ML19322C486

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Transcript of Prepared Testimony & Supporting Data Re Facility Design & Const
ML19322C486
Person / Time
Site: Diablo Canyon, Crane  Pacific Gas & Electric icon.png
Issue date: 06/06/1979
From: Brand D
PACIFIC GAS & ELECTRIC CO.
To:
References
TASK-TF, TASK-TMR NUDOCS 8001170815
Download: ML19322C486 (45)


Text

.

Applic: tion No.

Exhibit No-Date -

O Witness i

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PACIFIC GAS AND ELECTRIC COMPANY l

ELECTRIC DEPARTMENT 1

I PREPARED TESTIMONY AND SUPPORTING DATA O

DONALD A. BRAND

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PREPARED TESTIMONY OF 2

DONALD A. BRAND 3

4 Q.

Please state your name and business address.

5 A.

My nam! is Donald A.

Brand.

My business address 6

is 77 Beale Street, San Francisco, California 94106.

7 Q.

What is your position with PGandE?

8 A.

I am Vice President - General Construction.

9 Q.

What is your background?

10 A.

I am a registered nuclear engineer.

I received 11 B.S.

and M. S. degrees from Stanford University in 1

12 Mechanical Engineering.

In 1962 I joined PGandE as a

()

13 Field Engineer with the Station Construction 14 Department.

I advanced through various positions with 15 the company including a two year rotational assignment 16 in the capacity of Assistant to the Vice President -

17 General Construction.

In March of 1977, I was again 18 assigned to the Station Construction Department as a 19 Construction Superintendent where I remained until my 20 appointment as Vice Fcesident - General Construction in 21 June of 1978.

22 Q.

What is the purpose of your testimony?

l l

23 A.

My testimony covers the design, the construction, 24 and the cost of Diablo Canyor. Units 1 and 2.

I will 25 pay particular attention to the factors that were

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26 responsible for the increase in cost between the

1 original estimates and the cost as shown in this 2

application.

A number of factors, such as regulatory 3

requirements, inflation, and design changes have been 4

involved, and these will be discussed individually and 5

in detail.

6 Q.

Why did PGandE choose to build Diablo?

7 A.

To meet the power needs of the service area, 8

PGandE planned several types of generating facility 9

additions to the system -- geothermal, fossil-fueled, 10 and nuclear.

The largest of these additions were to be 11 the Diablo Canyon Nuclear Units 1 and 2.

The Company 12 chose to construct a nuclear power plant at Diablo 13 Canyon instead of a large fossil-fueled plant because, 14 among other things, nuclear power was more economical 15 and, by using nuclear power, fossil fuel resources 16 would be conserved.

17 Q.

What were the economic advantages of nuclear power 18 compared to a fossil-fueled unit?

19 A.

During the planning stages of the Diablo Canyon 20 project, nuclear and fossil-fueled units were compared.

21 In filings with the California Public Utilities 22 Commission in 1966 for Unit 1, fossil-fueled cost of 23 power was about 5.18 mills /kwh or 20% higher in cost l

24 than nuclear-fueled power.

This was based on an l

25 equivalent-output fossil-fueled plant burning 80% gas 26 at a cost of $2.01 per equivalent barrel and 20% oil at h

NA 1

a cost of $2.25 per barrel, operating at an 80% to 90%

2 capacity factor.

The 1968 application with the CPUC 3

for Unit 2 showed similar relationships.

4 Q.

Has current analysis shown that Diablo Canyon 5

Units 1 and 2 still retain a cost advantage over other 6

forms of thermal generation?

7 A.

Yes.

Cost of power estimates made ir. February of 8

this year show Diablo Canyon Units 1 and 2 to be more 9

economical than other potential forms of large scale 10 generation.

The decision to build a nuclear project in 11 1966 was an economically sound one.

It remains an 12 economically sound project today.

The cost of power O

( j 13 from a fossil fuel power plant which might have been 14 built to meet 1979 power demands is significantly 1

15 higher than the Diablo Canyon cost of power.

The cost 16 of power for coal fired generation is estimated at 17 29.02 mills per kwh, 42% higher than the average cost 18 of power for Diablo Canyon Units 1 and 2 of 20.46 mills 19 per kwh.

Oil fired combined cycle generation would 20 cost 42.19 mills per kwh or 106% higher than the cost 21 of power from Diablo Canyon.

The Diablo Canyon average 22 cost of power of 20.46 mills /kwh should not be compared 23 to the 33 or 27 mills /kwh cost of power set forth in 24 the application.

The cost of power estimates used here 25 for comparison of generation types are developed for

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\\~ s' 26 engineering planning and compare costs over the life of 1

the plant and exclude the effects of general inflation.

2 The costs of power as presented in the application 3

reflect the first year of operation only and certain of 4

these costs will be different when spread over the life 5

of the plant.

These cost of power estimates reflect 6

significant cost increases for both fossil and nuclear 7

fueled power.

The cost of nuclear plant investment has 8

risen sharply.

However, the price of fossil fuels, 9

both oil and coal, have increased at an even higher 10 rate.

The increasing cost of nuclear plant investment 11 along with corresponding shortages of fossil fuels and 12 their increased cost have occurred in such a way that 13 the cost of power generated by nuclear plants has 14 always, although in varying amount, retained a cost 15 advantage over the same time period.

16 In addition to cost factors, we recognized the 17 possibility of future natural gas and oil shortages in 18 making our 1966 decision to build Diablo Canyon.

We 19 are currently facing these shortages.

The Powerplant 20 and Industrial Fuel Use Act of 1978 prohibits new 21 electric power plants which utilize natural gas or 22 petroleum as a primary source of fuel.

The use of 23 natural gas or petroleum is prohibited in some existing 24 plants prior to 1990, and, after 1990, natural gas use 25 is prohibited except under certain specific conditions.

26 Q.

Please outline the regulatory history of Diablo -

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1 Canyon t;o date?

2 A.

Many agencies of government are involved in the 3

regulation of generating stations in general and of 4

nuclear generating stations in particular.

I will 5

answer your question by mentioning particular dates and 6

administrative actions that seem to me to be the most 7

important.

A complete listing is included in 8

appendix A.

9 On December 23, 1966, PGandE filed Application 10 No. 49051 with the CPUC requesting the Commission to 11 find that the public convenience and necessity would be 12 served by the construction of Unit No. 1 at Diablo (m

Q 13 Canyon.

On February 16,

1968, the Company filed 14 Application No. 50028 requesting a similar finding for 15 Unit No. 2.

After many days of hearings in San Luis 16 Obispo and in San Francisco, the Commission granted the 17 requested certifications in its Decision No. 73278 on 18 November 7,

1967, and in Decision No. 75471 on 19 March 25, 1969.

20 On January 16

1967, the Company filed an 21 application with the Atomic Energy Conission (now the 22 Nuclear Regulatory Commission) for a construction 23 permit for Diablo Canyon Unit No. 1 and on June 28, 24 1968, filed an application for a construction permit 25 for Unit No. 2.

After meetings with the Advisory

(

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v' 26 Committee on Reactor Safeguards and hearings before the !

1 Atomic Safety and Licensing Board, the construction 2

permit for Unit No. 1 was issued on April 23, 1968, and 3

on December 9, 1970, the construction pe;mit for Unit 4

No. 2 was issued.

Many days of hearings before these 5

Boards and others on, among other things, receipt of 6

nuclear fuel, specific safety issues and environmental 7

matters have continued throughout the construction 8

period.

The most recent series of hearings, which 9

consumed 33 days, was concluded before the Atomic 10 Safety and Licensing Board in February of this year, 11 and PGandE is awaiting the decision of this Board on 12 the issuance of operating licenses for the units.

13 Other federal agencies have also been involved 14 with the construction of Diablo Canyon.

For example, 15 the Corps of Engineers has issued a number of permits 16 generally under the Rivers and Harbors Appropriations 17 Act for the installation of facilities affecting the 18 beach and adjacent sea waters.

19 The State Lands Commission has granted permits for 20 the use of public lands, notably tidelands.

21 Various other state agencies have been involved in 22 Diablo Canyon, particularly the Department of Water 23 Resources, Parks and Recreation, Fish and Game, Harbors 24 and Watercraft, the Resources Agency, the Department of 25 Public Health, Division of Industrial Safety and the 26 California Coastal Commission.

V 1

The County of San Luis obispo has granted permits 2

for excavation and' grading for the construction of 3

Diablo Canyon and pertinent facilities.

The San Luis 4

Obispo County Air Pollution Control District has 5

granted authority to operate two auxiliary boilers at 6

the site.

7 Additional agencies have been involved in specific 8

actions but those noted above are the principal ones.

9 Q.

What were the initial cost estimates for Diablo 10 Canyon Units 1 and 2 compared with the current 11 estimates?

12 A.

The initial estimate for Diablo Canyon Unit 1, 13 prepared in the fall of 1966, was $162.3 million or 14

$150/kw of installed capacity.

The initial estimate

=15 for Diablo Canyon Unit No. 2, prepared approxmiately 16 two years later, was $157.4 million or $142/kw of 17 installed capacity.

18 These estimates were based on the best industry 19 information available at the time.

Technical data was 20 based on Indian Point Unit No. 2 (a 873 MW pressurized 21 water reactor scheduled to start construction in 1966) 22 and Burlington Station Unit No. 1 (now Salem Unit 23 No. 1, a 1040 MW pressurized water reactor scheduled to 24 start construction in 1968).

Cost information derived l

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25 from this technical data was prepared based on PGandE's

(-O 26 experience with our Humboldt Bay Unit 3 nuclear unit (a 1

1 63 MW boiling water reactor placed in service in 1962) 2 and Moss Landing Units 6 and 7 (739 MW fossil fueled 3

units placed in service in 1967 and

1968, 4

respectively).

The Moss Landing Units were about 3/4 5

the capacity of the proposed Diablo Canyon units.

6 Since we recognized that nuclear units would require 7

additional systems and be of greater complexity, the 8

$150/KW estimate for Unit 1 and $142/KW for Unit 2 was 9

deemed realistic even though the figures were 10 substantially higher than the known cost of $91/KW for 11 the Moss Landing units.

12 Both estimates were revised in May 1969 to a total 13 of $213.3 million for Unit 1 and $192.2 million for 14 Unit 2.

These estimates were based on updated industry 15 experience, more detailed design, and on the purchase 16 cost of components which had been deferred to follow 17 receipt of the AEC construction permit issued in April 18 1968.

19 The estimates were again revised in July 1971 to 20

$330 million for Unit 1 and $290 million for Unit 2.

21 This revision was based on then available detailed 22 design information.

In addition, these estimates 23 included provision for escalation during the 24 construction

period, inclusion of off-shore 25 breakwaters, increased scope of work and building 26

///

em i

sizes, uprating the nuclear steam supply systems and turbine 2

generators and revised operating dates.

3 Since 1971 many regulatory changes, plant 4

opti aization

changes, rescheduling and increased 5

escalation have caused additional cost increases.

At 6

the present time, the estimated cost to complete Diablo 7

Canyon is $907 million for Unit 1 and $736 million for 8

Unit 2.

9 Q.

Will you please list the major reasons for the 10 cost increases at Diablo Canyon subsequent to July 11 1971.

12 A.

The major reasons for the cost increases can be 13 broken down into five major categories:

14 1.

Changes to the plant due to regulatory 15 requirements.

16 2.

Changes to the plant due to plant 17 optimization (changes required to correct 18 generic problems and modifications aimed at 19 maximizing plant atailability and 20 performance.)

21 l 3.

Schedule delays which caused increased costs

,e i?ll due to the extended time period.

Included in I'3 this category are on-site items such as 24 contractors supervision, equipment, offices 25 and maintenance expense, PGandE General O

V 26 Construction and Division Payroll, guard 1

service, construction power, insurance and 2

other ongoing charges.

3 4.

Other items which include escalation, the 4

increased cost of nuclear components, the s.5 increased cost resulting from stringent 6

quality assurance requirements, labor 7

interruptions, delays caused by material 8

shortages, replacing or reworking of 9

defective materials, and cost increases of a 10 similar nature.

11 5.

General overheads which include allowance for 12 funds used during construction (AFUDC),

.3 general engineering and administrative 14 expenditures, and ad valorem taxes.

15 Q.

Please describe changes in the plant due to 16 regulatory requirements and their associated cost.

17 A.

The original plant design concepts were developed 18 in 1966 in close cooperation with the reactor vendor 19 using Indian Point Unit No. 2 and the proposed 20 Burlington Station Unit No.1 (now Salem Unit No. 1) 21 for the preliminary design basis.

22 Subsequent to granting the construction permit for 23

Diablo, the NRC issued many new regulations and 24 changes in its existing regulations.

Diablo Canyon 25 design has been continuously reviewed in light of these 26 changing requirements.

The changes resulting from this l

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1 review process have contributed to a major portion of 2

the cost increase since the original estimates.

3 The following describes some of the major areas of 4

change and their associated cost:

5 1.

Emergency Core Cooling Systems 6

In June 1971, the NRC issued a major change in 7

design criteria for nuclear power plants.

This change 8

centered around the performance criteria for the 9

emergency core cooling systems (ECCS).

These systems 10 automatically activate in the event of a loss of 11 reactor coolant and keep the reactor core covered with 12 water, thereby preventing damage to the nuclear fuel.

n 13 All plants had to demonstrate that they could comply (s_)'

14 with the new criteria.

Each nuclear steam supplier was 15 required to develop a new computer simulation model 16 acceptable to the NRC to run the new analyses.

As a 17 result of this analysis, the NSSS supplier recommended 18 that the nuclear fuel assembly design be changed from a 19 15 x 15 fuel rod array to a 17 x 17 fuel rod array to 20 provide greater heat transfer margins to meet the NRC's 21 ECCS requirements.

22 The cost impact of these changes is $1.5 million 23 for Unit 1 and $1.3 million for Unit 2.

24 2.

Pipe Break Protection 25 In response to new NRC requirements issued in (s,/

26 1972, pipe rupture restraints, pipe sleeves and 1

impingement barriers were added as a retro-fit.

These 2

devices serve to accommodate, without adverse safety 3

consequences, the effect of postulated pipe ruptures in 4

piping systems outside the reactor containment.

The 5

cost of these changes amounted to $11.3 million for 6

Unit 1 and $8.6 million for Unit 2.

7 3.

Blowdown Cleanup System 8

As a result of the issuance of appendix I 9

(Numerical Guides for Design Objectives and Limiting 10 Conditions for Operations to Meet the Criterion "As 11 Low As Practicable" for Radioactive Material in 12 Light-Water-cooled Nuclear Power Plant Effluents) to 13 10 CFR 50, a steam generator blowdown cleanup system 14 was backfitted into the plant to provide a means of 15 controlling the potential release of radioactivity to 16 the environment associated with a steam generator 17 blowdown.

This resulted in the design and installation 18 of additional pressure vessels, piping, instrumentation 19 and wiring.

The cost for adding this system was 20

$500,000 for Unit 1 and $500,000 for Unit 2.

21 4.

Hosgri Seismic Modifications 22 In 1972, PGandE became aware of an earthquake 23 fault, now known as the Hosgri Fault, off shore from 24 the plant.

Extensive evaluation by PGandE, NRC 25 consultants, and the USGS was conducted over the next 26 four years.

While evaluation by various PGandE seismic p(

1 consultants showed that the original plant design was 2

adequate to withstand any reasonably postulated ground 3

movement produced by this fault, in April 1976, PGandE 4

agreed to undertake analysis for a postulated 7.5 M 5

earthquake along the Hosgri fault.

PGandE did not and 6

still does not agree with the predicted magnitude of 7

this postulated earthquake along the Hosgri fault.

8 Nevertheless, we made the requested analysis and 9

resultant design changes in an effort to get this 10 vitally needed plant on line.

11 Early in June 1977, the company filed w1.h the NRC 12 a report, which now consists of seven volumes, 13 containing PGandE's seismic evaluation of the NRC 14 postulated Hosgri earthquake for the Diablo Canyon

~

15 units and responses to the comments of the Advisory 16 Committee on Reactor Safeguards (ACRS) consultants.

17 Analysis of the plant showed that major 18 modifications were required to the turbine generator 19 building and to piping seismic supports.

The following 20 lesser modifications were also required:

21 a.

Fuel handling building supports, containment annulus platforms, and spent fuel bridge and 22 hoists were stiffened.

b.

Outdoor tanks were braced.

23 c.

Miscellaneous NSSS System work was performed.

d.

Diesel fuel oil pipe supports were added.

24 e.

Seismic reactor trip system was added.

f.

Miscellaneous platforms were modified.

25 g.

Electrical raceways, 4.16 kw switchgear, and (V) 480 v. switchgear were upgraded.

26

///. _.

1 h.

Additional instrumentation for the steam dump was provided.

2 i.

Miscellaneous architectural work was performed.

3 4

The above changes had a significant impact on 5

design and construction costs.

The costs associated 6

with these changes for Unit 1 are $31.8 million and 7

$29.3 million for Unit 2.

8 5.

Fire Protection 9

In September 1976, the NRC staff requested that 10 the Company conduct a re-evaluation of the fire 11 protection progrcm for the Diablo Canyon units.

Late 12 in July 1977, the company filed with the NRC a 13 single-volume report on PGandE's review of the fire 14 protection system.

15 This review and subsequent requirements imposed by 16 the NRC ctaff resulted in the following modifications:

17 a.

Fire hose reels and automatic sprinklers were added.

18 b.

Seismic qualification of hose reel system and of new sprinkler systems was performed.

19 c.

Halon system for safeguards rooms was added.

d.

Smoke detectors were added.

20 e.

New fire barriers were added and existing barriers were upgraded.

21 f.

Doors in fire barriers were upgraded, g.

Ventilation systems were modified.

22 h.

Portable fire pumps were added.

i.

Electrical circuitry was fireproofed.

23 j.

Flame traps in floor drains were installed.

k.

Guard pipe for hydrogen line was added.

24 1.

Electrical supervision of fire system valves in yard loop was added.

25 m.

Dedicated safe shutdown instrumentation was provided.

26 (f

1 n.

Electrical circuits were modified.

o.

Position switches for fire dampers on 4 kv 2

switchgear were added.

3 The cost of these changes amounted to $2.4 million 4

for Unit 1 and $2.6 million for Unit 2.

5 6.

Plant Security 6

On August 24, 1978, new NRC regulations went into 7

effect relative to plant security.

On March 28, 1979, 8

the NRC staff issued its " Security Plan Evaluation 9

Report."

10 As a result, the following modifications to the 11 plant were required:

12 a.

Construction of a security br.ilding and armed 13 security force training facilities 14 b.

Enclosure of the outdoor storage tanks in 15 concrete 16 c.

Installation of additional detection aids and 17 physical barriers 18 d.

Addition of a comprehensive electronic 19 security monitoring system.

20 The cost increase due to these changes was 21

$7.7 million for Unit 1 and $5.3 million for Unit 2.

l l

22 7.

Environmental Monitoring 23 As a result of amendments to the Federal Water 24 Pollution Control Act in October 1972, a waste and heat I

25 discharge monitoring program was established at the

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In addition, extensive' studies were performed on 1

the power plant cooling water system.

A laboratory and 2

related facilities have been constructed and additional 3

personnel hired to man these facilities.

Field studies 4

are continuing.

The demonstration program requires one 5

year of field data collection under fairly consistent 6

power plant operations.

Costs for this effort N.11 7

continue to be accumulated after operation commences.

8

Also, NRC staff review of the Technical 9

Specifications has resulted in changes to the 10 meteorological and radiological monitoring programs.

11 These changes primarily consist of additional 12 facilities, instrumentation and associated circuitry.

13 Costs associated with the above changes are 14 estimated to be

$5.3 million for Unit 1 and 15

$5.1 million for Unit 2.

16 In addition to the direct cost of the above 17 changes, each of these changes had an effect on the 18 project schedule, AFUDC, and other owner costs which 19 are not included in the costs listed.

20 Q.

Were additional costs incurred due to the required 21 seismic modifications?

22 A.

Yes.

Unit 1 was essentially ready for fuel 23 loading and operation in the spring of 1976.

Due to 24 NRC concerns about a potential earthquake from the 25 Hosgri fault, licensing of the plant was suspended.

26 This delay in licensing caused a full 39 months pb 1

extension of the construction schedule.

The delay 2

added $112 million in AFUDC to the cost of the plant.

3 I have made no attempt to quantify additional indirect 4

and incidental costs such as plant maintenance and the 5

cost of replacement power during this time.

6 Q.

Did other regulatory changes affect the cost of 7

Diablo Canyon?

8 A.

Yes.

In April 1969, the NRC issued 10 CFR 50 9

appendix B, entitled " Quality Assurance Criteria for 10 Nuclear Power Plants," for public comment.

PGandE 11 immediately began developing a more comprehensive 12 quality assurance program to comply with 10 CFR 50, 13 appendix B.

It was submitted to the NRC in September 14 1969 with the application for the Unit 2 construction 15 permit.

With the issuance of the Unit 2 construction 16 permit in December 1970, PGandE began the detailed 17 implementation of this quality assurance procedure.

18 PGandE has been aware of the need for special care 19 or " Quality Assurance" from the' very outset in the 20 construction of nuclear plants.

We sponsored 21 participation in the ASME Committee on Nuclear Quality 22 Assurance and actively took part in writing and 23 developing industry standards which were issued by the 24 American National Standards Institute and endorsed by 25 the NRC in Regulation Guides.

V

-26

/// i

1 10 CFR 50 appendix B contains eighteen criteria to 2

assure the quality of the design, construction and 3

operation of nuclear power plants.

Simply stated, it 4

is a formal program to verify and document that 5

inspections, checks, and controls for every phase of 6

nuclear power plant design, manufacture, construction 7

and operation have taken place.

To comply with these 8

regulations, TGandE established a separate department 9

reporting directly to an Executive Vice President.

The 10 Engineering and Construction departments developed 11 quality control departments within their organizations.

12 Contractors and suppliers acted likewise.

13 I stress that PGandE is concerned about the 14 quality of every plant, and Diablo Canyon is no 15 exception.

We did not, however, anticipate the detail 16 in documentation and independent inspection of 17 workmanship which would be required by the NRC.

For 18

instance, simple field changes to avoid physical 19 interference between components (which would be made in 20 a conventional plant in the normal course of work) had 21 to be documented as an interference, referred to the 22 engineer for evaluation, prepared on a drawing, 23 approved, and then released to the field before the 24 change could be made.

Furthermore, the conflict had to 25 be tagged, identified and records maintained during the 26 change process.

These change processes took time (days h

O O

1 or weeks) and there were thousands of them.

In the 2

interim the construction crew must move off of this 3

piece of work, set up on another and then move back and 4

set up on the original piece of work again when the 5

nonconformance was resolved.

Installation of wire must 6

be done according to written procedure and must be 7

documented.

Every foot of nuclear safety-related wire 8

purchased is accounted for ' and its exact location in 9

the plant is recorded.

For each circuit we can tell 10 you what kind of wire was used, the names of the 11 installing crew, the reel from which it came, the 12 manufacturing test, and production history.

The O

'V 13 tension on the wire when it is pulled is recorded and 14 the tensioning device is calibrated on a periodic 15 basis.

16 None of these requirements were in existence when 17 Diablo Canyon was planned.

Hundreds of requirements 18 similar to these give us assurance of the quality of 19 the Diablo Canyon plant.

While this assurance is very 20

costly, a precise cost cannot be assigned to this 21 program.

22 Q.

What changes were required to improve plant 23 availability and reliability and what was their cost?

24 A.

Certain changes in the plant were necessary to 25 insure the best _ possible plant reliability and p

- N.

26 availability to the PGandE system.

During the early 1

design and construction stages of Diablo Canyon, other 2

utilities were gaining operating experience on similar 3

type reactor plants.

Due to the operating experience 4

of these other utilities it was apparent that there 5

were several areas where design changes would, in the 6

long run, be less costly to implement at a time prior 7

to the plant's operation.

8 The following list describes some of the major 9

areas of change to improve plant availability and 10 reliability and their associated cost:

11 1.

Reheater Drain System And Moisture Separator Reheaters 12 13 Modifications to the reheater drain system were 14 found to be necessary as a result of flooding of 15 reheater tube bundles that had been experienced at 16 other operating plants.

These changes resulted in 17 additional pressure vessels, valves, piping rerouting 18 and instrumentation.

19 Modifications to moisture separator reheaters 20 consisted of adding vent chambers for each moisture 21 separator reheater tube bundle in order to increase 22 plant reliability by eliminating tube to tube plate 23 weld failures due to thermal cycling.

24 Costs associated with these modifications are 25

$700,000 for Unit 1 and $700,000 for Unit 2.

26

/// 1

O

_s 1

2.

Additions To Make-Up Water Systems 2

As a result of steam generator tube corrosion 3

problems at operating plants, the NSSS supplier made a 4

complete change in its water quality requirements for 5

the secondary side of the plant by requiring a change 6

from phosphate to all volatile treatment of the 7

feedwater.

All volatile water treatment requires 8

extremely low levels of seawater inleakage to the 9

condenser.

In addition, the water quality requirements 10 for the make-up to the secondary side of the plant 11 became much more stringent.

All of these changes were 12 made after the condensate and make-up water systems

/

C) 13 were designed, purchased and installed.

These changes 14 resulted in the procurement of additional equipment, 15 retubing the condenser with titanium tubes, rerouting 16 of piping, and installation of instrumentation and 17 wiring changes.

18 Further changes in secondary system water quality 19 criteria has resulted in the following:

20 a.

A new ion exchanger is being added to each 21 unit to polish the seawater evaporator distillate.

22 b.

A reverse osmosis system is being provided to 23 treat Diablo creek water prior to processing it through 1

24 the existing make-up water system demineralizers.

The 25 g3, reverse osmosis system will provide a back-up when the 1

26

///

1 seawater evaporators are out of service either for 2

maintenance or when nuclear steam is not available.

3 The cost of these changes were $4.9 million 4

for Unit 1 and $2.7 million for Unit 2.

5 3.

Turbine Reblading 6

As a result of corrosion problems and turbine 7

blade failures experienced by other utilities, the 8

supplier recommended that the row L-3 low pressure 9

turbine blades be replaced with redesigned blades 10 before operating the unit.

This work was completed and 11 costs were shared by PGandE and the turbine supplier.

l 12 Approximately two years

later, the turbine 13 supplier recommended, as a result of additional 14 operating experience, that the existing L-4 row of low 15 pressure turbine blades be replaced with better 16 designed blades prior to operating the unit because of 17 stresses and resultant stress corrosion in the steeple 18 region.

The cost impact of these changes was $920,000 19 for Unit 1 and $947,000 for Unit 2.

20 4.

Additional Spare Parts j

21 As a result of operating experience gained from 22 l

other utilities and to improve the reliability and 23 availability of the Diablo Canyon units, additional 24 spare parts were purchased for the nuclear steam supply 25 system and the turbine-generator.

Some examples of 26 these spare parts are:

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(

)

<j 1

a.

Interchangeable low pressure turbine rotors 2

b.

Mechanical seals for reactor coolant pumps 3

c.

Safety injection pump and charging pump 4

rotating assemblies 5

The cost associated with these changes are 6

$16.1 million for Unit 1 and $9.5 million for Unit 2.

7 5.

Additional Storage Facilities 8

In order to optimize the storage requirements for 9

chemicals and solid wastes and to protect 10 safety-related equipment from possible

hazards, 11 chemical and gas storage vaults, radwaste storage 12 vaults and related facilities were constructed in the

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13 hill on the east side of the Auxiliary Building.

14 The cost of these changes was $1.5 million.

15 Q.

In addition to the changes and direct costs which 16 you have discussed, have additional indirect costs 17 resulted due to the timing of these changes?

18 A.

Yes.

The changes I have discussed were made after 19 construction had progressed to a significant degree.

20 In addition to the cost of the added items, there are 21 significant costs incurred due to working on or around 22 completed items.

There is the cost of the original 23 work which must be removed, and the cost of the removal 24 and/or relocation of existing equipment even though 25 that equipment has little or nothing to do with the 26 change.

There are significant inefficiencies in trying 1

to design to fit existing buildings and installed 2

components.

Work has to be done out of sequence in a 3

restricted access and work area.

Existing 4

installations are exposed to the hazards of 5

construction.

While they may be protected, some are 6

inadvertently damaged.

In the case of structural work 7

due to changes in seismic criteria, the contractor and 8

labor force had been released from the site.

This 9

factor created additional costs for the contractor as 10 well as lost production due to the need to train a 11 mostly new labor force.

12 Engineering manpower (both in-house and 13 consultants) has continually fluctuated throughout the 14 design stages for Diablo Canyon.

The Company's 15 original manpower requirements were based on our 16 experience with the Dresden, Vallecitos and Humboldt 17 Bay nuclear power plants and the first large steam 18 units at Moss Landing.

As additional analysis and 19 design changes were required to meet changing 20 regulatory requirements and to improve plant 21 reliability, the Company adjusted its manpower 22 requirements accordingly.

PGandE has attempted to 23 maintain an efficient and economical level of manpower 24 in-house.

However, engineering consultants have been l

25 used to supplement PGandE's in-house capabilities 26 during peak manpower periods.

Increased manpower N._, A 1

requirements clearly contributed to the increased cost 2

of the plant.

3 Q.

Did other items related to the actual construction 4

process cause schedule extensions and cost increases 5

above those originally planned?

6 A.

Yes.

The labor productivity level for the plant 7

was originally projected on the basis of our experience 8

in the construction of conventional fossil plants.

The 9

increased number of components and technological 10 complexities of nuclear power plant construction, 11 together with the vastly increased scope of quality 12 control with inspection documentation and audit p)

(,

13 resulted in lower levels of productivity than 14 originally estimated.

15 The availability of qualified craft labor is more 16 limited in Central California than in the Los Angeles 17 basin or the San Francisco Bay Area.

There is little 18 industry in the vicinity to attract or train skilled 19 craftsmen in heavy industry.

PGandE anticipated this 20 shortage of skilled craftsmen but not to the extent 21 that it eventually developed.

There was a heavy 22 industry construction boom in California and the 23 Western United States.

Many jobs were worked on an 24 extended work week basis in the Los Angeles and San 25 Francisco areas.

This work was closer and more

,q

(

i 26 attractive financially to the skilled craftsmen. -

1 Consequently, a shortage of skilled craftsmen was a 2

chronic problem at the Diablo Canyon site.

3 Starting in early 1971, and continuing for most of 4

the year, various construction delays and work 5

slowdowns resulted from the slow release of engineering 6

and design information.

The delays in producing 7

designs can be attributed to lack of timely information 8

on equipment and components because of the PGandE 9

policy to delay purchase of major equipment prior to 10 receipt of the construction permit, to a shortage of 11 engineering and design manpower, precipitated by an 12 underestimation of the cornplexity and difficulty in 13 nuclear plant design and to the imposition of extensive 14 and complex design check and review procedures to 15 accommodate NRC Quality Assurance regulations.

16 Labor interruptions have caused inefficiencies and 17 delays during the entire construction period.

Late in 18 1969, the Operating Engineers were on strike for two 19 months, causing a major work slowdown.

In the summer 20 of 1970, there was a two-month carpenters' strike which 21 halted carpentry and concrete work at a critical time 22 in the construction of the Diablo Canyon structures.

23 In mid-1974, major labor problems were encountered Two 24 hundred electricians stayed off the job for eight days, l

~

25 500 welders and pipefitters stayed off the job for five 26 days, and 125 carpenters and millwrights were off for m

in.

Lf 1

three days.

Finally, a series of labor disputes and 2

strikes shut down the site for essentially four months 3

starting in July 1974.

These stoppages were 4

craft-management disputes general to California and not 5

isolated to Diablo Canyon.

Since 1974, occasional site 6

labor disputes of sho'rt duration have had an impact on 7

construction progress.

Over the 10 year construction 8

period, labor disputes have contributed an estimated 9

1.5 million lost man-hours.

10 Q.

Have any other factors had a significant impact on 11 the construction schedule?

12 A.

Yes.

For example, bomb threats at the Diablo O

\\,/

13 Canyon site have had an impact on construction.

To s

14 date we have had a total of 50 bomb threats.

Each of 15 these has an impact on the construction schedule to 16 varying degrees.

In some cases, selected work areas 17 were shut down.

In others, the entire project was shut 18 down for the entire working day.

During these work 19 stoppages, workmen on the project are paid only for 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> worked.

Disruptions causing lost time result in 21 reduced paychecks.

Some of the skilled craftsmen then 22 become frustrated with the loss of work situation and 23 leave the project for more stable work conditions.

24 This loss of skilled manpower adds to the problems of 25 insufficient skilled labor already described.

-s 7

g 26

/// r,

1 Q.

Please describe the need for and the costs 2

involved in equipment maintenance during the extended 3

construction period.

4 A.

Essentially all construction for Diablo Canyen 5

Unit 1 Operating Systems was completed in late 1975.

6 Hot Functional Testing was performed in anticipation of 7

licensing and commercial operation in 1976.

Since the 8

plant did not go into operation at that time, it became 9

necessary to institute a significant plant layup and 10 maintenance program to prevent equuipment degradation.

11 This program consists of routine maintenance, 12 inspection, equipment cleaning and preservation.

13 Significant manpower is also expended to periodically 10 run equipment at near operating conditions to assure 15 that its capability has not been degraded.

Total 16 manpower dedicated to this effort has been on the order 17 of 125 full-time craft and technical people.

These 18 figures are difficult to quantify since these same 19 personnel are also involved in some new construction 20 work.

21 Major pre-operational tests are required within a 22 short time prior to initial fuel loading and operation.

23 Since the construction was thought to be completed in 24 1976 and again in 1977, these major tests, such as the 25 containment leak rate test and the hot functional test, 26 have been repeated twice.

These tests take two to four

. N

,/ y (vl 1

weeks each and require significant investment in 2

equipment, shift coverage and data logging.

3 Q.

Did the extended construction period effect our 4

dealings with private contractors working on the Diablo 5

project?

6 A.

Yes.

Most of the original construction contracts 7

for the Diablo Canyon Project were awarded as lump-sum 8

fixed price contracts.

As construction progressed, it 9

became evident that the increased scope of work was 10 such that the contractors could no longer reasonably be 11 expected to perform on a fixed price basis.

The 12 structural, electrical, air conditioning, and other C,a 13 major contractors were eventually converted to a 14 recoverable cost plus basis.

In some cases, scopes of 15 work had so significantly changed that it was necessary 16 to convert contracts to a cost plus basis for work that 17 had originally been performed under a fixed price 18 contract.

19 In today's environment of large nuclear projects 20 of long duration, it is not uncommon to have all of the 21 work awarded from the beginning on a cost plus basis.

22 This practice is done since both utilities and 23 contractors now recognize that the work scope at the 24 beginning of a nuclear project cannot be accurately es 25 defined to accommodate the seven or eight year

(

)

~'

26 construction span the industry is now facing. !

1 Q.

What other factors occurred during the period of 2

construction that contributed to the cost of the 3

project?

4 A.

Inflation or escalation has made a major S

contribution to the cost increases at Diablo Canyon.

6 As late as 1969, escalation rates used to estimate 7

Diablo Canyon costs were 2.5 percent per year for 8

materials, 3 percent per year for finished equipment, 9

and 5 percent per year for labor.

These rates were 10 based on the then current projections of PGandE's 11 Economics and Statistics Department.

12 The Nuclear Plant Construction Index and the 13 Fossil Fuel Plant Construction Index of the 14 Handy-Whitman Index for the Pacific Coast Area have 15 risen 130 and 146 percent, respectively, from January 16 1967 to July 1978.

The Engineering News Record 17 I

Construction Cost Index went up 157 percent from 18 January 1967 to January 1978, and the EBASCO Composite 19 Index of Direct Cost for Electric Generating Plants 20 rose 140 percent from January 1967 to December 1977.

21 As it actually turned out, the average rate of 22 escalation over the Diablo Canyon construction period 23 has been between eight and nine percent per year 24 compounded, about twice the rates assumed in early 25 estimates.

26

/// -

(

)

v 1

These inflation rates reflect not only inflation 2

in the general economy but an even higher inflation 3

rate for the nuclear industry in general.

Nuclear 4

component prices increased rapidly in the early 1970's 5

for two primary reasons.

Orders for equipment were 6

extremely high, overtaxing the manufacturing capability 7

of the many special supporting industries.

Also, 8

manufacturers were exposed to the same changing 9

regulatory requirements that PGandE was experiencing at 10 this time.

Increased quality control documentation, 11 special component testing, and seismic qualifications 12 are examples of costs passed on ta PGandE by equipment em I

)

13 suppliers.

14 The extended construction period also impacted the 15 cost by adding to the AFUDC required.

Not only was

'6 interest paid over a much longer period, but interest 17 lates increased from a 5 percent level to almost an 18 6 percent level in 1978.

In 1966, the Unit #1 total 19 GM estimate was $162.3 million, of which $17.5 million, 20 or 11 percent, was estimated to be AFUDC.

Of today's 21 total estimate, $309 million or 34% is AFUDC.

22 Q.

How have each of the changes you have discussed 23 affected the total cost of Diablo Canyon Units 1 and 2?

24 A.

I have identiffed many reasons for the cost 25 increases at Diablo Canyon.

Since the revised i

/

26 estimates of 1971, the cost of Diablo Canyon Unit 1 has 1

increased $577 million and Unit 2 has increased $446 2

million.

The regulatory changes account for 11.8 3

percent of the Unit 1 and 13.5 percent of the Unit 2 4

cost increases.

The changes to improve plant 5

availability and reliability account for 4.5 percent of 6

the Unit 1 and 3.6 percent of the Unit 2 cost 7

increases.

Schedule delays account for 12.5 percent of 8

the Unit 1 cost increase and 12.5 percent of the Unit 2 9

cost increase.

The cost increase due to other items is 10 17.8 percent for Unit 1 and 17.9 percent for Unit 2.

11 General overheads account for 53.4 percent of the 12 Unit 1 and 52.5 percent of the Unit 2 cost increases.

13 The costs for each of these categories is presented in 14 appendix B.

15 Q.

Have other utilities been exposed to similar 16 schedule delay and cost increases with their nuclear 17 power plants?

18 A.

Yes.

All nuclear power plants constructed during 19 this period have been exposed to schedule delays and 20 cost increases above original estimates.

These delays 21 and cost increases have occurred for many of the same 22 reasons as the Diablo Canyon increases.

Regulatory 23 changes, labor productivity, updating of designs to 24 increase reliability, material delays, and changing 25 economic conditions are not unique to Diablo Canyon or 26 to California. - - -

%v 1

Appendix C is a graphic representation of the cost 2

per kilowatt for nuclear units placed in service or 3

scheduled for operation in 1977 to 1980.

The average 4

cost of these units per killowatt net capacity ($/kW) 5 is $719/kW.

Diablo Canyon Unit 1 cost is $837/kW or 6

16% above the average.

The Diablo Canyon Unit 2 cost 7

of $665/kW is 7.5% below the average.

Considering the 8

extremely adverse cost impact of changes and schedule 9

delays due to the rostulated 7.5m Hosgri earthquake, it 10 is significant that PGandE has been able to construct 11 Diablo Canyon while maintaining cos'.s close to the 12 average of other units coming on line during the same

/

kJ 13 relative time period.

14 Q.

Do you believe that $907 million is a reasonable 15 cost for Unit No. 1 and $736 million a reasonable cost 16 for Unit No. 2?

17 A.

Yes.

In my opinion these costs are reasonable for 18 nuclear units of their size which were designed and 19 built during this period.

While the cost of the Diablo 20 Canyon units is higher than our original estimates, 21 these cost increases were due to various factors, l.

22 already described, which could not have been 23 anticipated in our original estimates.

The cost of 24 power from Diablo Canyon will be much lower than any

-,r 3 25 similar-sized fossil-fueled plant which might have been 26 constructed for 1979-1980 operation.

PGandE is 1

committed to provide safe, reliable power at the lowest 2

possible cost to our rate payers.

Diablo Canyon 3

fulfills this commitment.

4 5

6 7

8 9

10 11 12 13 14 15 16 17 18 19 20 21 l

22 23 24 25 0

26 4

_ _.=

J s.

O 4

-APPENDIX A DIABLO CANYON UNITS 1 AND 2 REGULATORY HISTORY This appendix describes the various licenses, permits and other actions which have taken place regarding the Diablo Canyon Project.

It is divided into three sections:

j I.

CALIFORNIA PUBLIC UTILITIES COMMISSION I

II.

NUCLEAR REGULATORY COMMISSION III.

OTHER FEDERAL, STATE AND LOCAL AGENCIES i

e 4

t A

i LO 1

a

-,--~,,-..,,.r-e v..

--,-y---.

-r--

r CALIFORNIA PUBLIC UTILITIES COMMISSION PGandE filed Applications Nos. 49051 and 50028 with the California Public Utilities Commission (CPUC) on December 23, 1966, and February 16, 1968, for Diablo Canyon Units 1 and 2, respectively.

In these applications, PGandE presented extensive data on the cost of power, safety factors, service reliability, and the environmental effects of the plant.

PGandE presented evidence in support of the applications through numerous witnesses, including scientists and representatives of governmental agencies, and 64 exhibits.

Those opposed to the project presented 20 witnesses and 32 exhibits.

The CPUC held a total of 20 days of public hearings on Unit 1 and 3 days of public hearings on Unit 2 from February 16 to December 12, 1968, in San Luis Obispo and San Francisco.

In Decision Nos. 73278 and

75471, dated November 7, 1967, and March 25, 1969, for Units 1 and 2, respectively, the CPUC found PGandE's requests for the two generating units to be in the public interest.

On March 22,

1971, a complaint filed against PGandE by Consumers Arise Now alleged that PGandE and others were making plans to build nuclear power plants alorg the California coastline.

It requested that the CPUC issue an immediate cease and desist order regarding planning or construction of coastal nuclear power plants.

The CPUC denied this order, striking complainant's allegations as being within the purview of the Nuclear Regulatory Commission.

In mid-1975, the Northern California Public Interest Group, Inc. petitioned the CPUC to issue a General Order requiring utilities to include, once each year, with ach customer's billing statement, instructions explaining

(

emergency steps the customer should take in the event of an incident.

This petition was also dismissed as being outside the jurisdiction of the CPUC and as being inconsistent with the provisions of the Emergency Services Act.

NUCLEAR REGULATORY COMMISSION PGandE submitted an application for a construction permit for Diablo Canyon Unit 1 on January 16, 1967.

For approximately one year, the Staff of the Atomic Energy Commission (now the NRC) scrutinized the plant, requesting and receiving additional information from PGandE.

The review culminated in a full Advisory Committee on Reactor AN]

Safeguards (ACRS) committee meeting in December 1967, an Atomic Safety and Licensing Board ( ASLB) public hearit;g in San Luis Obispo on February 20-21, 1968, and the issuance of a construction permit by the AEC on April 23, 1968.

The application for construction of Unit 2 was filed on June 28, '168.

The review progressed to a meeting of the full ACRS committee on October 10, 1969, and on January 13-14, 1970, public hearings were held by the ASLB in San Luis Obispo.

On August 7, 1970, these hearings were reopened to hear the intervenors' alleged new evidence' on geology.

Finally on December 9, 1970, the construction permit for Unit 2 was issued by the AEC.

On July 10, 1973, the application for an operating

license, the Final Safety Analysis Report (FSAR), was submitted by PGandE.

The FSAR was considered by the AEC to be incomplete.

PGandE revised it, resubmitted it on September 26, 1973, and it was docketed on October 2, 1973.

From 1973, right up to the present time, the NRC staff and its consultants and the ACRS and their consultants, have reviewed, analyzed and examined the Diablo N

Canyon design.

The extent and depth of the review in the (d

areas of seismology and geology was without precedent.

Seventy-eight amendments have been made to the FSAR, over 70 meetings were held between NRC Staff and PGandE, and countless information requests were made and answered.

In summation, ten ACRS subcommittee meetings and three full committee meetings were held, each of the latter resulting in an ACRS letter.

The last ACRS letter was issued on July 14, 1978.

The ACRS stated that it had completed its review and gave favorable recommendation for the operation of Diablo Canyon.

The NRC Staff did likewise.

\\

ASLB hearings were concluded Febraury 15, 1979.

A favorable decision regarding the safety of the Diablo Canyon Plant is expected at any time.

P G

l V

l.

DIABLO CANYON NRC LICENSING PROCEEDINGS THROUGH APRIL 1979 DOCKETS 50-275; 50-323 Application for Unit 1 CP filed January 16, 1977 ACRS subcommittee October 4, 1967 ACRS full committee October 5, 1967 ACRS full committee December 7, 1967 Public hearings on Unit 3 CP February 20-21, 1968 Decision of Atomic Safety and Licensing Board (ASLB) directing AEC to issue Unit 1 CP April 23, 1968 Application for Unit 2 CP filed June 28, 1968 ACRS subcommittee October 1, 1969 ACRS full committee October 10, 1969 Public hearings on Unit 2 CP January 13-14, 1970 Hearings reopened to hear Inter-h venors' alleged new evidence on geology August 7, 1970 Decision of ASLB directing AEC to issue Unit 2 CP December 8, 1970 Atomic Safety and Licensing Appeal Board (ALAB) affirms ASLB decision granting Unit 2 CP June 14, 1971 AEC denies Intervenors' appeal from ALAB Order July 21, 1971 AEC denies motion for reconsideration August 16, 1971 AEC Order granting Intervenors' request for hearing on supen-l sion of CP's pending NEPA review April 21, 1972 Public hearings re whether cps should be suspended pending NEPA review May; 17-20, 1972 O

O av ASLB decision permitting continued construction during NEPA review but forbidding removal of cofferdam June 5, 1972 NEPA hearing (<ait 2)

September 17-21, 1973 OL application (FSAR) for Units 1 and 2 filed September 28, 1973 ASLB decision permitting.

removal of cofferdam November 23, 1973 Reopened NEPA hearing to March 27-28, 1974 consider energy conservation April 30, May 1-2, 1974 ASLB Decision on environmental effects -(NEPA) authorizing continued effectiveness of CP for Unit 2 August 2, 1974 ACRS subcommittee September 12, 1974 ALAB affirms ASLB NEPA decision January 16, 1975 ACRS subcommittee February 18-19, 1975 ACRS subcommittee May 23, 1975

(')

ACRS full committee June 5-7, 1975

(,)

ACRS letter June 12, 1975 Public hearing on receipt of nuclear fuel for Unit 1 December 9-12, 1975 ASLB Order permitting receipt of nuclear fuel for Unit 1 December 23, 1975 AEC Order directing ALAB to hear appeal of ASLB order re receipt of fuel February 5, 1976 ACRS subcommittee May 21, 1976 ALAB decision affirming ASLB decision re receipt of nuclear fuel June 22, 1976 ACRS subcommittee June 25-26, 1976 ACRS subcommittee October 11, 1976 Further NEPA hearings Units 1 and 2 December 7-17, 1976 ALAB ruling regarding limited access to security plan June 9, 1977 ACRS subcommittee June 21-23, 1977 ACRS subcommittee August 2, 1977 ACRS full committee August 11-13, 1977

'ACRS-letter August 19, 1977 (h

V 1

ASLB hearings on remaining non-seismic safety issues other than adequacy of the security plan October 18-19, 1977 ASLB decision re NEPA issues June 12, 1978 ACRS subcommittee June 14-15, 1978 ACRS subcommittee June 21, 1978 ACRS full committee July 6-8, 1978 ACRS letter July 14, 1978 ASLB hearing December 4-23, 1978 ASLB hearing January 3-16, 1979 ASLB hearing February 7-15, 1979 0

O

rN Licenses, Permits Statutory Or Other

(,)

Agency Approvals Authority FEDERAL LICENSES, PERMITS AND APPROVALS Corps of Permit to install Section of the Rivers Engineers wave recorder and Harbors Appropriations (U.S. Army)

Act of 1899, sections 403 and 404 of title 33 of the. United States Code Permit to construct Section 10 of the Rivers breakwater and and Harbors Appropriations intake Act of 1899, sections 403 and 404 of title 33 of the United States Code Permit for barge Section 10 of the Rivers landing and Harbors Appropriation Act of 1899, sections 403 and 404 of title 33 of the United States Code Permit for Section 10 of the Rivers cofferdam, and Harbors Appropriation roads, soil Act of 1899, sections 403

N removal for and 404 of title 33 of the

/

discharge United States Code Bureau of Right-of-way for Acts of February 15, 1901 Land breakwater and (16 U.S.C. 522) and Management filled areas March 4, 1911 (16 U.S.C.

523),

and section 2234.4-1 of title 43 of the Code of Federal Regulations

. Federal Determination of Section 1101 of the Aviation no hazard for Federal Aviation Act meteorological of 1958 (49 U.S.C.

1501),

mast and part 77 of title 14 of Code of Federal Regulations Amendment to Section 1101 of the

" determination,"

Federal Aviation Act resulting from of 1958 (49 U.S.C.

1501),

l' height change of and part 77 of title 14 of l

meteorological mast Code of Federal Regulations

(

c s-

)

Licenses, Permits Statutory Or Other Agency Approvals Authority Federal Determination of Section 1101 of the Aviation no hazard for Federal Aviation Act of (continued) containment 1958 (49 U.S.C.

1501),

structures and part 77 of title 14 of Code of Federal negulations Determination of Section 1101 of the no hazard for Federal Aviation Act tower crane of 1958 (49 U.S.C 1501),

and part 77 of title 14 of Code of Federal Regulations Amendment to Section 1101 of the

" determination,"

Federal Aviation Act of resulting from 1958 (49 U.S.C.

1501),

removal of light-and part 77 of title 14 ing from meteoro-Code of Federal Regulations logical mast STATE OF CALIFORNIA LICENSES, PERMITS AND APPROVALS Dept. of Approval for Sections 1601 and 1602 Fish and culvert and fill of the California Fish Game and Game Code State Lands Lease of submerged Division 6 of California Commission lands for wave Public Resources Code height transducer Boundary line Section 6357 of the agreement California Public Resources Code Lease for intake Division 6 of California basin Public Resources Code Extension of lease Division 6 of California for wave height Public Resources Code I

transducer Right-of-way for Division 6 of California discharge channel Public Utilities Resources Code Industrial lease Division 6 of California right-of-way for Public Resources Code road and cofferdam O

Licenses, Permits Statutory Or Other i

Agency Approvals Authority Resources Agency Agreement No statutory requirements.

Dept. of Agreement sets forth Conservation certain commitments by Water Resources PGandE which will assist Parks & Recreation in the protection of the Fish & Game natural resources of Harbors & Water-California crafts Central Coast Waste discharge Section 13263 of Cali-Regional Water requirements fornia Water Code (Stats.

Quality control 1969, Ch. 482 Fed. Water Board, the Pollution Control Act of Resources Agency 1972 Permit for plant Federal Water Pollution discharges, Units Control Act - 1972 1&2 Approval of 316(a)

Section 316(a) of Fed.

demonstration that Water Polluticn Control present requirement Act - 1972 for closed cycle cooling is more p)

(_

stringent than necessary Approval of 316(b)

Section 316 study program to monitor effects of discharges State Water Water quality Section 401 of the Federal Resources certification Water Pollution Control Control Act and title 23, chap-Board, the ter 3, subchapter 11, of Resources the California Adminis-Agency trative Code Dept. of Program of radio-Section 25607 of Public logical monitoring California Health Health and Safety Code Division of Misc. reviews of Industrial code requirements, Safety construction safety, pressure vessels, elevator permits, etc.

g N m

Licenses, Permits Statutory Or Other Agency Approvals Authority Port San Luis Lease Section 6074 of the Harbor California Harbors and District Navaigation Code -

Port San Luis Harbor District California claim of exemption Coastal Commission LOCAL LICENSES, PERMITS AND APPROVALS County of San Use permit for None.

County Ordinance Luis Obispo plant site Code section 11-481 (3) as amended by County Ordinance 875 states that the plant is a permitted use at its location provided it is constructed with the approval of the Cali-fornia Public Otilities Commission Excavation and San Luis Obispo County h

grading permit ordinance 756 and by for access road reference portions of the Uniform Building Code (specifically section 7003 of chapter 70)

Excavation and San Luis Obispo County grading permit for Ordinance 756 and by borrow area reference portions of the Uniform Building Code (spec. section 7003 of chap. 70)

Excavation and San Luis Obispo County grading permit for Ordinance 756 and by Point Patton to reference portions of the Elevatiun 85' Uniform Building Code (spec.

section 7003 of chap. 70)

O

-9_

m

Licenses, Permits Statutory Or Other w

Agency Approvals Authority 1

j County of Excavation and San Luis Obispo County San Luis grading permit for Ordinance 756 and by Obispo Point Patton -

reference portions of (continued)

Elevation 85' the Uniform Building to 75' Code (spec. section 7003 of chap. 70)

Excavation and San Luis Obispo County grading permit Ordinance 756 and by for Unit 2 reference portions of the Uniform Building Code (spec. section 7003 of chap. 70)

Excavation and San Luis Obispo County permit for barge 756 and by reference landing portions of the Uniform Building Code (spec.

section 7003 of chap. 70)

Excavation and San Luis Obispo County grading permit ordinance 756 and by for temporary reference portions of laydown area the Uniform Building p)s Code (spec. section 7003

(_

of chap. 70)

Conditional use Division 5, chap. 11, permit for section 451.2, San Luis trailer housing Obispo County Ordinance Code Building permit Title 19.04.030 of San for Unit 1 - below Luis Obispo County elevation 85' Ordinance Building permit Title 19.04.030 of San for Unit 1 - above Obispo County elevation 85' Ordinance Building permit Title 19.04.030 of San for meteorological Luis Obispo County towers Ordinance Building permit Title 19.04.030 of San for barge landing Luis Obispo County Ordinance I

sv Licenses, Permits Statutory Or Other Agency Approvals Authority County of Building permit Title 19.04.030 of San San Luis for gate house Luis Obispo County Obispo Ordinance (continued)

Building permit Title 19.04.030 of San for conference Luis Obispo County and construction Ordinance office Building permit Title 19.04.030 of San for warehouse Luis Obispo County Ordinance Building permit Title 19.04.030 of San for compressor Luis Obispo County building Ordinance Building permit Title 19.04.030 of San for quality Luis Obispo County assurance Ordinance laboratory and office Building permit for Title 19.04.030 of San concrete batch plant Luis Obispo County ordinance Building permit for Title 19.04.030 of San 230 kv switchyard Luis Obispo County control building Ordinance Building permit for Title 19.04.030 of San 500 kv switchyard Luis Obispo County control building ordinance Building permit Title 19.04.030 of San for Unit 2 Luis Obispo County Ordinance San Luis Permit to operate obispo County two auxiliary Air Pollv*. ion boilers Control District Resources Approval to con-n/a (Dec. 1966 Agency struct cofferdam agreement) depositing fill material in the ocean 0

. ~.

t APPENDIX B

/

Page 1 of 2 j

4 DIABLO CANYON UNIT 1 COMPARISON OF ORIGINAL ESTIMATE TO DECEMBER 1, 1979 OPERATING DATE ESTIMATE j.

% OF

+

($1,000)

INCREASE PGandE Original Estimate (1966)

-$162,000 4

Increase based on the Revised Estimate 168,000 Revised Estimate (1971)

$330,000 l[}

I. Regulatory Changes

$ 68,000 11.8 II. Plant Optimization Changes 26,000 4.5 III. Schedule Delays 72,000 12.5 IV. Other Items 103,000 17.8 V. General Overheads 308,000 53.4 TOTAL

$577,000 100.0 Estimate based on an operating date of 12/1/79

$907,000

APPENDIX B Page 2 of 2 O

DIABLO CANYON UNIT 2 COMPARISON OF ORIGINAL ESTIMATE TO AUGUST 1, 1980 OPERATING DATE

% OF

($1,000)

INCREASE PGandE Original Estimate (1968)

S157,400 Increase based on the Revised Estimate 132,600 Revised Estimate (1971)

$290,000 I.

Regulatory Changes S 60,000 13.5 II. Plant Optimization 16,000 3.6 III. Schedule Delays 56,000 12.5 IV. Other Items 80,000 17.9 V. General Overheads 234,000 52.5 TOTAL

$446,000 100.0 Estin. ate based on an operating date of 8/1/80

$736,000

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