIMGy @1 $
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RE: NUCLEAR-STEAM - MIDIRID PLANT / ;c Y As we discussed Inst evening, I now have a serious concern as to whether the nuclear-project and our current contracts with Consur.ers Power Company aren't indeed in the process of becoming deterrents to our ability to assure the success-
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ful and reliable operation of the Midland riant in the future.
He declared publicly last fc11 that for planning purposes the Division was no longer considering the cos t and avail-ability of nuclear-steam to be an advantage to this location.
Since January of this year, we have been negotiating with Consumers for contract changes that would accomplish these objectives:
- 1. Reduce.to an absolute minimum our dependence upon the Consumers Power Company.
- 2.
- Gain complete freedom to generate our oun power -- in any way that we may choose. .
- 3. Gain the ability to make steam in any vay and in any quantity that we may choose.
- 4. Remove all restrictions on what we can do with the steam we purchase from Consumers Power Company.
- 5. Increase Consumers Power Company's responsibility for Dow plant shutdowns resulting from their inability to deliver contract quantities of steam.
- 6. Es tablish a timetable for the completion of key aspects of the plant and provide that Dow may termina te the s team ' contract if it becomes ap' parent tha t Consu=crs will be unable to provide s team by the end of 19 8.; .
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2- September 8, 1976 A v,erv, significant event occucred on July 21, 1376, when tae Washington D.C. Dis trict Court o f .4.ppeals remandcd to the N.R.C. the question of whether the construction license for the Midland Plant should indeed ha te been issu0d. The U.R.C. was ordered to reopen hearings on four specific ques tions -- one of which involve the disposal of nuclear-wastes and catentially imnacts all nuulcar-olants in the
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U.S.; and tnree other que'stions-tnat relate specifically to the Midland case. The N.R.C. has recons tituted the licensing board; and briefs on one initial question, regarding the disposal of nuclear-wastes , were duc in to that board yesterday.
One of the issues to be rcenamined is the cost-benefit analysis, which is based on the purchase of steam by Dow from the nuclear-plant. Consumers has always main-tained that Dov's commitment to purchase steam is critical to their retaining a valid construction license. We are -
nearly positive that we will be required, during some part of the upcoming proceedings, to state our current position; e.g., Is the nuclear-plant and nuclear-s team essential to Cow's Midland Plant? Is it advantageous? Does the evidence in 1976 de=anstrate a considerable cost advantage of nuclear over coal or oil? Is Dow's growth in Pldland dependent upon
' the availability of nuclear-steam? Will Dow continue to operate and build in Midland if nuclear-steam is not going to be available? I believe that answers to these kinds of questions are going to be required, or at the very least that we, Dow, need to have nell thought-out answers to then upon which to base our response, or responses, to ei ther a formal request from the N.R.C. or to questions from the attorney .for the intervenors -- Myron Cherry -- who is dedica.ted to stopping the Midland Maclear-Plant.
In our judgment, the July decision by the Court of Appeals has dramatically and adversely affected the odds that Consumers will complete the plant by their new, target completion-operation date. There is a new, official cost es tima te of S1,6 70M; and we are also aware that there are _,
unofficial, internal cost estimates from acch tel of $2,00 CM.
This information became kncun to us on Augus t 5th. Decisions arc being made at the present time by the M.R.C. on curious
" retro-fit" ques tions which , if adverse to Consuners, can add significantly to costs. All of this may also af fect the cos t-bene fit analysis upon which the cons truc tion license was based.
As of now, cons truc tion on the site continues . Russ Youngdahl told me on Augus t 5, 1976, this decision 13 subject to change on very r.hort no tice and could a ' mos t bc
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3- September 8, 1976 co nsidered " day-to-day . " He have had no uord from Cons umers since early Augus t on their plans for coping with the July 21st Court of Appeals decision -- or of their assessment of the situation which we believe is very fluid and very critical.
I believe that there are more unknowns for us today than perhaps at any time in the history of the Midland nuclear-project. Our deliberations here -- and my own j udgme n t --
cause me to conclude that under today's conditions and considering the history of this project, that the nuclear-project will be most likely to be disadvantageous to Dow and to the Midland Plant and to our employees in this community .
Therefore, I. recommend the following:
- 1. When we meet with Consumers on Monday, September 13, 1976, tha t we get, and then give full consideration to their analysis of the situation, to their plans and to their projections for the future. .
- 2. Using what they tell us , decide whe ther our conclusion as described in the previous paragraph is still a valid one.
- 3. If our conclusion is still a valid one, I recommend that this is an important enough issue that you, personally, call fcr a corporate review of the entire question. Such a review would be de. vcned to evaluate all aspects of
'the conclusion that we nave reached here in the Division and the potential problems that arriving at such a conclusion could cause for others.
Such a review sh'ould start as soon as possible after our session with Consumers and be ccmpleted in approximately one mon th . Until such a review is comple ted to your satisfaction, Dow should avoid taking any position. I have some ideas on questions that I think need to be addressed in this review and plan on discussing them with you next week when I know the results of'our scheduled meeting with consumers .
It is important that a minimum number of people know the Division's (my) conclusion and that those who do consider it very much "Dou confidential" because of its po ten tial impa u on the community. Please let me know if you have any gut stions. '
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'f. The testimony during a federal hear- htidiend community Consumers nucle
- construction license.
i Dy SANDRd L DICKEY 'd ,,
Y.: #.. ' fh Delly Ne-s staff writer . - 3..Ing on the Consumers'-owned nucienr, nr power in Michigan and the U.S.. and. . Dow's pr.Afem is that its aging fastil !
t . fuel planta which now penvide the{
- E' IInancially-trrgub!cd Consumert PoN .(h attle is the real-j only reason Even theDowlent Indicated thehitchigan potential legalj with the national will not, energy t{ pro.
E< er Company threatened Dow Chemical corporate stand is not firm. division power, .
,4. Cdmpany with a 1600 mit!!on lawsuit If ' from the paint.I firmed its commitment many, which to obtam statedsteam 4 according the nucicar
~opernte 3;nst 19H.
- plant is to Added Temple s written th the burdentesti.
is nn upcoming a
( - the chemgeng giant abandoned its com-t% Temple himself recommended to the'l_ under continuous review by the com- hearing with the Michigan Air Pollution
- l icorporate board of directo.rs the com t Commission (MAPC). in which the com , C lid nn 's nuc enr po er plan n er .
- s . N ' construction' .
.pany abandon nuclear power beenuse) all of its options pony open. and "Do* wlli continue 8
pnny must to Indicate keep. how it will comply --
would be dis. Temple said the company Is now "ac- with air quality standards by 19A0.
tI'i. ' 'The threat was revented Wednesday '*he concluded i itadvantageous "e Michigan Dl r1 tively to Dow. several alternative considering" Temple snid the MAPC has nilowed by JosephMichigan Division G. Temple general Jr.. who said if manager there' [tvision nnd its employes. j power sources Including a new power delays in the company's solving the air s,'f' was no chance of a Inwsuit. Dow would D . Ills conclusic.n is still the position of plant at the Michigan division. . ,qunlity problem caused by the old po"-
the Michigan 6 vision. Temple testifteel. If the nuctent plant cannot provide n 7.,er plants because of its plan to swite h
' * "go its own way" and not,use steam . and no one rom Dow U.S.A. has dis- . reliable s' upply of steam by 1984. to nucient power In 19R2. -
roduced by nuclent power to operate agreed with Im.
ts plant' ' - , Temple said. "we feel we have been dis- .
Dut the date le too smrertain. Temple r .' Temp!e testified Consumers bontd'hs ,Ilowever he said corporate board of charEed ,of our obilgations" to Con- believes. "We have been piomised n lot c r nu Ce. s P r" - sumns. .:
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of other things,(by Consumers) and it.
",'p" 7 chairman'A* II- (AI) Aymond told Dodj.tdent of'Ddw 1.f.S.A.* decided the com-j i
The two parties curreully are renego- ed and slippe.1 and slipp.d."
officiats the utility could go.hankrupt tge . pany would honor its. contract forg flating a contract for the steam. Con- has the plant is shut down permanently. .
alleSe called his conclusion that the Temp Ile. enld Aymond estimated ; Cod *. A steam Ings *!!!from the plantoffletnis, after twowhen meet-i thesumers contractclntms.Dow Ig negotlntions.
bound by a 1974 nucient plant "Is not going to be a kond 4
Cohsunte'rs per. ding the - deni for Dow" one of the most dlflicult
. ,. sume'rs potengini losses at $600 mit!!on I d But Temple said Aymond told Dow of. decialons of his enteeri And told Dow officials .Consumersdie..nvdults Th6 Edmpnny werealso threatene' tondiicted . a vas(I ficials they could get out of the contract Under quettlong by Intervenor at-would pursue any full damage from Dow. nvenue to recover .*r,eview of the nuclear project, assessing}. In 1984 unless Dow's nbandonment torney Myron Cherry. Templa sold the
- Impact of Dow's abandonment on the,. would.jeopardire the nuclear plant's decision was based on several factors:
- -The hubstantialincreases In cost of and several Dow corporate nffleers who i,.
( the plant. from $256 million to $1.67 bil- were aware Temple's confidential 8 ..
e llots since cdnstructlen blagnn. .' *" memo. . . . - *. *
- T y l- - Plumerous delays which giushtd 'Ihe. Chicago attorney. who repren-L 6ack the start-up'datt of the plant front
- sents the Saginaw Intervenors in the.
4 ' . Uit hl974-75 to 1982. ** * proceedings, sold he planned to ques t ' , ,
tion the men about factor's that led to ? ',
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- Consumers' abl!!ty to finan'ce con 5.Oreffice's rejection of Temple's recom.
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! struction of the plant 6hich "Is rgue.i- .menda tion.
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) tionable in our minds." .
- - Skyrocketing costs of nuclear. fuel.'
Ten I e se!ple'scond testimony was given during e,I IfollJay Inn _ day of hearings held at.the ,* q, , j a ~llis assessment that the level.of .
fconfidence of Constimers is "quite} D J * * - D
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h u 40 1 . '.s The henging was s'c heduled following g ,*
I('Io w."- Dow's concern of becoming totally 7e U.S. Court of Appents ruling that the .
~ dependent on Consumers for process Atomic Energy Commission (AEC).
O - steam. '
predecessor of the Fluclear Itegulator)
During Wednesday's cross 'exant
- Commisslott (f4RC' II<l not properly in-Inntion. w:frds flew among attorneys. vestignie full Impt of stucicar plant *
["
Q who.tvere reprimdnded by the pre . construction in Midland.
siding Atomic Safety and Licensing The bnste tssue is whether complete" e
h Doord (ASLD) several times. consideration was given to nuclear al.
- Cherry announced he plans to enll ternatives and whether the plant will
, sekeral more witnesses including Orel- he needed with rdcent emphasis on flee.g Aymond. Consum*ers e.t ecutive energy conservation, according to nn vice president Russell C. Youngdahl. if RC spokesman. , . ,
'N .
i i , i -e _
y,f,s. ar . , Mich:Can Avenue
$Nl1t/pth3
[ s.nc.n.
m
- ' n.. .:. s u , a Parnall P. cad
.-r"/.u c t e r//..':Croche t.t ,
r.
(-
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thrch 16, 197,,c b,Uid h,,n, O g , f Palisade: Unste Gas Systc= y ---
~- , Q., /
, fa c , s v freittt;AL, Coma c5Porects.c c o
q\,7gf,3
.- s.
s W
s >
L!':.husicr, Covert
- J.k, . * .*y, AL
) f:1< (
GS:-:cclcy, Michigan Avenue .
.c RCCaum.n, Michi Can l$ venue " ['4 .. , ,p f f,i i JESchaub, l'ichigan Avenue s.T';--
+,. .
w
_In reference to your letter to Bechtcl Corpol-ation dated thrch 9,19'/2, C$peration:
Department takes serious c>:::cption to t: o points which we hnvc not been able to reconcile in a meeting with R. C. Estu:.an and J. R. Schaub.
tates The ite:n on the wa:tc gas decay tank inlet and outlet valves tt.at r.cither Uc feel a they secor.d isolaticafor are necessary valve the following nor a test connection and valve are reasons:
essary.
1.
E belic.ve thenc valves will only be necc::nible stored in the during adjacen rcfteling, tanks.
chutdown: due to radir.ticn from.ca:
Thereforc, a second v:.lve is necessary ar. a backup to insure r.
reliable method of isolation will be available from ren: cling to . . . . .
refbcling.
in
- 2. Leahace thrcuch certain valves in the sy : tem is intolerable; the case of the ou'J c valves, the result tculd be leaknce out the tack (CV-1123, locatha downs:,rcen,- i s not a ps-tight valve).
In the car:c of the inlet valves, lechnge during .::Inten:nce of relief valves (.shich ?.2: been a frequent .nair. ten .nce item in the pact) would re:sult in leakacc frc: the high-preccure part of the
'syntc:. to atco::phere. .
3 It in uccccunty to have sc c mean: of detecting w me frc= the have-syste:: to the envirerment before_ :significan:. r.r..ounts of p,c.:
been loct. Leakage to ate.osphere c .n be detected. by bi:bble ter:tc.
But leakage through 'talven ca : only be detected by a tcat connecti Obscr.ing prensure decay is not an neceptable r'athed beer.uce, by the ti=n the prcn.curc (. rop is it rge enough to .re observed, tco
. nch c..: hr.: been
- Le lost.
lens Total th:n L',; r.rtn to inr.t.rc lon- in cc..:01;.unce bot'. :..:: ce tank wit.hand dec:7 -- w -
Appendie. I limit: en rare cr.ne:.
The cced dit c,.ea i tae i:, ::u .ber 2$ on the nee 1 for a chnrcen1 filter -
, , . k n , ,: .,
. . . ..,. it 5 0:7.m n,.c m m. r.y...t ..o t .m.m. a. . . s. . c.m y fer ? O#')S . p . h ~, ..- _ . -.
.I.O I *'
a 9}; ! .* , 1* _, t
- h.] -
- **g 'Ol,
. _ ,* lp,,, ,,(.
l . ') ,, d it* ,1 g ,
, a [i;C'O; O [ .[ d ,,)
e
- . . . . , . , ,, .a. ,[ _e as
,'g g j ,f,--. -
- 1 g i , f= 1'(, p M .~.
- m YE \' ,.
,L* / =* t's' d. 1,;,0 - ,- p . ; y ,4 s
- .h 0.r/. :a ]e; 2'c.ci . Ope ra dor. .
.:U .:d E. -
'L'-:- *
. e u :-:::.e. r ., c , _ e- *.-in tank
. . h(g 9
~
D'3'Y oW o m: :4 g, g
A
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. ./ / . ~
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,.;f'3 . , . - .M.Hsueter, Parcs.11 Rd f .g j' Qes
.a. ..
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g}-( 9 .f .,7 7
- ,.g'*. .
pe, J. k ...X.ASvarts, Michigan Ave
, , vf 'g g
.,. 'C c. , March 22, 1972 l ...~..)
D* 0 .qhy. E f., 0m g.1y -r F"
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kD
- kD'l'VdA r ..
OW 'y- #
- , ' ' . .s' us.q
. ' c,7*g*iPalisades Plant
.,,.,. Vaste Gas System
', ./
y .,..
IpsTC AssAl. COAAKSf'08*00CC E
" Rafarence 1) CPCo letter to Bechtel dated 3/9/72 Mj((,.g.
cc ..l', 2) RLHaueter =emo to KASvarts dated 3/16/72
,. RChau=an, Michigan Ave CSKeeley, Michigan Ave
.- AKCrockett, Parnall Rd GBMatheny, Michigan Ave
.,1 yg#
. agram 31e site JpSchabdij:M.sn Ave z _
XarchS.6,1972.Two They areas are:of concern are still unsettled as noted in your =ess of
- 1) Whether or not two valves and a test connection should
, be added to the inlet and outlet of the gas decay tanks; and
,, . . ' *. *. 2) Whether or not the filter from the gas decay tanks (7-58) ,
should be chan6ed to the charcoal variety, .,J
- f
,/ /
. for the fc11oving reasons! We feel that the additional valves and test connectics are no,t ne'eded . .. .' . __
~
/. * , , h' .
-t], f q
'g j' L V
' ' 2. K',. . " ',I', ,g. <of'r -
, e cost of $10,000 - $20,000 is prohibitive; -
.s**
Q 2) The present valves vill be replaced by. air tip.t v dves t l'c'). .I' ag i hM weg,f "'M / '.
/ -4
.s g/., 4 A /
which vill leak with such a(,s' low frequenepthat two vdves are not justified; C
8' W A\, W si
- l ... I . . . , d. % d. u, , , ,,f.y!.3l,g,
^fLWu.u4.)e.d.d),.Ifitispostulatedthat I the first valve vould leak, the proper solution vould be to replace the valve with a better c,w. A3 j 4, )
G w.o.$,-o hr ^*y' d valve, not add another leaky valve;
~-
3d .
2.t$,Q k)[ Three new tanks ill be added so that one could easily 4.g >>y.is *g divert the gas from a leaking tank and then keep the p
- 1eaking tank out of service until the next refueling period;
- 5) There are backup val'ves downstream of the otlet valves
- 4. /' %) 4 m
presently; + W l a k. -
k '. . L
/
+jg //. / f ,' {(6)\
~"~~' 4 I -.-sre eaka.2e vill be detectable even approached; go./. N e / $%) by RE-1113
,,,,,j j' b :s M:Aab before any li=
-- -- :::r - / ~ .5m .$ Iv d : +'s += N / C"##/4C-Ajf - -
Jf.'%Jfjk[I) The relief valves are being fixed so snat 'they vill not ' '.) # ' , '-
'3
,4 3
',t.
,-b u W W.jn.,, 1eak, vill onlythus, any potential recirculate leakagenot in the system througn go to the the te.x at=o-inlet ff,. ., [* ' - ' ."; "
sphere;
-~~-)
~ ~ ~ ~ ~
ra.,/tv.la.fJ).9
.l d. d ( U .'
,,i .
. 4 ct,.:.,..:. M n f.a
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, /." 3 7, i
.... N, . . - . , . -
" N' '
- e\ r~tg'h f. , U ^
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-~
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(.
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. u .t.0 "w/.-
d c.<.u.ma ?
& D }g-}(if
.,w t. , . s qw a g,n f M,hc'ucter, Parnall P.d .
O O
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~
2 Palise. des Plant cW c .
j E' Waste C.:.4 System
.A, . p *,
March.22, 1972 1.
f ./ _,
- .y .-
. '. %es
/ -
' ' ' .. ,,,3 4, ) According to Table 11 h of the FSAR, if al the gas t p
- ,.. l. . ## 8.,4 .0 44'.54 i t 20 li=its I p7.isreleasedwthnoholdup,thepresentP.(tAppendix!
,hna h, ,, j ,s,,
.' ' J' N voulgbeexceededby2.016.* Eccognising tha
. vill *,./.orense the limits by a f tetor of(50, that 15 3
75 N *
- p/
.A- 4
' Q 3 failed fuel is 10 ti=es too high (.1.5), and that the ", g *gg/ ,y~i"dW 4 .s .
- .C4 7%,
- factor of Ig conservatists, then the entire tcnk could f*^#- y' j Me I - [a,', he. ,;,;,J,l r.2 p be '.released . . ' source { without terms andstill diffusion ter=s I * " b a=o h %n, h 7
.*1>- , , , , u A., ffV ' s .-
holdup and meet Apppndix
.h >-
[Ol X 50 X11 0 X1 C' 1.00 2 7, o WI y h(
,'..,.,;.;,,'<,,.,..i r .. -. .. -
3 , ;, 4 4 ,
- <; - . 10 N,4g%.'to G
.. . ,. j . Y, H !.*p ; ';2
',Y,.'
a '/.,*.[,..i'.
, Thus a grey deal of gas vould have to be released before any limits are exceeded so that the leaking;
.f.
- h[w ,..
. '- . . . 'i '1 ' tank could easily be taken out ot' co==iasion 5 fore
' //(/g ~ /W
,'h;....'( Fj , .
any problem evolved; . . ,, / < ~
. v.;.s -[
b ohis
~
f g" Theloss.of_ gas.from.thissystemis_an.abnor=aI_.saar*!d'p -
j
% that should not be designed for as an everyday occur-Q,er
, cm,7.: ,
.i;* ,
,t .,, .;',.d,ffn
- M r.:2.l,l10),' It appears system which vill allow for more excesa tank space S'j that a cM$
recombiner .
,( j ', .,,,M y l~ so that a tank could easily be disconnected from d -
" the system; -
. ' _ . , . , H si ',,9. . i < .'.
j , ,
.# , 11)' If one postu.lates that a tank vill leak, the double
. .- t :1 ? . . . valve test connection has only a small probability -
' ' . I , ' e '[, .f r. .> - ,., of deter =ining the source of leakage since there are
.z ,;
. other points that could be leaking; e m.- p . . . 9 t, . ,,,/ ,s.!-
, p-/
' 'T j j '/
tl /',-l .~,,l* .: ,. < 12) ,by Jia - The inlet valves Shepards.
vill be jp ydouMe Lyw_ ,,vs.lur f 4 z [ as , ,7 discussed ,,,
r
, [
- 4. ..,.
, p.. . ,
. o-
- , c , . . . '( , ,,
Although we do not agree with the above valve addition, Qgp
.ve vould not object to the Plant installing such a )
77, s -[-s..,
. ...I '"JM system in the.gr futur,[5 {.
, i. '
~
Ve feel that 7-58Fahou..d '
,no,t be changed to a charcoal filter for i
. ., , ' - [,. e"the following reascns:
. .' '* [ $ 1)., The Plant is presently experiencing a vater problem b b ns, k:
. "I J.D U ' . vith F-58 that should be resolved before any other kjii( Sg w,, / .7i.,, '
- - Y changes are made; c,;,% egg j ,- '
g;y gN j.i 2)- A third co: pressor is being added to the system to c
N L..s b. $,t.g,' '
,- ,, increase
~~
.[o't b~e'oypassed; its reliability so that the decay tanks vill ^')F' 7
, .,f.
- 3) In the event the tanks are bypassed, ve vould be
' L "r '*
..t S4W g
- : 4 . experiencing an abnor=al or accident condition which t r ^'L
.' f ,' ' is discusacd as accident 3 of the envirennental repcrt. , oJG d3I
.v p . A Vo do not vich to design for poten:ial trivi.1 acciden Q
/ f M 6 (L" J i,f,.g, ,g, 4 ,/ 4*
~-
-p -
/)
't t4 / ;l, , , , f ,7' .: .' * . . t - .f /
p,u,44_%hgvj ei, k ,(,,,2, j,, s-
' , , k t i . ) / n. e's ( . gg ., ,.)7lgc g , 1].
w
.). f f. ,') l ' *
,, E,~/s s s h o . . y AA et .e r . 7/ -4 y . . .
. f * ,. g ' %* 0 . L .-* r f, L.,,ly \rC) .*
p ,/- ,I'. r J- c'-t. fh M' '
- C:w:ter, F:.rr.all Rd 3
'P.1 h.ci n .' h..
y ; Vssta c.u System -
. .-'f M rch 22t .1972
.,'_. > . . g. .,
y .. > n . . . ,.
~ ~ '
; g , e. .>..h) .If the canks vere bypassed, the a=ount of iodine that..
t
.c,,g,'T;.* *T vould be released is very questionn' ole. Experience ),.] g b,,,
. ','. 4 '. . , . 5, and =ost calculations indicate that essentially no S ,}w l '*. .'.; iodine vould be released; n ,a- s- q l,;. -e. ,.
r..%
- M
~
y 8
. , , 'f. -;,$
".'.".* W' $ ' 5 ) The eventual outco=e of Appendix I iodine li=its are ej CbCli.
i -% t . i ,. questionable and hopefully willcc.,pa be reduced [ og [-/./from the present suggestions; Oo'qf - Co(%/O*# #
/ w y gN) Even if Appendix I is upheld as is, and we then bypass
. t.
W }U the tanks, it is questionable that a charcoal filter vill be a manditory re u h,w, (, M/ Tkty 'ptw hR.wtyv% u,c=ent on acp,,d. eccsth: 1 plants h u ;hea fc hWf,f cfu.u:. 5 3g* i / o ,-'.
* . 'j 37) We do not vish to design and accordingly backfit to it
,[L ,0.e-tjpotential future regulations; Y^8' D g'p-
.> t r
' . . . y.,' 6,. : zs. ~E N , ~8 ) If it becomes manditory in the future to install a .<
, . , , . .s,:
' h. .'
- J,
- charecal filter in place of F-53, we vill then re '
%lgh( .
- p.1t[p.-[..Ievaluateourposition. .
f kee. A.d L:f4
'g; .QY'.A d o..afs .u l-lJ k.<j! @,,5 -
- {;. }.jf~ . . ,[g'on.~.c.
w .:.,. ; ,, ,. , ,
.,n, - . - .
1$.CbMadPm cm -
' ? % E&.$nd su, ;
g " f.W' A W d /Now=
+ c@%44 gwg . .. , . . ., .
r Swey4J4
. W.:.. . '., . -
,y .
,.v. w .rr. a .. p . . .
s C t/;g, ,
. 61 0 .
1, . . i,, .
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s:th. W , y .. - . 3 > .
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['(]((3[!((j(,j'S Int;an.let / f fao* Fij','!0f
-['O-D*Tc April 30, 1972 11 L, O !ilTd..,j.
i a Sun.tcer \!a::tc ~as Systcm; lu t c nia 4t cc, ant:, eor,:ct cc rnlicaden Plant. cc llL!!aueter D] }{D ( [ JM Sinpron Attached for your information is a copy of the recent memo fro:n K.A. St: arts to P..L. liauctcr on the Gas !?aste .Systen with plant staff con =ents.* vc You must be nuarc of the fact that althcuch our licenge :t.nte vc have in uni hold un nll radioactive nn::ce fo: a ninimum period " of 7 day , fact not been able to meet this rcouirccent to de t.c. Co.mpliance vill certain1/ borc in on thl: aren in the near future with a:: a minicun a slap on the urist citation fo.r the record. I?c are in doen trm:blcJ.,nd th'c socncr c:.gineering and llechtel admit:: it the socncr uc can find a solution. .
- I i i.
* = D:hibit 2 .
'i' h. , t t . .: . ;.cidt., c.f v.h:4 t ha, icTd th 3 MC; sec p .p'. 2 of Fxhibi . !.
. e nm-2+B- .
G
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- 1
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~
g..#* t g e l
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- b. ;mp;m Q.y- at yr o.iq
.._ ./,
t 17700- '00 Gonoint Orticess 212 West p.tienigan Avenue.Jackm s. htscii gen 49201. Arou coco : January 26, 1973
' 6 . -
o . .. a Re: Docket No 50-255
'Mr. Boyce H. Grier Licence no DP?.-20 United States Ato:aic Enercy .
Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Grier:
Your letter of Dece: bcr 21, 1972 stated that the Pe.licades Plant was in noncompliance with AEC requirc:::ents; namely, that 630-f ecus vaste may have been discharged directly to the stack for a period i of several months which exceeds the allovabic time for discharge of the This letter vill apprise i vaste gas surge tanh .rectly to the stack. yntera
, au of the action that has been taken to it:' prove the vaste cas s l puforaance such that the requirements of Articic 3.917 of the Techni-cal Specificat'icas can consistently be adhered to.
During the early operation of the Palisc. des Plant (January and February 1972), evaluation of the perfoma .ce of the vaste cas system was difficult because of excessive ga:: cellect. ion fron'sycte:.u ' the regt' iring the use of cover caccc as During voll as Cas collection this ti:.e, it was difficultfrc nany plant start-ups and shutdowns. to achieve the required ::cven-day holdup time in the decay tanks a: d , in addition, it vac suspected thet the decay tank relief valves vere leching. The relief valve in-t:.llatien was nodified to provie ease of naintenance and the relief valvea vere reset r.nd lapped. /dso during this period, the excessive cas collection proble:a was reduced sc=cvhat. Followinc the work on the relief vn]ves,InitApril vac concluded 3972, that leakage still e;.isted froa the decay tank:.. all ninc decay tenk isolt. tion valves were recoved, reworked and re-inst.alled in en atte.v.t to stop the Ica%cce. During May and Jtac 1972, valve packings ucre centinuous.ly be:na reworked to prevent let.::n a: c ,c.nN ri-Cas colicetion rc.tes were still excessive, but not as Great cnced early in the year. Even ::c, redioactive ncis collecticu enly represented en esticated 2GT, of the cc.ses we ucru trying to hold up. The total C:seous activity released during the first half of 1972 was very lov. o:
.~ .
I hf,' } {.o a Y D, s .
e Mr. Eoyce n. ut as:r .n e;n - m >,,.Q[
, January 26, 1973 D h &u
} eo ,1 k f
/ . By July, ve.lve led:at;c pr c. blues were again beginning to reduce holdup times. Continuous valve nair.tenance made no cicnificant improve-monts in decay tank holdup perfo::.an . . "II" c tamp diaphrar,m valvc: verc
. placed on order to replace the pri en .ly inctalled inlet, outlet and drain valves on cach of the three decry tanks; howcVer, due to the "!!"
stenp, delivery is not expceted ut.til February of 1973 Durinc Aucu t and September 1972, the execc.tive r, . . collection rate prob 1c:.c were ovex co::c; howcVer, lenhace f ec.. the decay tanha bec:::r.c vorce with valve usaCo. In October 1972, a s.?cond valv- va added on the inlet, outlet and drain lines to the decay tan ., which resulted in 1:aproved system performance. The system leaka,;c t ended to increase with time and usage of these valves. During December 1972, ceva valyco of a type used in natural gas systems vere acquired and innt.n21' !. Thic han minimited the gas leakanc to a point where the vaate c.n cystem is operating fully in accordance with Technical Sp:cifict.t kr requircrhents. At the firct opportunity following receipr. of the c.i aphrec,:a type valves , they vill be installed. This vill p ovido additiinal reliability with respect to decay tank holdup time:.. . In sumnary, va tc can nyntem perfor ::ancc van ::arcinal through-out meet of 1972. There vere inntt.t een when dec:y tanks have not been held up for the required ";cn day: :r tu~leahn,c; however, the nc- _joritv of the tir.e . the ' < ven-dn. hr ' ' n recoi re: ent ha: been achieved. In additi on . ve have neve r <!.4 ibo. : t .. i*.~;;3cd the decay tani:, to dicehar.r e directly to the r t.a.ck fo r . m . e_, i of r., renter than seven days . Throu.hout 1972, the activ; tis.: o f c.4 ." . ri 1canad have aivay:, been low cnd well within release limiu . It is significent to note th .t there verc originally ninc
' valves accociated directly uith ti. c. : ca., t...:/; . The efforts to re-duce the led: ace ratee, of canna ir : th. t. d.s have re:ulted in lo additional valves being instal h c. .?c .r cor.fi dent that the:e efforts have inproved the va:tc t as ab t ' n:n 1 :. ' in vill allow full com-pliance with all Techni Spec i li e st toi. r.qutrements.
l'ourc .c:y truly, b.f,..%..., G PSS/d b Ralph i.. "11
!!ucica ,.c 1:in;. Administra;.or J052-2 .
n m JLL
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