ML20032E059
| ML20032E059 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/26/1981 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8111190573 | |
| Download: ML20032E059 (17) | |
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10/26/81 g
/7 UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION e6 15 BEFORE THE AT NIC SAFETY AND LICENSIE, BOARD In the Matter of I
I Docket Nos. 50 M 5 APPLICATION OF TEIAS LTfILITIES l
and 50 _
GENERATING COMPANY, ET AL. FOR AN
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OPERATIEQ LICENSE FOR COMANCHE
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CASE'S MCTfION FOR POSTPONEMENT OF HEARIN3Sh <
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CASE (Citizens Association for Sound Energy), Intervenor herein, here '1 o
referred to as CASE, heyeb1 files its Motion for Postponement of Hearings.
As the basis for this Motion is the DP&L News release today (see CASE Attachment-A hereto) which states that the estimated cost of Coganche Peak has been changed to $3.h4 billion, and"that the estimated completion dates or the Comanche Peak nuclear plant...have been revised to 193h for Unit 1 and 1985 for Unit 2." (Emphasis added.)
Under these circumstances, and taken in conjunction with CASE's 10/17/81 Motions regarding Contentions 22 and 2h and the Joint Motion of Applicants and CASE regarding Contention 25 of 10/19/81, there is no remaining urgent need to prcceed with the 12/2/81 hearings prematurely. To do so at this time would be a vaste of everyone's time and resources and, in fact, will actually serve to delay the proceedings because of the cut-off of discovery prematurely on issues yet to be fully explored. This is especially true regardin;; Contentions 22 and 5 As stated in CASE's 10/17/81 Motion to Postpone Consideration of Centention 22 (originally dated 10/16/81), CASE did not receive Applicants' 8/24/81 Answers to 8111190573 811026 PDR ADOCK 05000445 0
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the NRC Staff's 7/23/81 letter to Applicants (See CASE Attachment A to our 10/17/81 Motion), in which Applicants responded to the Staff's 18-pages of questions and coments regarding emergency planning until 10/3/81 and we have not had adequate opportunity to review and pursue discovery regarding numerous questions raised by Applicants answers. Further, we have now received an answer frm FEMA to our request for the status of state and local radiolo61 cal emergency preparedness plans for Comanche Peak (See CASE Attachment B hereto). The attached 10/20/81 letter fr m John De La Garza, Jr., Regional Director of FD4A, states:
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"FD4A Region VI is unable at this time to assess the preparedness planning and capability of the State of Texas to make an off-site response to a nuclear accident at the Comanche Peak site. Texas officials have indicated their TARGETED date for submission of a plan for review by FD4A is June 1982.
(This infonnation applies to state planning as well as Hood and Scnervell Counties planning.) As indicated to you earlier, current status of planning information should be obtained from the State."
The current status of planning info'rmation has already been obtained by CASE from the State and was included as CASE Attachment E to our 10/17/81 Motion to Postpone Consideration of Contention 22; it was in the form of a sworn deposition from the State of Texas Administrator, Emergency Response and Investigating Branch, Division of Compliance and Inspection, Bureau of Radiation Control, Texas Department of Health, Robert E. Free. It stated, in part, that:
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"(the Bureau is) shooting for a January 1982 date for submission of the Plan (in draft form) to FEMA for coment; (hopes) to have coments by FEMA by March 1982; (is) tentatively planning for an exercise sometime in August or September 1982, and possibly for a follow-up exercise before fuel load-ing at the Comanche Peak nuclear power plant."
Since, by the Applicants' own statement, Unit 1 is not no-scheduled to be completed until 198h, CASE urges that the Board reco"nsider its previous rulings j
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which were based on a completion date of June 1982 for Unit 1 and on the Board's attempts"tc expedite the hearing schedules in order to alleviate the slippage between the ecxnpletion of <nnatruction and the issuance of an operating license."1
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We further urge that the Board instead schedule a pre-hearing conference for
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12/1/81 and 12/2/81 to ascertain the exact rer. sons for the projected two-year delay in the ccanpletion date. Obviously, the events which led up to this long delay did not occur overnight, and CASE has difficulty accepting the utility's explanation that:
pys-continually
"'The primary reasons for the revised cost of Comanche; Peak are:
changing interpretations of regulations; continuing design changes as a result thereof;.and the extended time period to completion,' (T.L.) Austin
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said."
This statement infers that this is also the reason for the delay; however, no specific resson is S ven for the delay of construction cccipletion. We urge i
and all the.t the Board schedule this pre-hearing conference so that the Board parties can be fully informed expeditiously regarding this important development, which has (we believe) direct bearing on Contention 5 For the reasons stated herein, CASE hereby moves that the, Board grant our motion to postpone the hearings and instead schedule a pre-hearing conference I
for the purpose indicated.
Res ectfully submitted,
' s.) Juanita Ellis, resident ASE (Citizens Association for Sound Energy)"
1h26 S. Polk, Dallas, TX 75224 Board Order of October 20, 1981 directing Staff and Applicant to infom the Board promptly and affirmatively of all changes that might have a bearing on scheduled dates, with a reasonable explanation thereof. -
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CASE ATTACE4ENT A - Page 1 c...
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For M, ore Information
Contact:
E OCT. M Ng{ " '_cJ I
t Ray Ward - 698-7641 gif-0 3 \\
DALLAS, TEXAS - OCTOBER 26, 1981 - The Texas Utilit mpany
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8 announced today, as a result of an annual review of the' Company's
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J construction program, that the estimated completion dates of the Comanche Peak nuclear plan near Glen Rose have beenr'evised to 1984 for Unit 1 and 1985 fm Unit 2.
The estimated cost of the plant has also,been change. to $3.44 billion.
The new cost estimate is an increase from the S2.235 billion estimate made in 1980, according to T.
L.
- Austin, Jr.,
chairman of the, board of Texa$s Utilities.
"Even though the cost estimate has increased substantially since announced in the early 1970s, the electricity produced by this plant will continue to be substantially less than electricity produced by either oil or natural gas,"
Austin said.
j This is because oil and natural gas prices have increased at an even more rapid rate than has the cost of building the nuclear I
plant.which will use a much lower cost fuel that also is a much more stable priced fuel.
extremely complex job
" Building a nuclear power plant is an today because it changes so much from start to finish.
Even with a competent and committed project management and construction group -- which we have -- building a nuclear plant has many moving
. targets.
(more) 506 Commerce, Danas, Texas 75201 i
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Page 2 "The pfimary reasoud t'or the. revised cos~t of Comanche Peak are: continually changing interpretations of regulations; continu-ing design changes as a result thereof; and the extended time period to completion," Austin said.
He stateo that the additional interest cost on borrowec construction money caused by the delay.is a major contributing factor and also cautioned that both the time-J table and cost estimates could change again in the future.
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Comanche Peak is jointly owned by Dallas Power & Light Com-piny, Texas Electric Service Company, Texas Power & Light Company, che Texas Mudicipal Tower Agency, Brazos Electric Power Coopera-tive, Inc., and Tex-La Electric Cooperative of Texas, Inc.
Combined,,the owners 39tve a population of more'than 4.5 mil-lion people covering about one-third of the area and population of Texas.
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Y CASE ATI'ACEMENT A - Page 3 COMANCHE PEAK HACKGROUND INFORMATI'ON 9
Comanche Peak Ste n Electric
.ian is a two unit nuclear fueled electric generating plant c" ly under construction near Glen Rose in Somervell County, Tcn
- ,- oximately 70 miles southwest 4
of..the Dallas /Ft. Worth area.
The heart of each of the nuc h
. is a We'stinghouse pressurized water. reactor.
The heat generated :,f :.. splitting of the uranium fuel will boil water to make steam to turn a trrbine generator.
Each generator will produce 1,150,000 kilowatts.for a station total of 2,300,000 kilowatts.
Originally, Comanche Peak Unit I was estimated to begin generating electricity in.1980 and Unit 2 in 1982.
The estimated operating dates are now 1984 for Unit i and 1985 for Unit 2.
The first cost estimate for the plant, made in 1972, was $779 million.
The co.ht, estimate was revised in 1975 to $987 million, in 1976 to $1.38 billion, in 1977 to S1.7 billion and in 1980 to S2.235 billion.
The current estimate is $3.44 billion, including interest costs' charged to construction of about 57E0 million.
The estimate is subject to further revision as construction continues.
Comanche Peak is jointly owned by Dallas Power & Light Company, Texas Electric Service Company, Texas Power & Light Company, the Texas Municipal Power Agency, Brazos. Electric Power Cooperative, Inc.,
a'nd Tex-La Electric Cooperative of Texas, Inc.
10/81
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CASE ATIACHKENT A - Paga 4 INCREASE 3 IN COST ESTIMATE FOR COT.NCHE PEAK Comanche Peak's new cost estimate is based on additional expenses in the following areas:
ENGINEERING AND REDESIGN S 36 :"! 3 lion Architectural and engineering work done off site on original design and modification of original design.
Site engineering by the field engi-a neering staf f to implement architectural and design changes and support construc-tio6 crafts.
Includes Three Mile Island
,h backfits, pipe support and hanger design.
Indirect support including engineering accounting,, personnel costs such as pay-roll, e tc., purchasing,. warehousing, production control.
LABOR COSTS'
$ 2,45 million Eighteen million additional manhours of direct costs of craft labor including electricians, welders, pipefitters, in-strumentation technicians, startup and tes. ting.
Indirect support personnel, timekeepers, auditors,, personnel items such as payroll insurance, etc.
MATERIALS, EQUIPMENT AND OPERATIONS
$ 22 0 million Oper tions personnel on site, their administrative costs, additional train-ing requirements -- including TMI Lesson Learned Task Force and Security.
Major orders -- nuclear steam supply, major turbine components, fluid handling systems, etc.
Operating support center, additional buildings for increased requirements, additional computing time, and computers.
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t-CASE ATTACHMENT A - Paga 5 Major Three Mile Island' items -
addition of four computers to the control room, a saf*ty parameter e
display system, additions to the nuclear steam supply system, a technical support center.
Miscellaneous items - microwave communication system, taxes (ad valorem), social sec~urity, workman's compensation, construction equipment, rigging, cranes,-etc.
COST OF BORR. OWED MO!'EY
$ 400 million Incrc~ sed interest cost charged to construction resulting from delay.
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CASE ATIACHMENT A - Pag 2 6 PROGRESS AND MAJOR MILESTONES Since Texas Utilities Company submitted an c;_ plication to the Atomic Energy Commission (now Nuclear Regulatory " =.ission) in, July, 1973 to construct the two Comanche Peak units, c 2.t has been accomplished and considerable progress has been nnde in constructing, a
licensing and readying Comanche Peak for operation.
Listed below are some of the m' ore significe -T tect milestones:
5 s Application to construct Comanche
!iuly, 1973 Peak Steam Electric Station sub-mitted to Atomic Energy Cormnission (AEC)
Public hearings on construction between July and..
application following AEC and ACRS November, 1974 reviews Construction permit received from AEC.
December, 1974 Construction began Began filling Squaw Creek Reservoir February, 1977 from Lcke Granbury Application to operate Comanche Peak February, 1978 submitted to.,NRC Reactor vessels set inside contain-Unit 1 May, 1978 ment buildings Unit 2 July, 1979 Conta'inment buildings ' topped out' Unit 1 January, 1979 with concrete Unit 2 October, 1979 Squaw Creek Reservoir filled May, 1979 Major concrete work completed Unit 1 July, 1979 Unit 2 October, 1980 Unit 1 control room manned for January, 1980 first time 6
t-CASE ATTACHMENT A - Pag 2 7 Startup transformers, energized 138kv January, 1980 345kv July, 1981 First major mechanical system run March, 1981 at Comanche Peak (Service Water Systent)
NRC issued Safety Evaluation Report July, 1981 (Operating license stage)
NRC issued Final Environmental September, 1981 Statement
(. Operating license stage)
Unit 1 steam, turbine and electrical September, 1981 generator ready for rotation Unit 2 electrical generator rotor October, 1981
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CASE ATIACBMENT A - Paga 8
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ESTIMATES OF THE COST OF ELECTRICITY FROM ALTERNATE FUELS IN 1986 AND 1990 When Comanche Per '- goes into operation, it is estimated that'the
' cost of the electrici. ;. generated will compare favorably with other available alternativu s.
In 1986, the cost of electricity in cents per kilowatt-hour from Comanche Peak is expected to be slightly more than that from a lignfle~
s unit pinced in servi::: c '- th:t time,.and considerabl,less than electri-ciky generated by natura; ad or oil in an existing unit.
By;1990, the 'expectef continued rapid increase in natural gas and oil costs.will make electricity from Comanche Peak even more-advantageous.
Based on errimates for 1990, it will then be less expensive than eldctricity.from a new lignite plant and less than half the cost of kilowatt-hours generated by out-of-state coal.
The numbers below ir.clude all costs - construc' ion, interest, t
maintenance, fuel, waste cisposal and decommissioning (in the' case of nuclear power).
,,i.v Estimates of the Cost to Deliver One Kilowatt-hour to the Transmission System 1986 Gas / oil Lignite coal Nuclear cents per 11.8 5.3 6.1 Kwhr 1990 Out-of-state Gas / oil Lignite coal Nuclear
- coal cents per 19.5 7.8
'6.5 13.6 Kwhr 10/81 9
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l-l.k'b CASE ATIACHMENT A - Paga 9
Service Company and Texc3 Power & Light Company - provides service in 87 counties in north t.entral, east and west Texas to more than four million people n.
-. one-thi.rd of the population of Texas.
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The Texas Utiliries Cob.pany System owns 85 2/3% of the comanche Peak plant - l'/970,000 i.
of the 2,300,000 KW total.
The other 14 113t-i.- owned by Texas Municipal Power Agency (6.2%), Brazos Electric Power Cooperative, Inc. (3. 8 %), and Tex-La Electric' Cooperative of Texas, Inc.' (4 1/3 %).
Texas Utilities Services Inc., a subsidiary of Texas Utilities Company, provide.s engineering, construction management, financial and other services to the System Companies and is managing the_
construction of the Comanche Peak station and is overseeing the
. o;J license application and related matters.
Texas Utilities Generating Company, a subsidiary of Texas Utilities Company, acts as agent for the three System owner companies in the operation of jointly-owned power plants and is the licensee for the Comanche Peak f acility.
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10/81
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~* Y CASE ATTACHMENT A - Paga 10 OPERATING LICENSE APPLICATION STATUS Texas Utilities Company submitted cn application to the Nuclear Regulatory Commission (NRC) in Februn y, 1978, for operating licenses
<nnstruction since late 1974.
for the two Comanche Peak units, e:v~ <
The applicatf.ons were subsequently r ec'pted and the operational ' safety cnd environmental reviews began.
Currently, Comanche Reak is well,
into this process.
The NRC issued its Pinal Environmental Statement Safety Evaluation Report on5 Comanche Peak in September, 1961.u...
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.go' on Comanche Peak in July, 1981.
A supplement to the Safety Eval 6ation Report is expected in the near future, covering safety related items that were still under consideration at the time of the Safety Evaluation Report.
In-addition the Advisory Comdittee on. Reactor, Safeguards, an independent and technical advisory group that revie'ws safety related matters, must complete its review before public hearinc.s on Comanche Peak's operating license application can begin.
The public he,arings, conducted by a NRC Atomic Safety and Licen-
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cing Board, will cover, as of late October, some 22 s.pecific issues and ques-tions raised by both the Licensing Board and citizen intervenor groups.
l At this ti'me, the first set of hearings are scheduled to begin l
l December 2 in Ft. Worth.
At the conclusion of the hearings the Licensing Board considers the I
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recommendations and conclusions found in the Final Environmental Statement, Safety Evaluation Report, Advisory Committee on Reactor Safeguards review and the record of the public hearings and makes a recommendation relative i
to the granting of operating licenses for the Comanche Peak units.
10/81
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yN CASE A'ITACHMENT A - Pag 211 LIGNITE GENERATING UNITS - CONSTRUCTION COST
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The cost of building an electric generating facility, whether coal or nuclear, has risen over.the past years.
Since the Texas Utilities Company System began building jointly! owned generating plants about 10 years ago, the cost of building those units has risen steadily.
The impacts of inflation upon the cost of borr.owing money and upon the cost of labor and materials, as well as the effect of complying with stringent regulations, are sh"own*in the d
following table comparing the construction cost per kilowatt of the i.
various Texas Utilities Company lignite generating facilities h
Lignite Units in Operation Cost per Station / Unit In-service Date Kilowatt Big Brown 1 & 2 1971
,$125 1972 Monticello 1 & 2 1974.
207 1975 Martin Lake 1 & 2 1977 275 1978 Monticello 3 *,
1978 327
, s.,
Martin Lake 3 1979 338 Sandow 4 1981 450 Lignite Units Under Construction and Scheduled for Completion Estimated Estimated cost Station / Unit In-service Date per Kilowatt Twin Oak 1 & 2 1988 1012 1990 Forest Grove 1989 1092 Martin Lake 4 1990 668 10/81
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CASE ATTACIDENT A - Pag 212 ESTIMATED COST PE14 MILOWhT* OP I;UCLF W r.rtWRATING CA?ACITY SAMPLE OF UNITS AROUND THE COUNTRY
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Estimated Estimated Electric Nuclear Capacity Commercial Total Cost Cost per Utilitv Unit (s)
(MW[__
Operation (million S) Kilowatt (S)
Source Arizona F_.;ic Palo verde 1 1270 1983 3780(b) 992 APS 10/81 Ssrvice Co.
Palo Verde 2 1270 1984
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Palo Verde 3 1270 1986 tarolin.
Shearon Harris 1 900 1985 2900 1611
' Dean Witter Reyno!
Power & ' Lirrt Shearon Harris 2 900 1988 Inc. 9/81 Co.
Consuecr;:
Midland 1 500 1984 3100 2296 CPC 10/81 Pcyx co.
Midland 2 850 1983 g
Detroit Enrico Fermi 2 1C93 1983 1800 1646 Tennessee" Valley Edison Co.
Authority (TVA)
. Cost & Schedule
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Study 7/81 Gulf Stat r Bend 1 4"O 1984 2700 2872 CSC 10/81 Utilities Cc.
Houston
- cth Texas 1 2250(a) 1984.1987 2700-4780(b) 1080-1912 HL&P 10/81 Lighting &
Jouth Texas 2 1250 1986 1989 Power Co.
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Long Island Shoreham 820 1983 2500 3048 LILCO Prospectus 10/17/81 Lighting Co.
Louisiana Waterford 3 1104
,1993 1600 1449 LP&L 10/81 Power &
Light Co.
Nirgara Mine Mile Point 2 1080 1986 3700 3426 LILCO Prospectus 10/7/81 Mohawk Power Corp.
Pannsylvania Susquehanna 1 1050 1983 3500 1666 TVA Study 7/81 Power & Light Sasquehanna 2 1050 1984 Co.
Philadelphia Limerick 1;.
1055 1985 4215 1998 PEC Prospectus Elsetric Co.
Limerick'2 1055 1387 9/30/81 4
Public Service Seabrook 1 1150 1984 3560 1547 PSC 10/81 Company of New Seabrook 2 1150 1986 Hampshire Public Service M::ble Hill 1 1130(a) 1986 4300 1902 Utility Spotligh3 Indiana Marble Hill 2 1130 1987 10/8/81 Southern San onofre 2 1100 1982 3350 1522 SCE 10/81 California San onofre 3 1100 1983 Edison Co.
Union Callaway 1 1150(a) 1984 2100 1826 Nucleonics Week Elsctric Co.
10/15/81 Washington WPPSS 1 1250 1986 3920 3136 TVA Study 7/81 3103 2820 Public Power WPPSS 2 1100 1984 Supply System WPPSS 3 1240 1986 4367 3521 (a) source,for capacity; Atomic Industrial Forum, 1981 Map of nuclear power. plants.
(b) does not include interest on construction funds.
10/81
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.e CASE ATTACHMENT B 4
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1 Federal Emergency Management Agency s
g Region VI Federal Center Denton, Texas 76201 S
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October 20, 1981 n
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Mrs. Juanita Ellis
,USNEO President, Citizens I9 Association for Sound Energy 2-0008 gggip i
1426 S. Polk gmeg elDe SSN,7 Dallas, Texas 75224
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- [8 Dest Mrs. Ellis:
p ro In response to your letter of October 10, 1981, concerning the status of state and local ~ radiological emergency preparedness plans for the Comanche Peak nuclear plant operations, the following information is provided.
1 FEMA Region VI is unable at this time to assess the preparedness planning i
and capability of the State of Texas to make an off-site response to a nuclear accident at the Comanche Peak site.
Texas officials have indicated their TARGETED date for submission 'f a' plan for review by FEMA is June 1982.
o (This information applies to state planning as well as Hood and Somervell Counties planning.) As indicated to you earlier, current status of planning information should be obtained from the State.
If we can assist you further, please call on us.
.Sincer y yours, I
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. w-Jo hn De La Garza, Jr.
R gional Director M
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 1
APPLICATION OF TEXAS UTILITIES 1
Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR AN I
and 50-446 OPERATING LICENSE FOR COMANCHE 1
PEAK STEAM ELECTRIC STATION 1
UNI TS #1 AND #2 (CPSES) 1 CERTIFICATE OF SERVICE By my signature below, I her.eby certify that true and correct. copies of CASE's 10/26/81 Motion to Postpone Hearines have been sent to the names listed below this 26th day p October 1981, by First Class mail locally and by Express Mail elsewhere..',%,f, Administrative Judge Marshall E. Miller David J. Preister, Esq.
U. S. Nuclear Regulatory Commission Assis tant Attorney General Atomic Safety and Licensing Board Panel Environmental Protection Division Washington. D.
C.
20.555 P.
O.
Box 12548, Capitol Station Austin, TX 78711 Dr. Kenneth A. McCollom
. Dean, Division of Engineering, Marshall Gilmore Architecture and Technology 1060 W. Pipeline $d.
01ri mhe== State University Hurst, TX 76053 Stillwater, Oklahcma 74074 Dr. Richard Cole, Member' Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel 1
U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D.
C.
20555 Washington, D. C.
20555' Nicholas S. Reynolds, Esq.
Atomic Safety and Licensing Debevoise & Liberman Appeal Panel 1200 - 17th St., N. W.
U. S.
Nuclear Regulatory Commission Washington, D. C.
20036 Washington, D. C.
20555 Marj orie Ulman Ro,thschild, Esq.
Docketing and Service Section Office of Executive Legal Director Office of the Secretary U. S.
Nuclear Regulatory Commission U. S.
Nuclear Regulatory Commission Washington, D.
C.
20555 Washington, D.
C.
20555
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OCT 2 8 'S61 V L_,
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0 s.) Juanita Ellis, President ek N 'i h ) #
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2 ASE (Citizens Association for W
Sound Energy) cc: Eczner Schmidt, Texas
- Utilities, Dallas
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