ML19351A705
| ML19351A705 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/06/1989 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | |
| Shared Package | |
| ML19351A704 | List: |
| References | |
| OL, NUDOCS 8912270061 | |
| Download: ML19351A705 (17) | |
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December 6. 1989 l UNITED STATES OF AKERICA before the I
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NUCLEAR REGULATORY COMHISSION i
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In the Matter of )
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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50 443 0L-1 NEW HAMPSHIRE. 11 11 ) 50 444 0L-1
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(Seabrook Station. Units 1 and 2) ) ,
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) l AFFIDAVIT OF TED C. FEIGENBAUM I. Ted C. Feigenbaum, hereby depose and say as follows:
- 1. I am Senior Vice President and Chief Operating Officer of the New Hampshire-Yankee Division (NHY) of Public Service Company of New Hampshire.
1 have held this position since July 1989. I am the management official in l
charge of all operations at Seabrook Station. A statement of my professional qualifications is attachment 'A' hereto.
- 2. Any further delay in obtaining a full pcwor license for Seabrook i
Station and reaching commercial operations which might be caused by further litigation, besides being unnecessary, will also be very costly. Each day ,
that full power commercial operation is delayed equctos to an additional plant cost of well over one million dollars, which must ultimately be borne ,
by the companies, their shareholders, or their customers. Further, each day of delay results in a loss in revenue to the Seabrook Joint Owners of about
$2.8 million to $3.6 million per day.
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- 3. However, it will not only be the Joint Owners and their ratepayers and shareholders who will be hurt by unnecessary delay. The puwer that Seabrook Station can produce is needed now to satisfy New 0912270061 891200 l' PDR ADDCK 05000443 0 ,
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England's growing demand for power. New England is experiencing one of the highest rates of growth in the nation. Since August of 1987. New England has experienced severe shortages of electrical power during both the summer and winter peak demand periods. It has been through aggressive action by the New England Power Pool (NEP00L), which manages the power supply for New Ergland, that service throughout the area was maintained. During 1988, challenges in power system operation occurred frequently, whether it was generation shortage throughout the region or a transmission limitation.
Emergency actions taken to meet these challenges and decrease the high demand included enforcement of interruptible power contracts with industrial users, voltage reductions, and puts c appeals to cut back on electricity usage. A study commissioned by the Greater Boston Chamber of Commerce in September, 1988, estimated that the total impact of non-accidental energy supply shortages on the Massachusetts business community alone, during the preceding 12 month period, was approximately $86.8 million.
- 4. The electricity capacity shortage situation is not likely to change for the better anytime soon. New England's economy has been growing significantly, with a parallel increase in electrical energy consumption (KWH) and peak electrical power demand (MW). In fact, as recently as July 27, 1989. NEP00L reported a new summer peak power demand. It was only because all available power plants were running steadily, with no unplanned outages occurring, that this peak demand was met. This growth has placed an unprecedented strain on the New England electric system, since there has not been a corresponding increase in electric generating facilities. With the decrease in the electrical reserve margin has come an increase in the frequency of use of NEP00L emergency operating procedures. During the oil crisis of the early 1970's, these emergency operating procedures were used on many occasions. As this crisis eased and non-oil generating facilities were brought into production, emergency operating procedures were not used again in New England from 1974 through 1983. Emergency load relief measures, however, were implemented by NEPOOL more times in 1988 than at any time since the early 1970's. As recently as December 4 1989, emergency actions including voltage reductions, enforcement of interruptible power contracts, and public appeals for reduced electricity usage were required by NEP00L in order to meet high demand.
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- 5. New England's electrical energy consumption increased 5.22 in 1988, nearly equaling the 5.32 growth experienced in 1987. Since 1983, i electric energy consumption has grown at a compound annual growth rate of 4.62. Along with growth in energy consumption, vinter and summer peak l demand has been increasing at an average rate of 4.52 per year since 1983.
- 6. With the continuation of sustained load growth in New England !
during 1988, and into 1989, NEP00L and New England utilities were required to make optimum use of virtually every generator and transmission line in the New England region.
- 7. Based on a NEP00L draft 1990 Annual Maintenance Schedule, it is projected that, in 1990 New England will experience capacity deficiencies in 25 of 52 weeks without power from Seabrook. In some cases the deficiencies range as high as 1050 MW, which corresponds to a power plant nearly the size of Seabrook Station. New England is in a severe capacity shortage situation. NEP00L is very restricted in scheduling' planned outages during the Summer and Winter peak periods. This places heavy maintenance demands in the Spring and Fall, which results in additional capacity deficiencies within this time period and thus results in capacity shortages throughout the entire year.
! 8. A report published in November, 1988, by the State of New Hampshire, State Electrical Energy Needs Planning Conunittee, recognized the importance of Seabrook operation in meeting the electrical demands. As stated under their recommendations, "[t]he Committee urges the Nuclear l Regulatory Commission to promptly resolve all outstanding questions relating to the Seabrook Nuclear Power Plant".
fbbf Ted C. Feige'nbaum
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TED C. FEIGENTAUN i
Senior Vice President and Chief Ooeratinn Officer i I :
Education c i The City College of the City University of New York ,
Bachelor of Engineering (Mechanical) - 1972 e
Mr. Feigenbaum, a registered Professional Engineer, was elected -
Senior Vice President and Chief Operating Officer of New Hampshire Yankee in
' July, 1989. He is the management official in charge of all operations at Seabrook Station. He is responsible for the activities of a total work force of over 1400 personnel.
- t Mr. Feigenbaum joined Public Service Company of New Hampshire in 1986 as Executive Assistant to the Senior Vice President. Subsequently in 1987 Mr. Feigenbaum became the Vice President, Engineering Licensing, and Quality Programs. In the latter position, he was the corporate officer ;
responsible for all aspects of design, engineering, licensing, quality j assurance and quality control. He was responsible for the conduct and operation of Plant Engineering, Configuration Management Group. Reliability and Safety Engineering, Licensing, Quality Inspections Audit and Surveillance Groups Independent Safety Engineering Group, Independent
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l Review Team, and Employee Allegation Resolution Program. He directed the ;
l efforts of 175 professional staff and contract personnel.
As Executive Assistant to the Senior Vice President, Mr. Feigenbaum was responsible for assisting the Senior Vice President in accomplishing Company goals and objectives by developing and implementing programs to assure safe and reliable plant operation. He performed independent reviews of Company operations on a regular basis and appraised the effectiveness, efficiency, economy, and conformance of activities to established standards of performance. He advised senior management regarding realistic, practical and comprehensive actions to effect improvement or correct deficiencies.
(C.)
Mr. Feigenbaum came to Public Service Company cf New Hampshire from .
Ebasco Services. Inc. , where he was employed (rnm 1978 to 1985. He held the position of Independent Review Team Leader for the Seabrook Station, supervising engineers who conducted detailed evaluations of construction and engineering activities. He provided oral and written reports and recommendations to senior project management and Joint Owners relating to schedule budget and technical adequacy of Project activities. ,
Mr. Feigenbaum was a Project Engineer for the St. Lucie Nuclear Power Plant. Units 1 & 2 of Florida Power & Light Company responsible for design and retrofit engineering. He supervised the activities of eighty multi.
disciplined engineering and design personnel and was responsible for technical quality, planning, and scheduled adherence and cost control. He also supervised home office engineering personnel, liaison with site engineering staff and construction support, licensing activities and coordination of all major regulatory related tasks. This Project experience included lead mechanical engineer responsible for all phases of mechanical, nuclear, water treatment and radweste systems engineering.
Mr. Feigenbaum was Lead Piping Engineer for Shearon Harris Nuclear Power Plant of Carolina Power & Light Company responsible for engineering, design, and procurement of all piping and support systems.
l Between 1972 and 1978. Mr. Feigenbaum was employed by Stone & Webster Engineering Corporations as a Lead Systems Engineer, Turbine Engineer and Engineer. As a Turbine Engineer on NYSPA Greene County Plant he was responsible for administration of the turbine-generator contract and as a Lead Systems Engineer on Virginia Electric and Power Company Surry Nuclear Power Station, Units 3 & 4 he was responsible for engineering, design and l equipment procurement for all BOP systems, l
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STATE OF NEW HAMPSHIRE Rockingham, ss. December 6, 1989 Ted C. Feigenbaum, being on oath, deposes and says that he is the author of the foregoing affidavit and that the statements set forth therein are true to the best of his knowledge, before me.
14 Au b $cNcuatu Notary PabIlic )
My Comission Expires March 6, 1990
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IN THE UNITED STATES COURT CF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT COMMONwtALTN OF MASSACNUSETTS, )
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Petitioners, )
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- v. ) Hos. 89-1308 '
) 08-1821 UNITED STATES NUCLEAR REGULATORY ) 88-1819 C019415820N and the UNITED ) 84-1417 STATES OF AMERICA, )
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Respondents. )
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1 DECLARATION OF JAMES D. WATRINS .
I, James D. Watkins, hereby declare under the provisions of 28 U.S.C. 1744 as follows:
- 1. I as the Secretary of Energy and, as such, head of the United States Department of Energy.
- 2. The Department of Energy was established to " promote the general welfare by assuring coordinated and effective administration of Federal energy policy and programs." 42 U.S.C.
7112. In establishing the Department, Congress found that "a strong national energy program is needed to meet present and future energy needs of the Nation consistent with overall national economic, environmental and social goals" (42 U.S.C.
1 7111(3)), ano it charged the Department with, among other things, l
responsibility for coordinating, formulating and implementing l
" national energy policy * *
- to deal with the short , mid- and long-term energy problems of the Nation" (42 U.S.C. 7112(3));
"promot(ing) the interests of consumers through the provision of an adequate and reliable supply of energy at the lowest
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f ro2sonablo c:st* (41 U.S.C. 7112(9)): cnd 'assur(ing) l
- inoerporation of national enetrarmantal protection goals in the -
fo nulation and implementataan af energy programa" (42 U.S.C.
7112(13)).
- 3. This Declarattan to preytaled to inform the Court of the :
! public interest, which the :fust desertbed mandate of the l
Department of Energy sabes of sponial concern to es, in not -
staying the low power testing.at the sembrook nuclear power plant ,
recently authorised by the steelear negulatory consission (NHC).
I The specific facts and figures set forth in this Declaration have .
been assembled by Departmental staff in the regular course of l their duties.
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- 4. I have been advised that the ongoing NRC proceedings i
involving Seabrook could result in issuance of a license for full power operation by as early as September 30, 1989. The Leeue I here concerns possible delay is the use of such a full power license. Even though actual . low power testing may take only a I few weeks to perform, this testing is designed to permit early discovery and correction of any unanticipated problees.that might delay full power operation. *
- 5. Seabrook's generating capacity is about 1186 MW. Over SS billion has been opent building..this plant, which is now completed and awaiting final NRC authorisation to enter into full power operetten.
As.the following facts demonstrate, New England urgently neede the power that Seabrook is ready to provide, and I
there are no satisfactory near-term alternative sources of l
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, supply ;
(a) To maintaan reliable electric service, most utilities [
- subscribe to a reliability standard which requiras a reserve
margin, or an sacess of generating capacity over peak demand, of 18 to 20 percent. Although the reserve margin in New England is I'
currently at about 24 percent, the actual operating margin has on occasion fallen as low as 3 percent due to equipment failures ,
and/or eseoerbated peak dessada (which, in New England, occur in both summer and winter), Moreover, in 1987 and again in 1988, the demand for electricity in New England grew at about 5 percent a year. This sustained and relatively rapid demand growth refiscts both a robust regional economy and several very het suaners and was appremimately double the rate of projected growth for the region.
i If Seabrook does not become operational, and if demand grows only at a modest 2.5 percent rate, regional reserve margine could fall below 20 percent later this year. As reserve margins fall below 20 percent, the syst&m becomes more vulnerable to contingencies.
During the past year, in fact, New England suffered repeated " brownouts" and rolling " blackouts," and similar emergency procedures will probably again become necessary as soon as this summer.
An unreliable electricity supply system can inhibit regional economic growth and diminish the quality of life of our citizana.
For New England, the danger of falling below the point where l
adequate electric service can be assured to both real and immediate. Within a year of coming on-line, Seabrook could l
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prcvido enough power to add an cddittenal 6 porocnt to New England's electric reserve margin.
(b) There are no satisfactory alternative sources of supply to Seabrook that could meet New England's near-tera energy needs (1) Although the region's estating oil-fired steen plants could conceivably be t. sed more intensively, this would increase the region's and the Nation's dependence on imported oil and regional reserve mergine still would be insufficient to deel with entreme weather or equipment failures. (11) There has been no significant construction of coal-fired plants in New England for the last two decades and, even if strong environmental cpposition to such plante could be overcome, it would take S to 8 years to build new coal-fired capacity. (iii) New England presently has very limited gas pipeline capacity and, although there are plans to espond gas pipeline capacity, new lines and gas-fired combined cycle units could not be available until the mid 1990s. Gas.
fired combustion turbines could be built more quickly, but they would be more expensive to operate and the uncertainties related to completion of the proposed natural gas pipeline projects make this alternative uncertain as well. (iv) Relying on imported Power, either from Canade or from other regions of the United States, also will not provide energy reliability and adequacy.
The future development and availability of Canadian electricity is uncertain et beat and, in the time it would take to build new transmission lines, strong demand growth in other regions of the United States is expected to deplate any power surpluses these 4
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1, regions currently hSvo. -(v) Finally, wh110 thoro h0VO been aggressive conservatten programs carried out by utilities in New England, esperience has shown that these conservation afferta cannot keep up with the rapid economic growth in the region and I with consequent electric demand.
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- 6. Energy security, economic and environmental considerations also weigh strongly against any delay in Seabrcok I coming on-lines (a) Neerly half of the installed generating capacity in New '
England is now designed to run on oil, and that region is heavily )
) and uniquely dependent on imported oil. Furthermore, the Nation as a whole is becominri increasingly dependent on insecure sources of imported oil to meet its energy needs. By a conservative estimate, Seabrook will generate about 6.8 billion kilowett-hours :
each year, which would displace demand for roughly 11 million barrels of oil a year. At the recent crude oil price of approutmately $20 per barrel, running Seabrook could reduce our trade deficit by some 8220 million a year, and simultaneously ;
enhance the Nation's energy security.
(b) Since the costs of building Seabrook already have been incurred, the relative economics of alternative sources of supply depend on a comparison between the costs of operatino Seabrook and the coste of develocino and operating alternative facilities.
j Such a comparison makes it clear that there is no economically sound alternative to Seabrook, which currently stands ready to l
produce power at a levelized cost of operation of about 2.7 5
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cents / kilowatt hour: (1) The levelised costs of an equivalent 1 increment in oil-fired capacity would be about 8.1 1 cents /kilowett-hour for new combined cycle generation (which !
would take about 5 years to develop) and about 11.1 cents / kilowatt-hour for new combustion turbine generation (which t i
would take 2 4 years to develop). (11)
The levelised costs of an equivalent increment in new coal-fired capacity (which would 1 take about 5-0 years to develop) would be about 5.6 cents /kilowett-hour. (111)
The levelised costs of an equivalent increment in new gas-fired capacity would be about 5.2 cents / kilowatt-hour for combined-cycle units (which would take -
about 5 years to develop) and about 6.5 cents / kilowatt-hour for combustion turbines (which would take about 2-3 years to develop). (iv) Current contracts suggest that it would cost about 4.2 to 4.9 cents / kilowatt hour to import additional t ,
electricity from canada, if such electrietty is available at all.
(c)
Although there are environmental issues related to operating Seabrook, the alternatives to operating Seabrook also raise environmental issues. of particular concern are the " Acid Rain" and " Greenhouse" effects of fossil-fired plants, which amit sulfur dioulde, nitrogen oxides and carbon dioxide. These are Capecially serious concerns in New England, whose electric utilities in 198'1 emitted an estimated 390,000 tons per year in sulfur dioside and 130,000 tons per year in nitrogen oa, ides --
J which are precursors to " Acid Rain" -- and an estimated 49 '
million tons per year in carbon dioxide -- which is one of the 6
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gase3 that some s21entists bO11 eve is o asjer contributor to i l possible etasepherte warning. Replacing Seabrook with equivalent i coal-fired especity could add up to an additional 20,000 tons per !
l year in both sulfur dioside and nitrogen oxides emissions, and an '
i additional 6 million tons in carbon dicaide emissions.
stallarly, replacing seabrook with equivalent oil-fired capacity ,
l oculd produce 5,000 tons of additional yearly sulfur dioxide '
emissions, 8,000' tons of additional yearly nitrogen osides ,
emissions, and 4 million tons of additional yearly carbon dioside emissions. And although the emissions problems from gesafired
! plants are slightly less dramatic, even they could result in additional yearly emissions of 6,000 tons of nitrogen oxides and 3 million tone of carbon dioxide.
- 7. Considerations of energy reliability, energy security, ,
economics and environment thus all indicate a pressing need for seabrook. Any unnecessary delay in bringing this plant on-line would be, quite simply, bad energy policy and flatly inconsistent with the public interest.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on May 19, 1989 es D. Watkins dairal, U.S. Navy (Retired) 7 0td SC-1d-NdMo-DMMSU ',, nyttt tt SG EE '90
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q3Lm CERTIFICATE OF SERVICE 89 EC 11 M2 :26 I, George H. Lewald, one of the attorneys for the Applicants herein, hereby certify that on December 8, 1989, I made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or where indicated, by depositing in the United States mail, first class postage paid, addressed to) the individuals listed below:
Kenneth M. Carr, Chairman Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 James R. Curtiss, Commissioner U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Kenneth C. Rogers, Commissioner William C. Parler, Esquire U.S. Nuclear Regulatory General Counsel Commission Office of the General Counsel One White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 l
G. Paul Bollwerk, III, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing l Appeal Panel Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Alan S. Rosenthal, Esquire Thomas S. Moore Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 l
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Administrative Judge Ivan Smith Administrative Judge Kenneth A.
Chairman, Atomic Safoty and McCollom Licensing Board 1107 West Knapp Street U.S. Nuclear Regulatory Stillwater, OK 74075 :
Commission ;
East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Richard F. H. Joseph Flynn, Esquire Cole, Atomic Safety and Office of General Counsel Licensing Board Federal Emergency Management U.S. Nuclear Regulatory Agency Commission 500 C Street, S.W. :
East West Towers Building Washington, DC 20472 4350 East West Highway Bethesda, MD 20814 ,
Mr. Richard R. Donovan Diane Curran, Esquire Federal Emergency Management Andrea C. Forster, Esquire t Agency Harmon, Curran & Tousley Federal Regional Center Suite 430 .
130 228th Street, S.W. 20C1 S Street, N.W.
Bothell, WA 98021-9796 Washington, DC 20009 Robert R. Pierce, Esquire John P. Arnold, Esquire Atomic Safety and Licensing Attorney General Board George Dana Bisbee, Esquiro U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street
- 4350 East West-Highway Concord, NH 03301-6397 Bethesda, MD 20814 Adjudicatory File Mitzi A. Young, Esquire Atomic Safety and Licensing Edwin J. Reis, Esquiro Board Panel Docket (2 copies) Office of the General Counsel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building One White Flint North, 15th Fl.
4350-East West Highway 11555 Rockville Pike
! Bothesda, MD 20814 Rockville, MD' 20852
- Atomic Safety and Licensing Robert A. Backus, Esquiro Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105
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Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectman's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333
-Paul McEachern, Esquire John Traficente, Esquire Shaines & McEachern Assistant Attorney General Maplewood Avenue Department of the Attorney-P.O. Box 360 General Portsmouth, NH 03801 One Ashburton Place, 19th Floor Boston, MA 02108 .
Chairman Mr. Calvin A. Canney Board of Selectmen City Manager 95 Amesbury Road City Hall Kensington, NH 03833 126 Daniel Street Portsmouth, NH 03801
- Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton &
Washington, DC 20510 Rotondi (Attnt Tom Burack) 79 State Street .
Newburyport, MA 01950
- Senator Gordon J. Humphrey Barbara J. Saint Andre, Esquire ]
One Eagle Square, Suite 507 Kopelman and Paige, P.C.
Concord, NH 03301 77 Franklin Street ,
(Attn: Herb Boynton) Boston, MA 02110 '
Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 ,'
Ashod N. Amirian, Esquire Judith H. Mizner, Esquire 145 South Main Street 79 State Street, 2nd Floor P.O. Box 38 Newburyport, MA 01950 Bradford, MA 01835 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03842 Concord, NH 03301
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i Marjorie Nordlinger, Es7 dire Office of the Guneral counsel One White Flint North 11555 Rockville Pike Rockville, MD 20852 i
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=N George' H. Lewald __
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