ML20004C565
| ML20004C565 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 05/28/1981 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Kacich R AFFILIATION NOT ASSIGNED |
| References | |
| LSO5-81-05-055, LSO5-81-5-55, NUDOCS 8106040282 | |
| Download: ML20004C565 (4) | |
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gammrucan Docket No. 50-213
'A 1.505-81-05-055 May 28, 1981
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Mr. Richard M. Kacich 7
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Dear Mr. Kacich:
A You letter dated March 24. 1981 addressed to President Reagan has been referred to me for response. Your letter stated that because of the dramatic rise in costs of your electricity over the past several years, you have tried to determine some of the reasons behind the cost escalations and in particular why the costs for nuclear energy appear to be escalating as well.
Your letter indicated that there are two recent letters submitted to the NRC by Northeast Utilities which show that the NRC was grossly in error regarding cost projectians for coglying with certain regulatory require-ments. The first letter, dated March 2,1981 and addressed to former Chairman John Ahearne, discusses capital costs associated with Three Mile Island (TMI)-related requirenents. The second letter, dated March 19, 1981 and addressed to Chairman Joseph Hendrie, concerns fire protection regulations.
Specifically, you stated that the March 2,1981 letter identifies numerous instances in which the actual expand 4ture incurred was more than a factor of ten greater than the original NRC cost estimate.
In addition, you stated that the cost of the fire protection requirements will be over 1.2 billion dollars and that you are not convinced that the public interests are best served by this expenditure.
The NRC staff realized during the development of the TMI Action Plan that cost estimates generated solely by the staff, with no industry input, could be in error. However, we had the benefit of cost estimates prepared by the Atomic Industrial Forum, Inc. (AIF).
I am enclosing a copy of a letter dated February 22, 1980 from the AIF (Enclosure 1) that includes cost estimates with regard to the "NRC Action Plan Developed as 3 Result of the TMI-2 Accident" NUREG-0660, draft. The AIF coments were considered by the NRC.
The NRC response to the AIF conments, including resource estiates, is shown in Volume 2 of NUREG-0660 (Enclosure 2). These comments formed the basis for the resource estimates used by the NRC staff.
With regard to the fire protection requirements, a group of utilities, including utilities in your service area, has filed a petition for judicial review of the NRC's fire protection rule. Simultaneously, this group of l
utilities filed a motion with the Comission for a partial stay of the rule.
l The motion for partial stay is currently under review by the Commission.
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In addition, as shown in the March 19, 1981 letter, the estimated cost of
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Mr. Richard M. Kacich May 28, 1981 1.2 billion dollars would be significantly reduced if the request, now before the Conniston, for an exter.sion of time for iglementation of certain fire
. protection requirements is granted. You will also note that the March 19. 1981 letter states that the utility intends to submit exegtion requests for various areas of the plant where the physical configuration and fire loads can be shown to justify fire protection features othar than those required by the Rule.
Should any of these exemptions be granted, it would further reduce the cost you have quoted.
The above discussion relates to the consideration that the staff makes for cost-i' effective alternatives for meeting safety requirements. The staff's mandate from the Congress is that our paramount responsibility is protection of the health ano safety of the public. Where less costly alternatives are proposed that will meet the safety requirements, the staff will of course endorse their implementation. However, safety comes first, then consideration of costs as appropriate.
I hope that this letter is responsive to your concerns.
Sincerely.
DarrE9TrSll6fsEnMAhp}%irector Original signed by Division of Licensing
Enclosures:
DIS W BUTION:
1.
AIF letter dated Docket ECase 2/22/80 2.
NUREG-0660. Vol. 2 R
TERA SHanauer NSIC RMattson ORB #5 RF TMurley DEisenhut RVollmer RPurple BSnyder JRoe Glainas NHughes HSmith WPaulson TWambach OELD DNottingham (NRR-81-227)
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1.2 billion dollars would be significantly reduced if the request, now before i
the Consnision, for an extension of time for implementation of certain fire protection requirements is granted. You will also note that the March 19, 1981 letter states that the utility intends to submit exemption requests for various areas of the plant where the physical configuration and fire loads can be shown to justify fire protection feitures other than those required by the Rule.
Should any of these exenptions be granted, it would further reduce the cost you i
have quoted.
I hope that this letter is responsive to your concerns.
Sincerely.
'i Darrell G. Eisenhut, Director Division of Licensing I
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DISTRIBUTI0it' 1.
AIF letter dated Docket ECase NRC POR HDenton 2.
NU 0, Vol. 2 LPDR PPAS TERA SHanauer NSIC RMattson ORB #5 RF TMurley DEisenhut RVollmer RPurple BSnyder JRoe Glainas NHughes HSmith WPaulson TWambach OELD
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Mr. Richard M. Kacich h8 Wopovog Road East Hampton, CT 06424 March 24,1981 The Ecnorable Ronald Reagan President of the United States of America The White House 1600 Pennsylvania Avenue Washington, DC As a resident in the state with one of the highest dependencies on nuclear power for its electricity supply, I'have beccme increasingly alarmed over developments regarding the regulation of the nuclear power industry in general and Northeast Utilities in particular.
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I have experienced a dramatic rise in my electric bill over t' ! past several years to the point where it has a very substantial impact on my monthly bud-get.
I own a totally electric home; and, therefore, I have few alternatives but to endure these exorbitant cost increases to keep my family comfortable.
For the above reasons, I have tried so determine some of the reasons behini these cost escalations.. The ever increasing costs for oil are clearly a factor, but are recogni::ed to be outside the control of Northeast Utilities.
This leads me to believe that every effort should be =ade to utilize energy sources not dependent ons oil. For the iz: mediate future, it appears to me that the nuclear option is the only viable one for the state of Connecticut.
I have, therefore, investigated this matter in terms of determining why costs for nuclear energy appear to be escalating as well.
My review has revealed two recent documents submitted to the Nuclear Regulatory Cc= mission (NRC) by Northeast Utilities which strongly suggest that the NRC is abusing its authority and has lost its perspective on the scope of regulation which is optimal for the protection of publie health and safety.
I am attaching these two documents, the first being a March 2,1981 letter to then Chairman John Ahearne discussing the capital costs associated with 24I related requirements. The second is a March 19, 1981 letter to Chair =an Joseph Hendrie regarding recent fi.=e protection regulations. I find it in-comprehensible that ad independent agency such as the NRC with a clear mandate to promulgate regulations that protect the public health and safety in a cost effective manner can be so grossly in error regarding the cost projections for complying with their requirements.
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- Regulatory reform has clearly been one of the principle objectives of your administration, and ultimately I believe such reform vill be a significant stimulus to the economy. At this time, however, the attached documents suggest that these new policies have yet to have an impact within the NRC.
The first letter identifies numerous instances where the original NRC cost estimate was more than a factor of 10 less than the actual expenditures incurred.
'"he second letter involves a new regulation where the NRC estimated that no additional costs would be incurred, and Northeast Utilities estimates that over $1.2 billion vill be expended. I a= not convinced that the public interests are best served by the expenditure of this exorbitant sum to ex-tinguish hypothetical fires in nuclear power plants.
You he.ve been quoted to say that:
"Too much big government and all their inane regulations can actually be dangerous."
It appears the attached documents may be examples of this concern.
I believe I speak for the majority of the citizens of the State of Connecticut when I ask for some positive action to be taken to insure that our energy dollars are invested visely.
Although you undoubtedly have many other priorities demanding your attention, I would appreciate a response to this letter at your earliest cenvenience.
Very truly yot rs,
Richard M. Kacich ec:
Dr. J. Hendrie, Chairman Nuclear Regulatory Cormission Representative Toby Moffett
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4 March 2, 1981 Docket Nos. 50-213 50-245 50-336
_B10163 Dr. John Ahearne, Chai m n U. S. Nuclear Regulatory Comission Washington, D.C.
20555 Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos.1 and 2 Capital Costs for Implementation of Action Plan Reauirements As a result of the March,1979 accident at Three Mile Island Unit No. 2, the NRC developed a comprehensive and integrated plan for implementation of actions jud ed necessary by the Co= mission to correct or improve the regulation and 6
operation of nuclear power plants. In May,1980, the NRC published NUREG-0660, the TMI Action Plan. Included in the Action Plan vere NRC Staff estimates of industry resources and schedules necessary to implement the various Action Plan require =ents.
Sections 2(E) and 3(A) of Executive Order 120.'s frca former President Jimy Carter required the NRC to establish criteria for evaluating regulations and analyzing alternatives. A letter from former Commission Chairman Joseph H. Hendrie to the President of the United States, dated July 21, 1978, includes the following quote frem the NRC's Value-Impact guidelines, adopted by the Commission in January, 1978.:
"The policy of the Fuelear Regulatory Comission in that value-impact l
analysis be conducted for any proposed regulatory actions that might impose a significant burden on the public (where the term public is defined in the broadest sense). Such policy is not to be construed to mean that cost considerations take precedence over considerations of health, safety, environment, or national security. These factors r main paramount. However, where there are alternative means of realizing equivalent benefits in regulatory matters, cost should be a prime consideration."
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The purpose of a value-impact analysis is to assure that the expenditure of capital and manpower resources by both the licensee and the Staff vill result in increased plant safety. Thus, the expenditure of significant resources is justified only if it significsntly furthers the protection of the public health and safety. In a value-impset analysis, there is always a trade-off between cost and benefit. These value-impact analyses zur.t be relevant input in determining the appropriateness of new re-quirements contemplated by the Ccamission. As with any decision making process, accurate input is sine qua con, and is a prerequisite for the NRC to make informed decisions.
Experience has descostrated that the Staff's estimate of indt.atry resources required to achieve compliance have been consistently lov, sometimes b/
an order of magnitude or more. Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) maintain that had the NRC performed realistic value-impact analyses on the Action Plan re-quirements and properly weighed cost against benefit, a number of the requirements vould not be justified in terms of increased plant safety.
In s'upport of this position, CYAPCO and ICIECO hereby prcvide the attached listing of Actica Plan requirements and c. ecmparison of the Staff's re-source estimates with actual costs incurred to date for the Haddam Neck Plant and Millstone Unit Nos.1 and.2.
Clarifying footnotes are included as sppropriate. It should be noted that the costs listed in the Attachment ere not the final costs in all cases, but only represent dollars expended to date. In addition, these figures do not include replacement power costs incurred by increased plant down-time. NRC estimates for implementation of the Action Plan requirements were obtained frem NUR9G-0660. CYAPCO and NNECO are not aware of any quantification of the benefits which should have been used as justification for premulgation of these requirements.
As is clearly shown on the attached table, the NRC has significantly under-estimated the recources required to comply with these requirements. For example, the Staff's estimate for installation of the Reactor Coolant System High Point Vents, Item 11.B.1 is $100,000 per plant. Actual costs for installing the vent system at the Haddam Neck Plant and Millstone Unti No. 2 were, on the average,1,000 percent higher than the NRC estimate.
CYAPCO and NNECO are providing this unsolicited information with the in-tention of knproving future Staff estimates of industry resources used in cost-benefit analyses. To that end, we trust the Staff vill perform more realistic value-impact analyses before mandating costly directives.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY SO:GANY
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W.'G. Counsil Senior Vice President ec: See next page
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Comunissioner 'P. ~A.' Bridford Commissioner V. Gilinski Commissioner J. M. Hendrie r.
Mr. J. Carson Marli-
. Chairman, Advisory Conunittee on Reactor Safeguards
! E'. Bruce Babbitt
- Chairman, Nuclear Safety Oversight Com:nittee 1
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l NRC COST ESTIMATES VS. ACTUAL CAPITAL COSTS FOR TMI ACTION PLAN REQUIREMENT
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TMI Action Item NRC Cost Haddam Neck Millstone Millstone Plan No.
Description Estimate Plant
~ Unit No. 1 Unit No. 2 11.B.1 Reactor Vessel 100,000 1,102,000 NA 988,000 Head Vent i
ll.B.2 Plant Shielding 50,000 6,000 252,000 155,000 Review
'll.B.3 Post Accident 100,000 652,000 651,0G0 400,000 l*
11.D.3 Valve Position 100,000 186,000 222,000 97,000 l
Indication
- I2) f 11.E.1.1 Auxiliary Feedwater 30,000 162,000 FA
?y System Evaluation ll.E.1.2 AFWS Initiation and 20,000(3) 305,000 NA 714,000 1
Flow Indication I4)
--(5) li.E.4.2 Containment 350,000 59,000 5,000 Isolation 11.F.1; Accident Monitoring 250,000 1,245,000 1,746,000 832,000 l
ll.F.2 Instrumentation to 250,000(6) 146,000 NA 51,000 Detect ICC
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111.A.I.2 Emergency Operations 4.54 million 6,237, G 2,625,500(8) 2,625,500(8)
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Preparedness I9I ll1.D.l.1 Systems Integrity 5,000 1,149,000 125,000 6,000 lli.D.3.4 Control Room 500,000 257.000(10) 256,000(10) 205,000(10) i Habitability l
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FOOTNOTES i
(1) Readers of this document are cautioned against totaling the columns to determine the average comparison of NRC estimates vs. actual expenditures.
Items III.A.1.2 and III.A.2 dominates the totals and incorrectly bias the results of such a comparison. A valid comparison can only be made on an item-by-item basis.
(2) The resources required to comply with the Bulletins & Orders Task Force recommendations for this item consist primarily of costs for an engineering evaluation of the auxiliary feedwater system, and capital costs for minor system modifications. NNECO is unable to quantify these costs, however, total ost should not exceed the NRC estimate.
(3) The NRC cost estimate includes safety-grade Automatic Auxiliary Feedwater Initiation and ilow Indication. Actual costs were approximately 35 times higher than the NRC estimate for Millstone Unit No. 2.
Such a significant expenditure is justified only by a substantial increase in plant safety. During the ACRS Subcommittee meeting of the Bulletins and Orders Task Force held on January 3, t
1980, in testimony from M. P. Matthews of NRR responding to Dr. Zudans of '.he Equipment Qualification Branch, Matthews acknowledged that the only reason for requiring automatic initiation of auxiliary feedwater was because an analysis showed that automatic initiation provides higher reliability for the Auxiliary Feedwater System.
Matthews acknowledged that automatic initiation does not necessarily lessen the consequences of a particular event.
In the case of Millstone Unit No. 2, expenditure of close to three quarters of a j
million dollars has, in the judgment of the Staff, only increased i
reliability and not necessarily increased plant safety. The position of CYAPC0 and NNECO was thoroughly discussed in a letter from W. G.
I Counsil to Commissioner Hendrie dated November 30, 1979.
(4) This figure does not reflect the total cost to comply with this requirement. Final expenditures will not be available until other i
NRC issues regarding containment isolation are resolved. However, the cost is expected to be significantly greater than is given here.
(5) Costs to comply with this requirement were for an engineering evaluation of the requirements of this item. NNECO is unable to quantify these costs, however, total, cost should not exceed the NRC estimate.
(6) The NRC estimata includes costs for a subcooled margin monitor and a reactor vessel water level monitoring device. The Haddam Neck Plant and Millstone Unit No. 2 costs reflect only the cost of the subcooled margin monitor. The resources required to achieve full compliance with this requirement will significantly exceed the Staff's estimate.
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.o (7) This estimate is from the December,1979 draft of NURCG-0660.
Later versions of NURLG-0660 quoted industry estimates'for this item and were much more realistic. The NRC estimate given here is for total resources to comply with Chapter III in its entirety..A comparison of this estimate with actual expenditures for only two sections of Chapter III shows that this estimate is significantly low. Compliance with Chapter III, including (Se Nuclear Data Link (NDL), will require resources in excess of t.
se already expended and far more than in the NRC estimate.
(8) This represents one-half of total cost, since costs are equally shared by Millstone Unit Nos.1 and 2.
(9) Includes modifications to prevent unplanned releases as a result of the North Anna incident.
(10) Actual expenoitures to date far this requirement reflect only the cost of evaluating present habitability systems. Modifications to these systems are under development and will significantly increase capital costs for all three units.
It is clear that the NRC estimate will ultimately be exceeded by a significant amount.
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March 19, 1981 Docket Nos. 50-213 50-245 50-336 A01426 Commissioner Joseph Hendrie, Chairman U. S. Nuclear Regulatory Commission 1717 H Street Washington, D.C.
20555
References:
(1) Federal Register, Volume 45, No. 225, dated Wednesday, November 19, 1980.
(2)
D. G. Eisenhut letter to All Power Reactor Licensees with Plants Licensed Prior to June 1, 1979, dated November 24, 1980.
(3)
W. G. Counsil letter to D. G. Eisenhut, dated January 13, 1981.
(4)
D. M. Crutchfield letter to W. G. Couasil, dated February 13, 1981, transmitting Amendment No. 71 (Docket No. 50-245).
(5)
W. G. Counsil letter to Secretary of Corraission, dated June 16, 1980.
(6)
D. G. Eisenhut letter to All Power Reactor Licensees with Plants Licensed Prior to January 1, 1979, dated February 20, 1981.
(7) McNeil Watkins II letter to 9. J. Chilk, dated January 16, 1981.
(8)
J. Michael McGarry III and MaNeill Watkins II Petition for Review Filed with the U. S. Court of Appeals for the District of Columbia Circuit, dated January 16, 1981.
(9)
W. G. Counsil letter to Dr. J. Ahearne, dated March 2, 1981.
(10)
D. L. Ziemann letter to W. G. Counsil, dated February 22, 1980 (Docket No. 50-213).
(11) Transcript of October 27, 1980 Commission Meeting.
(12) Transcript of October 10, 1980 ACRS Meeting.
Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1 and 2 Fire Protection By Reference (1), the Nuclear Regulatory Commission promulgated amendments to 10CFR Part 50, regarding a new fire protection program for nuclear power l
plants licensed to operate prior to January 1, 1979.
The Federal Registcr Notice was published on November 19, 1980 and became effective February 17, 1981.
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