ML20064B887
| ML20064B887 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 12/18/1982 |
| From: | Frey D SASSAFRAS AUDUBON SOCIETY |
| To: | Doolittle E Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8301040234 | |
| Download: ML20064B887 (15) | |
Text
T N 6fW The INDIANA SASSAFRAS AUDUBON SOCIETY of Lawrence - Greene - Monroe -
! /' .j Brown - Morgan & Owen Counties 1 Sp h,
g oG s
/ __jM vecember lt,1982
^
( f
/4 % N y-- s e 0l\ 9:[ $ Y
( [b E. P. Doolittle Project Manager, Marb]o Hill URC Division of Licensing Washington, D.C. 20555
Dear Ma. Doolitt3c:
Public Service Indiana's (PSI) mport to the URC Caseload Fomcast Panel, Decomber 1, 1982, on the progress of the Marble Hill Huclear Project, indicated an efficient tion of the construction process and a quality control-quality assurance organizp%Illd prograMA mduce the mcessity for muork of construction to a minirmm. The PSI staff was proud of r:eeting a number of construction rnilnatoms ahead of sched-u]c, giving then confidence that they can meet the demanding construction schedule that they have established of completing Unit 1 by December 1,1986 and Unit 2 by Jum 30,1988. The fact that Marble Hill is a mplicate (design) of the Syron Uuc]nar Plant mar Rockford, Illinois, further advanced in the construction process so that PSI can profit from the Byron experience, was cited frequently as an expediting factor.
This is all well and good, but we maain skeptical regarding PSI's construction schedu3o and projected cost of the project because of the delay that has occurmd historically in the licensing of nuclear plants from a variety of causes, and be-cause of PSI's consietent undemstimation of the cost of Marble Hill. Our concerns also extend beyond one constmetion of Marble Hill to the reliability of its opera-tion and the capital and other costs associated with its maintenance and decommis-sioning, which will be borne by ratepayers (enclosure, CO:CCI:2S ON HEARIUG HELD BY PUBLIC SEIUICE COIIIIGSIGH OF INDLU!A FROI OCTOBER 14-26, 1982 ON EOUGIICS OF CQi-PLHflNG MARBLE HILL).
Considerable appmhansion exists mgarding ti.e performance of the Ucstinghouse D-4 and D-5 steam comrator models to be instnllnd in Marble Hill (page 5 of enclosum entitiled "CCCTS" and letter to Larry J. '.lellace, Chairman, Indiana Public Ser-vice Co:xaission. September 1,1982), and the efficacy of the " technological fix(es)"
to be desigmd and inplemnted by '..batinghouse, particularly as the NRC staff does not regard "technolodi cal fiX(es)" as an effective colution of steam generator prob-lems (Steam Gamrator Status Benort, February 1932, U S. Muclear Regulaton Commission).
To whnt extent could steam cercrator problems, testing, mgulatory mquiremnts re-Carding inspection, etc., impact the coming on line of Marble Hill to sustaimd, full-powr operation? Impact tbo reliability of operation and projected life of the pl:.nt?
8301040234 821218 DR ADOCK 05000 (Bod g/'
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We would appreciate a copy cf the Caseload Forecast Parel's Report of their visit to Marble Hill on December 1,1982, with their appraisal of PSI's construction schedule with regard to current and potential mgulatory requiremnts, particular-ly those applying to unresolved safety issues.
Yours 2nw . sinco c0Smly'j 4 4 f Mrs. David G. Froy Emrgy Policy Committee, SAS 2625 S. Smith Road Bloomington, Indiana 47401 cc: L. Parvin Price L. Unl 1 n ce
\ ;s . . 47 - g .
The INDIANA SASSAFRAS AUDUBON SOCIETY N
JI \ 7 I
.- 5 of Lawrence - Greene - Monroc - I
! b' Brown - Morgan & Owen Countics 1
yv / ___.g>
i w w September 1,1982 M .
l' ,\ t- w p
.k ,\ y' g TO THE PUBLIC SERVICE CG:MISSJCll 0? INDLUIA
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' )( . 4 . .gy-.v g{ N % .-
- a.* Iarry J. Wallace' C11 airman
%%.C+V FROM THE INDLU!A SASSAFRAS AUDUBON STIb7T The Indiana Sassafras Audubon Society requests that the Public Service Cocmission of Indiana stay tle installation of the Wstinghouse steam gererators on site at Marble Hill until an assessrent has been made of the reliability of their perform-ance under operating conditions. W ask, also, that the assescrent be made part of the record of the October 14, 1982 Hearing on Marble Hill and be a factor in the decision as to whether construction of Marble Hill Units 1 and 2 should be termin-ate d.
Installntion of the Estinghouse steam gercrators could .onstitute consurer fraud for similar models have proven defective in operation.
Sassafras Audubon noted in its request of March 15, 1982 to the Public Sarvice Commission of Indiana for a public hearing on Marble Hill, that steam gererator degradation had reached epidemic proportions in operating nuclear mactors. At least 40 of the 47 operatin ator problems (enclosure 1)gwhich prussurized water reactors have resulted in costly(PWR's) outages,have steam repairs, gerer-ard in sore instances, complete replacerent of generators. More replacerents will have to le made if plants are to continue in operation. .
The Nuc1 car Pegulatory Commission (NRC) has acknowledged that the majority of plants under zuview for operating licenses have steam cercrators of similar design to those currently in operation. These plants are therefox expected to develop the sare Cercrator problems that have pingued operating reactors for more than a decade.
This is applicable to Marble Hill.
The Estinghourc Steam Generator Models D-2 to D-5 and E which were expected to be better than earlier models, have been found to have, in addition, a vibration prob 1cm believed to be caused by turbulence in tle pre-heater section of the gener-ator. Marbic Fill Unit 1 is scheduled to have Wstinghouse model D-4 and Unit 2, D-5 This vibration phenorenon known as "fm*, ting" or " shake 'n breaks has occurred in the first four nucinar plants to core on lire equipped with these modeJs. Sweden 's most mcent Wstinghourc mactor, Ringhats 4, had to shut down on October 21, 1981, less than a year after leginning operation, lecaure of a 2 3 gallon / minute leak from steam cercrator tules. It resured operation core months later at 40% capacity.
A month after the Swedish rector shut down, the Almaraz reactor in Spain experienced tle sure difficulty. Brazil has mportedly stopyed further payrent to Wstinghouse for construction of the country's first nuclear power plant locause of faulty steam gererator syste:"s (enclosum 2). It was also learred recently that Yuroslavia's rew Ercko reactor, which has Wertinghouse D-4 gercrators, tic sa o as%rble Hill 1, had exycrienced vibration problems and was unabic to o! crate safely at full power.
\
-z-Tic only U.S. reactor to core on lire with a pre-heater steam gercrator has been McGuire 1 in Correlius, North Carolina, where because of excessive vibration and accelerated wear, operation has been restricted to 50% capacity. McGuire 1 has had an average lifetire capacity of 26.6%.
Tic NRC believes that tle vibration problem is r,nreric, and for'this reason, that all steam rercrators with a pre-heater comporent are defective. Nevertleless, the Nh; staff has reconnended that Su:rer 1, Parr, S.C., tic rext plant to be licensed with a pre-1 cater comporent, be allowed to operate, although with the expectancy of restricting operation to low-level power. The NRC did not consider the econonic impact of ticir decision on the consurer nor on worker safety.
The utilities with pre-heater steam gercrators have asserted at recent licensing hearings, that Estinghouse will invent and impler.cnt a design change in the rext year or two that will allow plants to orcrate normally. Can this be relied on?
Wstinghouse has made staterents about solving steam gercrator problems for more ,
than a decade without apparent progress. Steam gererator degradation remains a top-priority urnesolved safety issue (USI) of the Nuclear Fcgulatory Connission.
Utilities obviously don't want to delay bringing a plant on lire until Wstinghouse has perfected a design change. Utilities have a great financial interest in placing tleir plants in the rate base as soon as possible. Consumers will be forced, on the other land, to beCi n paying the fixed costs of a plant that might be produc-ing less than half of the electricity promised.
Further nore, what will be the cost of repairs wlen a design fix is achieved? Even low-power testing and low-power operation make repairs far more costly. South Carolina Gas and Electric estimate that repairing their defective steam gereretors could take 4 months and involve as much as 900 person rems (enclosure 3 ).
Should Marble Hill be delayed until Westinghouse has perfected a design change?
What will be the impact on concurers in the Marbic liill area if a design fix is implerented prior to operation? After cieration? Steam gererator problems bear directly on tle econonic feasibility of Marble Hill. Your consideration of thris matter will be appreciated.
Yours sincerely, Mary Pat Lynch, President Sassafras Audubon Society 605 South Fess Avenue, #6 Bloomington, India na 47401
e Enclosum 1 -
- -~
Plants.with Steam Generator Problems Plant -- Vendor Location *'
Arkanras .I - B&%.* Russelville, AR*
~
ArLar sas 11: ~
,C-E~ , Russelville, AR fj
' Calv .-rLClif fs I - -
C-E . Lusby, MD : . . .)
'C7: vert Cliffs 11 < .C-E 7 Lusby, MD ' - ,.
W Iladdam Neck, CT-
.'ronnecticut Cook.11 . v.
)'ankeeW..
. Briddnan,' MI' ' ,
~ CrystalRiser til .. _, B&W ~ Red Level, FL". 4
'7 B&WJ' Oak Harbor, OHN' i
, ' Davis.Besie.1 .-
Farle' y if_ h. . .; "'f ' ~
- W-
'Ginna';; -,i., r', ',f,.1.C. W ,;jDothan,. Ontario. NY.' AIM ' c' ' [; 4
, ; Indian Point H 2 a*.< ; 'W. ~ Buchana'n NY % *. 'l '
[ India,n: Point.1.I I N. P.~.! WdBuchahan,'NiV
.Kewaunch)S ~'r v Q W " < Carlt' n, .WI-'eq*(;f]
~
o
. Maine.Y.ankee?' ~~ . r .C-E Wishasset, MEd.. .' d.,
- Millstone.Il ?. , c. y C-E. .. Water' ford c CTI.'.}; ,q W.f Afineral, VA . '.f. , P 3' orth Anna I t .
Oconee I! . , ?. if - ' B&W.> St;peca, SC k.5
- W
- ,0 cone'c h ; n . ,' lVAW L' Seneca, sci @*.,.;*]
- Ocor.ee 111 ^. ',', . ^.g. g ;,B&W
- , Seneca, SCys -?, -
' Pal.isade , g .W , '3M ,C-E , South Haven, MI'Ja l Poin
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Poin.t. Beach'l 35.. ..,A 1...Two . .. -.
. :..W:'t Beach IIy .' . .' W- ; W1. 'Two. Cree. k.s.',.WN. . .
Creeksi.WI.
Pra'irie island i F j 'f ': W[' Red Wing, MN:
.' Pra.irie Isla.'n.c.fII..I"/.....:.:.-
., . W. . ,7 R ed Wing l MN L. . :'.
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. Rancho'Seco:IT-7-M - B&W Clay Stationt-CA * "'
[Robiris'od IliR5*J 'T $
';Salern'I < [*Yi.iN ...DW . WDSalem,'NJ @ IIar'Isville'.
W. 5 ,f Sd[D'f c
' San Onofre'.I
. 'St. Luc.ie I.c..d, .
.- ~ ~ C.E s !..k~' ~ 'W3 */ San. ,.Cleniinte,' i CA -
- .Surry 1. ..
...: e _ . i. . . W l..,Gravel
. Ft. Neck,-VA Piere'c7.F. > dL
-1 . '.-
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. Surry II: Gravel NeckiVA . .
- Three Mile' IslandB&W li.I !...W Middlet'own,- PK. K .
.Three Mile Island llY B&W.' Middletown, PN . Y
" , -','t .* Wl ' ' Prescoti, OR' . .? ' '
t '. Trojan' .. ; ' .
Turkey Point'llH W
' Turkey Point IV-W , 't Florida FloridaCity, City?FLFI'l *.'. .
l Yankee Rone4 J ' * ". - > W '. . Row e'/ M A
' Zion' I'. ,+ ' . - W -[.W ~ Zion, IL' ' .
Zion II , 'I' 'W:' J ~ W ' Zion. '!L' -
Source: U.S. Nuclear R."crulatory Comrnission, March 19,82_
It&W = flat.cyck &, Wilros.- . ,. '
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C.E = Cn mt.ustion finginceHng. -
j W =, M estingl.ouse l
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Brazilian Reactor Delaved.
- Enclosure 2 Westinghouse, the world's leading man 6facturer cf -
nuclear power plants,'has gotten itself into hot water overseas due to faulty steam gen'erator ."-
systems on its reactors. ! O. .'
The Journalof Commerce quoted Braziliani -
Minister of Mines and Energy Cesar Cals as~saying that " Brazil has stopped further payments to
~
Westinghouse for construction of the country's. - . !
first nuclear power plant" on ac' count of this ' ' ?
problem. Neither the Brazilian embassy in'-
Washington nor Westinghotise wotild confirm Cals',1
.1l statement. But one knowledgeable Brazilian source ,
notes that the Brazilian press has been running
~
reports saying not only that Brazil had stopped payment, but also that'it "was thinking of suing'.
Westinghouse." -c.- * - -
Brazil's Westinghouse reactor, Angra 1, has been i i under construction for the past 10 years, and ' 3 because of delays and cost overruns, the~ project is 'j
' not popular in the country. ',, .: ;J--g - w ;
- The,whole deal _is considered a disaster," says .y the Brazilian source. 'lThere is a widespread feeling ; .
that we wasted billions ~of dollars, that this thing - 3 !
will never work, and that Brazil does not need c, J
< nuclear power.','z .,. . ; g. /.. ; .-. . 5 . y.; ,.], 3i t ~~;
g . n . .w.; r .- s -
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- -... - m. .a. c Brazil's AnEra 1 Nuclear; Power Plant * :;.r* (..
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_Westinchouse,has encountered similar difDcuhies ;
with its steam generator systems in Yugoslavia,e Spain. and Sweden. "There is some problem withN; ,
the steam renerator tubes" in Sweden's three -- - i Westinchouse reactors says Leif Ericson, scientific ~.
a,ttache at the Swedish embassy. The most recent ;4 Westinghouse reactor, Kmghaus 4, had to'shuty ;
, down last October because of this problem, says Ericson, and it only resumed operations a mont,h
, ago at 40 pgcent capacity due to leakage from the(f ,
steam generator tubes. "As far as I know,'.': -
l Ericson says, Westinghouse officials "have not' 1 decided how to solve the problem.".E ~
There is "an error in design which Westinghouse' is pushing sery hard to correct," says Joseph D.
Laneur, deputy director of the' office of 1 international programs of the Nuclear Regulatory Administration. This error "is' marginally a safety , _
probiem," he adds. "It's a big problem for ; ' . 1, Westinghouse," says Lafleur. "It certainly doesn't
, improse their image any." -
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A []lew RothschiJd -
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SIEAM GE::ERATGi RE%IES "7 " 7' ~ ~ - - " ' ~ ~ ~ ~ ~ "
AND RE?L'sCEME .T COSTS I?J l Trouble Coast To Coasti .
TERMS 0? RAD 11sTIO:I ETPOSURE k -
'.Three Mile Island I . . . ~. ". f
- Federal ~sianda~rds~ permit the ~ nuclear inaustry to , 7"ff'* - . - - ;- - j cxpose workers' to ,0 times the amount of radiation Between 8,000 and 10,000 steam generato b
_ Unit 1 must be repaired or replaced.esMeasur,r under j tu es at ,
' that the general public may receive. While the max. ~
consideration by Gqneral Public Utilities, owner of the.
imum a i
! rems pc'llowable r year, and nolevel more ofthan exposurc 3 rems in any forgiven workers is 5 plant, might take oser a year and cost' tens or even, j three hundreds of millions of dollars. GPU had hoped to d r-pubh.-month.
c is 0.5 rems, peried, or 500the standard millitems.
(Oneforrem.is the general start up Unii I lo raii.e money for thrclean up at Unit !
, 11, which has been idleiince the accidem there in '
t equivalent to the radiation of about 50 chest x-rays.) March 1979.- ; ., ,
?
,- The link between radiation and cancer is well '
, - . . C - .t 4
- ~ documented. But it takes 10, sometimes 20 years for Yurkey point III and IV ;
- -
cancer to develop, and by that time both the cancer 3 sictim and the cause of cancer are lost ~in the; ; Seveie corrosion led Florida Power and light to ?
statistical crowd of cancer-rclated deaths and cancer-
- replace'both units' steam generators. The utility has- i causing afents'. Experts agree, however, that ex- jnearly finished replacing Unit til's steam generator !
posure to radiation increases the risk of getting. gand is planning to replace Unit IV's next year. The i
! cancer or passing on genetic damage ' ~
to future ;P'.ojected cost of the Turkey Point repair is $459 j generations. - -
'nu j n doDars.
- I'P * " "" 5ne " *' ut%, dans to stgre radio Steam generator repairs piesently' account for a.
significant percentage of the worker exposure levels'.
_'J. } -
W.H. Robinson II .
A 7$
! at PWRs. The sleeving of over 6,000 tubes at the San . - . . - . c. . & m.- 1 i
Onofre I reactor near San Clemente, California,jIjf. Robinson 11 was ' shut dbwn as a 'restfli of S O.'3. I volved more than 2,000 workers. Currently, there is gallon per minute leak on)uly 30 1981.~ Inspectioris'.
no limit on the totalamount of radiation theindustry- llater sevealed cracks and corrosion thr'oughout th can distribute to its work force, nor is there any limit . l plant's steam generators.' At last count, 1,068 on the number of workers'iha ndustrs can " burn ' icent) of.the tubes had been plugged.'.The~ plant ~is. f 'at
_ nut" in a eisen sear._The iricreasine number of peo.
pie who are exposed c.ach year at nuclear plants is Iopeiating uplacernen: at reducco capacity awai. ting comjiietei j
' fits steam scherators ig 1984/ *.. g,g ,
, cause f or alarm. Over 60,000 reactor workers were b ~ '
exposed to measurable doses of radiation in 1980. - San Onofre l ".. '
's
-- s
- ... w q After reviewing plans for a steam generator Virtually identicalin dNsigr[to Ginna, Sa'n Onofre I
^
replacement operation at the Tu'rkey Point plant near has recently the subject of an'u'nprecedented sfeevingj Miami, Florida, Dr. Karl Z. Morgan, a founder of I operation insolving over 6,000 tubes. Sixty-sis workers:
the health physics f.rofession and formerly a pro- kere oser4xposed durine a 1980 steam renerator m- J fessor of nu' clear engineering at Georgia Institute of . :speenon The NRG subsequently fined the utitifyt.,i s
Technology, wrote: "The impacts [of replacement] '5150,000. <- y ,!,
are outweighed by the benefits only because a low b- ' ' ' ' ,.(J. ,
t
" e2 7 7 . .,
- dollar value is placed on human life.".Dr. Morgan, ' .. N ,7'5' fe d l
, went on to propose that a srust fund be established I help compensate w1orkers' famdies. b['k"I'*McGuire's I :owner,Nke has
.from 75 percent to 50 percenioT eapacity under.NRCi Power r'edubed[t- -
output!
Dr. Edward Radford, who chaired the National forders. The utiliiv learned that two Furopean reae .
j Academy of Science's' Iliological Effects of lonizing ~
!! ors'with Westing' house steam ' generators similar to 2~,
Radiation Committee, suggests that the yearly doi j to workers be reduced Irom 5 rems a year to 0.3 rents jlMcGuire's~were emy. The un't will not exceed esperiencine the 50 percent severe lesel undvibration .
vro a year because of health hazards. -
ltil this new problem has been investigated and solved.
! To add insult to injury, many temporary workers 8, -u - -. .a N ahae'i .
".is w d. ,s, team,- generator problems require".
I feel that the utilities and industry did not give them - '- ,
I adequate warning of the risks involsed. "The word me. , * ',nspects ns and repairs that require "down, r cancer was never mentioned," one wo'rker told n a nuclear plant goes out of servic~e, the;
~
" I C..the lost power either byfgen-01EJ w hen describing the training he and his fellow - * "*' l'P ' C e
' . repair workers receised. -
- t Ong mme electreity at its' other power plants, or In addition to'the' environmental,'heahh, and safe- Mc ng supplies fr m neighboring utilities. In c erCase
~
e p wu is Mely to c me fru coal; oil, ty hazards crators, there areassociated with defective enormous financial steam costs involved. tend'r Igasif ed plants. at a higher fuel cost than nuclear ;
n s nw nnw, f atep yers continue to pay !
Hesides the costs of the repairs themselses, the price !
en c sts k nuruco n c us/ tases, of buying replacement power while the plant is down j eprec a n, etg f the nuclear plant, even though for repaks has added considerably to the cost of , ,
_ nuc! car;dw - - er. The result: electric
- _ . . . . . . - _ Uraics'S mcrease n t generaong to coser additic.naelectricity.,l costs of as much as
.51 million a day. Es en brief shuidow ns can caute fuel CRITICAL MASS ! bi!!s to rise. . 4
~
, Sicam generator repairs cost mi!! ions, and -
!*. arch 15 - April 15, 1982. ' ' *"5
- ' '" h ""d ' ed s r millions. And
'"".'*"*.'deutilities are a t tem ptin e to cet consumers, nationwi ,
n_ot stock holders and manufacturerr,_to pay the cost ~
of faune egyipment that was supposed tolast the life !
of the plant.
. .. a!
9 ,
The INDIANA SASSAFRAS AUDUBON SOCIETY Q{,
/',
< <{' o of Lawrence - Greene - Monroe -
Brown - Morgan & Owen Counties x b-
Nf' ._
A November 15, 1982
- , .-h -
-s , 'Q s
/ TO: OFFICE OF UTILITY CONSUMER COUNSELT, (f,j 3f L. Parvin Price, Consumer Counselor COMMENIS ON HEARINO HELD BY. PUBLIC SERVICE COMMISSION OF INDIANA MlOM OCTOBER 14-26,1982'ON~ ECONOMICS OF COMPIEf1NO MARBLE HILL NEED Mr. Lewis Perl of National Economic Research Associates, Inc. (NERA), the firm hired byythe Public Service Commission of Indiana (PSC) to evaluate the economics of completing Marble Hill ( when asked whether Marble Hill' was needed, replied there was no need for Marble Hill.
Mr. Neil Talbot of.' Energy Systems Research Group, Inc. (ESRO), hired to perform a similar service for the Office of Utility Consumer Counselor ofrIndiana, firmly supported Mr. Perl's opinion, testifying that under no conceivable circumstances was Marble Hill: needed.
CWT
'Ihe unanimity of'NERA and ESRO: on NEED, evaporated on COST. NERA found Public Service Indiana's (FSI) estimate (supposedly their final estimate) of $51 billion for the capital costs of constructing Marblb Hill!."not unreasonable" (III-15) and/
or " plausible" (V-4), while ESRO estinfated the final capital costs of the two units at 47 9 billion, assuning that the units enter service on 12/1/86 and 6/1/88 as projected by ISI. The ESRG estimate of: nearly $3 billion more than JSI's estimate approximates the 1981 estimate of Mr. Fred Hauck of Save 'Ihe-Valley, Inc. , who predicted a $7.2 billion minimum and a likely cost of.'$8-10 billion for Marble Hill's two units. '
NERA commented in their exhibit on the very rapid rate of. escalation of nuclear construction costs over the last five years but did not extrapolate this trend into the future, and, of course, ISI's estimate would not have been plausible if I
they had. NERA was contenti.to olcerve that, "perhaps , the rising costi trend is over." (V-4).
On the other hand, NERA, quite aware of the significant uncertainties in the con-s truc ti on c os ta of Marble Hill', and the significant difficulties ISI will have in financing the project on the current schedule, let themselves off the hook by recoczendin6 an independent audit of the Farble Hill' capital cost estimate. (I-1) 1HUltcCE When should IGI lave recognized there was no need for Marble Hill? ESRO does not
fault.ISI for its initial dccicion to osck a ccnttructicn percit. ESRG does fault PSI, however, for using load forecasting. procedures in 1978 which were out-of-date:
"the Company could and should have used well-known, more sophisticated, forecasting procedures which would have tended to reduce their pro--
jections of. demand growth and would have enabled the. Company to pause in this construction program to review the risks and uncertainties of its planning situation."
A major cc,clusion of IERG is that PSI should have canceled Marble Hilli by 1978, or at the latest 1979, for the negative economics of. nuclear power, and the rela-tively poor reliability of nuclear units had been firmly established by that time (Talbot, 9).
NERA notes in their exhibit that "It is certainly PSI's responsibility to make ac-curate load forecasts and to adjust those load forecasts as circumstances dictate.",
and, "Thus it is; reasonable for the Commission (Public Service Commission of Indiana) to determine, in light of information available in 1979- .
falling growth forecasts, escalating costs and relatively low sunk costs--whether the project should have been canceled or deferred at that time.", and whether the decision was imprudent. (III,18-19).
Mr. Fred Hauck of Save-The-Valley, Inc., an intervenor in the Marble Hill proceed-ing, testified in April 1977 at the Nuclear Re6ulatory Commission (NBC) Construc-tion License Hearing on Marble Hill that PSI's projection of need, based on arn annual growth rate in electrical' demand of 8.2%, was unressonable, and that the-plant was not needed. Save-The-Valley had established publicly the fact of no need before the construction license hearing, using PSI Annual Report data in support of their arguments.
Sassafras Audubon, in a REQUEST (to the NRC) TO SUSPEND AND REVOKE CONSTRUCTION PERMIT AND TO REOPEN SAFETY HFARINGS ON MARBLE HILL NUCLEAR CENERATING STATION, <
June 29,1979, noted that l
l "ISI's accelerated schedule' is particularly disturbin6 in the con-text of the major reassessment taking place today of all phases of the nuclear fuel cycle with re6ard to public health and safety l and the true cost of nuclear power."
Sannarras Audubon, in a lettei of September 4,1979, to Mr. Harold R. Denton, g Director of the Office of Nuclear Reactor Regulation, NRC, noted:
1 "ISI's rationale for Farble Hill has always been based on highly inflated growth rates of electric consumption. By 1979, PSI had lowered their estimate to a 6% growth rate, still far above less-biased growth-rate estimates.", and, "While the growth rate of electrical consumption is declining, the cost of construction is risin6 sharply. The Nuclear Re6ulatory 1 Comminsion approved Marble Hill's Units 1 and 2 at a projected cost of $1.4 billion while the total cost at:co:npletion is like-ly to be approxicately $4 billion Insed on the I.U. Bupp, et al, study of Trends in Light Water Reactor Capital Costs in the United States: Caunes and Consequences, Centar for Policy Alter-natives, Massachuse tts Institute of Technology, Casbrid 6e, MA December 18, 1974.", and asked the question,
9 "If Marblo Hill is not needsd, and pro =icos to be en exce2aiva economic burden to the ratepayers, should construction be allowed to continue?"
PSI had aple time and opportunity to reassess the Marble Hill Project during the 20-month eptdown of safety-related construction of Marble Hill. PSI could not have been oblivious toathe nation-wide reassessment of nuclear power taking place at that time, particularly by the nation's utilities, is refusal to examine and ap-praise the evidence of negative economics and poor reliability of operating planta, not impr ident? Is imprudence g this magnitude worthy of " regulatory relief" that would encourage and support completion of Marble Hill?
OPERATION & MAIhTENANCE (O & M)
Under Guidylines for the Audit (V-6), NERA asks:
5 Is the project design consistent with current NRC regulations?
6; Are there any specific unresolved re6ulatory issues which might add to the cost?
'1he above questions are relevant to the capital and other costs of operating and maintaining nuclear plants and has a direct bearing on whether Marble Hill is a financially sound investment and whether it would be prudent to cancel Marble Hill immediately.
The reasons for the serious and continuing deterioration of the economics of oper-ating and maintaining (O &?M) nuclear plants are common knowledge. It is also com-mon knowledge that the Westinghouse steam generators to be installed at Marble Hill' are a potentially significant short-term and long-term economic problem that will negatively impact the capacity factor and life-expectancy of the plant (Sassafras Audubon letter to the Public Service Commission of Indiana, September 1,1982).
Mr. Perl acknowledged on the witness stand that NERA had not evaluated the steam generator problem. This fact , and the fact that NERA did not evaluate adequately 0 &~ M costs, in general, in their economic evaluation of FArble Hill, constitutes a major flaw D their study, and cannot be justified by passin6 it on to an inde-l pandent audit.
i ESRC gives appropriate attention to O &>M as a nuclear power cost. Mr. Richard l
Rosen, pace 5 of his testimony and exhibits, mentions the signficant increases
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which occurred in operation and maintenance costs of nuclear plants throu6hout the 1970's:
i "In fac t, t.he real 0 &' M cost increases during this period appear to have l
becu sulntantially greater than the capital cost increases. Utility in-dustry data avai_lable.by the end of 1978 indicated that nuclear O &' M costs; for individual plants were escalating at real rates typically ranging between 10 and 2St."
l Mr. Rosen's statistical analysis indicates that the O & M costs of the Marble Hill Units will on average escalate at about 14% in the late 1980's assuming 8% infla-tion, while ISI O & f oot estimates appear to be cocalating at about 6% per year in the late 1980's.
l Mr. Rosen did not take into, account in his base case analyses for rarble Hill the l historical exj:erience of rather cubstantial fixed or capitalized 0 & M ccats
t' hat havo been incurrcd by all operating nuclcar fccilitia, but dow mentica on page 32, under Economic Risk of Nuclear Power Plant 1Investeent that:
" Problems of potential: emb'rittlement of reactor vessels, steam generator problems, and other safety issues which are receiv-irg increased attention, may contribute to sustainin6 or even increasing the pre-Three Mile Island cost trends.",' arid on page 43,
" Ignoring these costs, as the Company (PSI) appears to have done and as I have done in my inse case aralyses, is therefore econom-ically optimistic. There is a real likelihood that such costs will be routinely incurred, and that they will indeed become si 6nificant as the plant ages, causing the economics of Marble Hill to deteriorate further."
Mr. Rosen testified on the witness stand that it was imprudent to ignore O & M costa citing in the instance: of steam generators that 23% of all nuclear plant outa6es were attributed to this problem, that costs of replacement could be enormous as at Turkey Point, Florida, and thattretrofitting would be required with the D-Model steam generators at Marble Hill.
STEAM CENERATm DFERADATION--A LO!G-TERM KEY UNCERTAINTY OF MARBIE HILL Steam generator degradation .is a KEY UNCERTAINTY of Marble Hill' because Vesting-house is not seeking-an effective solution to the problem, but is trying a variety of technological fixes to prolong steam ger.erator service life and reliability, which the NRC does not regard as a panacea to the problem.
'Ihe " fixes" 'ht Wstinghouse bas propose? to date cannot te. termed successful.
The chort-terz:3 soluffog f or minimizing: wastage and. stress cercosion crackirq of steam generator tubern conversion from phosphate to AVT wafer chemistry, did mini-mize wastage and stress corrosion cracking. but pro =oted denting, a serious problem in itself.
_, 'Ihe NRC believes that there are no simple corrective actions and that indust.ry ef-fort should center on ensuring primary oystem integrity of steam generators (SG):
"An effective solution to S.C. tube de6radation problems would re-
- quire major changes in S.G. mechanical design, thermal-hydraulics, caterials selection, fabrication techniques, and changes in the r.econdary system design and operation. Elimination of S.C. degrada-tion requires a systems approach integratin6 allt of these considera-tions." (Steam Generator Status Report, Fehmary 1932, U.S. Nuclear Regulatory Comnission; hge li).
- NRC engineers testified in March 1982 as subpoenaed witnesses of IRARE/ SAFE;.
Byron nuclear p] ant intervenors, that " AIL Model Ds have unique probleza.", re-ferrire to Westinghoune steam generator Dweries. Marble Hill is expected, there-fore, to have additional problems with its D4 and D-5 steam generators, which must be " fixed" before they can operate at fulli power.
All D-Model steam generators that have come on line have had serious vibration pr obl ems , requirins prolonged shutdowns of the plants and operation af ter shut-dcwns at greatly reduced power. 'Ihe only D4 Model to co:e on line, at Krsko, Yuconlavia , experienced an unacceptable'1cvel of flow-induced vibration in the fint row of tubes, despi4e the presence of an impingerent plate (a design fix to prevent hi6 h cross flow velocities directly ot.to the tub-s frca the feedwater no::le).
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7ha fact that tha D-5 Modal ottaa genernter haa n2vrr be:n tzat:d in con =rcial operation in- furth r grounda for apprehensicn, considering that Weatin6 hou20 did not predict the tube vibration problem at the McGuire and Rin6 hals D2/D3 by the useroftcom ter codes and sca2e modeling tests, and we presume that they did not.
for the I/+ 95 models either.
What was the reason for installing two different D-Nodels at Marble Hill, Byron, and Comanche peak? Is the D-5 Model considered a superior design? If so, why in-atall D4 in Unit l? To be able to replace a defective steam generator part dur-ing operation, will the utility have to stock two separate sets of replacement parte on site for the two models? Or if' the parts are interchan6eable, why install two different modela?
What is the amenability of the D4 and D-j Models to corrective modifications?
What: warranty does Westin6 ouse h give on D-Models? HOV LONO AT FULL POWER? WHAT WILL BE THE NRC REULATORY REQUIREMENIS FOR INSERVICE INSPECTION BEFmE AND AFTER FULL PCWER OPERATION?
NERA's principle recommendation is that " PSI should proceed to complete Marble Hill on schedule. This recommendation, however, is contin 6ent!.on resolving uncertain-ties about the capital cost of the project." NIRA's apprehensions, as pentioned previously, center on ISI financing the project on the current schedules ~ Could the technological "fixin6" and " testing" of the D4 and D-5 steam generator models at Marble Hill not affect the current schedule? ICven if the " fixing" was installed prior to completion of the plant?
According-to the NRC Steam Generator Status Report, February 1982, the consequences of steam generator tube ruptures can present a si5nificanttcha11enge to plant op~ra=
tors and safety systems. The present design base for aesap+ q .that plants are acceptably protected is a. postulated double-ended rupture of a . single steam genera-tar tube. However, the NRC recognizes the potential for more si5nificant events sucian multiple tube failures, and multiple equipment failures such as the stek-open .PWV during- the Ginna accidentiand the consequences of such events have not been:. rigorously 7 studied nor evaluated as yet. The cost of the Cinna accident, with its 5-month outage, has added considerably to the negative economics of nuclear power for Rochester Gas & Electric,and its customers are litigating the matter of paynent for the clean-up in the courts. Ittcannot be assumed that such an accident
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could not happen at Marble Hillt
. .3 21ECOMMISSIONI?C AND SPENT FUEL DISPWAL
'Ihere is no national policy for the decommissioning, deconta.mination, and dismantlict of nuclear power planta and nos.e is in sightt Radiation standards are not likely to be finalized before mid-1986 according to a Comptroller General's Report to the Congress of/ May 25,1982 (CAo/EMD-824G)~and radiation standards are -essential' to the decommissioning process.
Mr. Rosen; in response to questioning, said that the subject of deccamissioning had beeno" vastly underf esearched" and the estimates of the cost "way, way, too small."
He also noted the need of " independent" study. 'Ihis is a valid appraisal. As long an evaluation of costs of decommissioning " hot" cozzercial-scale nuclear pog Pl ants remains anninhouse exercise of the NRC, DOE, Battelle, NES,4111 ties,. there will be no valid estimate. The recent Hearin6 cn establishing a decormissioning fund for the Donald C. Cook Nuclear Plant (Cause No. 36760) is a case in point.
Not a sin 61 e plant. that is a candidate for deco ==issioning has been accurately researched and this includes the very smalli (72Kd) Shippin6 sport Plant which the DOE plans to dismantle as a demonstration of the feasibility of "Irr6e-scale dismantle-ment" of nuclear reactors. Shi PP i n6 sport as a part-6cvern=ent facility has the
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advantaEs cf n " final" resting placo ct tha Fadaral'Covr.rnarnt'c nuc1=r wanto dump (not a final repository) at Hanford, Vanhin6t on, but can the costs of dis-mantling a " hot" 72MW plant be extrapolated to the dismantling of a " hot" 2260MW nuclear plantisuch .as Marble Hill? The core-dama6e accident at ihree Mile Island-2 and the costs of that clean-up, will be more indicative of the gravity of the problem.
Mr..Rosen testified that disposal of spent fuel was another problem that was underestimated in terms of prospective costa of disposal and/or storage. Spent fuel willibe otored at Marble Hill!during the plants operation and disposal of the spent fuel will be an inertricable part of the decommienioning of Marble Hill and the Marble Hill site. .
DECOMMISSIONING is another economic KEY UNCERTAINTY of the Marble Hill' Nuclear Project and a realistic estimate of the cost cannot be made until'a final Federal Repository (les) is available for receiving <the radioactive wastes and remains of large-scale commercial nuclear plants and the actual decontraination and dismantling of such a plant and restoration of the site been successfully accomplished.
CONSERVATION AND LOAD MANAGEMENT NERA does not give credence to conservation as an alternative to Marble Hill in their report, but does mention that "As conservation reduces demand growth, it delays the need for new generating facilities. This reduces the economic attrac-tiveness of Marble Hill and increases the attractiveness of deferral or cancella-tion (IV-3)."
ESRG did not incorporate a conservation program in their business-as-usual Base Case forecast, but Mr. Talbot stated in his testimony (Talbot,16) that he had no doubt but that "a cost %ffective conservation program implemented by PSI could i reduce the growth of future electicity needs below 1 percent per year without
, affecting comfort levels and customer amenities."
Mr. Edward P. Kahn, a witness for the Citizen Action Coalition of Indiana, and an
' export on utility conservation programs, noted that conservation and load manage-ment programs provide consumer benefits so sulntantial that it is beneficial for utilitien to promote conservation and load management programs with financial in-centives.
Mr. Kahn, reviewing the tentimony of PSI witnesses on ISI efforts with regard to conservation and 1oad management, concluded that ISI overall had shown very linited interest in conservation and load-management, and noted that their testimony did not indicate a sound cost-banefit justification for this position.
Mr. Kahn reco2 mended that the Public Service Commission order a thorough study of conservation and load mana6ement as reasonable alternatives for controlling future utility costs, with one of the parameters of t.he study possible adjust-nents to ISI's construction budget, including cancellation of projects under con-l n truc ti on. Sassafran Audubon aupports this recommendation.
l CWIP AND NERA ASSUMPTIONS Sannafras Audubon in opposed to CVIP in principle and has stron6 y1 opposed CWIP lecislation in the Indiana General Assembly. There are numerous reasons for this opposi ti on, but first and forecost, it would place an economic burden on rate-
. payers for cospletion of an imprudsnt projnct for which th;ra io no nsd, and who j had no psrt in the decision-making process, either in its conception or continua-tion up to the point of this hearing.
NERA is obviously apprehensive about the assumptions on which they lase their con-clusion that "ISI should proceed to complete Marble Hill on schedule.", and note "But our conclusion mi 6ht be reversed by combir.ing a number of chan6es in assusp-tions adverse to Marble Hill."
NERA is rightfully apprehensive about the ultimate cost of Marble Hill, not only because of the vast discrepancy between PSI's estimate, which they support, and ESRO's irdependent esti:r. ate, but because of their underestimation of 0 & M costs.
The Hearingfor the House Subcommittee on Oversight and Investigations of the House Committee on Insular and Interior Affairs, on STEAM CENERATOR DECHADATION, should provide further insight on the steam generator problem as it might impact the economic viability of the Marble Hill' Project, a matter not evaluated by NERA.
NERA is appropriately apprehensive, also, about the significant difficulties PSI will have in financing the Marble Hill Project on the current schedule, for Moody's Investor Servicei for the third time within a one-year period, has lowered PSI's rating on its bonds and preferred stock because of lon6-term concern over the utility's financial ability to complete the Marble Hill. plant.
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SASSAFRAS AUD,UBON SUPPORIS ESRG CONCLUSION Saccafras Audubon strongly supporta ESRG's conclusion, that, "Takin6 into account the ma6nitude of construction costs still to .be expended, continuing financing char 6es, lack of need, a glutted ntrket in the Mid *'est for electric energy; the severe financial difficulties of completing the project, and especially the poor economics of the project, we conclude that it would be in the best l interests of the Company and its customers to cancel both Marble Hill units immediately. Cobtinuation of either unit would be un-economical and would entail substantial financial risks for the Company." (Talbot, 10-11). , ,
Wrt ask' that no form of regulatory relief be granted PSI that would support con-tinued construction of Marble Hill.
W h .odlecz M k Mrs. Ihvid G. Prey, for the 1 Energy Policy Com::ittee, SAS 262,5 S. Smith Road Bloomin6t on, Indiana 47401 C: Public Service Commission of Indiana l s 1 ,',
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