ML19347E270
| ML19347E270 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/31/1981 |
| From: | Mendl J WISCONSIN, STATE OF |
| To: | Trammell C NRC |
| References | |
| 6630-CE-20, NUDOCS 8104240450 | |
| Download: ML19347E270 (39) | |
Text
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THIS DOCUMENT CONTAINS POOR QUAUTY PAGES Siete of Wisconsin \ eustic saavice commission STANLEY YORK, CH AIRMAN EDWARD M. PARSONS, JR.. COMM13SION E R March 31, 1981 WILLIE J. NUNNERY, COMMISSIONE R Hill Forms State Office Building Madison. Wisconsin 53702 (608)266 1241 File No.
6630-CE-20 NRC Docket 50-266 Mr. Charles Trammell U.S. Nuclear Regulatory Commission Mail Stop 228 Phillips Building Washington, D.C. 20555
Dear Mr. Trammell:
Thank you for your March 3 answer to my letter of February 23, 1981. We did change our response to one of Mr. Anderson's questions as you suggested. Your answers to our questions were very informative, and they have been used in the environ-mental screening.
I am enclosing a copy of a Preliminary Staff Determination and of the final version of the Environmental Screening for your files. We have had four days of hearings thus far (March 12, 13, 23, 24) and have scheduled a further three days (April 6, 7, 8).
Thank you again for your assistance and cooperation.
Sincerely, g% he
Jerry E. Mendl WEPA Coordinator JEM/kmw 4 CO 03 Enclosure //
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Stoie of Wisconsin \ eustiC seaviCe Commission STANLEY YORK.CH AIRMAN EDWARD M. PARSONS JR., COMMISSIONER WILLIE J. NUNNERY, COMMISSIONER Hill Forms State Office Building Madison, Wisconsin 53702 (608) 266 1241 February 27, 1981 6630-CE-20 Fh No. 6630-UI-2 To The Person Addressed:
INFORMATION FOR PERSONS AFFECTED BY PURCHASE AND INSTALLATION OF SPARE STEAM GENERATORS AT POINT BEACH NUCLEAR POWER PLANT, UNIT 3, IN THE TOWN OF TWO CREEKS, MANITOWOC COUNTY, WISCONSIN PRELIMINARY STAFF DETERMINATION: NO ENVIRONMENTAL IMPACT STATEMENT REQUIRED.
The purpose of this notice is to request comments and informa-tion regarding the staff's preliminary determination that no environmental impact statement is required for the proposed project.
This step is in addition to the requests for notification and is expected to provide additional opportunity for public participation in the agency review. A preliminary staff determination may be changed in response to consideration of comments received, and is not in any way binding on either the staff or the Commission. The preliminary staff determination process has the a dvantage of inform-ing ir.terested parties of the staff's view of the nature of the factual evidence available to the staff. Affected parties are requested to send comnents or additional factual information for staff review to the person identified at the end of this document.
If effective, the notice of preliminary determination may become a required step in a revised environmental review process.
The Wisconsin Electric Power Company (WEPCO) has applied to the Wisconsin Public Service Commission for permission to purchase and store two replacement steam generator lower sections and primary moisture separators for the Point Beach Nuclear Power Plant, unit 1, in the Town of Two Creeks, Manitowoc County, Wisconsin. WEPCO also plans to insert sleeves into the tubes in the present steam generators in crder to allow unit 1 to operate at full capacity.
The resulting capacity factor would be greater than it is presently and would remain so for the balance of its anticipated useful life.
The replacement steam generators would be available for installation in case the sleeving proves to be inadequate at any future time.
Thus the proposed action is repair of an existing power plant.
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February 27, 1981 6630-CE-20 Page 2 6630-01-2 Staff of the Systems Planning, Environmental Review, and Consumer Analysis Division (SPERCA) of the Public Service Commission have identified three alternatives to the proposed action: (a) use the replacement steam generator sections as soon as they are delivered without inserting sleeves into the present steam generators, (b) continue to operate Point Beach unit 1 at less than full capacity and plug tubes in the steam generators as they begin to leak, and (c) begin to decommission Point Beach unit 1 in 1981.
SPERCA staff have reached a preliminary determination of the environmental significance of the proposed action and found that no significant environmental impacts are likely to occur as a result of the proposed or reasonable alternative actions.
In reaching this preliminary determination, staff reviewed and evaluated the following points. All construction activities will be within the existing security fence or just north of it on previously disturbed ground. Thus, there will be little or no terrestrial environmental impact. Staff assumed that decommission-ing will occur sometime, thus the impacts of the act of decommission-ing are not considered. The impacts of different timing of decommis-sioning are evaluated for alternative (c) identified above. Staff relied on staff of the U.S. Nuclear Regulatory Commission (NRC) for a discussion of safety and both public and occupational radiation exposures. NRC staff stated that for all alternatives, the appropriate analyses would be required and acceptance criteria would have to be met. NRC has reviewed other facilities where steam generator replacement and plugging have occurred, and has allowed resumed operation. NRC staff have given initial approval to sleeving San Onofre in California; final review will occur after sleeving is completed. Releases of radionuclides during repair operations are predicted by NRC to be less than releases during normal operation. Releases after repair are predicted to be least for replacement of steam generators, slightly greater for sleeving of steam generator tubes, and greatest for the no action alternative. Occupational exposures are predicted (by NRC) to be greatest for replacement, slightly less for sleeving, and i
about 50% less for ten years of continued tube plugging and inspec-tion (at the present rate of tube failure). In all cases, oc-cupational exposures were predicted to be within the normal range )
of annual exposures observed to date at operating reactors. SPERCA staff concluded that for terrestrial environmental effects and the nuclear issues (safety and both public and occupational radiation exposure) the differences between sleeving and the three alternatives are not significant.
SPERCA staff identified two issues where there are clear differences: the emission of air pollutants and operating costs due to generation of power to replace that lost due to operation of l
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February 27, 1981 6630-CE-20 Page 3 6630-UI-2 Point Beach unit 1 at less than full power, that lost during the outage for repair, or that lost due to shutting Point Beach unit 1 down. The attached table displays the differences in cost and emissions. This table represents an amalgam of all the Eastern Wisconsin Utilities, because these utilities plan and operate on a highly coordinated basis. For each case (proposed and alternatives), a change in emissions is spread among many plants on the system (Eastern Wisconsin Utilities),
and is not concentrated in any one particular geographic area.
The decommissioning alternative would also require firm capacity purchases in 1987-1989, and would require increasing the size of the proposed 1989 and 1990 coal fired units from 400 to 650 ffWe each.
Comparison Table Purchase Replace Plug Leaks Decommission spares & Steam Replace S/G in 1981 sleeve Generators in 1991-2 Differential present worth cost at 12%* 0 32 107 1351 Differential present worth cost at 18%* 0 25 61 636 Differential sulfur dioxide emissions 1981-1992 0 22 118 505 Emissions increase compared to base case (percent) 0 0.035 1.95 14 Costs in millions of 1981 dollars.
Emissions in thousand tons. Nitrogen oxides and particulate emissions parallel sulfur dioxide emissions.
- Cost includes investment cost and operating cost.
If sleeving is inadequate for the remaining plant life, l sleeving and installing the replacement steam generators would l have a cost somewhere between the " Purchase spares & sleeve" i and " Decommission in 1981." The shorter the period between identification of inadequacy and replacement, the lower the cost.
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l February 27, 1981 '6630-CE-20 Page 4 6630-UI-2 SPERCA staff have concluded that there are definite but small differences between the proposed action (purchase spares and sleeve existing steam generators) and the alternatives of replacing steam generators now or plugging leaking tubes and replacing the steam generators in 1991-92. There are large differences in costs and emissions and system plans between the proposed action and the alternative of decommissioning Point Beach unit 1 in 1981. Staf f examination of a fourth option-plugging leaking tubes and then decommissioning in 1992-found impacts to be close to those of decommissioning in 1981.
SPERCA staff have reached the preliminary conclusion, subject to review at the end of the comment period, that the environmental effects of the proposed action are not significant and that no environmental impact statement is required for this project.
If you want to comment on this preliminary determination, you may do so by writing Sarah Jenkins, Public Service Commission, 4802 Sheboygan Avenue, Madison, WI 53702 or by telephoning Ms.
Jenkins at (608)266-5990. Comments must be submitted by March 9, 1981. Copies of the preliminary environmental' screening are available from Ms. Jenkins.
Sincerely, h $.A [M)
Jerry E. Mendl Division Administrator Systems Planning, Environmental Review and Consumer Analysis JEM:SJ:se
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Investigation on the Commission's Y.otion Into )
the Actual and Potential Financial, Accounting )
and Ratemaking Effects of Steam Generator Tube ) 6630-UI-2 Degradation at Unit 1 and Unit 2 of the Wis- )
consin Electric Power Company's Point Beach i Nuclear Plant )
Application of Wisconsin Electric Power Company )
for Authority to Replace the Steam Generators )
for Its Point Beach Nuclear Plant, Unit 1, in ) 6630-CE-20 the Town of Two Creeks, Manitowoc County, Wis- )
)
consin ENVIRONMENTAL SCREENING A. Wisconsin Electric Fewer Company Application for Approval to Purchase and Store Two Spare Steam Generators for Point Beach Nuclear Plant -
Unit I B. Infomation
- 1. Project description The proposed project is purchase of replacement steam generator sec-tions plus (a) or (b) below.
Wisconsin Electric Power Company (WEPCO) proposes to purchase two replacement steam generator lower sections and to store these in a build-ing north of the turbine building, outside the present security fence.
Depending on the success of an experiment in sleeving steam generator tubes (thus coverir.g areas subject to leaks), WEPCO would propose to also do either (a) sleeving or (b) replace the steam generators as described below (see Figure 1).
- c. Steeving steam generator tubes The replacement steam generator lower sections would be stored for an unknown period of time (see B.2 later). In each existing steam generator, sleeves would be inserted into up to 2500 tubes to block areas near the tube sheet that may leak in the future or have been plugged in the past l (see Figure 2).
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Figure 1. Steam Generator l Water / steam outside the tubes containing primary coolant constitute i
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secondary coolant that enters the steam generator as feedwater and flows to and through the turbines as . steam. !
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- b. Replace the steam generator lower sections The replacement lower sections would be used. All piping connections to the steam generators would be cut, the steam generator itself would be cut at the transition cone, the lower section would be removed and put into the storage building. The moisture separators in the upper section
' would be refurbished. The new lower sections would be attached to piping and the old upper section.
- c. Continue operations - no change Unit I would continue to operate at 77% capacity and 60% capacity fac-tor until 30% of the tubes have leaked and been plugged. At that time Unit I would shut down for sleeving or replacement of the steam generators or for retirement. .
- d. Retire Unit 1 and decommission it immediately This alternative would mean shutting Point Beach I down in the spring of 1981. The exact method of decommissioning is assumed to be the same now as at the expected end of life. Until regulations governing such actions are further developed, detailed discussion is speculative.
Detailed discussion is unnecessary because the impacts of decommissioning will eventually take place, either now or at the expected end of life.
The question is not whether, but when.
- 2. Purpose ,i proposed action The purpose of the proposed action plus sleeving is to allow Unit 1 to operate at full capacity and at a greater capacity factor for the balance of its anticipated useful life.
Unit 1 began full operation in December 1970. Leaks due to tube defects (thinning and stress corrosion cracking) required tube plugging beginning with the first refueling shutdown in September 1972. Minor thinning was noted in April 1974. In February 1975, a tube ruptured. A large number of tubes were plugged during the ensuing shutdown. Some denting was noticed in 1977. Through September 1978 further problems were minor. Unit I was shut down in March, August (twice), October and December 1979 to plug tubes leaking due to crevice corrosion (intergranular attack).
The unit was returned to operation at a lower tempernture (557'F instead of 598'F1. Pressure was reduced later (from 2250 to 2000 pounds). Through Nov. 26,1980,12.5% (407 tubes) of the tubes in steam generator A and 12.2% ( 399 tubes) of the tubes in steam generator B have been plugged.
Unit 2 began full operation in August 1972. Fewer tube problems have occurred -- less denting and crevice corrosion in particular. Through April 11, 1980, 1.7% (57) of the tubes in steam generator A and 0.6% (19 4
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5 Each steam tubes) of the tubes in steam generator B have been plugged.
generator contains 3,260 tubes.
- 3. Project cost The total cost of steam generator lower section purchase and storage is predicted to be $12 million. If sleeving works, The ability thethe to sell spare sections surplus sections might.be sold to other companies.
is uncertain because other companies may also choose sleeving as the nethod of repair and because the potential for use in a new plant is uncer-tain. If sleeving does not work, the spares will be used at Point Beach, Unit 1.
The cost of sleeving is predicted to be $11 million, of which the anticipated cost to WEPCO is $5.5 million (due to cost sharing with Westinghouse). The cost of steam generator lower section replacement (not including replacement power) is esti=ated to be $48.5 million, of which the cost to WEPCO is anticipated to be $34 million (due to cost sharing with Westinghouse). Commission staff anticipates that the decommissioning cost There are also costs for the entire Unit I would be $48 million in 1981.
for repiscenent power -- to replace power lost due to changed operating conditions and during the repair outages. (All costs are discussed further in section D.)
- 4. Effect on system operations Sleeving and replacement require generation of replacement power until the conclusion of the repairs. After sleeving or replacement, WEPCO pro-jects that Point Beach i vill be able to operate at 100% capacity and a capacity factor of 75% or greater for the remainder of its operating life (to 2007).
WEPCO believes that the continued oresent pattern of operation (77%
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capacity and 60% capacity factor) cou,d last until sometime between 1991 and 2007. When 30% of the steam generator tubes are plugged, the unit would be shut down for repairs or deco:missioning (if the unit is near er at the end of its normal operating lif-).
- 5. Relation to long-range planniri If the no action alternative is chasen (and 30% of tubes are plugged by 1991),100 MW firm capacity purchasesforecasts) would be required from 1988 until and purchase of 330 MW the end of the repair (assuming present in 1991-92.
replacement power during the outage for replacement If Point Beach 1 is decom=issioned immediately, Pleasant Prairie 2 would have to be co=pleted about 15-16 months earlier than is now planned.
The following firm capacity purchases would be required after 1986:
315 MW - 1987, 430 MW - 1988, 213 MW - 1989. The presently planned 400 MN coal units scheduled to begin operation in 1989 and 1990 would have to be increased to 650 MW.
6 D. Description of Alternatives Before either sleeving or replacement, alt fuel is removed from the reactor and stored in the spent fuel storage nool.
- 1. Sleeving The first step is the selectioh of the approximately 2500 out of Plugs are removed from plugged tubes to 3260 the tubes extent that will be sleeved.The inside surfaces of the possible. The tubes to be slee cleaned. Sleeves are inserted and top and bottom joints formed.
sleeving is then inspected. The sleeves are made of Inconel 600 and extend 6-12 inches above the top of the tube sheet (see Figure 2) .
For sleeving, an existing construction building on the north side of the plant (next to the security gate) would be used for training the workers who will perform the sleeving and as a warehouse. A steam genera-tor storage building (about 80 x 100 feet with 18-24" thick walls) would be built of steel and concrete on the north side of the plant. It would hold the spare steam generators until they are used or sold (see Section 2 below). Temporary trailers for office and lunchroom facilities as well as for radiation protection activities would be put next to the containment and the training and warehouse facility. An operations building may be needed.
- 2. Replacement of steam generators The steam generator would be full of water (secondary side--space surrounding tubes) until the final cut is made at the transition cone.
All piping connections must be cut, and instruments and insulation removed.
Then a cut is made at the transition cone. The upper shell will be moved to a storage stand inside the containment. Steel caps will be welded over all openings in the old lower steam generator section while it is inside the containment. The lower section will be lifted and moved from the con-tainment to the new storage building (same building as in the previous sleeving discussion). The replacement lower section will be moved into i the containment and lowered onto the supports. New reactor coolant piping l
i sections will be welded onto the lower section. The refurbished upper section will be replaced and welded to *he lower section. All piping will be connected; instruments and insuinctor. replaced. The welds will be inspected and the repair hydrostatically tested, as necessary.
For replacement, a steam generator storage building is needed (as men-tioned above). The building constructed to store the new steam generators would serve to store the radioactive steam generators being replaced. An ,
operations building constructed of steel framing and siding will be built t
on the north side of the plant for training, qualification, materials
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7 This building will be left receipt and office use during the outage. intact after the repair for possible futu receipt use. A containment access building on the south side of the Unit I containment will be needed for personnel change areas, sanitaryThis facilities, lockers, lunchroom and radiation protection be removed afteractivities.
repairs are com-would also be a steel building and may plete.
- 3. No action .
Under this alternative, operation would continue at present lower tem-perature and pressure. As steam generator tubes show signs of leaking or of excessive defects, the tubes would be plugged. WEPCO believes that this could continue until 30% of the tubes are plugged. At that time, Point Beach I would be repaired (sleeved or steam generator replacement) or retired (if the unit is near or at the end of its normal operating life).
- 4. Retube in place This involves disassembling the steam generator, cutting and removing the tube bundle and removing the tube stubs from the tubesheet. The tube-sheet is refurbished, then new tubes are inserted and welded. This process has been demonstrated by Westinghouse at the factory. It has never been done in the field on radioactive steam generators. The anticipated cost and occupational radiation exposure are greater than for the other options, so this option has been rejected.
S. Decommission Point Beach I immediately Decommissioning will occur sometime -- soon under this option or about the year 2007 under other options. The physical impacts of actual decom-missioning will be the same whenever they occur and thus do not help to differentiate the options. There is a difference due to the cost and impact of generating replacement power and due to the number of stored spent fuel assemblies. This difference is evaluated in detail in the following two sections (D and F).
D. Cost of options PSC staff ran a cost of production model for the Eastern Wisconsin Utilities (EWU) system to determine the operating cost of producing the required energy for the following four options:
(1) Sleeve the steam generator tubes during the last three months of 1981; (2) Replace the steam generators between October 1983 and March 1984;
Table 1 Point Beach -- 6630-CE-20 Costs are all in millions of dollars, present worth to 1981 4
Alternative 3 Alternative 1 Alternative la Continue as Alternative 3a sleeve and Alternative 2 is; Then Continue as Alternative 4 sleeve and lunediately Purchase Steam D;n't Purchase Replace Steam Replace Steam is; then Cenerator Decomunission Decommission 4
Generator Maam Generator Cencrator 7599 7677 7677 8141 1 Operating Cost 92 7578 7578 pw e 12%
0 0 568 568 Differential Operating Cost - 0 0 93 07; pw 8 12%
57 54 246 266 Investment Cost pw a 121, 46 35 7656 7731 8491 8975 Total: pw to 1981 0'12% 7624 7613 5720 5767 5767 6126 Operating Cost 92 5705 5705 1
pw 0 18%
0 0 220 220
, Differential Operating Cost - 0 0 93-07; pw 0 18%
] 33 22 134 188 Investment cost pw 0 18% 23 14 5753 5789 6121 6364 Total: pw to 1981 0 18% 5728 5719 i
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9 (3)
No action now and replace the steam generators between October 1991 and March 1992; and (4i Shut down preparatory to decommissioning en April 1, 1981, (5) Apply 495 MW of additional conservation - retain Point Beach 1.
(6) Apply 495 MW.of additional conservation - decommission Point Beach 1. "
Capital investment costs were also calculated for alternatives including the above. Costs were determined for the year of occurrence (for 10%
inflation) and the 1981 present worth calculated using both 12% and 18%
discount rates. Peak demand and annual energy use were assumed to increase at 3% per year, which is in the range approved by the Commission in the second Advance Plan. Table I compcres operating and investment costs of the alternatives. From the data developed, other specific options can be evaluated, but the alternatives reported here represent a spectrum.
Table 2 gives differential costs with respect to sleeving without steam generator purchase.
Table 2 Differential Total Costs (Millions of 19815)
Case A: sleeve without purchase Alternative 1 Alternative 3 Alternative 3a Alternative 4 Sleeve 6 Alternative 2 No action 6 No action then Decommission Purchase Replace replace later decommission now PW at 12% 11 43 118 878 1362 PW at 18% 9 34 70 402 645 Case B: Sleeve and purchase 107 867 1351 12% -- 32 61 393 636 18% 25 It is possible that sleeving might not be adequate to solve the problems at Point Beach 1. In such a case the most likely procedure would be to replace the steam generators. It is difficult to estimate the life cycle cost of this option, since it is not known when the steam generator replace-ment might take place. However, it is likely that, if WEPCO owns spare
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10 steam generators, aEl there also is extra capacity on the systen A likelyat this upper time, the replacement would be,done as quickly as possible.
range for the cost of this option is the cost of alternative 2 (replace stear generator without sleeving) plus the cost of the sleeving (5.5 million dollars).
It is very clear that either decomm!)sioning immediately or in 1992 is substantially more expensive than eithe sleeving or replacing. The no action alternative with eventual replacement shows that the cost of delaying replacement is substantial. Replacement is more costly than sleeving, but the difference is small comparc? to the other options.
E. Conservation as an Alternative The preliminary environmental screening considered the issue of con-servation is response to Mr. Anderson's comments of February 2, 1981. Sub-sequent to that, continued misinterpretation has prompted staff to provide the following expansion of that discussion.
- 1. Conservation is desirable given present conditions where it is less expensive environmentally and economically to con-serve a kilowatt hour than to generate it.
- 2. Conservation, by reducing system loads, could be used to replace Point Beach Unit 1. This assumes that conserva-tion could somehow be made available for that purpose.
More about that follows later in point 4.
- 3. Conservation, if available, would produce greater returns if applied to facilities other than Point Beach. The availability of conservation to replace capacity should be applied to the capacity which is most expensive and environmentally damaging. Conservation should be con-sidered as a replacement for Point Beach 1 only if Point Beach 1 is the most environmentally damaging and expensive plant on the system. An examination of economic, environ-mental and safety aspects clearly indicates that replacing coal- and oil-fired facilities would produce greater bene-fits.
The following table compares the economic costs per kWh of Point Beach'i to other units on the WUMS system. Also shown is a comparison of several environmental parameters.
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11 Table 3 Operating Low Level Cost Per S02 Per Radioactive Spent Fuel Airborne kWh (1981$) kWh Waste Assemblies Radiation Point Beach 1 0.6e 0.0 0-5000 32/yr
- 30g/Y#
ft Columbia --
(inexpensive coal plant) 1.0( .014 lbs 0 0 Blount Street (expensive coal plant) 2.51t .13 lbs 0 0 -
Germantown (oil-fired plant) 8.7e - .006 lbs 0 0 -
- Airborne radiation releases were compared in the Assessment of the 1978 Advance Plan For Future Electric Power Facilities, Public Service Commis-sion, October, 1979, pages 50-51. The comparison was for similarly sited 1000 MW nuclear (PWR) and western coal-fired units. The whole body popu-lation dose commitment was 19 person-rem / year for the coal plant compared to 13 person-rem / year for the nuclear plant.
With this representative individual plant data in mind, one can evaluate the economic and environmental costs of operating the WUMS system with conservation applied to replacing Point Beach or applied to reducing usage of coal and oil plants. The system costs of operating the WUMS sys-tem with and without Point Beach 1 (with conservation equal to the capacity of Point Beach 1 included) were compared using the Commission's computer models. The differential operating cost between using conservation to replace Point Beach I vs. using it to back off the operation of other facilities grew from $47.8 million in 1982 to $151.3 million in 1992 (more expensive with Point Beach I decommissioned). The present worth of these differentials in 1981 dollars is $497 million (c 12%) or $350 million (9 18%). In addition there will be further operating cost differentials from 1993 through 2007. These amount to (in 1981 dollars) an additional 568 million dollars (@ 12%) or 220 million dollars (618%). These values can be compared to the cost of fixing Point Beach I which is less than 35 million dollars.
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12 There is also a significant differential in the emissions of air pollutants under these two scenarios. Our computer analysis indicated that with Point Beach I decommissioned, the additional 502' emitted between 1981 and 2007 is over 1,400,000 tons. Spent fuel and low level radioactive waste are discussed elsewhere in the text.
The safety question for Point Beach 1 is very simply whether or not Point Beach I will be safe. If unsafe, then it would be appropriate to shut the unit down regardless of the cost and environmental impacts. If safe, then there is no environmental or economic rearon to shut it down and, in fact, staff has determined that such an action would be an unreasonable alternative. There has been no allegation made by anyone involved in this case that the plant will be unsafe after fixing the steam generators, and staff's investigation and the NRC staff's review uncovered no reason to suspect such a problem.
i Summarizing, conservation could be used to replace Point Beach, but it would be unreasonable to do so. The argument that conservation would reduce the need for replacement power, hence reducing the economic and l
i environmental impacts of decommissioning Point Beach is fallacious.
With reduced demands, decommissioning Point Beach would result in higher economic and environmental costs to produce the remaining energy. Thus I
conservation is not the true issue in the context of the Point Beach plant. Rather, the issue raised by Mr. Anderson is whether some combina-tion of the safety, economic, and environmental costs of Point Beach make
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it the worst plant on the utility system. We have found no evidence that l
that is the case.
- 4. Availability of Conservation It is likely that additional conservation would be available in sufficient quantities to replace Point Beach 1, even though such a strategy would not be the most effective use of const:vation. It is l
difficult to estimate how icng it uvuld take for such a level of incre-
' mental conservation to be implemented. A 1978 study by the Carnegie-Mellon Institute estimated the investment cost of conservation measures on a national basis of 7-15 billion dollars (1978) per quad per year (1 quad = 1015 Btu) . Point Beach I can produce approximately 0.011 quads per year. Thus the cost of conservation equivalent to Point Beach 1 out-put would be approximately 77-166 million dollars in 1978 dollars, or 100-220 million dollars in 1981 dollars, assuming that 1978 national figures can be used for Wisconsin. It is likely that the additional conservation installed between 1978 and the present would have been the most cost i
I effectivo leaving the remaininr. nynilabic conservation more costly. liow-ever, if the cost figures remain valid, the approximately 35 million dollars which repair of Point Beach 1 might cost would purchase conserva-tion equivalent to about 80-175 MW, or 16-35% of the unit's capacity.
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F. Description of Present Environment All construction would be at an existing site. The total site is approximately 1,260 acres of which 43 acres are occupied by the plant, roads, switchyard, etc. The proposed activities would be within this area or next to the security fence on the north, where the area was disturbed during plant construction. This previously disturbed area has reverted to grass. Figure 3 shows the location of present and proposed buildings.
In the past 15 years, the major local population change has been in the village of Mishicot which grew by 500 people. Residential land use increased proportionately. The town of Two Creeks lost about 75 people. Land use out-side the village of Mishicot has changed very little since 1966; dairying is the dominant land use. The area is gently rolling. There are low bluffs along Lake Michigan. The soil has a high clay content so drainage is poor.
G. Impact of Proposed and Alternate Actions on the Environment
- 1. Air The major environmental impact of these actions is from generation of replacement power at coal and oil fired power plants. The environmental impacts of coal, and nuclear plants have been previously described in the environmental assessment of the 1976 Advance Plan and the environmental assessment of the 1978 Advance Plan. Table 3 gives the annual emissions of sulfur dioxide and oil use by the EWU system for the proposed and alternative actions. Emissions of nitrogen oxides and particulates parallel those of sulfur dioxide. The bottom line compares the alterna-tives with the proposed action (sleeving) Also shown are typical annual emissions from Oak Creek 5-8, Columbia 1 and 2, and a typical newer coal plant -- all assumed to operate as base ic ded units. The new unit corre-spor.ds to a unit that might replace Point Beach Unit 1.
Some of the replacement power would be gererated at newer power plants (built since 1970). During licensing of these units, it was shown that emissions from maximum operations, using the poorest expected quality of fuel, with the worst meteorological conditions would not cause a violation of ambient air quality standards. Some of the replacement power would also be generated from older power plants in southeastern Wisconsin. Effect of emissions from these units on ambient air quality has recently been reviewed. Under certain conditions, these units are under operating restrictions.
No single power plant generates the major portion of requir3d replace-ment power. Thus the impacts would not be localized geographically, but spread throughout the entire EWU system. Estimated increases in emissions from each power plant were not presented here since they could not be used to predict increases in ambient pollutant levels. It is not possible to i
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16 Table 4 Environmental Effects of Options 011 is in millions of gallons S02 is in thousands of tons Proposed Replace No Action 1 Decommission Sleeve Steam Generators Replace in 1991 Now Oil 50 011 502 011 Year S0y 011 SO2 2 492 42.7 479 32.2 479 32.2 517 56.1 1981 1982 488 44.1 486 35.5 486 35.5 536 68.8 483 33.6 507 47.4 499 40.7 524 50.6 1983 483 32.3 498 49.0 497 39.2 527 41.4 1984 1985 472 19.7 472 19.7 487 23.6 537 45.1 481 27.5 481 27.5 495 32.8 541 61.8 1986 511 47.4 511 47.4 524 55.6 565 72.6 1987 534 71.3 534 71.3 546 76.0 585 93.7 1988 1989 537 76.8 537 76.8 548 82.5 580 93.2 526 64.6 526 64.6 538 68.4 556 72.1 1990 ,
1991 517 61.5 517 61.5 539 72.7 540 65.6 514 56.3 514 56.3 520 58.7 537 60.1 1992
~~'
Total 81-92 6040 577.8 6062 589.2 6158 617.9 6545 781.1 Differential 98-07 0 0 0 0 0 0 345 0 Cumulative Total Emissions 1981-2007 6040 577.8 6062 589.2 6158 617.9 6890 78).1 Differential wrt Sleeving -- -- 22 11.4 118 40.1 850 203.3 Annual emissions for selected plants:
Oak Creek 5-8 (c.f. 72%) S0y - 131 (1057 MW)
Columbia 1 6 2 (c.f. 77%) S0y - 51 (1032 MW)
New unit (c.f. 70%) S02 - 13 to 20 (500 MW) l l
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17 predict the meteorological conditions at the time replacement power would be generated, nor the exact time when it would be generated. This infor-nation is required for air quality modeling.
Even if exact increases in emissions from each power plant were presen-ted here, it would not be possible to predict increases in ambient pollutant levels.
Air quality modeling can give you estimated increases in concentration above background levels, but only for specific test conditions. The actual increase in pollutant concentrations would depend on plant design charac- .
teristics such as stack height and pollutant exit speed, meteorological conditions such as wind speed, wind direction and mixing heiF ht and topo-graphical considerations such as presence of bluffs, hills or valloys.
The environmental impact from air pollutants of increased operation of coal fired power plants would depend on the resulting ambient air pollutant concentration and on the sensitivity of the environmental resou rce in ques-tion, such as human health, animals, or plants. The impacts t, human nealth, animals, vegetation, ecosystems and materials from coal-fired pol-lutants including acid rain were discussed in detail in the Assessent of the 1978 Advance Plan for Future Electric Power Facilities and testineny in the second Advance Plan preceedings (05-EP-2). Additional analysis of the environmental effects of coal fired generating station pollutants is under-way in conjunction with preparation for the third Advance Plan (05-CP-3).
It is clear that decommissioning causes much greater pollutant emis-sions and entails much more use of oil than the proposed action. Delaying action until 1991 would also have significant effects on air pollutant emissions and oil use. The proposed action and the replacement option differ slightly, due to the difference in timing of action and the duration of outage.
Decommissioning also differs in the number of spent fuel assemblies that must be sent to a proper disposal area. At present, there are 180 spent fuel assemblies stored at the Point Beach site. In previous years, 108 120 assemblies were sent to Nui. lear I-uel Services near Buffalo, N.Y.,
to the General Electric facilities at Morris, IL for storage and 1 to Battelle Columbus for inspection (from both units). If Point Beach I operates until 1991, there would be an additional 320 assemblies; if to 2007, an additional 832 assemblies which would require proper disposal.
ne significance of the additional 832 fuel assemblies to dispose of must be viewed in the context of the high level waste disposal problem.
D e problem is national in scope, with the federal government assuming responsibility for spent fuel once it is shipped to them for permanent disposal. There is no means of permanent di.:posal presently available, The U.S.
only interim storage until a federal repository is constructed.
Dept. of Energy is presently developing siting studies for a deep geologic repository (or several regional repositories in several rock media) to
18 commence construction by 1990, and' commercial operation in about the year 2000. The federal program is being sized to accept wastes from the entire U.S. nuclear industry.
Staff recognises that spent fuel disposal is a serious problem, one which is receiving much attention at the federal and state levels. How-ever, the ultimate issue relative to the additional 832 spent fuel assen-blies is whether they will in any way alter the outcome of the federal program. Existing nuclear plants will generate approximately 150,000 spent fuel assemblies over their lives. Staff believes the increment (.6%)
represented by the additional Point Beach 1 spent fuel assemblies will affect neither the outcome of the federal repository program nor the need to develop it.
A seconlary issue concerns the question of storage of these addi-tional assemblies pending the availability of a federal repository. WEPCO has, and will continue to have to acquire on and off site storage for the Point Beach Unit I and 2 spent fuel assemblies. First, WEPCO has on site storage capability (in addition to the 180 assemblies already there) for 1322 fuel assemblies. This would hold the discharged elements from both units through the year 2000. Second, irrespective of whether Point Beach I was decommissioned, WEPCO would be providing storage for the existing ele-ments plus up to about 900 more from Unit 2. Third, the storage of spent fuel assemblies must be maintained until a federal repository is available for permanent disposal. The existence of adequate on site storage capacity for both Point Beach units through 2000 and the fact that WEPCO must main-tain a spent fuel storage program regardless of Point Beach 1 status has convinced staff that the additional 832 elements are not a significant factor in this case.
Decocaissioning would also result in the elimination of low level wastes generated by Point Beach 1. Presently both units(In together generate 1979, 9504 ft 3 6,000-10,000 cubic feet of low level wastes annually.
o' wastes containing 1220 Curies were transferred from the site in 20 ship-ments.) As an estimate, about one-half of the low level wastes would remain for shipment on an annual basis if Point Beach I were decommis-sioned. For perspective, total low leve' wastes shipped from Wisconsin in 1979 was 20,108 cubic feet. _
- 2. Water lleated water discharge will be cut by not quite one-half while Unit 1 is being repaired. Discharges will not drop to :ero unless both units increase are down at the same time. Sanitary discharges to Lake Michigan will not because wastes from the increased number of workers will be trucked offsite.
If the water usually in the primary and secondary loops is stored, there would be minimum other discharges. With the unit shut down, discharge of liquid containing radionuclides should be very slight.
19
- 3. Terrestrial Environment All construction activity is expected to occur within the security fence or just north of it. The area north of the fence was disturbed when the plant was originally built. Thus land use and terrestrial ecosystem impacts are expected to be minor.
It is not known how the steam generators will be delivered. They will probably be shipped by barge. If possible, they will be unloaded in Kewauneo and shipped overland to the site. If necessary, a barge slip will be dredged -- about where one was dredged during original construction.
The slip would extend about 105 feet into the shore area and 215 feet out into the lake. The top width is 80 feet, the bottom width 60 feet (see After Figure 4). The depth would be about seven and one-half feet.
delivery, the slip would be allowed to fill in naturally.
- 4. Implications of Storage of the Illd Steam Generators The old steam generators contain radiation in the form of deposited radioactive crud. This crud is predominantly oxides of metallic activated corrosion products. Each steam generator lower assembly may contain About 85%
between 250 and 1000 Ci of radionuclides in this crud.*
of the radiation from this crud is from two nuclides of cobalt (Co-58 and Co-60). The following tables show the source of the radiation and the estimated curie content of crud deposited on the channel head. (Different amounts of crud are deposited in each part of the steam generator, the amounts shown do not represent total deposition in the entire steam generator.)
Table 5 Sources of Radiation from Deposited Crud Radionuclide Percent of Radiation Cr-51 <.2 Mn-54 .8 Co-58 29 Fe-59 <.2 Co-60 70 Zr-95 <.2
- 0ffico of Nuclear Reactor Regulation, U.S. Nuclear - Steam Regulatory GeneratorCommission Repair, Surry (July 1980), Final Environmental Statement Power Station, Unit 1. NUREG-0692.
Ibid. (December 1980), Draft Environmental Statement - Steam Generator Repair, Turkey Point Plant Units 3 and 4. NUREG-0743.
floenes, G.R. , M. A. Mueller, W.D. McCormack (December 1980), Radiological Assessment of Steam Generator Removal and Replacement: Update and Revision NUREG/CR-1595 (PNL-3454) .
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20 Figure 4. Dimensions Barge Slip.
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21 j Table 6 Contamination Levels on a Steam Generator Channel Head (After 7 Years of Operation)
Activity Radionuclide Activitg)
(uCl/cm Radionuclide C.Ci/cm4)
Cr-51 1.35 - I-131 0.45 Mn-54 2.03 I-132 0.45 Co-58 25.03 Te-132 0.45 Fe-59 0.465 Cs-137 0.067 Co-60 18.1 Ba-140 0.45 Zr-95 2.25 La-140 1.35 Nb-95 3.15 Ce-141 0.75 Mo-99 0.45 Cc-144 3.72 Ru-103 1.5 Np-239 4.8 A portion of the crud is " loose," that is, it could be dislodged if the steam generator is dropped. A conservative amount of " loose" crud is 35%.
Steel caps will be welded over all openings in the steam generator lower assemblies before they are removed from the containment. Airborne releases are possible if the steam generator assembly is dropped during handling in such a way that one of the welds fails (both are low proba-bility events). At the Turkey Point site, such a release was estimated to cause a 15 mrem exposure to the lungs of someone at the site boundary.
The options for steam generator handling are: on site storage until the plant is decommissioned, intact shipment to a disposal facility immediately after replacement, or cutting the lower assembly up and ship-ping the pieces to a disposal site immediately. Storage on site would be in a building with walls thick enough to attenuate radiation to levels which allow unrestricted access. The building will keep the stored lower assemblies dry and building air will pass through a HEPA filter. Estima-
) ted annual site boundary dose from on site storage is on the order of The con-I mrem. Shipment intact would require use of a shipping cask.
ceptual design of such a cask is: 42' long, 20' diameter, weight 132 tons. The weight of a lower assembly is 173 tons so the weight of a loaded cask is 305 tons. The lower assemblies could be barged to a landing 40 miles from the Barnwell, S.C. waste disposal site. Traffic would have to be stopped to allow passage of the cask. Movement of the cask over this stretch of road on four occasions (to and from for two lower a,semblies) could damage the road. If the lower assembly is cut up prior to shipment, airborne releases of radioactive crud vaporized by O
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22 the cutting would occur. Estimates of occupational exposures and airborne releases are shown below.
Table 7 Steam Generator 1.ower Assembly Handling Options (For Two Assemblies)
Radiation Exposures and Releases Occupational Airborne Exposure Releases (man-rem) (Ci)
Store until decommissioning then ship intact 20. Negligible Ship intact immediately 4.S Negligible Store until decommissioning then cut up and ship 32. 0.010 Cut up and ship immediately 1160. 0.084 The cost of on site storage is predicted to be one million dollars.
Cost of shipment from Wisconsin to a storage site nas not been estimated.
(From Turkey Point to Barnwell, a 600 mile one-way trip, the estimate is $870,000.) There are barge unloading facilitics near the Barnwell but not the Hanford site. The estimated cost of cut;ing up and shipping is about $1.8 million. Thus on site storage until decommissioning is the option with the lowest occupational and public radiation exposure.
S. Low Level Radioactive Wastes Both sleeving and replacement would generate some low level radio-active wastes. In both cases there will be water cleanup actions which create volumes of contaminated ion exchange resins and evaporator con-centrates. Miscellaneous tools and the scaffolding required to get to the work areas are contaminated. The scaffolding includes that used to enclose areas where cuts are made (and plastic) in order to contain any vapori:ed crud. During cleanup of surfaces, rags and paper are contami-nated. Clothing worn by workers is laundered where possible and included in low level waste as necessary. The estimated volumes of these wastes and the contamination levels are shown below; the volume corresponds to 35 truckloads.
23 Table 8 Low Level Waste Volumes Sleeving Replacement Volume Activity Volume Activity (cu . f t . ) '(Ci) (cu. ft . ) (Ci) 100 5 100 5 Ion exchange resins i
500 5 500 5 Evaporator concentrates Miscellaneous tools and Negl.
scaffolding 2,000 Negl. 2,000 Miscellaneous rags, paper and clothing 15,000 150 15,000 150 Total 17,600 160 17,600 160 The estimates for other sites have been:
Volume Activity Turkey Point /3 steam generators / replace 38,850 130 to 270 Surry 2/3 steam generators / actual replacement 57,140 64 Generic /3 steam generators / replace 78,300 57 San Onofre/3 steam generators / sleeve 10,600 100 The Point Beach volumes assume compaction. Whether wastes at other sites are compacted or not is unclear. No specific isotopes are identified.
Low level wastes from Point Beach are now shipped to three sites:
Barnwell, South Carolina, Beatty, Nevada and Hanford, Washington. There are local pressures in each area to stop accepting wastes from out of state. If sleeving is done this year, wastes can probably be shipped.
If the steam generator lower assemblics are replaced between 1983 and 1990, it is less certain that the wastes will be accepted by one of these three sites. If that is the situation, and if no regional or in state disposal site has been opened, the wastes may have to be stored on site until a disposal facility is opened. The steam generator storage building is well designed for such storage.
-=
24
- 6. Release of radionuclides - public exposure During either repair option (sleeving or replacement), there would be no routine releases due to operating Unit 1. At the start of either repair operation there would be releases due to removal of the reactor fuel, sini-lar to releases in any refueling operation. For other units, U.S. Nuclear Regulatory Commission (NRC) staff have estimated that releases during repair will be much less than routine annual releases.
NRC staff predict that either repair option will reduce releases during operation due to increased steam generator tube integrity and decreased primary to secondary coolant leakage. NRC staff ranks the alternatives in order of increasing amount of routine radionuclide releases as: steam generator replacement, tube sleaving, lo115wed by continued operation and tube plugging.
- 7. Occupational radiation exposure NRC staff estimate the occupational exposure for the three options to be:
Tube sleeving 1230 man rem Steam generator replacement 1380-1520 man rem Continued operation for 10 years 670 man rem Thus the exposure for tube sleeving followed by steam generator rep would be 2610-2750 replacement would be 2050-2190 man rem.
Their estimate is based on actual exposures to workers during replace-ment at Surry 2 (Virginia) and estimates for Surry 1, Turkey Point 3 and 4 (Florida), and Palisades (Michigan) for sleeving at San Onofre 1 (Califor-nia), and actual exposures during steam generator inspection and tube plug-Their ging at Point Beach. Average exposure per worker was roughly 2 rem.
conclusion on the significance of these exposures is as follows:
"In each case the plants in question took steps to ensure occu-pational exposure was less than the limits set forth in 10 CFR The Part 20 and was maintained as low as reasonably achievable.
estimated doses were reasonable and fell within the normal range of occupational doses (i.e. radiation exposures) observed in recent years. The additional health risks due to these doses over normal risks were quite small, less than one percent of nor-mal risks to the project work force as a whole. The doses to the work force as a whole and to the average worker will be within the variations in lifetime doses due to natural background radiation in the U.S."
25
- 8. Labor force Radiation workers may receive a radiation dose of 3 roms per quarter, not to exceed S rems per year. If the average dose per worker is kept to 2 rems, the anticipated number of workers would be (using NRC estimates of occupational dose):
615 workers for full-scale sleeving; and 690-760 workers for replacement.
WEPCO believes that the actual doses at Point Beach will be less than this, and that the required work force will be sms11er. Dose estimates will be available after the sleeving demonstration this summer. Making measure-ments before then would entail additional occupational radiation exposures.
Dose estimates will determine t he number of workers. In any case, there would be additional supervisory personnel who would receive little to no radiation exposure. WEPCO plans to hire as many skilled workers as pos-sible from the local labor pool. Workers would be employed for a few weeks for the sleeving option and for a few months for the replacement option.
- 9. Safety If the steam generators are sleeved, safe repair, reactor startup and operation procedures will be the responsibility of NRC. If NRC's procc-dures are parallel to those for San Onofre 1 in California, we assume that review of return to power will involve a safety evaluation. The NRC staff have concluded, in the San Onofre case, that sleeving is a sound repair technique (letter of November 28, 1980 from Dennis M. Crutchfield to Mr. R.
Dietch and attached " Interim Assessment" Docket 50-206).
i If the steam generators are replaced, we assume that Point Beach 1 l
would be no less safe than any well run existing reactor.
NRC staff have informed PSC staff that if the "no action-continued operation" alternative is chosen, "as long as the required analyses are l
performed and acceptance criteria met, the risk or severity of an accident -
would not be increased as the number of steam generator tubes plugged increases from 12% to 30%" (letter of Ft vary 11, 1981 from Robert A. Clark to Jerry E. Mend 1).
n Use of Resources For sleeving, about 12,000 pounds of Inconel 600 alloy will be used.
l Because WEPCO plans to purchase the steam generators for either sleeving or replacement, the material in the steam generators will be the same for either of these alternatives. For the replacement alternative, the esti-mated material requirements are: 500,000 pounds of steel, 300,000 pounds of Inconel 600 alloy and 1,600 cubic yards of concrete.
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Inconel would be irreversibly committed. The steel in building walls is expected to be recovered from the containment access building. The steel in the operations building could be recovered when the plant is retired.
Other amounts of steel and concrete are irreversibly committed. The materials required for decommissioning are presently unknown.
I. Cumulative Impacts See discussion of system impacts, costs, emissions of air pollutants and spent fuel.
.l . Secondary Impacts The proposed action and replacement are expected to have no significant secondary effects. The decommissioning alternative would require firm capacity purchases in 1987-1989 and would increase the si:e of the next two coal fired power plants to be added by EWU (1989 and 1990) by 250 MWe each.
Pleasant Prairie 2 would have to be completed 15-16 months earlier than is now planned.
K. Reaction of Experts
- 1. If a barge slip is required, both the Nisconsin Department of Natural Resources and the U.S. Army Corps of Engineers would have to authori:e the dredging. The beach sand would have to be sampled for sign of contaminants.
- 2. Role of U.S. Nuclear Regulatory Commission (NRC). In preparing this environmental screening, PSC staff solicited the advice and assis-tance of staff of NRC which has jurisdiction over and expertise on issues of occupational and public radiation health and safety. PSC staff informed NRC staff that the environmental screening should disclose and analyze environmental impacts that are outside the expertise of the reviewing agency. NRC comments were solicited in much the same way comments from DNR or the State Historical Society are solicited. A copy of the NRC response is attached.
L. Permits Required
- 1. If a barge slip is required, permits from both the U.S. Army Corps of Engineers and Wisconsin DNR will be required. It usually takes the Corps of Engineers 90 days to process an application for the necessary per-mit. If there are no obje:tions, it usually takes DNR 60 days to process i a Chapter 30 permit. If there are objections, it may take 120-180 days.
Thus if a barge slip will be required, applications should be filed at least 6 months in advance with these two agencies.
l l
27
- 2. It is not presently clear what permits will be required from NRC.
Their actions will depend upon the option chosen. Their cosanon standards for licenses are shown below.
STANDARDS FOR LICENSTS AND CONSTRUCTION PERMITS 10 CFR 550.40 Conunon Standards
' In determining that a license will be issued to an applicant, the Nuclear Regulatory Commission will be guided by the following considers-tions:
(a) The processes to be performed, the operating procedures, the facility and equipment, the use of the facility and other technical specifications, or the proposals, in regard to any of the foregoing col-1ectively provide . . . that the health and safety of the public will not be endangered.
(b) ... (financial qualifications).
(c) The issuance of a license to the applicant will not, in the opinion of the Conunission, be inimical to the conunon defense and security or to the health and safety of the public.
M. Contacts with the Public Copies of all consnents and our responses are attached.
u.- % ~
ST)SPVRc&
TOWN OF TWO CREEKS . c ,.' , .3.t u m* : m - *
ROUTE 3 p TWO RIVERS, WISCONSIN b4241 "f4 81 FEii -2 P1 :36 g $@
yt.B f
l January 28, 1981 To Sarah Jenkins:
4e, the Town Board of Two Creeks wish to make a comment on File Jumber: 6630-CE-20.
We think the Wisconsin Electric Power Company should have the right to fix their plant any way they feel is safe.
We are not interested in decommissioning Point Beach plant number 1. de do not feel there will be a great impact an our community, Sincerely, To Cheirman capervi sup rvisor i
1
29 Response to Town of Two Creeks Sirs: The Public Service Commission must review utility actions to ensure that the proposed action is reasonable from an engineering, economic and environmental standpoint. The economic review must balance the finan-cial health of the utility against the interests of the ratepayers (adequate and reasonably priced supply of electricity). PSC staff must review the environmental impact of utility actions and determine the relative impacts of the proposed and alternative actions.
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30 stars soAmo or omectons
- Prof. John Nees. tuscutM omoc1os M. Joonte Deeceo cm
- Poser Anoereen. nac uwe erscas Pew Anoereon Dr. unoo Memooe Sporter Bock.MCUu:uc*scocuoMoe Prot. Georp socker Prof. John Neees Mary ea==e. cacree ce anaosw.r vtcort Hainees mehoro presnes Kapteen Fost. Esq. cesan ecusa shery imerman Nchoes Secy. Eso. Musgeset Thegeon. scoeures unce Heen - Thomas von Ahoo Dorow Loosnoce m Wofoon ,
Acstn urceoy Arre we reorg merwee usee James were 302 iest wesrwsten Aw Moosen ws:enin 53703 (eO8) 251-7020 ,
c-February 2, 1981 c,5 gy "m
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-m 'tJ PUBLIC SERVICE COMMISSION OF WISCONSIN Att: Sarah Jenkins 4 j 4802 Sheboygan Avenue g
~C Madison, Wisconsin 53702 -g Re: Wisconsin Electric Power Company .
~"
PSCW Docket 6630-CE-20 m ,
(Screening Co=nents) CD
Dear Ms. Jenkins:
G5 Reference is made to your letter dated January 20, 1981, requesting 9 comments on the environmental screening worksheet in the above-matter.
The primary coccent that we would make from reading your letter is that three major factors appear to have been omitted in balancing the costs and benefits of continued operation of Point Beach Nuclear Plant Unit 1.
First, nuclear safety issues must be considered. Your attention is directed to the 1975 report of the American Physical Society which concluded that corroded steam generator tubes "could induce essentially uncoolable conditions in the course of a loss-of-coolant tecident".
Second, ic:pending costs of continued operation of the facility must also be considered. Your attention is directed to growing concerra that radio-active crud buildup and reactor vessel embrittlement will cause further sub-stantial repair costs by the twentieth year of plant operation.
Third, conservation cust be considered as an alternative means of meeting power demands that would otherwise be met by the unit were it to be shut down.
If you would like further detail in regard to any of these matters, please do not hesitate to call.
Sincerely, WISCON S E; win 0NMEh
- ECADE, INC. !
By:
P .r.R Ait"tRSON Public Affairs Officer l 4 .ocs - m oc. l PA/cm ,
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' 31 1
Response to Mr. Anderson's Comment A. With regard to your concern about the safety implications of corroded steam generator tubes.
- 1. If the steam generators are replaced, this concern becomes moot.
- 2. If sleeves are inserted into the existing steam generator tubes, J safe repair, startup, and operation procedures would be the responsibility of NRC. If NRC's procedures are parallel to those for San Onofre Unit I in California, we assume that review of return to power will involve a safety evaluation. The NRC staff have concluded, in the San Onofre case, that sleeving is a sound repair technique (letter of November 28, 1980 from Dennis M. Crutchfield to Mr. R. Dietch and attached " Interim Assess-ment" Docket 50-206).
- 3. If the no action alternative is chosen, NRC staff have informed PSC staff that "as long as the required analyses are performed and accep-tance criteria met, the risk or severity of an accident would not be increased as the number of steam generator tubes plugged increases from 12% to 30% (letter of February 11, 1981 from Robert A. Clark to Jerry E.
Mend 1). PSC staff analysis indicates that this alternative would be more costly and more environmentally damaging than the sleeving or replacement options, and thus a less desirable choice.
Further, the NRC staff prepared Safety Evaluation Reports Related to Steam Generator Tube Degradation Due to Deep Crevice Corrosion on November 30, 1979 and April 4, 1980. Even if sone tubes collapse during a postulated Loss of Coolant Accident (LOCA), the resulting leakage would be tolerable. In Appendix A of this document, two tube defect situations were considered (a crack 10 inches below the top surface of the tubesheet and a guillotine rupture .5 inches below the top of the tubesheet). In both cases, it was concluded that "a very large number of tubes must be simultaneously broken in a guillotine manner to induce a large total in-leakage (from secondary to primary coolant] (>1300 gpm) to be of concern regarding the steam binding effect." "Thus, the concern in the Wiscon-
' sin's Environmental Decade's Petition of November 14 and 26,1979, regard-ing the APS study of steam binding is not an applicable concern in this case."
- 4. The 1981 retirement of Point Beach Unit I would also make your con-cern moot.
B. Re possible costs to cure crud buildup or to reduce reactor embrittle-ment.
NRC staff have informed the PSC staff that Mr. Anderson's concern with radioactive crud buildup was the result of problems at Dresden 1. That was determined by NRC to be a special case, and large-scale decontamination is
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32 Decontamination, where not expected to be necessary at Point Beach.
required, is not a costly operation.
NRC staff informed PSC staff that some of the components of nuclear reactors (specifically the core shield) are designed to retard serious reactor embrittlement. NRC has finished a generic study of this probles, entitled " Resolution of Reactor Vessel Material Toughness Safety Issue,"
NUr3G 0744, which is scheduled for release April 15. NRC staff predict that Point Beach I will retain an adequate safety margin throughout its life.
C. Conservation must be considered The forecast used already includes the effects of anticipated conser-vation efforts. Where either conservation or energy from alternative sources reduces the demand for electric energy, it makes the most sense to reduce generation frem the most expensive to operate and most environmen-tally damaging units first. If this is done, the last unit to cene off line will be the nuclear units. Thus conservation as a means of reducing costs and environmental damage makes sense at all times but would affect the operation of plants other than Point Beach. It is not an issue in this case.
33 PUBLIC SERVICE COMMISSION OF WISCONSIN DEPARTMENTAL CORRESPONDENCE 6630-CE-20 Date: February 27, 1981 To: File 6630-CE-20 From: SarahJenkinsshI
Subject:
Phone Conversation with Mr. Robert IIalstead, Of fice of Coastal Management, February 5, 1981, 4:15 p.m.,
Regarding Screening Announcement Mr. Halstead stated that the Office of Coastal Management would like to see an EIS in order to adequately address the following points:
- 1. The extremely small possibility of a nuclear event
[ accident] during the process of ccmpletely draining the cooling system and removing the core, and storing it in the spent fuel pool.
- 2. To quantify the release of radiation to the offsite environment.
- 3. The probability of and degree of radiation exposure of workers -- what number of workers and what worker burnup.
- 4. Unknown but possibly major construction period impacts -- the design of the storage building, possible need for a barge slip.
- 5. The unknown health, safety and institutional impacts of on-site disposal of medium level and low level wastes (quantif'ied in previous testimony). This is creating a precedent.
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34
- 6. Major reason: a desire to see a thorough compara-tive analysis of replacement with respect t.o sleev-ing including the costs of the options and possible air quality impacts.
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35 Response to Mr. H,1 stead - Office of Coastal Management
- 1. Possibility of accident while draining cooling system and removing reactor core.
R: The possibility of such an event is only slightly greater than for a normal refueling.
- 2. Release of radionuclides offsite.
R: See section F6. (revised section G7)
- 3. Occupational exposure to radiation.
R: See section F7. (revised section G8)
- 4. Possible construction impacts.
R: See section F. (revised sections G2,3,3)
- 5. Unknown health, safety and institutional impacts of on-site disposal of medium and low level radioactive waste.
R: 'The only waste storage lasting more than a few months will be storage of the radioactive steam generators if the replacement option is chosen. Because no waste site could handle the steam generator lower sections now, it makes sense to store them on-site until Point Beach Unit 1 is decommissioned at which point four rather than two steam generators would have to be dealt
' with.
- 6. A comparative analysis of the options of replacement and sleeving --
economics, air quality.
R: See entire document.
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/ 'o. UNITED STATES ,. ,.,. qg
- % NUCLEAR REGULATORY COMMISSION
- E WA36HNOTON, D. C. 20065
\,,,,,. February 11, 1981 ,;) ;g 13 $q1 g3J GENDR State of Wisconsin Public Service Commission Hill Fams State Office Building Madison, Wisconsin 53702 Attention: Jerry E. Mendi
Dear Mr. Mend 1:
In your letter of January 16, 1981 you presented three questions concerning radiological health and safety aspects related to possible steam generator replacement at the Point Beach Nuclear Plant and other alternative courses of action. You pointed out that these questions were raised as part of an environmental screening in response to Wisconsin Electric Power Company's app 1tcation for authority for the acquisition of replacement steam generator lower assemblies and primary moisture separators for Point Beach Nuclear Plant, Unit 1, to determine if a state environmental impact statement is required.
Our response to the specific questions of your January 16 letter is as follows:
- a. "For the alternatives of steam generator replacement, steam generator resleeving, and continued operation at decreased capacity (no action), how does each alternative affect the amount and kind of routine radionuclide releases and ensuing public radiation exposure?"
Since we have little operating experience to gage the effectiveness of tube sleeving as a repair mechanism we will assume that tube sleeving will yield tube integrity that can only approach that of a replaced steam generator. Either replacement of steam generators or tube sleeving would be expected to reduce the amount of routine radionuclide releases due to the anticipated increased tube integrity of new or sleeved tubes, compared to tubes that have experienced some measurable degradation due to various types of corrosion.
There currently exists some small but continuous leakage from tubes in the Point Beach Unit 1 steam generators. This leakage does not approach the Ifmits in 10 CFR Part 20 and is kept under close surveillance. The Point Beach license imposes strict requirments to control and maintain leakage rates within allowable Ifuits. Close surveillance of leakage is expected to continue regardless of which af ternative is chosen.
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37 Based on the above, the ranking of alternatives as to the least amount of routine radionuclide releases would be steam generator replacement, followed by tube sleeving, followed by continued operation and tube plugging.
Finally, none of the alternatives affect the kinds of routine radionuclides released as they have no effect on the fission process.
- b. "How do the above alternatives differ with respect to occupational radiation exposure?"
From data obtained from nuclear facilities conducting operations similar to the mentioned alternatives we estimate the occupational radiation exposure as follows:
- Steam generator replacement Name Estimated Dose Measured Actual Dose Surry 1 2070 man rem Surry 2 2070 man rem 2140 man rem Turtey Point 3 2100 man rem **
Turty Point 4 2100 man res **
Palisades 1519 man rem Based on the above, the estimated dose for Point Beach would be about 1380 to 1520 man rem for replacement of its two steam generators.
Tube Sleeving I Southern California Edison Corrparty (San Onofre 1) estimated a total occupa-tional dose of 1800 man rem for the 7,000 steam generator tubes to be f sleeved. Based on Point Beach's estimate of an upper limit of 4,800 steam j
generator tubes as potential candidates for sleeving, the estimated dose I
would be about 1,230 man rem.
Continued Operation Point leach's last steam generator inspection and tube plugging yielded an l
occupational dose of 33.6 man rem. We feel this is a representative
- The Surry and Turtey Point estimates are for three steam generators, the Palisades estimate for two steam generators.
- AcP.ual occupational exposure is unavailaole as the steam generator replacement has not yet been performed.
38 number for future inspections and resulting tube plugging. Assuming an average of two steam generator inspections per year over the next ten years the total dose from these inspections and any associated tube plugging would be about 670 man rem.
In conclusion, estimated doses for the three alternatives are:
steam generator replacement 1380 - 1520 man rem tube sleeving 1230 man rem continue:1 operation (no action) 670 man rem Copies of the radiological evaluations for steam generator repair or replace-ment at the nuclear facilities previously mentioned are included for your i nf ormation. The following general conclusions were reached in these reports:
"In each case the plants in question took steps to ensure occupational exposure was less than the limits set forth in 10 CFR Part 20 and was main-tained as low as reasonably achievable. The estimated doses were reasonable and fell within the normal range of occupational doses (i.e. radiation exposures) observed in recent years. The additional health risks due to these doses over normal risks were quite small, less than one percent of norsal risks to the project work force as a whole. The doses to the work force as a whole and to the average worker will be within the variations in lifetime doses due to natural background radiation in the U.S."
- c. "If the no action option is chosen, is the risks of, or possible severity of an accident increased as the number of plugged steam generator tubes increases from 12% to 30%?"
To increase the allowable number of tubes plugged in a steam generator beyond the current limit of 18% would require a license amendment request from Wisconsin Electric Power Cogany and an acco@anying safety evaluation. An analysis of the emergency core cooling system performance would be submitted by the licensee and would require our approval for the new plugging limit.
We have reviewed the applications for increasing the plugging limit of the Tudey Pont Units 3 and 4 steam generators to 25% of total tubes plugged, the Point Beach Unit 1 steam generators to 18% of total tubes plugged and Surry Units 1 and 2 steam generators to 28% of total plugged. The conclusions reached in these analyses were that the increase in plugging limits "does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin". It is our belief, therefore, that as long as the required analyses are performed and acceptance criteria met, the risk or severity of an accident would not be increased as the number of steam generator tubes plugged increases from 12% to 30%.
1
I 39 We hope we have satisfactorily answered your questions and are including copies of the environmental assessments referenced in this letter for your information. If you have any questions, please contact T. G. Colburn at (301) 492-8129.
Sincerely.
Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing Erclosures:
- 1. NRC letter to SCE, dated November 28, 1980
- 2. NRC letter to VEPCO, dated January 20, 1979
- 3. NRC letter to VEPCO, dated May 9, 1979
- 4. NUREG-0692
- 5. NRC letter to FPL, dated June 12, 1980
- 6. NUREG-0743
- 7. NUREG-0756
, 8. NUREG/CR-1595 l PNL-3454 cc: w/o enclosures See next page
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Docket No. 50-266 NS n Mr.- Jerry E. Mendl - 8.*u- #88/
WEPA Coordinator N Wisconsin Public Service Comission State of Wisconsin Hill Fams State Office Building Madison, Wisconsin 53702
Dear Mr. Mend 1:
This is in response to your letter of February 23, 1981, wherein you asked 3:
about the possible costs of operating a facility with radioactive crud buildup and reactor vessel embrittlement. This response reflects the clarifications offered by both you and Mr. Peter Anderson of Wisconsin's Environmental Decade, Inc. in a conference call on February 23, 1981.
The question about crud stems from the knowledge that Commonwealth Edison Company has requested permission to decontaminate the reactor coolant system at their Dresden Nuclear Power Station, Unit No.1 (a dual cycle boiling water reactor). Information related to this decontamination operation
-(including costs), and the reasons for it, are contained in NUREG 0686,
" Final Environmental Statement Related to Primary Cooling System Chemical Decontamination at Dresden Nuclear Power Station, Unit No.1" (copy enclosed).
As discussed in Section 2.3 of this document, the reason for the request for decontamination at Dresden-1 is a special case. It should not be inferred from this that each nuclear plant will need to undergo this evolution after an operating period of about 20 years. Such is not the case. The crud levels at Point Beach are typical for pressurized water reactors. Although the possibility of a full-scale chemical decontamination at Point Beach over its lifetime cannot be ruled out, there is nothing to indicate at this point that it would be necessary. We should add that the steam Generators at Surry and Turkey Point are going to be or have been replaced without the need for chemical decontamination of the entire reactor coolant system.
Rather, local decontamination has been used to reduce occupational radiation exposure. These measures would probably be employed by WEPCO for either steam generator replacement or tube sleeving. No specific cost information is available, but the nature of the operation leads us to conclude that the cost is small.
As to your question about reactor vessel embrittlement, we learned from you that the question steats fron a discussion of Unresolved Safety Issues presented in the HRC Annual Report for 1979. We have enclosed the pertinent pages of this report for your convenience. The origin of this issue and its plan for resolution are summarized therein. Point Beach Unit 1 is one of the 20 older operating plants included in this summary.
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Generically, this issue is now satisfactorily resolved. Its resolution will be issued as NUREG-0744 to be titled, " Resolution of Reactor Vessel Material Toughness Safety Issue". This document is scheduled for publica-tion on April 15, 1981 for public comment.
As for Point Beach Unit 1, we fully expect that the pressure vessel will maintain adequate toughness and safety margins for the remaining If fe of .
the unit.
We have also reviewed, as requested, your draft response to Mr. Anderson's letter of February 2,1981 which you enclosed with your letter. We should point out that the San Onfre sleeving operation is not going as well as expected. Southern California Edison is having difficulty obtaining a leak-tight joint between the top end of the sleeve and the steam generator tube in certain areas. The problem is believed to be due to sludge. The Point Beach Unit I steam generators do not have a sludge problem of this magnitude, and therefore it may well be that this would not pose a problem for Wisconsin Electric Power Company. Edison is now installing leak-limiting sleeves in areas where leak-tight sleeves have proved difficult.
Your proposed response A.3 (second paragraph) warrants minor comment. In Appendix A to our Safety Evaluation Report of November 30, 1979, the NRC staff made two in-leakage calculations: the first assumed that a crack existed in a steam generator tube in the mid-depth of the tube sheet (about 10 inches); the second, more conservative calculation assumed that a steam generator tube had a complete circumferential (" guillotine")
break 0.5" below the top of the tubesheet.
Sine rely, Robert A. Clark, Chief Operating Reactors Branch #3 Divison of Licensing
Enclosures:
- 1. NUREG-0686
- 2. NRC Annual Report, pp. 75, 76
O.S. NUCLEAR REGULATORY COMMISSION 42 1979 Annual Report P00R ORlGlML w .
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- changes, to lengthen the time to crack initiation and to slow crack growth are taken into account in the deter-tion of pressure and temperature will remain well below that which might cause brittle fracture of the d mination of inspection techniques and criteria. reactor vessel if a sigaliicant flaw were present in the Q The CRD nozzle issue will be resolved by a com-bination of actions which includes nozzle inspection vessel material. The effect of neutron radiation on the fracture toughness of the vessel material is accounted h, fi and repairs and some CRD system notifications. Cer- for in developing and revising these technical specifi.
f!'t. tain system modifications recommended by General cations over the life of the plant.
N Electric involved cutting and capping the nozzle and For the service time and operating conditions return line but that action would reduce the capability typical of current operating plants, reactor vessel frac.
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to direct high pressure water through t! e CRD system when the vessel is otherwise isolated. Jthough this ture toughness provides adequate margins of safety-against vessel failure. Further, for most plants the system is not normally expected to peric.. : i this fune- vessel material properties are such that adequate frac-M. tion in safety analyses, the capability played a major ture toughness can be maintained over the life of the p
- { role in keeping the core covered during the incident at plants. However, results from a reactor vessel y Browns Ferry Unit 1 on March 22,1975. As a result of surveillance program indicate that up to 20 older
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ir the CE recommendations. Unless the licensees of the of operation. This issue has been incorporated in the sc'lC',
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s remaining plants demonstrate, by testing, that suffi-IP. cient flow is available to the feactor vessel with the h
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- specifications for power reactors set limits on the testmg of a weld. repair portion of a sa. inch thick prenure vessel.
t A flaw more than five mches deep and 13 inches ionic was created operating pressure during heatup and cooldown in the .re. which was then subjected to pressure overio.ds snare b,.,g -- }t. operations. These restrictions assure that the thancombina- double the design pressure, withoui disrupiive f..iure.
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develop appropriate criteria for the evaluation of nor-mal. transient, or pmtulated accidcht conditions under the improved method. This method could then Fracture Toughness and Potential for be used to provide such an assessment for those older Lamellar Tearing of PWR Steam Generator rtactor pressure vessels that will eventually have marginal toughness according to the current method.
And Reactor Coolant Pump Supports Because relatively large amounts of prefracture plastic deformation can be expected at high temperatures Dun.ng the course of liceming reu.cw for a specib.e i even in pressure vessel steels of low toughness, the new pressurized water reacter (PWR) a number of ques.
evaluation method will employ " clastic-plastic" frac- ti ns wem raised as to (1) the adequacy of the fracture ture mechanics concepts. The basis for this improved toughness properties of the material used to fabricate
' methodology is described in NUREC-0311, "A Treat- the reactor coolant pump supports and steam ment of the Subject of Tearing InstabilityJ' descioped generator supports, and (2) the potential fur failure under an NRC-sponsored progrun at Washington due to lamellar teanng of these same supports. The University. Additional Washington University work safety concern is that, although these supports are extending the methodo ogv to reactor pressure vessets designed for worst-case accident conditions, low frae.
was funded by the Department of Energy. The ture toughness er lamellar teanng couhi came thaup-engineering method deseloped will account for let to fait during such accidents. Support failure radiation induced material degradation. could conceivably impair the effectiveness of systems Task A-Il also includes or relies on programs spon- designed to mitigate the' consequences of the accident.
sored by the NRC Office of Nuclect Regulatory Re. An example of a postulated event sequenci.cf potential search to provide: (1) an improved evaluation of concern would be a large pipe break m the remetur material degradation mechanisms resulting from coolant system which would severely load the sup-neutron irradiation, and (2) the developruent of Im. ports, followed by a support failure of sufh,esent proved testing methods for me in determining the magn;tude that a major component such as a steam elastic-plastic properties of materials. generator would be displaced resulting in failure of the Since last year's report, the following has been ac- #* *'E'"#I "" #" *I* "* E *N "## P'*
vide cooling water to the core.
. complished: Because materials and designs similar to those cf the
- Although delayed, an clastic plastic fracture test PWR originally reviewed have been used in other method for routine determinatior of fracture plants, review of this issue was includad m the NRC toughness was developed. Verification of the test Program for Resolution of Cencric Issues as Cencric method is underway. Task A-12.
A consultant was engaged to reassess the fracture
- The elastic-plastic fracture mechanics methea.s of toughness ci the steam generator and reactor coolant NUREG-0311 were confirmed by work supported pump support materials for all operating PWR plants by an Electric Power Research Institute program, and those in the later >tages of operation license
" Methodology for Plastic Fracture." review. This reassessme.v included review of the
- The methods developed in these programs were materials utilized in the support of 38 potentially af.
successfully used by NBC contractors to analyze fected PWRs. Based on the comultant's evaluation, it two pressure vessel burst tests reported in the was determined that there are 21 plants whose sup-Heavy Section Steel Technology Program, spon- ports are of questionable toughneu and, accordingly, sored by the NRC Office of Nuclear Regulatory further detailed plant-specific review is required. This
, Research. decision concluded the generic study of this subject
- The potential for restoring by thermal annealing under Task A-12. During the plant specific reviews the pressure vessel toughness lost by neutron that will follow, either the ttructural integrity of the radiation was shown to be impractical. supports must be demonstrated, or measures to assure their structural inteenty will be required.
Significant delays have developed over the past year A report describing the NRC staff's safety evalua.
as a result of difficulties encountered in extending the tion and conclusions and desenbing its plans for imple.
new engineering methodology to reactor pressure mentation (i.e., the more detailed plant specific vessels. There is agreement among experts that the reviews referred to above) was issued for comment in methodology can be extended, but it will require a November 1979. It is entitled, " Potential for Low significantly greater effort than that accomplished Fracture Toughness for Lamellar Tearing in PWR v
P00R ORIGINAL
46 PUBLIC SERVICE COMMISSION OF WISCONSIN M8 "o-DEPARTMENTAL CORRESPONDENCE 6630-CE-20 6630-UI-2 Date: March 19, 1981 To: File 6630-CE-20 File 6630-UI-2 From: SarahJenkinsN Sub.j ect : Phone Conversation with Larry Weber, March 4, 1981, 5:30 p.m.
Mr. Weber stated that he believes that repair of Point Beach is a good idea because it would prevent throwing away the millions invested in the plant. Mr. Weber stated that generation of power in nuclear power plants has saved the U.S. money and that he supports a balance of different types of fuel.
The author told Mr. Weber that the preliminary conclus-ion of PSC staff is that repair is the most desirable option.
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. BEFORE THE
$ /, J 4 - (/I f 4H PUBLIC SERVICE COMMISSION OF WISCONSIN g, Request for Hearing Under Section ) "*
227.064 of the Wisconsin Statutes by )
"I Wisconsin's Environmental Decade, Inc., ) " -
Lavinia and Joseph Dworak, Ann and Paul ) -
Kortens, Mollee Sager and Beth Satchell )
to Retire the Point Beach Nuclear ) '
Plant Unit 1 Forthwith )
Investigation on the Commission's Motion ) j Into the Actual and Potential Financial, ) .--
Accounting and Ratemaking Effects of )
Steam Generator Tube Degradation at Unit ) 6630-UI-2 "'
1 and Unit 2 of the Wisconsin Electric )
Power Company's Point Beach Nuclear Plant)
Application of Wisconsin Electric Power )
Company for Authority to Replace the )
Generators for Its Point Beach Nuclear ) 6630-CE-20 Plant, Unit 1, in the Town of Two Creeks )
Manitowoc County, Wisconsin )
COMMENTS BY WISCONSIN'S ENVIRONMENTAL DECADE ON PRELIMINARY STAFF DETERMINATION OF NO SIGNIFICANT IMPACT This is to provide comments by Wisconsin's Environmental Decade on the Staff's Preliminary Environmental Screening and finding of no environmental impact statement required, in the above-referenced matter.
In the unreasonably short time provided for comments, it is in-possible to include all the comments which this important matter requires. The following is filed, without waiver to our objection to the inadequate response period, so that the Commission may be informed of some of the major insufficiencies with the document.
These comments address: (1) nuclear safety; (21 conservation; (3) l replacing steam generators and (4) costs.
(1) Nuclear Safety One of the most established scientific institutions in the country, the American Physical Society, has concludadthat steam generator tube
1
-l
. l 48 degradation at' pressurized water reactors, such as Point Beachl, could
" induce essentially uncoolable conditions in the course of a loss-of- )
coolant-accident." (1) That is to say the ability of such plants to withstand a minor occurrence, and prevent it from running out of control to become a worst case accident, has been substi:- ' ally impaired.
Consideration of these safety implications of steam generator tube g degradation have been omitted trom the screening, however. In the screen's response to our earlier submission on the subject, the Staff essentially relies upon assurances from the Nuclear Regulatory Commission that denies the American Physical Society conclusion and assera safe:y problems do not exist. Screen, at 23. (2)
Such a policy constitutes an abrupt and tragic reversal of fifteen years of progress. When Point Beach I was originally licensed in 1967, the Commission staf f began delving into the economics of nuclear aspects
- of the facility, without yet looking at safety questions, directly or indirectly as to their effect on economics and reliability. Re Wisconsin Electric Power Company, PSCW Docket CA-4689, Tr. 62.
By 1975, in the licensing proceeding involving the ill-fated ,
Koshkonong Nuclear Plant, the Commission de c]sred its authority to inquire into nuclear safety issues "in order to determine what effect such a plant will have on the public it is designed to serve," over-turning the objections to such an inquiry from the utilities. ]tjt Wisconsin Electric Power Company, et al., Docket CA-5491, Order Sustaining Examiner's Ruling (May 1, 1975), at 2. I l
And by 1978, the Commission called experts on its own motion to testify on nuclear safety per se. Re Advance Plan 1, Docket 05-EP-1 Tr. 7546.
, , - , - - , - -- ,e- , ,,- , - -
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l s . .
49 Events sitice that time have further underscored the necessity for
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the Wisconsin Conscission to inquire into nuclear safety, not only because g of its indirect impacts on economics and reliability, but also because the Nuclear Regulatory Coimaission has been shown by all independent evaluations to be incapable of adequately performing its assigned role. In the wake of the accident at the Three Mile Island Nuclear Plant Unit 2, the President's ,
r - y Commission concluded that the NRC "is unable to fullfill its respons-ibility for providing an acceptable level of safety for nuclear power plants".(3)
Similarly, the NRC's own in-house investigation by the Rogovin Inquiry Group found that the NRC "is incapable, in its present configuration, of managing a comprehensive national safety program for existing nuclear powerplants".(4)
Yet, in the face of these facts militating for deeper independent review by the State, the screen attempts to turn back the clock and mindlessly rely on what the "NRC staff have informed the PSC staff". Screen, at 23.
But, it must be noted that even if the Commission did choose to reverse fifteen years of progress insofar as it exercises discretion, it may not do so when operating under the non-discretionary c:andates of the Wisconsin Environmental Policy Act in the screening process. Chapter 274, laws of 1971, se affected by ch. 204, laws of 1973. Even if, arguendo, the effect of safety on economics anc reliability were ignored, impact statement law requires consideration of matters that are not within the jurisdication of the agency.
N.R.D.C. v. Morton (D.C. 1972), 458 F. 2d 827, 834; Sierra Club v. Lvnn (5th Cir.1974), 502 F. 2d 43, 62; E.D.F. v. Corps of Lui-= ara (5th Cir.
1974), 492 F. 2d 1123, 1135.
To eschew any independent evaluation of the possibility of a worst 3, case accident identified by such prestigous institutions as the American Physical Society under the circumstances described here is unlawful, unconsciencable and irresponsible.
9
1 r
(2) Conservation Conservation has been made a high priority by both the Legislature and the Governor in Wisconsin since the Arab Oil embargo in 1973. Over the past several years the Legislature has enacted a series of bills that have underscored its emphasis on conservation to meet our energy needs. See, e.g. , ch.157, laws of 1973; ch. 339, laws of 1975; ch.29, laws of 1977; ch. 31,, laws of 1977; ch. 369, laws of 1977, ch. 418, laws of 1977; ch. 34, laws of 1979; ch. 221, laws of 1979; and ch. 350, laws of 1979. Most recently, the Governor in his State of the State message called for an energy policy which emphasi:es conservation first.
Senate Journal (Jan. 13,1981), at 27.
Part of that series of legislation directing the Commission's action is secs. 1.11 and 1.12, Wis. Stats. The first, the environmental igact statement law, creates a peregtory duty to evaluate conservation as an alternative. See, generally, Gerrard, " Disclosure of Hidden Energy Demands," Environmental Affairs, at 661. If there were any doubt in this regard, the second statt.te reinforces the obligation to fully consider conservation.
Even without that recent spate of new legislation, the Wisconsin Supreme Court has been forced to remind the Commission that its long-standing existing statutes make conservation a factor to be considered.
Wisconsin's Environmental Decade v. P.S.C. (1975), 69 Wis. 2d 1, 16.
The screen's state =ent ignores this and assumes conservation is r
- f. l not an alternative. ,
According to the screen, first, all the conservation which is possible f' has already been accounted for in the utility's existing forecasts which were ratified by the Commission. Screen, at 24. Such shortsightedness is too acute to explain away as simply an ocularity problem. Rather,
51 the refusal to consider improved electric efficiency measures that could be effected with the sizable monies that would otherwise go to maintaining Point Beach can only be seen as a derelection of duty. The hundreds of millions of dollars could go a long way toward purchasing energy efficient refrigerators and air conditioners, as well as solar water heaters for existing customers, and this must be considered.
6, The screen's second contention is even more difficult to accept
'on good faith in that it turns reality on its head. If the alternative being considered is the retirement of Point Beach, one cannot rationally contend, as the screen does, that saved-energy will result in turning back a coal plant rather than Point Beach for the simple reason that the a alternative assumes Point Beach has been shut down.
In splendid isolation, this Commission is standing against the over-whelming tide of scienctific and political opinion, contending that conservation does not even deserve to have a full airing, nevertheless be implemented.
(3) Steam Generator Replacement The utility application before the Commission in this docket includes a request for authority to purchase two spare steam generators, in addition to conduct a sleeving program. Letter from S. Burstein, dated February 11, 1981.
Even the Nuclear Regulatory Commission has been forced to acknow- 7.
ledge that steam generator replacement requires the preparation of a full environmental impact statement because of the major and significant impacts of such an undertaking. Re Surry Power Station, NRC Docket 50-280, NUREG-0663.
Yet, based upon a cursory qualitative review, the screen concludes that no further analysis is necessary to adequately consider the environmental
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effects of the replacement alternative.
It must be emphasized that no recourse for this abdication can be' found in a claim that the application only seeks to purchase and not install replacement generators. WEPA law bars bifurcation of a project and the irreversible committment of resources without full environmental review. Patterson v. Exon (D. Neb. 1976), 415 F. Supp. 1276; N.R.D.C. v.
Morton (D.C. Cir. 1972), 458 F. 2d 827, 835; Kleppe v.~ Sierra Club (1976),
427 U.S. 390, 409.
(4) Costs The screen does not provide sufficient detail to inform the reader of all the significant variables used in running the programs. From the limited information provided, however, it would appear that at least the following errors exist in the cost study:
First, the replacement power costs foi existing impaired operation 7, and.for turbine repair and TMI midifications from April 1980 to the pro-jected time of resleeving has been ignored for cogarison of Alternative 1 with Alternative 4. It would be a violation of WEPA to have let those major costs be incurred without environmental review as they were, and j then ignore them later because the agency did not cosply with the law in a timely manner.
Second, it is impossible to determine what 2:aounts, if any, were used 9, for replacement power in the various alternatives.
Third, there is no basis shown, nor is there in fact of which we Jo.
are aware, to assume, as the cost study does, that either repair option in Alternatives 1, 2, 3 or 3a will restire optimal operation.
Fourth, there is no independent evaluation of other costs that ff, may be needed to maintain Point Beach 1 16 operation in the future other than reliance upon the Nuclear Regulatory Cor. mission.
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53 Fifth, it is unclear what assessment was made, if any, of the /2.
realism of the utility's estimates for nuclear fuel disposal in the advance plan.
Sixth, the apparent assumption that the cost of decommissioning /3.
Point Beach in twenty years is the same as today is invalid to the extent that decommission escalation rates are higher than the discount rate. If the differential were 8%, reflecting the present magnitude of the. spread between the escalation in nuclear construction and the utility cost of money, decommissioning would cost more than four-and-one-half times at that future time.
Seventh, it is unclear whether any costs for or handling low level /4I, and high level radioactive wastes during replacement are reflected in decommissioning the steam generators in Alternative 2 and 3.
Eighth, there is no alternative scenarios run for assumed growth /5",
rates less than 3% per year, a prospect which the past record of declining growth rates with each passing year would indicate to be probable.
Ninth, the conservation alternative is ignored as is discussed abeve. /6, In conclusion, the result of t!.a pross inadequacies in the screen is to deprive the decision-maker and the public of an informed basis to weigh, on the one hand, the risk of a nuclear accident attendant upon continued operation of Point Beach I under various alternatives, and, on the other hand, the relative cost of producing an equivalent amount of conservation-energy versus the cost of maintaining the plant including all potential additional costs in the future.
O
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54 ,
Respectfully Submitted, NISCONSI ENVIRONMENTAL DECADE, INC.
{ ~
By:
- ON Public Affiars Officer 302 East Washington Avenue Madison, Wisconsin 53703 (608) 251-7020 Dated: March 11, 1981
- cc: Full Party Service List (1) American Physical Society, Report to the American Physical Society, 47 Reviews of Modern Physics Supp.1, at S-85(1975), a copy of which is attached.
(2) More specifically, with regard to the replacement alternative /7 the screen asserts that the safety concern becomes " moot". No support or rational is given for this statement, so it is impossible to comment upon except to note that, on its face, it is absurd.
(3) President's Commission on the Accident at R ree Mile Island, n e Need for Change: The Legacy of TMI (1979), at 56.
(4) Nuclear Regulatory Commission Special Inquiry Group, % ree Mile Island: A Report (1979), at 89.
d
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55 Responses to Comments from Wisconsin's Environmental Decade (3/11/81) .
- 1. Staff has considered the safety implications of steam
- 2. generator tube degradation in the screening. Refer to Sections E and G.9 and to staff's response to Mr. Anderson's comments of February 2. Staff relied on input from the NRC, the intervenors, and the utility in evaluating the safety aspects of this case.
- 3. The 1975 study by the American Physical Society has been the sole basis for Mr. Anderson's request for review of nuclear safety. That study briefly discusses possible safety implications of corroded steam generator tubes in a loss of coolant accident situation. The study does not address the implications of repairing or replacing steam generators. Staff beliefes that the cited APS study is not relevant to this proceeding, in which no one is proposing the continued operation of Point Beach 1 with the steam generators in their degraded condition.
(Further, that alternative is considered an unreasonable alternative by staff.)
- 4. This comment is incorrect. Conservation was addressed at page 24 of the Preliminary Screening. It is addressed in more detail in Section E of the Screening.
- 5. This comment misstates the contents of the Preliminary Screening. At page 24 the Preliminary Screening states that the forecasts already include anticipated conserva-tion, not all possible conservation as Mr. Anderson claims. The question of conservation is addressed in more detail in Section E of the screening.
- 6. It is' proper for an impact assessment to consider all reasonable options. If one of the alternatives being considered is the installation of additional conserva-tion and decommissioning Point Beach 1, it is also appropriate to consider the alternative of the installa-tion of additional conservation without decommissioning Point Beach 1. Both of thesa options are addressed in Section E of the Screening.
- 7. NRC staff prepared the EIS in response to a directive by the Commissioners to investigate occupational radiation exposures. In that March 4, 1980 order the NRC Commis-sioners stated, "Our review has focussed on the occupa-tional radiation exposure that the repair program will
Response to WED 56 Page 2 entail because we believe that this adverse environmen-tal impact is the only one associated with the repair program that might be considered significant" (emphasis added).
- 8. Replacement power costs from April 1980 to December 1980, and turbine repair costs have already been spent.
They would appear in AlternativeThese1 andcosts Alternative 4 would drop (as well as la, 2, 3, and 3a).
out of the comparison. The cost of TMI modifications is ongoing; however, most of those costs would need to be expended for point Beach 2 in any case. These Commission approved costs would appear in all alterna-tives and would drop out. Other costs to be expended after January 1981 are included in the analysis.
- 9. Mr. Anderson has received this information from the staff.
- 10. The present reduced output from Point Beach 1 is a If result of corroded and degraded steam generators.
the corrosion and degradation of the steam generator tubes is eliminated, there is no reason to believe that the plant would not return to full output. Complete replacement of the tubes should eliminate the corrosion and degradation. Sleeving may eliminate the problem, but this is not known at present. However, reduced output of the plant costs approximately 19 million dollars per year; thus, a 10-15 million dollar sleeving job (cost of sleeving plus outago) will pay its cost in less than one year's return to full output.
- 11. This comment is incorrect. The staff made no use of NRC cost figures. There is no way of knowing in advance exactly what it will cost to maintain Point Beach 1; how-ever, no evidence has been brought forward indicating any possible major future maintenance expenses. Routine maintenance is included in the staff's analysis. In any case the continued operation of Point Beach I will save approximately 50-150 million dollars per year (1982, 1992) in operating costs which should provide an adequate pool of savings to pay for futuro non-routine maintenance.
- 12. It is unclear what this comment means. However, we have assumed Mr. Anderson means to imply that the actus1 cost of nuclear plant operation will be higher than assumed because the cost of spent fuel disposal will be higher than assumed. If we use the figures for spert fuel dis-posal which Mr. Anderson developed in the 05-Ep-1 case,
Response to WED 57 Page 3 we find that these figures increase the cost of opera-tion of Point Beach I by approximstely 0.149 per kWh in 1981. This would increase the operating cost of those scenarios including Point Beach 1 by approximately 5 million dollars per year in 1982. Such a change would decrease the operating cost savings of continuing the operation of point Beach I from approximately 50 million dollars per year in 1982 to 45 million dollars in the same year.
- 13. If we assume that decommissioning costs may escalate at 8 percentage points higher than the utility cost of money (or 20% per year), then the cost of decommission-ing in 2007 would have been 4.60 billior, dollars instead of the 565 million dollars used by the etsff. The pre-sent value of the dif ferential in 1981 would be 236 million dollars (@ 12%) or 64 million dollars (@ 18%).
Even if this possible additional cost of continued opera-tion of Point Beach L were included in the cost compari-son, it would still be significantly less expensive to
~
continue to operate Point Beach 1. However, there is also a significant possibility that decommissioning costs will not escalate at the same rate as nuclear construc-tion, and that that rate will not be 20% per year until 2000. Finally, it is possible that the staff estimete of the cost of decommissioning is too high. The NRC's Draft Environmental Impact Statement on Decommissioning of Nuclear Facilities (NUREG-0586, January 1981) developed
' a cost of decommissioning for Point Beach 1 of 19.4 mil-lion dollars in 1978 dollars, or 25.8 million dollars in 1981, only 54% of the value used by the staff.
- 14. During replacement, there will be no production of high I
l 1evel wastes (as usually defined) because Point Beach Unit I will not be operating. If you mean high activity, l
low level wast e, there will be less production of these wastes during the replacement outage than during normal operation.
After the replacement outage, high level wastes (spent fuel) and low level wastes will be produced in propor-
' tion to power production. There will be less routine release of radioactivity to the environment after steam i generator lower assembly replacement than during present l operations or Alternative 3 (continue to plug leaks).
l The cost of storage of radioactive steam generators is included in the costs of options 2 and 3 (storage building). Other options for radioactive steam generator l
58 Response to WED Page 4 handling are discussed in section G4. The volume of low level waste generated during the replacement is equal to the volume normally produced during two year's operations but the curie content is expected to be only Alternately 13% of that from two years of operation.
stated a six-month outage for replacement would produce about 160 curies of low level waste while six months of operation would produce about 300 curies of low level waste (see sections G1 and G5).
The costs of disposal of this waste are included in the cost of replacement i Tr , p. 41, $200,000).
- 15. The conservation scenarios discussed in Section E of the screening address the question of growth rates less than 3% per year. However, to reiterate, unless the demand for electricity drops drastically there will still be a need to generate electricity from some plants. It is less costly and less environmentally damaging to generate even a reduced amount of electricity from existing nuclear plants such as Point Beach 1 than from more expensive, dirtier, existing coal- and oil-fired plants.
- 16. This comment is untrue. Conservation was addressed in the Preliminary Screening and is addressed in more detail in the Screening.
- 17. Staff stands by this response. Since Mr. Anderson raised a concern with the safety implications of degraded steam generator tubes, it is clear on its face that replacing the degraded steam generator with new ones would moot the issue. Also note that the APS study being referenced by Mr. Anderson deals with corroded steam generator tubes.
i I
l 1
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- 6 March 5,198f 'R 9. , %-Lw -
" UII COMMENTS OF CITIZENS FOR A BETTER ENVIRONMENT (CBE) CONCERNING THE COMMISSION DECISION NOT TO -
COMPLETE AN ENVIRONMENTAL IMPACT STATEMENT gg FOR THE REPAIR OF STEAM GENERATORS AT THE POINT BEACH NUCLEAR POWER PLANT, UNIT I The Comission staff's preliminary determination that no environmental impact statement (EIS) is required for the proposed Wisconsin Electric Power Company (WEPCo) project of sleeving the leaking tubes of the steam generators at Point Beach Unit I and purchasing replacement The steam gene as inventory items is entirely inadequate and legally incorrect.
Wisconsin Environmental Policy Act (WEPA), ch.1.11, Wis. Stats., cle requires the preparation of an EIS.
to underta6 e a more detailed study of all the reasonable replacement steam generators as inventory items.
WEPA, section 1.11(2)(c), Wis. Stats., requires an EIS where " major actions undertaken.
significantly affecting the quality of the human env steam generators and the purchase of replacement generators as invent WEPCo items at a total cost of $18 million.
project significantly affecting the quality of the human environment.
has cournitted itself to not decorrrnission Point Beach I at this time, and, l-as a practical matter, to not seriously consider this option in the fu of some catastrophic event.
that the environment will be saddled with 20-plus years worth of radioactive waste.
disposal, the alternative chosen is definitely a major action significantly affecting the quality of the human environment.
Even ignoring the issue of whether an EIS is required for this action, it is obvious that the Commis ion has not complied wit In Wisconsin's alternatives to recommended courses of action. . .".Envir ,nme
~-
- , (1977), the Wisconsin Supreme Court discussed s The court stated that federal law Act (NEPA), 42 U.S.C. s 4332 (1970).
interpreting this section of NEPA is persuasive authority. Id. at 174.
of NEPA " imposes an independent and affirmative fulfilled by state agencies regardless of wnether under the circumstances an environmental impact statement. is required under sec.102(2)(C)." Id. at 17 Thus, under WEPA, cor. sideration of alternatives is required re whether en LIS is re<u. .' red.
M '5MWest W 4uten A..% . p.t .,,w n.' '
- N . 414 271 7475
.v-
- - m- -w
- c ..o Cbt. Loc aat c Negativa EIS Decision _. ___
Dockat :a. 6f,J0-CE-20 us itsis 60
[St:1 IIII Emiru uTaisis requires thorough agenc/ action. I.d_. A greater obligation is imposed than the simple consideraticn of alternatives by the agency. M. The agency must
'" study, develop, and describe"' alternatites. M.
The Comission ch .irly has not sufficiently studied, developed or described all of the rusonable alternatives. To begin with, the Comission has all but ignored thc 1cng-term affects of sleeving the leaking tubes and purchasing replacement stcam geierators as inventory items. By purchasing replacement steam generators as inventory items WEPCo has arguably decided against any serious fut are consideration of an early decommissioning of Point Beach Unit 1, our ;ide of the casa of a catastrophe. If any serious 1 problems occur with the steam anerators in the future WEPCo will presumably sin;plv ve its inyt itor ;d rnpl icement genera . ors. WEPCo certainly_.would.not spend $!2.5 million on the rapl.icement steam 'lenerators and then not utilize them in the future if necessary would it? At the .very least, making this quite substantial financial comittment to purchase and store replacement steam generators gives 'JEPCo a strong incentive not to consider an early deconnissioning of Point Beach Unit I in the event of future steam generator problen s. After all, if WEPCo did decomission early in the event of steam generator problems it would have to admit that the $12.5 million investment was a waste, scmething it probably would not be too eager to do. The Comnission simply has not considered this ramification of the chosen alternative. It must study and describe it in writing and in adequate detail to fulfill the mandate of WEPA. Id,. a. 176.
Another glarinq deficiency in the Comission's study of alternatives is h.
its conplete ignoring of possibly the most reasonable alternative which is to simply sleeve the leaking tubes of the steam generators. If the Comission is really serious about its statement in the preliminary staff detennination that the sleeving woelc reinain effective fer the balance of the anticipated useful life of Point Betch Unii I it should definitely consider the alternative of sleeving the leaking tubes cnd not purchasing reolacement steam generators as inventory items. If the sheving will be effective for the life of Unit I there is no reason to s?nnd $12.5 million for replacement steam generators.
Because a 20 or 30 year old steam generator (at the time of decommissioninq) would have little or no salvage value, $12.5 million of the ratepayer's money would be completely wasted. For this reason, consideration of the ~
alternative of only sleeving the leaking tubes must be studied and described.
In its notice the Commission stated that since <* cmmissioning will occur sometime the impacts of decommissioning would riot be considered The key assumption behind this statement is that decor.missioning has the same impact whenever it is done. This is blatantly false. Decomissioning 20 years e.1rly would certainly mean much less radioactive waste to dispose of.
The timing of deconnissioning, as was pointed out earlier, may be affected by the choice of the alternative here. Therefore, consideration should be given to the affects on radioactive waste generation of the various alternative
Pag 2 Three CBE Conment on Negativa EIS Decision .. __
Docket No. 6630-CE-20 UI e ,, g istil Itf ErMOnmENT The Commission's preliminary determination not to complete an EIS for-this project is legally incorrect. In addition to WEPA requiring an EIS for this project it also requires the Cornission to undertake a more detailed study of all of the reasonable alternatives including the alternative of sleeving the leaking steam generator tubes and not purchasing replacea.ent steam generators as inventory items.
Dated this 5th day of March 1981 Respectfully submitted by:
CITIZENS FOR A BETTER ENVIRONMENT l.
<.c_
By'RTchard Whi te, Research 'A_sso.,
ciate Citizens for A Better Environn:ent 536 West Wisconsin Avenue, Suite 502 Milwaukee, WI 53203 (414) 271-7175 l
-l 62 Response to Citizens for a Better Environment Comments
- 1. The screen did consider these issues in determining that reasonable Commission actions would not significantly affect the quality of the human environment.
- 2. Commission staff did consider all reasonable alternatives.
The presence of available replacement spare steam genera-tor lower sections would be expected to affect a' future decommissioning decision only if the decision relates to a problem with the steam generators. If a problem develops in the rest of the plant, the decision will likely be determined by a combination of economic and regulatory factors: the relative costs of repair and decommissioning whether repair is acceptable to the PSC and NRC.
Staff analyeis indicates that the financial incentives for WEPCO to uvatinue operating Point Beach Unit 1 are far greater than the 12.5 million. See Tables 1 and 2.
Staff does not believe it likely that the availability of steam generators would have any effect on the decision to decommission.
- 3. This comment is incorrect, see Table 1, page 8 and Table 2, page 9, and section B.3., p. 5.
- 4. Early decommissioning would mean less radioactive waste for disposal. This is described in section G1, pp. 17-18.
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m . i .i PCD 63 7 d NNp . 7 sq 'iO h Box 117, Sheboygan, WI 53081 ffarch 8, 1981 Jerry E. ?/endl Division Administrator SPERCA The Public Service Commission of 'fisconsin Hill Farms State Office Building Fadison, Wisconsin 53702 Dear Mr. Mendle I am writing to express the concern of the board of directors of Safe Haven Ltd. regarding the determination by the SPERCA staff that no environmental impact statement will be required in the repair of the steam generators at Point Beach, Unit 1.
A specific concern invovles the housing of the damaged steam tube generators should the replacement option be chosen. If,in fact, the public is to have confidence that such an operation is being con-ducted with the public welfare in mind, an Environmental Impact Statement should be considered a necessity.
The public should be informed that the housing of the steam generators is being accomplished with regard to the safety of the nearby population at the time of the removal and until such time as the generators pose no further threat to the environment. Without a full and complete hearing on the issue, including a determination, on the duration of the housing, not only will doubts persist, but there remains the chance that major defects in the planning will be over-looked.
l Safe Haven Ltd. would like to go on record as requesting l an Environmental Impact Statement on the proposed actions at Point Beach. Unit 1. We understand that such a procedure is costly in both
! time and money, but we also feel it is the only prudent step.
Sincerely, William Charles Hanley, secretary To CREA TE A BAL ANCE BE TWEF4 Ot>R NEED FOR ENERG Y ANO.
OUR NEED FOR A CLEAN. SAFE ENVIRONMENT ~
._ _ _ _ _ . _ _ _ - ~ - -
64 Response to Safe Haven Comment See section G4 and following response. Note that on site storage or intact shipment have the least impact on the public near Point Beach. It is not clear that shipment of intact steam generator lower assemblies is feasible or economic.
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65 PUBUC SERVICE COMMISSION OF WISCONSIN DEPARTMENTAL CORRESPONDENCE 6630-CE-20 6630-UI-2 Date: March 19, 1981 To: File 6630-CE-20 File 6630-UI-2 From: SarahJenkinsj
Subject:
Phone Conversation with-Jame Schaefer, March 10, 1981, 3:30 p.m. , Regarding Preliminary Screening of Steam Generator Repair / Replacement Mrs. Schaefer stated that her main concerns with the pro-posed action are:
- 1. What is the composition of the radioactive crud deposited in the steam generators? Does the crud contain any nuclides from spent fuel due to failed fuel elements?
- 2. How will radiation in the old steam generators be contained? Are any special methods required?
- 3. What will be the impacts of steam generator i storage on the environment, workers, and public health?
- 4. How appropriate is on-site storage and what are the alternatives?
The author stated that the screen would be amended to discuss these points. The author also stated that the pre-sent storage plan includes welding steel caps over all openings in the steam generators while inside the contain-ment. The design of the storage building will further limit radiation exposures. If the steam generators are cut 1
! up for offsite shipment, some of the crud may be vaporized leading to possible public exposures.
SJ/kmw l
l
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66 Response to Jame Schaefer Concerns regarding steam generator storage. In general see revised section F4.
- 1. The composition of the radioactive crud has been quanti-fied to the extent possible prior to analysis of crud removed during decontamination of the channel head. Such analysis is planned as part of the sleeving demonstration -
to be performed this summer.
The crud is expected to contain very low levels of nuclides from failed fuel elements. Material from failed fuel elements is collected in the normal letdown and cleanup systems and the offgas system. One of the major nuclides released, cesium, binds to crud very weakly (10,000 times less strongly than the metallic elements), hence would not be present in great quantities.
- 2. Radioactive material in the old steam generators will be contained behind welded on c:ps. Radiation levels are reduced by the thickness of the steel in the stema genera-tors and the walls of the storage building.
- 3. See section G4.
- 4. See section G4.
67 Saw of Wi.co..i. \ COASTAL MANAGEMENT COUNCIL I l tm, % p,,y6. c/o 7m Floor om 101 S. WoosteQtreet Madq. Wisconsw. 53702 CD E7 1 March 11, 1981 '
O. .,
Sarah Jenkins -.
~~
Public Service Commission 4802 Sheboygan Avenue :
- Madison, WI 535702 -
2 RE: DOCKETS 6630-UI-2, 6630-CE-20: APPLICATION OF WISCONSIN ELECTRIC POWElICO.
FOR AUTHORITY TO REPLACE STEAM GENERATORS FOR ITS POINT BEACH NUCLEAR PLANT, UNIT I, IN THE TOWN OF TWO CREEKS, MANITOWOC COUNTY, WISCONSIN
Dear Ms. Jenkins:
We have reviewed the Preliminary Environmental Screening and Preliminary Staff Determination: No Environmental Impact Statement Required, dated February W 1981.
We support the preliminary SPERCA staff conclusion that tha environmental effects of the proposed action (sleeving of Unit 1 steam generator tubes and purchase and on-site storage of spare steam generators) are not significant i and no environmental impact statement is required (Determination, page 4). We commend Wisconsin Electric Power Company for modifying its original l
I application for authorization to replace the steam generators as soon as possible. We have felt throujhout this proceeding that a repair option other l
than complete replacement of the steam generators would be environmentally preferable. Our position on this matter was conveyed to the Public Service Commission by Robert Halstead in telephone conversations with Jerry Mendl on March 26, 1980, and with Sarah Jenkins on June 6 and 7, 1980.
l While we agree that the environmental impacts of the proposed action are not significant, we must disagree with the preliminary SPERCA staff conclusion regarding environmental effects and nuclear issues that the differences between sleeving and the three alternatives (replacement, continued plugging, l and immediate decommissioning) are not significant (Determination, page 2).
We are primarily concerned about the possible radiological impacts and the institutional precedent of onsite storage of the radioactive steam generators and low level radioactive waste in the event of replacement. We are also concerned about the possibility of a major nuclear event during removal and reloading of the reactor core, and about construction period impacts resulting from replacement. Nowhere in the Screening or the Determination is there an adequate discussion of these issues. Until such a specific discussion occurs, we cannot support the conclusion that the replacement alternative will have no more serious adverse impacts than the proposed sleeving action.
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68 March 11, 1981 Sarah Jenkins Public Service Commission Page No. 2 It is our understanding that approval of this application will only permit Wisconsin Electric Power Company to sleeve steam generator tubes and purchase and store steam generators onsite. Additional authority would be required from both the Public Service Commission and the Nuclear Regulatory Commission before the existing steam generators could be removed and the replacement steam generators installed. Before approval for replacement is granted, there are still several major concerns which have not been adequately addressed in the preliminary environnental screening. These concerns regard safety issues, onsite storage of the radioactive steam generators, sanagement of low level radioactive wastes generated by the replacement operation, and construction impacts.
Safety Issues - In our original comment on this screening we expressed our concern about the increased possibility of accidental release of radioactivity as a result of the removal, storage, and reloading of the reactor core. 2 SPERCA staff's response that the possibility of such an event is only slightly greater than for a normal refueling (Screening, page 27) does not answer the question. We would like a fuller discussion of this issue, particulary since the possibility of sleeving followed by replacement at a later date would require removal of the reactor core on two separate occasions. l
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l Onsite Storage of Radioactive Steam Generators - A brief discussion i subtitled "laplications of Storage of the Old Steam Generators" (Screening, page 14) states that the retired steam generators "will contain some <
l radioactive crud and the metal itself will be somewhat radioacti*e. Welded caps over the openings will keep the crud inside and prevent its movement to 3 the environment. The combination of the steel caps, steel steam generator valls and the walls of the storage structure are expected to keep radiation levels at the outside surface of the structure quite low." We think this discussion of the radioactivity of the old steam generators is inadequate. l The conclusion that radiation levels are " expected" to be "quite low" is not ,
supported by any evidence of fered in the screening. Before making such a determination, SPERCA staff must identify the isotopes which will be present in the accumulated crud and in the metal of the generators themselves, the anticipated radionuclide content in curies, and a detailed discussion of the effectiveness of the proposed containment structure.
Low Level Radioactive Waste Management - It would be imprudent to approve the replacement option without first reviewing .: complete plan for the management and disposal of low level wastes generated during the repair operation. Such a plan should include a discussion of the anticipated volume ct a
the isotopes of low level wastes, the waste forms (gases, liquids, present, and the anticipated radionuclide content in curies. solids), The plan should include a discussion of the packaging and transportation requirements and a discussion of the availability and cost of offsite disposal. Wisconsin currently has no low level waste disposal site, and Wisconsin's future access to out-of-state disposal facilities is not secure. The volume of low level
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69 March 11, 1981 l Sarah Jenkins )
Public Service Commission l Page No. 3 wastes generated by the repair option, estimated during the proceedings at 17,600 cubic feet (Transcript, page 41), must be compared with the total of 20,108 cubic feet generated in the entire State of Wisconsin in 1979. Our major concern is that lack of off site storage may result in the creation a temporary or permanent low level waste disposal facility at the Point Beach Nuclear Plant.
Construction Impacts - Before any final approval of the replacement option is granted, a more specific determination of the size of the workforce and the duration of the construction period should be conducted. During the jr proceedings, Mr. Garry Frieling testified that approximately 300 workers'would be required for the replacement operation (Transcript, page 82). The staff determination suggests (page 16) that from 690-760 workers may be required for the replacement operation. We would hope that a more accurate assessment of the personnel needs as well as a discussion of the availability of skilled workers from the local labor pool would occur before final authority is granted.
While the comment period war quite short, thank you for the opportunity to review and comment upon the preliminary environmental screening. If you have any questions about our participation in this proceeding please contact Mr. Robert Halstead at 266-9810.
Respectfully, l #
, /,
1 Allen H. Miller Program Manager Office of Coastal Management AM:RH:jh:0746P
70 Response to Coastal Management Council Comments
- 1. Staff did not conclude that the differences between the alternatives listed in the comment letter were not sig-nificant. Staff said that continued plugging and decommissioning are unreasonable alternatives and that the differences between sleeving and replacement are not significant.
- 2. During a routine refueling, every fuel assembly is picked up and moved. During a complete core unloading each fuel assembly would be picked up and moved twice. This would double the very low probability of dropping a fuel assembly.
Complete core removal is a planned event which must occur at least every ten years to allow inspection of the reac-tor vessel. The core in Point Beach Unit 1 has been com-pletely removed twice (in 1973 and 1976) and the core of Point Beach Unit 2 was completely removed in 1977. Thus complete core removal is not a new procedure for the Point Beach operating personnel.
Complete core removal does not expose fuel cladding to any unusual temperature changes. After the reactor is shut down the core is cooled to a temperature similar to the spent fuel storage pool. There is thus no thermal shock hazard.
The core is removed during sleeving or steam generator lower assembly replacement in order to allow dry "layup" of the reactor vessel internals and head. If the core were not removed, the upper internals and reactor vessel head would be exposed to a wet, corrosive atmosphere for three to six months. With the core removed, the reactor vessel can be filled with dry nitrogen during the outage.
- 3. See revised section G4.
- 4. See new section G5.
- 5. See change in section G8.
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71 Deter March 13, 1981 Fie ne/: 6630-CE-20 6630-UI-2 ro: Sally Jenkins Jerry Mendl from Bob Halstead subjur: Screening and Preliminary Determination Point Beach Steam Generator Jepair Options Based on testimony delivered on 3/12 and 3/13, the preliminary staff determination should be revised to reflect the evidence that sleeving will result in significantly less adverse impact upon the environment than will replacement. Compared with replacement, sleeving is anticipated to:
- 1. Generate only half as much low level radioacti e wante.
- 2. Eliminate the need for disposal of the existing steam generators, which should be considered intermediate level radioactive waste, either on-site or off-site.
- 3. Result in less total occupational radiation exposure (12-23% less than replacement, according to NRC).
- 4. Result in less construction period impacts, due to slightly smaller work force requirements and shorter construction period.
A staff recommendation that further environmental assessment I is required to determine.whether an EIS should be prepared prior to approval of replacement of the steam generators would seem to be in order.
The screening should be revised in two areas:
- 1. A section discussing low level radioactite waste should 2 be added, including:
- a. A comparison (for sleeving and replacement) of anticipated
- 1. Volume of LLW generated
- 2. Isotopes present in LLW
- 3. Curie content of LLW
- 4. Cost of disposal
- 5. Transportation requirements.
- b. WEPCO's plan for disposal of LLW (presumably same for both options).
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- c. Uncertainties surrounding availability of off-site LLW disposal, and need for contingency plan for on-site storage.
- 2. Revise discussion of implications of storage of the old 3 steam generators to:
- a. Reflect lack of specific information r3garding isotopes present and curie content of steam generators.
- b. Based on Surry and Turkey Pt., estimate curie content and isotopes present.
- c. Note that off-site storage is available and technically feasible, although cost may be 2-3 times greater than on-site storage and trans-portation impacts could be significant.
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73 Response to Halstead's Comments
- 1. Staff does not believe that further evaluation is needed before steam generator lower assembly replacement occurs unless there are substantial changes in the available information or process.
- 2. See section G5 which discusses points a. 1 and 3, b and c.
Isotope information (point a.2) is not available now.
The isotopic composition of the crud will be determined during the sleeving demonstration this summer.
Cost and transportation (points a.4 and a.5) depend upon unknown future events. (See new section G5.) Exact quantification is not possible.
The record contains a cost estimate of $200,000 (tr.p. 41).
- 3. See above comment and revised section G4 for all points.
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3/13/81 74 TO: Ms. Sarah Jenkins Public Service Comission 4802 Sheboygan Avenue Madison, Wisconsin 53702 FIGl: Senator Joe Strohl, Gaiman Senate Energy Comittee 334 South - State Capitol Madison, Wisconsin 53702 IRO.NENTAL IMPACT STATDENT RE: PRELIMINARY STAFF DEIT.RMINATION TilAT NO EW.
IS REQUIRED AS PAI4 OF 'INE RECORD IN 1HE IhYESTIGATION '0F STEAM GENERATOR ltJBE DEGRADATION AT UNITS I AND II CF 1RE POIST BEAG NUC POWER PLANT (6630-UI-2) AND llE APPLICATION OF WISCDNSIN ELEC11 TIC CmPAW IOR AlmORITY 10 REP 1 ACE 'DE STEAM GENERA 1DRS (6630-CE-20)
With regard to the staff's preliminary finding that no environmental igact statement slould be required in the dockets cited above, I can agree only inasmuch as I see little need to do an EIS for the limited range of options set forth by the staff. Ilowever, I cannot accept as complete, the list of alternatives staff has enumerated as possible solutions to the tube degradation problem at Point Beach.
The contention that the range of options has not been fully developed ,
is best supported by simply outlining a conservation-oriented approach l to the problem, which his been heretofore omitted from the analysis, but in my mind, is a far more preferable solution than those examined by staff.
In a nutshell, a conservation option would entail early shutdown of the faulty Unit .I reactor and spending a sun of money cegarable to that required to perform the repair or replacement options to instead perfom weatherization measures, efficiency improvements or install renewable energy systems. A goal oriented search for solutions, as opposed ta the fix-the existing plant approach taken by the Systems Planning, Environmental Review and Consumer Analysis Division (SPERCA), would have readily shown the conservation scenario to be an attractive altemative for amliorating the detrimental effects of tube degradation. A comparison of the potential economic costs, environmental impacts and safety risks associated with each option would, I believe, call to question many of the assumptions that focus problemsolving efforts on fixing a failing plant instead of solving the problem.
No one can dispute that conservation is at least as viable an energy source as nucicar power. If a new nuclear plant, with the same level of b
safety and environmental risks as are associated with a fully repaired Point Beach plant, could be purchased for the same price as two spare steam generators, then constmctipn of a new plant would be a strong choice. Similarly, if consenation measures.in the utility-s-service area could absorb the demand now being met by Point Beach Unit I, at the same or lower environmental and safety risk levels, it is obvious that ,
weatheri:ing, more efficient fumaces and altemative energy systems would be a wise (or wiser) purchase than two steam generators for the existing plant.
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75 SPERCA has estimated that an early shutdown of Point Beach Unit I would result in a $636 million to $1.3 billion loss to ratepayers, when compared with the cost of steam generator repair or replacement. 11owever, when' the conservation option is cowled with early decomissioning of Unit I, the result is very different. Specifically, I am requesting comparison of the 3 economic, environmental and safety costs of repairing ($5-10 million) or replacing ($22 million) the steam generators and buying replacement power, versus the costs of closing the defective Unit (I) and spending that amount of money system-wide for the most cost-effective conservation improvements possible. The Altemative Advance Plan currently being prepared by SPERCA would provide preliminary estimates of the potential that exists in '
Wisconsin Electric Power Company's (WEPCO) service area for meeting demand through conservation, development of renewabic energy sources and better utilization of existing over-capacity.
Without a thorough examination of 1)the environmental, 2) economic, and 3) safety igacts of the conservation option relative to other altematives, a decision to go forwant with either repair or replacement is little more than a blind choice to do some expensive tinkering with an old, broken piece of equipment. To this end, I fully endorse and urge immediate Comission approval of the March 11, 1980 motion filed by Wisconsin's Environ 7 ental Decade, which asks that Energy Systems Research Group, Inc. he retained by the Comission to examine for the record the conservation scenario vis a vis the options heretofore considered by staff.
76 Response to Senator Strohl's Comments
- 1. In actuality, the conservation question was addressed in the Preliminary Screening, although not in great detail.
It is addressed in much greater detail in Section E of the screening. It is unclear from this comment just what the goal referred to is. However, if your goal is to safely supply needed electricity at the lowest cost and minimal environmontal impact, staff believes that the screening addresses this goal. If your goal is to decom-mission Point Doach Unit 1, staff believes that the screen-ing addresses that. If your goal is to conserve energy, staff has considered that to the extent appropriate in the context of this case. Staff does not agree with your characterization of its review as a "fix-the-existing-plant approach." Rather this is a case where fixing the existing plant is consistent with other goals. Please re# r to Sections D, E, and G.
- 2. Conservation is clearly a viable energy source. We also agree with your comment that, if a nuclear plant is safe, reliable, and environmentally non-risky as a fully repaired Point Beach I could be purchased for the cost of two steam generators, it would be an appropriate choice.
All the evidence in this record indicates that such a purchase is not only possible, but would ba the result of repairing the Point Beach 1 steam generators.
- 3. This specific point is addressed in Section E of the screening.
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- El l e jitate of %isconsin prpartment of 3ustice ' ' " L'-!
77 jlladison 53702
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Attomw comes March 12, 1981 o m d J Nerusa onouty Attomw Gewei Public Service Commission 4802 Sheboygan Avenue Madison, Wisconsin 53702 Attention: Sarah Jenkins RE: Comments on Preliminary Environmental Screenine -
Docket Nos. 6630-UI-2 and 66 30-CE-20.
Dear Ms. Jenkins:
This office has recently received a copy of the Commission's Preliminary Environmental Screening in the above-referenced applications of Wisconsin Electric Power Company (WEPCO). That document assesses the economic and environmental consequences of the replacement of steam generators and resleeving of steam generator tubes at Point Beach Nuclear Power Plant, Unit 1. In the context of these applications, Wisconsin's Environmental Decade (Decade) has raised issues questioning the safety of the facility.
You should know that the issues raised by the Decade herein have previously been raised before the Nuclear Reg u'.a tory Commission (NRC). On November 30, 1979 and January 3, 1980, the NRC issued orders in Docket No. 50-266, requiring WEPCO to reduce coolant pressure, conduct tests and otherwise monitor the condition of the steam generator tubes in Unit 1. Thereafter, Decade petitioned the NRC for an adjudicatory hearing on the propriety of those orders. It was the Decade's contention that the remedial orders did not go far enough, in that they failed to address critical safety considerations. In this reg ard, the State of Wisconsin filed a Petition for Leave to Participate, I and, at a prehearing conference, strongly urged the NRC to grant I the requested hearing . While the State took no position on the merits of the Decade's contentions, we felt that significant questions were raised and deserved attention. A copy of our Petition is attached hereto as Attachment A.
Despite our efforts, the NRC denied the Decade's request and authorized WEPCo to resume operations at full capacity. By letter dated October 3, 1980, this office voiced its objection to !
both the substance of the NRC's action and the procedures which !
were followed. A copy of that letter is attached hereto as l Attachment B. The result of this action has been that the safety i
. issues surrounding Point Beach Unit I have not been adequately i addressed by the NRC in those proceedings. !
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Ms. Sarah Jenkins 78
.Page 2 This letter is provided for your information so that yes are !
aware of previous State action in related matters. l Sincerely, Bronson C. La ollette Attorney General BCL:CAS:sd cc: F. Joseph Sensenbrenner !
Carl A. Sinderbrand Peter Anderson l
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- UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF Wisconsin Electric Power )
Company )
Point Beach Nuclear Power )
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Plant Unit 1 )
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PETITION FOR LEAVE TO PARTICIPATE AS INTERESTED STATE
- The State of Wisconsin Department of Justice, at the request of Governor Lee S. Dreyfus, and on behalf of the State of Wisconsin, requests leave to participate as an interested state in the above-entitled proceeding, pursuant to 10 C.F.R.
- 2. 715 (c) (1978). The State further requests that the -
Commission grant a hearing addressing each of Intervenor's contentions, filed with the Commission on July 15, 1980.
The State of Wisconsin has a substantial interest in the I continuing problem of steam generator tube degradation at the Point Beach nuclear power plant. The State has a responsibility to insure that the health, safety and i
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..& n- 80 environment of its citizens are protected and that all questions regarding steam generator tube degradation are fully considered.
Dated this dO day of July, 1980.
Respectfully. submitted, BRONSON C. LA FOLLETTE Attorney General
'N U/ p
, PATRICK WALSH Assistant Attorney General Department of Justice 114 East, State Capitol Madison, Wisconsin 53702 (608) 266-7344 i
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Erpartmmt of h$lict 81
/Hadilon Carl A Sonoorbrend 53702 eronsor,c u ro:ee Assistent Attorney General Attorney General Daed,1 Hanson October 3, 1980 o ,,ury ar,,,n ,y a ,n ,,,,
The Honorable John F. Ahearne, Chairman Mr. Victor Gilinsky, Commissioner Mr. Joseph M. Hendrie, Commissioner Mr. Peter A. Bradford, Commissioner U.S. Nuclear Regulatory Commission Washington,'D.C. 20555 Re: Wis. Electric Power Co.
Docket No. 50-266 (Point Beach Nuclear Plant - Unit 1)
Gentlemen I am writing to you, on" behalf of the State of Wisconsin, to register our sentiments and concerns with respect to the resumption of full power operation at Point . Beach 1, and particularly with respect to an exchange of correspondence surrounding this action.
On August 8, 1980, Mr. Edson Case, of the Office of Nuclear Reactor Regulation, sent a letter to Mr. Sol Burstein, of Wisconsin Electric Power Company (WEPCO), authorizing resumption of operation at Point Beach 1. Thereafter, on August 26, 1980, Ms. Kathleen Falk, of Wisconsin's Environmental Decade (Decade), sent you a letter criticizing the form of this authorization and suggesting that its purpose was to subvert the opportunity for meaningful public participation which had been previously agreed upon between Decade and your staff. I have recently received the staff response to that letter, dated September 19, 1980, contesting Decade's assertions regarding the propriety of the Case letter.
l The State of Wisconsin is dismayed and discouraged by the manner in which the NRC chose to convey its authorization.
However, we are far more concerned with the tone of the correspondence and attitude of the NRC staff. Throughout the course of this controversy the staff has consistently resisted all efforts by the public to participate in the process. At this juncture, when the responsiveness of the NRC to public concerns is being called into question from all quarters, indeed from within its own ranks, the NRR and Commission staf f should not be permitted to run rough-shod over legitimate public concerns.
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The Honorable John F. Ahearne, Chairman Mr. Victor Gilinsky, Commissioner 82 Mr. Joseph M. Hendrie, Commissioner Mr. Peter A. Bradford, Commissioner Page 2 October 3, 1980 In this controversy, the State of Wisconsin has, to date, refrained from taking sides on the merits of the Commission's orders. We do feel that the Decade has raised legitimate concerns over the safety of Point Beach 1, and believe that the only way to ensure public confidence in the Commission and its actions is to permit full scrutiny of those orders in a public forum. The staff's cavalier attitude and resistence to public disclosure and scrutiny instill and accentuate an overall mistrust of the Commission and suspicion of its objectives. We are thus finding it increasingly difficult to maintain a neutral stance on this and other issues.
By this letter, we strongly urge the Commission to grant the hearing which the Decade has requested. If the Commission staff has acted reasonably with the objective of promoting safe operation of the plant, a public hearing can only serve to reinstill that confidence in the Commission which is so noticeably lacking. If the Commission's actions have compromised the safety of the plant to maximize energy production, the public has a right to be apprised of this decision. Only in a public forum can this controversy be finally resolved.
Sincerely, h Lt'stAsJ-Carl A. Sinderbrand Assistant Attorney General ,
l CAS/cje l cc: Atomic Safety & Licensing Board Panel '
Atomic Safety & Licensing Appeal Board Ms. Karen D. Cyr, Esq.
Ms. Kathleen M. Falk, Esq.
Mr. Gerald Charnoff, Esq.
Mr. Sol Burstein l
83 RECOMMENDATION:
,t y No significant impact.
W Environmental evaluation complete.
O More information needed.
O Prepara environmental impact statement.
Submitted by: fd Planning Analyst (SJ)
Title:
Director. nureau nf syst.m an 21 v,4 , ros)
Date: March 24.1981 This environmental screening worksheet complies with 1.E1, Wis.
Stats., and PSC 2.90.
By: 3 3h &M WEP{Coopinator March 24,1981 Date:
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