ML19338C192
| ML19338C192 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/27/1977 |
| From: | Lieberman J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 8008050641 | |
| Download: ML19338C192 (14) | |
Text
..
1/27/77 UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION
{
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
/
)
O.
21-g
-In the Matter.of
)
.pe'
- 0'
)
'l 4
CONSUMERS POWER COMPANY ~
)
Docket Nos.
?
4 Y'V,4
-)
)
50-330
.(Midland Plant, Units-I and 2)
)
D e
NRC STAFF'S ANSWER,
.'O INTERR0GATORIES OF INTERVENORS DVED JANUARY 3,19/7
- On January ~3,1977, the Intervenors other thani Dow Chemical Company filed fourteen interrogatories directed to the NRC Staff (Staff).
By separate. filing dated January 14, 1975, the Staff objected to certain interrogatories (See Also Tr. 1560-1578, January 20,1977).
The Staff's answers to those interrogatories not objected to are attached as Attachment A.
The Affidavits of' F. 'S. Echols and Sidney Feld, which certify that the indicated NRC Staff responser are true and. correct to the best of their knowledge, are attached as Attachments B and C, respectively.
-1 Re,spectfully submitted, q',Lt/<hl, ANJames Lieberman Counsel for NRC Staff Dated.at Bethesda,' Maryland this 27th day.of January,1977 :
/
[jg
.8008060
n
~
ATTACHMENT A Interrogatory 1 The date for commercial operation of Unit 1 is March 1982 and of Unit 2 is March 1981.
The basis for these estimates is found in the Applicant's ER supplement (See Fig. 4.1-1).
Consideration'was not given to the
. factors explicitly. enumerated in this interrogatory.
. Interrogatory 6' The major benefit of the Midland Nuclear Power Plant remains the production of. electricity and steam over an estimated 30 year plant life.
The Staff is not. aware of any new benefits, of any significance, that were not already.
. addressed in the original cost-benefit analysis prepared for the Midland proceeding.
The Staff contends that the benefits of electricity and steam fully compensates for the considerably higher. cost projections for the Midland
^
units.
l
- Note:
Licensing Boards have repeatedly questioned the Staff's attempts'to quantify the;valua of electricity -- presumably because of' discrepancies between market' prices and' societal banefits (i.e., market imperfections,
]
consumer surplus).
Essentially, the Licensing Boards have adopted the
- position that-the value of electricity is immeasurable.
That is, independent 1
of'the analyst's.:value judgments, as.long as there is.a. forecasted demand z
, for the. product;which reflects / society's tastes and preferences, and-1 i
c-
'(Interrogatory 6 cont'd.)
vdllingness to spend, it should be provided.
Vermont Yankee Nuclear Power Corpo' ration (Vermont Yankee Nuclear Power Station), ALAB-179, 7 AEC 159,
-175(1974).
Consequently, the Staff believes that if one adopts this approach, the alternative analysis (Midland DES - Section 5) provides the cost-benefit justification for the Midland units.
That is, taking-the new Midland projected costs into account, the Midland units are still the most cost-effective alternative available to the Applicant.
Thus, if one of the alternatives was selected over Midland it would be a case of foregoing benefi ts.
Interrogatory 7A-i Under the circumstances outlined in this interrogatory, Dow may still find t-
- the-Midland Plant steam to be economically justifiable as planned; Dow may find a different quantity of. steam from the Midland Plant ^ economically.
justifiable; or Dow may find none is economically justifiable..In the event none is justifiable to Dow, CPC may want to consider converting the steam
.into electricity or operating-the _ plant at a lower power level to concerve the core or'do both'at different points in time. Alternatively, at;that time CPC may want to cancel Unit No. 1
-A more definitive response to
-this' interrogatory is not possible under the circumstances given.
1
+
3-s
/
Interrogatory 78-The Staff believes it would be possible to construct a coal fired plant at the Midland site.
(
(a) The Staff examined' coal fired units that have equipment for sulfur dioxide removal in order that they might burn coal"with a high su? fur content, and coal fired units that utilize low sulfur coal which consequently does not require such equipment.
Each coal option assumes two units capable of supplying a total of 1600 MWe (800 MWe each) of i
energy which will be utilized' solely for the generation of electricity.
(b) The estimated capital costs are:
i 1
Low Sulfur Coal 1,061 million dollars High Sulfur Coal 1,270 million dollars A discussion of these estimates appears in Staff testimony on. cost of alternatives, and the Applicant's ER supplement.
These values are expressed in 1981 dollars.
(c).The Staff estimates approximately 6 years to construct the fossil
.l fired facility described in (a) above.
This estimate is based on-ERDA 76-141, Comparing flew Technologies for the Electric Utilities, (Draft Final Report, December 9, 1976'at page 104).
l
-(d)
Based on (c) above, it would not appear possible to construct a fossil fuel facility before the end of 1980, (unless, of course, price was noobject).
If we are talking about the end of 1980, just under v-14 years would be available to design, plan, and construct the facility, which inithe Staff's view is.not'a reascnable time 6ewod.
s.
s
. (e) The capital cost of the low sulfur coal option plus an assumed complete' loss of Consumers' current investment which is estimated at $412 million.as of December 1, 1976, would result in a total capital cost of
$1,473 million.
This is about $200 million less than the capital cost estimate for Midland.
With respect to the high sulfur option, the total capital cost would be approximately the same as the nuclear option.
It should be stressed however, that these comparisons consider only cne element in the. total cost of generating electricy. When the cost of fuel, 0 & M. taxes, insurance, decommissioning, and interim power are also accounted for, the~ nuclear plant would have an estimated cost advantage of over 1 billion dollars over the ~next best cost effective alternative (low sulfur coal).
Interrogatory 8 The Staff identifies energy conservation as those efforts directed at
' bringing about a more efficient utilization'of our energy resources..In the Staff'sfopinion,~ energy l conservation with respect to electricity demand should be viewed as a reduction in the quantity of electricity consumed in ' response to a c$ange in society's tastes and preferences, well being
- (income),and-thelpriceofelectricityrelativetoothergoodsavailable to society.
t r
^
.r-
. Interrogatory 10 The Sta'ff has assumed that over the operating life of the Midland Nuclear units the capacity factor will average 65%. 'Since the nuclear units have a net electrical capability of 1271 MWe, this means that the annual electrical output will average about 7.2 billion KWh.
The Staff recognizes that the use of h{storical experience in forecasting capacity factors'for nuclear power plants suffers because of the relatively small amcunt of' experience in operation of reactors.
Many of the' plants currently or previously on line were' in the developmental stage and lacked substantial operating experience. The historical base indicates wide variations in capacity factors have been realized.
When data on a given chaiacteristic vary widely and do not show-tendencies 4
to congregate around a central value, the average or arithmetic mean is not a particularly useful measure of the characteristic.
Such is the case for nuclear power plant capacity factors.
In the past, some units have been shut down for extended periods for a varict/ cf reasons, including equipment or operator failures or backfitting for corrections of deficiencies.
Measures 'other than.the mean may be more adequate to forecast capacity factors such as the mode (most_ frequent value), or the median (middle val'ue of data arrayed by magnitude).
Another more useful measure is the frequency
. distribution.
k h:
s s
,~1 a
s.
(Interrogatory 10 cont'd.)-
l The attached table shows the frequency distribution of capacity factors in 1973, 1974, 1975 through September, and historical cumulative data through December 1974 and through September 1975.
The two sets of cumulated data do not include Indian Point 1, because data on the historical capacity factor was not available.
In the other cases, where only one year of data was used, Indian Point 1 was included using a capacity factor of zero.
In 1973 the most frequent value of the capacity factor was in the 60.01 - 65 range.
In both 1974'and 1975, the most frequent value of the capacity factor was in the 75.01 - 100 range.
This table also shows the percentage of nuclear reactors which have a capacity factor above 60%.
In 1975, almost 60% of the reactors had a capacity factor greater than 60%.
For 1974, this figure i
l was about 45%, and in 1973 it was 53%.
While nuclear plant capacity factors have been variable in the past, it l-is evident that many nuclear power plants can operate at capacity factors
. in excess of 75%.
It appears reasonable to assume that as' experience is i
. gained in construction and operation of nuclear plants that many will-' operate l
at these capacity factors. : Improved designs and operator skills are often cited as' factors that will improve the future performance of these plants,
'Furthermore, much effort is undeneay on the part of the FEA, the reactor manufacturers,'and-the electric utility industry to improve capacity factors on nuclear. plants and there is a' good deal of confidence that this can be achieved. :However, the Staff analysis uses:only a 65% capacity factor in estimating the benefits of the. Midland Nuclear Power Plant.
. Interrogatory 12 Upon a-determination that steam would not be supplied to Dow, the Staff would not recommend that the facility be constructed as presently designed.
In the event that Dow no longer required electricity but continued to require steam continued construction would be acceptable if a need for i
power were shown.
' Some of the options open to CPC if the contract was terminated are listed in the response to Interrogatory 7A.
If no steam was to be delivered to Dow, the Applicant would have to modify the applications to reflect a single l
purpose (electricity production), rather than dual purpose (electricity and
.steamproduction), facility.
Such a modification may not require significant-j' time and money expenditures if the plant were to operate at approximately 1300 itle,.or construction were to proceed with.only Unit 2.
If CPC chose to modify Unit 1 to produce electricity with the steam originally planned for Dow then greater. time and money expenditures would be involved.
In addition, construction might be suspended while a new application.was evaluated.
~
l-If and:when a new app 1'ication would be forthcoming, the Staff at~ that time
'will review the. application and assess the revised project in detail with respect to~such items as need.'for the project, alternatives, financial
--responsibility, desiga of the facility and site selection.
3
.- ' Interrogatory-13
' Based on a telephone conversation on January 17, 1977 with L. Jager, Chief, Air Pollution Control Division, Michigan Department fiatural ~ Resources and
(
a meeting with EPA representatives in Chicago on January 20, 1977 the Staff I
responds as follows:
I Dow exceeds stack emission limits for both sulfur and particulates the pol-l.
1utants of concern. The present limit for sulfur content in coal is 1-1/2%.
This will be reduced to a limit of 1% by the end of the year.
Dow uses 3 to 3-1/2% sulfur coal.
Particulate concentrations at the' stack greatly
~
exceed emission limits.
However, the Federal Ambient Air Quality Standards are being met for both sulfur and particulates.
To reduce sulfur concentrations in air to meet Ambient Air Quality Standards, l
Dow implemented a Supplemental. Control System in 1976 where gas or oil is
(
substituted for coal under. conditions of poor meteorology.
l~
Therefore, in' Midland, Michigan, and the surrounding area, no public health hazard has-been11dentified.- Thus', no environmental costs have been identified
.for the'Dow units.
However the EPA and.the.-State of. Michigan are now in the process of discussing. alternate meth'ods, if any, that may. be required to limit emissions measured atlthe stack. The cost of meeting stack emission standards are
.not expected;to1 exceed $20 million.
r, I
h y
e 4*e a
w i-3 m P
- T u
~
(ELATIVEfFREQUENCY AND FREQUENCY; DISTRIBUTION.0F CAPACITY FACTORS FOR OPERATING NUCLEAR. RE
- of Da ta.!to Capactty' Factor Range-
' Capacity' Factor;.
ors the Date 0-35.0 35.0-40.040.01-4545.01-5050.01-55l55.01-6060.01-6565.01-7070.01-7575.01.100Above 60 0
Cumulated 4.2; 2.1.
- 2. l!
8.3
' 18.8 g14.6 10.4 (7)
.(5)-
. 20.8
~ :10.4 --
8.3"-
~50.0
.to 09-75 (2)
(1)
' (1 )l-(4)
' (9)=
(10)
-(5)-
(4)
(24)-
- *s 1975 'only 12.2'
'4.l~
-- 4.1 4.1.
4.1
-12.2 16.3-
'14.3 6.1 122.4 59.2 oJan-Sept)
'(6 ) '
(2)
_(2)
- (2):
.(2)-
.(6)
(8)-
(7)
(3)-
(11)~
(29)'
Cumulated 11-4' O.0 6.8.
' 18. 2 '
22.7 4.5 6.8 11.4-9.1 9.1 -.
36.4:
to 12-74
-(5)_
_(0)
(3)'
(8)L (10)-
'(2)
(3)
- (5)'
(4)
(4).
-(16) l 1*
1974,only 71 5.'6 "
- 2.2 6.7-
- 8.9'
' 13.3 8.9 15.6' 6.7:
2.2 20.0-44.4 Jan-Dec)=
(7)- '
(l)
-(3)
(4)
(6)
(4).
(7)
(3)
(1)~
-(9)-
(20):
l 1973.w.ly '10.0!
l 3. 3 '
10.0 13.3
-10.0 0.0 20.0
- 20.0
'10.0 3.3:
53.3
~
'D Jan-Dec)
(3).
(1)
~(3)
(4)
(3)-
(0)
'(6)
(6)
.(3)
(1)~
'(16)
. Includes Indian Point I at zero capacity factor.
I~
' OURCES: ' Operating Units Status: Report, NUREG-75.020-9, October,1975; 0perating Units Status Report, January 24,.1975;
~ '
Nuclear Power-Plant Operating Experience During 1973, December 1974, 00E-ES-004.
The First line of each category is percent, the second line is number of plants.
f 4
4 2.
m m
m.
_._____m-_____._______.,___-.._1
. - - m-A
+---
's ATTACHMENT 8 UNITED STATES OF AMERICA flUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSI;lG BOARD In the Matter of
)
CONSUMERS POWER COMPANY Docket 'os. 50-329
)
50-330 (Midland Plants, Units 1 and 2)
)
AFFIDAVIT OF F. S. ECHOLS F. S. Echols deposes and says under oath as follows:
1.
I am the Environmental Project Manager for Midland Plants, Units and 2 in the Division of Site Safety and Environmental Analysis, U. S. Nuclear Regulatory Commission. As Project Manager for the Midland Plants, Units 1 and 2, I am responsible for coordinating and supervising.the Office of Nuclear Reactor Regulation's evaluations of remanded issues, the continuation of the construction permits in light of the issues remanded for consideration by the court in Aeschliman v. USNRC (D. C. Cir., July 21,1976).
2.
The answers to interrogatories 1, 7A, 12, and 13 were prepared by me or under my supervision.
I hereby certify that the answers given are true and accurate to the best of.my kr.owledge.
LA-F. S. Echols Subscribed and sworn to before me this anth day of January,1977 couM D. A h,,d L.Notarf Public Q My Commission Expires AL i Aw.
q g
i UNITED STATES OF' AMERICA NUCLEAR REGULATORY COMMISSION BEFORE-THE ATOMIC SAFETY AND LICENSING BOARD
' In the Matter of
)
' CONSUMERS POWER COMPANY Docket Nos. 50-329 50-330 (Midland Plants, Units l'and 2)
AFFIDAVIT OF SIDNEY FELD 1
Sidney.Feld deposes and says under oath as follows:
1.
I am a Regional / Environmental Economist in the Division of Site Safety and Environmental Analysis, U.S. Nuclear Regulatory Commission.
I am responsible for reviewing and analyzing the Applicant's Environ-mental Report Supplement and for the preparation of the cost benefit,
section 'of the Staff's Environmental ' Statement and th'e Staff's testimony on need for. power and conservation.
2.
The answers to Interrogatories 6, 7B, 8, and 10 were~ prepared by me or under my supervision.
I hereby_ certify that the answers given are true and correctito the best of my knowledge.
ab.,,
t[A Sidney Feld/-
Subscribed'and sworn to before me'this d ' day of January, 1977 Owd R.M Notary.Publicg My Commission Expires 6. A L' A 19 j-T*
9 w
s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSUMERS POWER COMPANY
)
Docket Nos. 50-329
)
50-330 (MidlandPlant, Units 1and2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S ANSWERS TO INTERROGATORIES OF INTERVENORS DATED JANUARY 3, 1977," dated January 27, 1977 in the above-captioned proceeding have been served on the followina by deposit in the United States mail, first class or air mail, this 27th day'of January,1977:
Frederic 'J. Coufal,.Esq., Chairman Honorable Curt T. Schneider Atomic Safety and Licensing Board Attorney General U. S. Nuclear Regulatory Commission State of Kansas Statehouse Washington, D. C.
20555 Topeka, Kansas 66612 Dr. J. Venn Leeds, Jr.
Ms. Mary Sinclair Atomic Safety and Licensing Board 5711 Summerset Street 10807_ Atwell Midland, Michigan 48640 Houston, Texas 77096 Harold F. Reis, Esq.
Dr. Emmeth A. Luebke Robert Lowenstein, Esq.
Atomic Safety and Licensing Board Lowenstein..Newman, Reis &
U. S. Nuclear Regulatory Commission Axelrad Washington, D. C.
20555 1025 Connecticut Avenue Washington, D. C.
.20036 Myron M. Cherry, Esq.
l IBM Plaza L. F. Nute, Esq.
- Chicago, Illinois.60611 Dow Chemical, U.S.A.
. Michigan Division Juddz L. Bacon, Esq.
Midland, Michigan 48640
- Consumers Power Company
. 212 West Michigan Avenue Mr. Steve.Gadler Jackson, Michigan 49201.
2120 Carter Avenue St. Paul, Minnesota 55108
I..
~,.
R. Rex Renfrow,'III, Esq.
- David'J.'Rosso,;Esq.- '
Atomic Safety and Licensing Isham, Lincoln & Eeale Appeal Panel
-One First National Plaza' U. S. Nuclear Regulatory Commission
' Suite 4200 Washington, D. C.
21555
' Chicago, Illinois 60603 Docketing and Service Section Office of the Secretary
- Atomic Safety and Licensing U..S.. Nuclear Regulatory Commission Board Pa'nel
-Washington, D. C.
20555 U. S. Nuclear ~ Regulatory Commission Washington, D. C.
20555
) / 0 L ~~
/
Richard V,. Hoefling i
Counsel for NRC Staff /
,