ML20032D865
| ML20032D865 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 11/05/1981 |
| From: | Farris J CITIZENS ACTION FOR SAFE ENERGY, FELDMAN, HALL, FRANDEN, REED & WOODWARD |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-CP, NUDOCS 8111180190 | |
| Download: ML20032D865 (9) | |
Text
4 DOCKETED t
USHRC UNITED STATES OF AMERICA 3
E -9 A11 :58 NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD c qE 0F SECRETARY
[OCW ii!!iG & SERVICE CRANCll Before Administrative Judges Sheldon J. Wolfe, Chairman Dr. Paul W. Purdom Frederick J. Shon In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
OKLAHOMA, ASSOCIATED
)
Docket Nos. STN 50-556CP ELECTRIC COOPERATIVE, INC.
)
STN 50-557CP and
)
WESTERN FARMERS ELECTRIC
)
?
b COOPERATIVE,
)
d,(,f," y "
8 (Black Fox Station,
)
Units 1 and 2)
)
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INTERVENORS' MOTION TO RE-OPEN THE RADIOLOGICAL AND SAFETY HEARINGS qgr fb-Intervenors, pursuant to Consumers Power Co., ALAB-235, 8 AEC 645, 646 (1974), respectfully move the Board to re-open the record as to the following contentions:
1.
Financial Qualifications (Intervenors' Original Contention 18) 2.
Containment (Intervenors' Original Contention 16)
In so moving the Board, Intervenors are mindful of the showing mandated by Vermont-Yankee Nuclear Power Corp., ALAB-124, 6 AEC 358 (1973);'however, it is submitted that the exhibits and' matters submitted herewith more than satisfy the test of Vermont
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s Yankee.
In particular, Intervenors recognize that:
[A] licensing board is required to reopen the record only when'the matters raised are, in the board's opinion, of major significance to-plant safety.
Vermont Yankee at 365.
As will be shown, infra, the new evidence bearing on both issues will have the requisite impact on safety to justify this request.
A.
Financial Qualifications 1.
Pursuant to the Commission's. regulations found in 10 CFR 550.33 (f).and 10 CFR Part 50, Appendix C, applicants for a construction permit must file financial information to show they 4
have funds,-or have reasonable assurance of obtaining the funds, necessary to safely construct a nuclear power plant.
In that regard, Public Service Company of Oklahoma, Associated Electric Cooperative, Inc. and Western Farmers Electric Cooperative ~sub-mitted various financial information with their application s
for a construction permit.
In S20.1 of the Safety Evaluation Report ("SER") issued in June, 1977, the Commission _specifically postponed reporting i
its decision as to the financial qualification. issue until.a.
I supplemental SER could be issued, reasoning:
"To assure that we have the latest information to l
make a determination of the financial qualifications I
of an applicant, it is our current practice to review this information during the later stages of our l
review.
." (Emphasis added) l l
c L
l
,~.
Unfortunately, the information reviewed "at the later stages" is now clearly outdated, and if current financial information were reviewed, the Board would likely view the financial qualification question in an entirely different light.
The Staff's initial determination that the applicants were financially qualified, with accompanying analysis and rationale, can be found in S20.0 et seq., of Suppl. 1 to the SER dated September, 1978 (NUREG-0190, Suppl. No. 1);-and the final, unconditioned decision can be found in Suppl.
2.
2.
Follcwing the Staff's conclusion that the applicants had met the requisite reasonable assurance standard and, therefore, satisfied the financial qualifications test, Intervenors filed, among other contentions, their Contention #18 stating that P
applicants had not demonstrated they were financially qualified to build Black Fox Units 1 and 2.
Contention #18 was summarily-disposed of by the Board as being too broad.
3.
In an Order dated September.8, 1978, the Licensing Buacd narrowed original Intervenors' Contention #18 to the more specific Board question, #18-1, asking:
Has PSO provided different data on coverage rating for bonded debt to NRC and OCC,-and if so, what is the recron for the difference?
This question was addressed at later hearings by the parties and to date no change has been made regarding the financial qualifications issue.
4 4.
Using an estimated total cost of $2,042,300,000 for i
the Black Fox Units 1 and 2, and estimated completion dates of i
l -
i 1983-1984 and 1985-1986 for the two units, the Staff accepted the Applicant's financial projections as reasonable and concluded that the reasonable assurance standard had been satisfied. (SER Suppl. 1)
Since the date of these projections and the Staff's determination, however, the economic and financial conditions affecting the nuclear industry overall and the Applicants, in particular, have changed dramatically.
The projections used as the bases for the original determination are no longer viable (indeed, Intervenors believe they never were), and significant new evidence, found in the Touche Ross report, discussed infra, shows that the reasonable assurance standard can no longer be met by these Applicants for a Construction Permit for Black Fox Station.
5.
The aforementioned Touche Ross report was prepared by Touche Ross & Co. for the Oklahoma Corporation Commission in connection with a pending rate-case filed by PSO. A copy of this report has previously been supplied to the NRC as an enclosure to a letter dated September 8, 1981, from Joseph Gallo, one of the attorneys for PSO, to the Board (See Exhibit 1).
Hired as an independent and unbiased economic consultant to l
assist the commission in its rate-making decision regarding,
(
inter alia, PSO's-Black Fox Station, Touche Ross concluded in its report filed August-24, 1981, that based on cost and risk assessment, the Black Fox project should be cancelled i
and converted to a coal-fired facility.
Ie, the overall economic viability of the project has been-seriously jeopardized m
L by the effect of various factors including construction, financial, regulatory and political risks.
In considering this Motion To Reopen, the Board is-urged to note, among other changed circumstances, that:
(a)
The assumptions and projections contained in the Touche Ross report relate to a period encompassing the years 1981-2001 (cover letter to report dated August 24, 1981) whereas the now seriously outdated information used as a basis for the Board's initial'SER conclusion was based on information provided in projections for 1978-1986.
(b)
The SER decision was based on a total estimated cost for Units 1 and 2 of $2,042,300,000.
This estimate, which may have been " reasonable" in 1978, is no longer valid nor " reasonable" and the most recent. estimated completion cost is from 8.177-billion to 10.120 billion.
(c)
The SER conclusions were based upon an assessment that the financing projections-constitute a reasonable and sound-financing plan. (SER Supp. 1 at 20-4)
The Touche Ross report, however, updates and analizes the present financial integrity of PSO in depth and concludes that "although PSO is currently rated AA, our review of the historical and prospective financial condition of the company _-
indicate that significant difficulties exist with respect to the ability to meet certain minimum financial integrity parameters and to ensure. continued-capital; market access _
at reasonable cost."
Touche Ross Report'at p. 113.
(emphasis supplied) i
6.
The financial qualifications of an applicant are directly related to safety.
The Commission's position has been, from the outset of the civilian nuclear power program, that
. safety is the first, last, and permanent consideration" in its licensing activities.
In re Power Reactor Dev. Co.,
1 AEC 128,136 (1959).
Statutory guidance found in 42 U.S.C.
S2133 (b) provides:
The commission shall issue such licenses on a nonexclusive basis to persons applying therefor.
.(2) who are equipped to observe and who agree to observe such safety standards to protect health and to minimize danger to life or property as the commission may by rule establish.
42 U.S.C. S2133(b) (Emphasis added)
Just as the technical qualifications of an applicant are a necessary condition to ensure that it is equipped-to observe the strict
-standards necessary to ensure public health and safety, so are financial qualifications.
The construction and operation of a -
nuclear power plant, a highly complex and delicate technology, requires an organization with commensurate technical competence ---
and financial' stability to meet its-obligation to conform withr--
the strictest of safety standards.
Cost-cutting in this sort of venture could have disastrous consequences.
In the published statement which' accompanied :the pro -
mulgation of 10-CFR Part 50, Appendix C, the Commission unequivocally stated that the purpose of-the financial qualifications requirement is to ensure safety.
This requirement operates in tandem with the various substantive technical regulations:
The Act and-the Commission's regulations reflect =
that the fundamental purpose of the-financial qualifications provision of [42 U.S.C. S2232] is the protection of the public health and safety and the common defense and security. -. -
Although, the Commission's safety deter-minations required the issuance of facility licenses basad upon extensive and detailed technical review, an applicant's financial qualifications can also contribute to his ability to meet his responsibilities in safety matters.
33 Fed. Reg. 9704 (Ja)y 4, 1968).
Thus, the'NRC acknowledged that the Congressional intent behind the Act manifests an effort to erect a double line of defense for-the protection of the public health and safety.
The NRC has stressed previously that the financial qualifications issue arises under the Atomic Energy Acts safety provisions; unless a utility is equipped to observe the NRC's safety requirements, it may not be licensed.
Duke Power Co. (Catawba, Units 1 and 2), ALAB-355, 4 NRC 397, 413-14 (1976)
The Commission's program to ensure safety could, i
unfortunately, be easily undermined by a company's financial instability:
We should not close.our eyes to the likelihood that letting a financially ~ strapped company go ahead with
- Cconstruction will inexorably. result-in decisions to.do, _
less testing, to use lower quality materials,-to ipprove borderline workmanship, and the like.
In-insidious fashion, each such decision even though not consciously designed or believed to do so, increases the-risk-to the public from an eventual _
accident Public-Service Co..of.New Hampshire, et al (Seabrook Station,- Units 1 and 2), - ALAB-422, 6-NRC i
33, dissent at~109.
While not suggesting that PSO is currently " financially strapped,"
even a cursory reading of the recent Touche Ross report indicates
(
l that if PSO continues-in-its efforts to build Black Fox, it may, indeed, guickly approach the brink of financial disaster.
The
m.
~
temptation to cut costs could.then present serious potential-
)
safety problems for the Black' Fox facility.
For all the'above reasons, Intervenors urge the Board to reopen its hearings regarding the financial qualifications and to admit evidence with regard to the foregoing matters.
CONTAINMENT B.
1.
Intervenors original contention No. 16 was as.follows:
Contention No. 16 Intervenors contend, generally, that the applicants for Black Fox, Units 1 & 2, have not established.the integrity of the Mark III containment system in terms of its ability.to withstand the hydrodynamic i
fcrces associated with a. postulated design basis accident (LOCA)..
More specifically, in Contention 16 the intervenors contend that "the applicant has not established the integrity of the Mark III containment-in that5the-following items have not'yet been resolved:
(1)
Vent clearing.
l (2)
Vent / coolant interactions 1
(3)
Pool Swell-(4)
Pool-stratification.
~
(5)
Pressure loads and flow bypass."
i However, subsequent to -the close: of-the--record' on this issue, Applicant, pursuant to a..itter from~Mr. Gallo on July 18,.1979, identified a change-to the containment-design, to-wit:
the construction.of a. concrete reinforcing wall outside the. steel r
containment shell in the annulus between the shell and the containment.. building adjacent to the suppression pool.
This design change was formally documented for the first time in l
Amendment No. 17 to the PSAR..Intervenors submit.that the change i
l l
l I t.
.~
t could have significant impact on safety _n that Applicant has not provided sufficient preliminary design information to show how it will impact the following design factors:
(a)
Thermal transients in.the suppression pool and lines during blow-down and LOCA events.
(b)
Heat transfer from the suppression pool.
(c)
Stress levels in the welds and joints of the Jining and connected piping.
(d)
Connections with the base mat and shield wall.
(e)
Vibratory motion transmitted to other structural components.
(f)
Ability to perform in-service inspection and
- ' leak rate analysis of the suppression-pool-lines.
Without the foregoing analyses.there is no assurance the present suppression pool and containment-design'is adequate to protect containment: integrity during accidents and LOCA conditions.= ~'
CONCLUSION Intervenors respectfully submit, therefore, that the record i
should be reopencC with respect 1to-the foregoing safety issues.
Respectfully subaitted, FELD H
L, FRANDEN & WOODARD Cy os6ph R.
Farris 81 nterprise Building Tulsa, Oklahoma 74103 Attorneys for Intervenors
~
6 003 ETED LWC UNITED STATUS OF AMERICA
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ECPET/ M ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges N, x
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Sheldon J. Wolfe, Chairman 7
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M Dr. Paul W. Purdom Frederick J.
Shon
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,"$2143Pau In the Matter of
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- PUBLIC SERVICE COMPANY OF
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l OKLAHOMA, ASSOCIATED
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Docket Nos. STN 50-556CP
^
2LECTRIC COOPERATIVE, INC.
)
- STN-50-557CP and
)
WESTERN FARMERS ELECTRIC
)
COOPERATIVE,
)
)
(Black Fox Station,
)
Units 1 and 2).
)
INTERVENORS' MOTION TO RE-OPEN THE RADIOLOGICAL AND SAFETY HEARINGS i
Intervenors, pursuant to--Consumers -Power-Co., ALAB-235,
~
8 AEC 645, 646-(1974), respectfully-move the Board to re-open i
'_72- -
l the record as to-the following contentions:
i l
1.
Financial Qualifications (Intervenors' Original Cobtention18)
/
2.
Containm,ent (Intervenors ' -Original-Contention 16) _
In so moving the Board, Intervenors are mindful of the shc, wing mandated by Vermont-Yanke'-Nuclear > Power Corp.,-ALAB-124, 6 AEC 358 (1973); however, it is submitted that the exhibits-and-matters submitted herewith more than satisfy-the test of -Vermont 4. - ~-:_.
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Yankee.
In particular, Intervenors recognize that:
[A] -licensing board is required to reopen the record only when the matters raised are, in the board's opinion, of major significance to plant safety.
Vermont Yankee at 365.
As will be'shown, infra, the new evidence bearing on both issues will have the requisite impact on safety to justify this request.
i A.
Financial Qualifications 1.
Pursuant to the Commission's regulations found in 10-CFR 550.33(f) and 10 CFR Part 50,; Appendix C, applicants-for a construction permit must file financial information to show they have funds, or have reasonable assurance of obtaining the funds, necessary to safely construcf~E nuclear power plant.
In ' hat regard, Public Service-Company of Oklahoma, Associated Electric.
Cooperative ~, Inc._and Western Farmers Electric-Cooperative'sub...
mitted various-financial information with their application for a construction permit.
In S20.1 of--the Saf.'ty Evaluation Report ( " SER" ) issued in June, 1977, the. Commission specifically-postponed reporting.
_s its decision as to-the financial-qualification issue until-a -
supplemental.SER could-be issued, reasoning:
i "To assure that we have the latest' information-to make a determination-of the financial qualifications of an applicant, it.is our current practice to review-this information during the later stages of our l
review.
." (Emphasis added)_
s 1
t
_2-
4 4
Unfortunately, the information reviewed "at the later. stages" 1
is now clearly outdated, and if' current financial information
. were reviewed, the Board would likely view the financial-i qualification question ir. an. entirely different light..
The Staff's initial determination that.the applicants were financially qualified, with accompanying analysis and rationale, can-be found in.520.0 et seq.,.of Suppl. 1 to the SER dated September, 1978 (NUREG-0190, Suppl. No. 1) ; and the final, unconditioned decision can be found in Suppl. 2.
2.
Following the Staff's conclusion that the applicants had met the requisite reasonable assurance standard and, therefore, satisfied the financial qualifications test, Intervenors filed, among other contentions, their Contention #18 stating that applicants had not demonstrated they were financially qualified to build Black Fox Units 1 and 2.
-Content on #18 was summarily i
disposed of-by.the Board as being too broad. - _ _
--3.-
In an Order: dated; September-8, 1978,n the Licensing - -
Board narrowed original Intervenors' Contention _ #18 to the more ipscific.;oard. question,.fl8-1, asking: _
Has PSO provided dif ferent -data on coverage rating _for bonded deot to NRC_and OCC, andrif so, what-issthe-t
/
reason for the_diffe,rence?
~
I This question was_ addressed at later hearing-by.the parties and to date no change has been made regarding the financial qualifications. issue.._
4.
Using an estimated total cost of $2,042,300,000 for the Black Fox Units 21 and 2, and estimated completion dates of--
1 i
6 <
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1983-19S4 and 1985-1986 for the two units, the Staff accepted the Applicant's financial projections as reasonable and concluded that the. reasonable assurance standard had been i
satisfied. (SER Suppl.1)
Since the date of these projections and the Staff's determination, however, the economic and financial conditions in affecting the nuclear industry overall and the Applicants, particolar, have changed dranatically.
The projections used as the bases for the original determination are no longer and viable (indeed, Intervenors believe they never were),
significant new evidence, found in the Touche Ross report, discussed infra, shows that the reasonable assurance standard can no longer be met by these Applicants for a Construction Permit for Black Tox Station?
The aforementioned Touche Ross report was prepared 5.
by Touche Ross- &cCo. for-the Oklahoma Corporation Commission i
_ in connection with a pending rate case filed by: PSO.*-A copy of ithis report = has previously been - supplied to -the--NRC-as an -
enclosure to a letter-dated ~ September-8,- 1981, f rom ~ Joseph ~ Gallo,--
one of the attorneys for PSOf.to the Board (See Exhibit 1-)., -
L Hired as an~ independent and--unbiased economic-consultant-to c c __
j assist the Commission in. its rate-making decision. regarding,
- r-inter alia,. PSO's Black-Fox Station, ' Touche Ross concluded in its report ~ filed August 24, 1981, that based og cost and -
risk assessment, _ the Black Fox project-should be. cancelled. c. _ e and converted to.a coal-fired facility.
Ie,- the overall -.
economic viability of the project has been seriously jeopardized v,
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y-by the effect of various factors including construction, financial, regulatory and political risks.
In considering this Motion To Reopen,_the Board is urged to note, among other changed circumstances, that:
(a)
The assumptions and projections contained in
'the Touche Ross report relate to a period encompassing t!ae years 1981-2001 (coverLletter to report dated August 24,
~'
-t h.:
1981) whereas the now seriou: ly outdated information used as-a basis for the Board's initial SER conclusion was based on information provided in projections for 1978-1986.
(b)
The SER decision was based on a total estimated
~
cost for Units 1 and 2 o' S2,042,300,000.
This estimate, which may have been " reasonable". in 1978, is no longer validLnor " reason @
and_the most recent-est mated completion cost ~is-from 8.177 billio@
to 10.120 billion.
u r_-
(c)
The SER conclusions were based upon an assessment._
..... - ;7-th.ic the financing projections constitute a reasonable-and sound -.
financing plan..(SER Supp. 1"at 20-4)
The Touche ~Ross report, however,. updates and analizes_the-present financial integrity of PSO in depth and concludes.
xx
/
that "although PSO is currently rated AA, our review of -the -
historical and; prospective. financial condition of7the company r- -
indicate that significant difficulties exist with respect to the ability to meet certain minimum financial integrity parameters and to ensure continued capital. market access-u_ - -
at reasonable cost."
Touche Ross Report at p. 113.
(emphasis supplied)
-S-
+
The financial qualifications of an applicant are 6.
The Commission's position has been, directly related to safety.
from the outset of the civilian nuclear power program, that
. safety is the first, last, and permanent consideration" In re PowE-Reactor Dev.
Co.,
in its licensing activities.
Statutory guidance found in 42 U.S.C.
52133 1 AEC 128,136 (1959).
(b) provides:
The commission shall issue such licensef on a nonexclusive
. (2) who are basis to persons applying therefor.
ge uipped to observe and who agree to observe such
~
life or property as the commission may by rule establish.
42 U.S.C. b3133 (b) (Emphasis added) danger to Just as the technical qualifications of an applicant are a necessary' condition to ensure that it is equipped to observe the strict standards necessary to ensure public health and safety, so are The construction and operation of a financial gualifications.-
a highly complex and delicate technology, nuclear power plant, requires an organization with commensurate: technical. competence w.-
1 and financial stability to meet-its-obligationtto-conform with n-Cost-cutting in this sort the strictest of safety standards.-
of venture could have disastrous. consequences.,.,
~_.._.
In the published statement which accompanied: theapro-r-
~
the. Commission unequivocal 4
mulgation of.10.CFR Part 50, Appendix.C,
~
stated that the purpose of the financial-qualifications requiremen%
This requirement operates in tandem with i
is to ensure safety.-
the va ious substantive technical regulations:
t r
The Act and the Commission's -regulations reflect -
that the fundamer.tal purpose of the.. financial-
.u-
[4 2 ~ U.S.C. S2232) is qualifications provision ofthe protection of the public hea i
the common defense and security..
=
e Although, the Commission's safety deter-minations required the issuance of facility licenses based upon extensive and detailed technical review, an applicant's financial qualifications can'also contribute to his ability to meet his responsibilities in safety matters.
33 Fed. Reg. 9704 (July 4, 1968).
Tuus, the NRC acknowledged that the Congressional ~ intent behind the Act manifests an effort to erect a double line of defense for The NRC has-the protection of the public health and safety.
stressed previously that the financial' qualifications issue arises under the Atomic Energy Act's safety provisions; unless it m&
a utility is equipped to observe the NRC's safety requirements, not be licensed.
Duke Power Co. (Catawba, Units-1-and 2), ALAB-355, 4 NRC 397, 413-14 (1976)
The Commission's program to ensure safety could, unfortunately, be easil'f'Endermined by a company's financial instability:
We should not close'our eyes--to the likelihood that
'~
. -letting a financially strapped-company-go ahead with_
_2
_ 22 _ _ __- -
construction will inexorably result-in decisions to do less testing, to. use -lower quality-nateri~als, -to -:
approve borderline workmanship,__and_the_like.
In
insidious fashion, each -such decision even though not consciously designed or believed to-do so,= -
increases the risk-to-the public-from -an eventual =
accident Public Service Coa-of_New Hampshire, et al. n.--
(Seekrook Station, Units-1. and 2), ALAB-422,.6iNRCT 33, dissent at 109.
~
While not suggesting that PSO is: currently."finarcially strapped," r even a cursory reading of the recent Touche Ross report indicates that if PSO continues in its ef forts. to build. Black-Fox,_ it may,.
The indeed, quickly approach the brink of financial. disaster..
i l temptation to cut costs could then present serious potent a safety problems for the Black Fox facility.
For all the above reasons, Intervenors urge the Board to d
reopen its hearings regarding the financial qualifications an to admit evidence with regard to the foregoing matters.
B.
CONTAINMENT 16 was as follows:
Intervenors original contention No.
1.
Contention No. 16 Intervenors contend, generally, that the applicants 2, have not for Black Fox, Units 1 &
integrity of the Mark III containment system in terms of its ability to withstand the hydrodynamic forces associated with a postulated design basisMore spec (LOCA).
"the applicant has accident 16 the intervenors contend that not established the# integrity of the Mark III containment in that the following items have not.yet been resolved:
(1)
Vent clearing (2)
Vent / coolant interactions (3)
Pool Swell Pool stratification-(4)
Pressure loads and flow. bypass."
(5) subsequent to the close of the record on this issue,
- However, 18, 1979, pursuant to a letter from Mr. Gallo on July Applicant, to-wit:
the.
identified a change to the containment design, l
construction of a concrete reinforcing wall-outside the stee h
containment sh(11 in the annulus between the shell and t This containment building adjacent to the suppression pool.
design change was formally documented for the first time in Intervenors submit that -the change =--
Amendment No. 1.7 to the PSAR.
could hive'significant impact on safety in that Applicant has not provided sufficient preliminary de;ign information to show-how it will impact the following design factors:
(a). Thermal transients in the suppression pool s_.3 lines during blow-down and.LOCA events.
(b)
Heat transfer from the suppression pool.
(c)
Stress levels in the welds and joints of the lining and connected piping.
(d)
Connections with the base mat and shield-wall.
(e)
Vibratory motion transmitted to other structural components.
(f)
Ability to perform in-service inspection and leak rate analysis of t[he suppression pool lines.
Without the foregoing analyses there is no assurance the
=._.
._ pres _ent. suppression pool and. containment design is adequate-to.
m.
protect containment-integrity during. accidents,.and LOCA conditions. - -
CONCLUSION Intervenors respectfully submit, therefore,.that the record should be reopened with respect to the foregoing safety issues.
Respectfully submitted,
~
FELDMA', HA L, FRANDEN & WOODARD By os6ph R.
Farris 81-cnterprise Building -
Tulsa, Oklahoma 74103 Attorneys for Intervenors
..