ML20064C748

Responses to 821126 Discovery on Stamiris Cost/Benefit Contention.Certificate of Svc Encl

ML20064C748
Person / Time
Site:	Midland
Issue date:	12/29/1982
From:	Barth D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	STAMIRIS, B.
Shared Package
ML20064C730	List: ML20064C725 ML20064C748
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8301040467
Download: ML20064C748 (19)

Text

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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA 1

.g3 (191-3 pn 25

)

In the Matter of: ) Docket Nos 50-329 OM

) 50-330 OM CONSUMERS POWER COMPANY ) Docket Nos 50-329 OL

) 50-330 OL (Midland Plant, Units 1 & 2) )

)

) December 29, 1982 i BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD CONSUMERS POWER COMPANY RESPONSES TO DISCOVERY ON STAMIRIS COST / BENEFIT CONTENTION Question 1

1. a. Explain in detail the manner and extent to which the change in Dow's low pressure steam reservation (#22 A-31 FES) from 1,400,000 to 1,800,000 lb per hour affects aay portion of CPC's input to the FES c/b (cost / benefit) analysis. Explain the effect upon:

(1) Replacement energy costs (2) Reduced generating costs (3) Increased lifetime capacity factor (4) Any other factors

b. When did Dow make this change in steam reservation?

c) For what purpose was this change made as explained to CPC?

d) Why does the FES increase in the steam for Dow not result in a decrease in the electrical capacity?

e) Provide documents on the change in the steam reservation and its effects as addressed in this question.

f) Include and denote which documents were provided to the NRC on this subject for their cost / benefit analysis.

Response 1

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1. a. It should be noted that the 1,400,000 lb/hr was never a reserved flow rate for low pressure steam. It is the contract minimum flow rate for low pressure and high pressure steam combined. However, Dow's low pressure reserved steam flow rate was changed from 1,500,000'to 1,800,000 lb/hr in January 1982. This change results in a 16 MW incre-se, approximately 1.2%, in electrical capability of the plant.

r Such a change would have very little impact upon the replacement energy costs, reduced generating costs, increasing lifetime capacity factor or any other factor of the cost / benefit analysis in the FES.

b. The change in steam reservation by Dow was made in January 1982.

c. No specific reason was given by Dow for change in steam reservation.

d. The Unit 1 electrical generating capability is dependent upon low pressure steam flow rate, but it is not ; " fixed" relationship.

Between 1,000,000 lb/hr (the contract minimum) and approximately 2,000,000 lb/hr (the point of maximum electrical production) s. team, an increase in steam flow to Dow results in an increase in electrical output. Between the point of maximum electrical production (approximately 2,000,000 lb/hr) and 3,650,000 lb/hr of steam (the design point and the contract maximum) the effect is the opposite; that is, an increase in steam flow to Dow results in a decrease in electrical output.

e. Documents on the effect of Dow's low pressure steam reservation change from 1,500,000 to 1,800,000 lb/hr regarding replacement energy cost, production costs and lifetime average capacity factor are attached.

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f. The only document provided to the NRC relating to change in steam reservation is part of the FES and is included in the comment section of the FES (See page A-31, #22).

Question 2

2. a. Define and differentiate between the terms " gross nameplate rating" and " design rating."

b. Give DES and FES " design ratings" and explain the reason for any changes suggested to the NRC.

c. Give the DES and FES " gross nameplate ratings" and explain the reason for any changes suggested.

d. Explain the basis for the suggested change between the DES 1310 MWe rating and the FES 1357 MWe (#107, A-48 FES, 6-5 DES and 6-3 FES).

Response 2

2. a. The term " design rating" refers to the turbine generator vendor's guaranteed electrical output, which in the case of Midland Unit 1 is at the design steam flow rate of 3,650,000 lb/hr of low pressure steam to Dow. The design rating based on the vendor's guarantee is always a gross rating, and is also known as " gross nameplate rating".

There is also a net design rating which is the gross nameplate rating minus the estimated station power requirements. It is a good practice to clarify which design rating is being stated by including either gross or net in the term.

b. The DES and FES design ratings should have both been 1357 MWe. The 1310 MWe figure in the DES is an apparent error (see answer 2d below).

c. Again, these figures should have both been 1357 MWe. The 1310 MWe figure in the DES is an apparent error (see answer 2d below).

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d. The 1310 MWe rating in the DES is apparently an incorrect rating used by the NRC in their summary statement. Possibly, it was derived by adding 505 MWe gross for Unit 1 and 805 MWe net for Unit 2.

It is Consumers Power Company's preference to use gross nameplate ratings and as such Consumers Power corrected the apparent error by commenting that 1310 MWe should be changed to 1357 MWe (505 MWe gross for Unit 1 and 852 MW gross for Unit 2).

i Question 3

3. a. Explain in detail the complete basis for the suggested change in the DES-FES lifetime capacity factors.

b. Include but do not limit (3a) explanation to effects of components cited in the #19, A-31 FES basis.

c. Provide documentation for this answer, including and denoting which documents were also provided to the NRC for their cost / benefit analysis.

Response 3

3. a & b. Consumers Power Company in its comments on the DES, provided a figure for lifetime average capacity factor, based on the company's latest projections of Midland's electrical generation and capability (see comment #19, A-31 FES).

Consumers Power Company did not provide the 60% lifetime average capacity l

factor in the DES and does not know what methodology the NRC used in arriving at this figure. Consumers Power Company's suggested lifetime average capacity factor of 66%, as mentioned in the comments to the DES, is derived by using the results of a computer program, future projections of plant availability and projections of electrical capacity. This program models the operation of Midland and calculates the projected electric output for both units. Iloweve r , since Consumers Power did not mil 282-0070a168-100

5 furnish the capacity factor of 60% included in the DES and does not know what components were used to derive that figure, we cannot evaluate what affect those components cited in comment #19 (A-31, FES) have on the capacity factor difference between the DES and the FES. Any questions regarding the components used in deriving the capacity factor included in the DES should be directed to the NRC.

c. The documents relevant to Consumers Power's derivation of 66% lifetime average capacity factor are those provided in connection with question le, and the " Midland Model Output" and associated work papers, also attached hereto. The NRC has not previously been provided with a copy of these documents, although the " Nuclear Plant Performance and Application to Midland" study has recently been requested by the NRC.

Question 4

4. a. Define, quantify, and explain in detail the meaning and impact of " Applicant's 12-14-81 load forecast revision" (#16, A-31 FES) for the cost / benefit analysis.

b. On what basis is this load forecast revised?

c. Provide documents regarding the 12-14-81 load forecast revision and its bases including and denoting which of these documents were also provided the NRC for their cost / benefit analysis.

Response 4

4. a. The meaning and impact of the 12/14/81 revision on the cost / benefit analysis is that it affects replacement energy costs. This effect, combined with the effects of other components, is shown for 1984 I in note "d" of Table 2.1, page 32, FES and Comment #16, A-31 FES. It should be noted that replacement energy prices beyond 1984, as shown in the DES are those projected by the NRC. To evaluate the effect of the 12/14/81 revision separately f rom the ef fects of other components would mil 282-0070a168-100

', 6 require a detailed study involving a significant amount of time, which we

! feel is beyond the requirements of answering discovery requests.

b. Load forecasts are revised at least once every calendar year as a matter of general Company policy.

c. Attached is the documentation for the 12/14/81 electric j forecast. The NRC has not previously been provided with a copy of this document.

1 Question 5

5. a. Explain in detail the basis of the change in replacement energy costs suggested by CPC for the FES cost / benefit analysis. Include but do not limit this explanation to the following facets of replacement energy costs:

(1) The extent and manner in which CPC takes account of existing coal and oil fired facilities currently placed on economy reserve.

(2) Why CPC maintains a 70% reliance on purchased power despite its DES to FES rise in cost (sub tables 2.1, p 2-3 DES, A-32 FES).

(3) What electrical demand rates are used as a basis for CPC replacement energy estimates supplied to the NRC for the DES and FES cost / benefit analysis?

(4) What reserve margin percentages are used as a basis for CPC replacement energy estimates supplied to the NRC for DES and FES cost / benefit analysis?

(5) To what extent and in what manner is inflation taken into account as a basis for CPC replacement energy estimates supplied to the NRC for their c/b analysis?

(6) Explain the basis for any changes between DES and FES estimates or methodology if they exist in 3, 4, and 5 above.

(7) Compare the estimated replacement energy amounts to the projected electrical capacity of the Midland facility--explain any 4

differences if they exist.

(8) The extent and manner in which capital or construction costs of projected replacement energy facilities have been taken into account.

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b. Provide documents regarding replacement energy costs as addressed in this question including and denoting which documents were provided to the NRC for their c/b analysis.

Response 5

5. a. Consumers Power's comments on replacement energy costs were for the purpose of providing these costs based on then current Company proj ections. These projections were based on results of the company's production cost program and latest forecasts for its input.

(1) Consumers Power Company has only oil-fired capacity placed in economy reserve. This capacity was assumed not to be available for purposes of generation in the FES cost / benefit studies.

(2) The amount of purchased and interchange power required for replacement energy is a result of using the company's production costing program. This production costing program assumes that any replacement energy will be made up by available alternative sources of least cost. The rise in price of purchased and interchange power for 1984 from the DES to the FES was not enough to significantly alter the reliance on purchased and interchange power. It should be noted that the l

replacement energy prices after 1984 as shown in the DES were not supplied by Consumers Power Company (see note 4 of Table 2.1 in DES).

(3) Assuming that " electrical demand rate" means load growth, the annual load growth rate can be derived from the Electrical Load Forecast Report, dated 12/14/81, which is being provided in response to question 4c (refer to the first page inside front cover). The percent change in load growth can be determined by dividing each year's figures by the preceeding year's figures.

mil 282-0070a168-100

8 (4) Replacement energy costs are not based on reserve margins.

(5) Inflation as measured by the GNP deflator is incorporated as part of the projected fuel cost for Consumers Power Company and Detroit Edison generating units and in the projected price paid for other sources of purchased and interchange power.

(6) Consumers Power Company does not wish to speculate as to what methodologies were used by the NRC to determine the estimates of replacement energy costs. Such questions on the DES should, therefore, be directed to the NRC. However, suggested chaages to the DES for replacement energy costs were made by Consumers Power based on then current estimates for electrical demand and GNP deflator, and are documented in Appendix A of the FES. The bases for these suggested changes can also be found in Appendix A of the FES.

(7) We assume that " projected electrical capacity" means projected energy amounts. Otherwise, the question would be asking for a comparison of two incomparable quantities (MWh for energy amounts and MW l for electrical capacity).

l The Midland projected energy amount and the projected replacement energy amount are the same.

(8) Capital or construction costs for projected replacement l

energy sources are not included in the cost / benefit analysis because they i

l are irrelevant to the costs of replacement energy.

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b. The only relevant document regarding the replacement energy costs, as discussed in this question, is the attached " Production Costing Output". This was neither requested by nor provided to the NRC.

Question 6

6. a. Explain in detail the basis for CPC's estimate of production costs provided to the NRC for their c/b analysis.

b. To what extent were operation and maintenance expenses related to soils remedial measures included regarding:

(1) Permanent plant dewatering system (2) Pipe monitoring systems (3) Structural monitoring systems (crack or stress analyses)

(4) Any other soil related measures

c. Provide an estimate of expenses (1-4 above) over the projected 40 year life of the plant and explain the basis for these estimates.

d. If the soil remedial 0 & M expenses (1-4 above) were not included in CPC submittals to the NRC for their cost / benefit analysis, explain and justify their ommission.

I I

e. Estimate when the soils remedial monitoring systems (1-4 above) will be completely installed--what their costs (equipment and installation) will be--and how these costs are taken into account.

Response 6

6. a. The production costs as shown in our comments to the DES (Table 2-1, page 32, FES) consists of two separate components-fuel costs and O&M costs.

The basis for calculating the nuclear fuel costs for Midland is the same as used for Palisades and Big Rock. The capital cost of the fuel, the financing costs (AFUDC and leasing) and the perpetual storage charges for spent fuel are amortized and collected as a function of the electrical generation produced by the assemblies during their in-core life. The mil 282-0070a168-100

O 10 calculations were based on actual costs for Midland's initial core material and services and estimated costs for reloads, finance charges and perpetual storage costs.

The basis of the O&M costs is the operation and maintenance costs workpapers in the 1981 electric rate case U-6923. The total O&M from this cost derivation was divided equally between both units. Unit No 1 required a further allocation of O&M costs between steam and electric portions of that facility. Property and liability insurance and administration and general costs were then allocated to Unit 1 steam and electric portions and to Unit 2. The total O&M costs, therefore, included O&M, insurance and other administrative and general expenses.

The Unit 1 electric portion and the total of Unit 2 were combined to determine the total O&M for the electric portion of the total facility as shown in our comments to the DES (Table 2.1, page A-32, FES).

b. The operation and maintenance expenses specifically related to soils remedial measures were not included in the cost / benefit analysis (table 2.1, page A-32 of FES). The reason for not including these costs is that these O&M costs had not been fully developed. In our opinion, any soils related O&M costs are so minimal in comparison to the total O&M costs that they will not have any significant impact on the overall cost benefit analysis.

c. Consumers Power does not have estimates of these expenses.

However, we would estimate the soils related O&M costs to be less than one percent of the total O&M costs. A formal estimate of these soils related O&M costs will be developed in the near future.

mil 282-0070a168-100 -

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d. As stated in 6b, Consumers Power Company is of the opinion that inclusion of these O&M estimates will have insignificant effect on the cost / benefit analysis because such soils related costs will be insignificant in comparision to the total O&M costs.

e. Consumers Power Company does not have an estimate of the completion date for the soils remedial monitoring system. As such, Consumers Power also does not have a cost estimate for the system. Both the installation schedule and the costs are under review at present.

Being a construction cost, the soils remedial monitoring system installation cost has not been taken into account in the cost benefit analysis.

Question 7

7. Consumers Comment #3 (A-28 FES) states, "CPC has recently revised plant and production cost data based on the latest cost forecasts."

a. What in the latest cost forecast to which this statement refers, and when was it submitted to CPC?

b. Do the referenced cost forecasts of Comment #3 represent the most recent cost forecasts from Bechtel that were available to CPC as of April 2, 19827 If not explain.

c. Have more recent cost forecasts been submitted to CPC by Bechtel since April 2, 1982?

l

d. Explain in detail the manner in which the " latest cost forecasts" were used to revise any plant and production cost data by CPC l

(Comment #3) and submit to the NRC for their cost / benefit analysis.

Response 7

7. a. Comment #3 (A-28 FES) does not refer to forecasts submitted to Consumers Power Company but those made by the Company. These cost forecasts refer to fuel, O&M and purchased and interchange power costs.

The plant costs are partially based on input from Bechtel. However, the mil 282-0070a168-100

12 fuel, O&M and purchased and interchange power costs do not involve any input from Bechtel. The latest cost forecasts referred to are our Adjusted Forecast No 7 for construction costs and latest forecasts available as of March 1982 for the other costs.

b. The construction cost forecasts reflects Bechtel's most recent input as reflected in the Adjusted Forecast No 7.

c. No more recent construction cost forecast has been submitted by Bechtel.

d. Table 2.1 (A-32 FES) explicitly shows then current forecasts of fuel and O&M for Midland's production costs. Other cost forecasts current at the time of Table 2.1 development are fuel and variable 0&M for Consumers Power (CP Co) and Detroit Edison (DECO) generating units

~

and the price paid for purchased and interchange power. These cost forecasts, for CP Co and DECO generating units and purchased and interchange power, are used as inputs to Consumers Power's production r

l costing program. Using this production costing program for scenarios that first assume Midland's projected electrical generation is available and then that it is not, results in those projected replacement energy costs shown in Table 2.1 (A-32 FES).

With regard to Plant construction cost forecast, the Adjusted Forecast 7 1

l shows the most recent plant construction cost data. However, this data is not relevant to the cost benefit analysis except in the determination of taxes.

l l

l l mil 282-0070a168-100

CERTIFICATE OF SERVICE I hereby certify that copies of the attached Consumers Power Company Responses to Discovery on Stamiris Cost / Benefit Contention vere served upon all persons shown on the attached service list by deposit in the United Statec mail, first class, postage prepaid.

1<

David E Barth I

l

. ., -f SERVICE LIST _ (

Frank J Kelley, Esq Ato:nic Safety & Licensing -

Attorney General of the Appeal Panel State:of Michigan U S Ntelear Regulatory Coms Carole Steinberg, Esq .

Washington, D C 20555 Assistant Attorney General -

Environnental Protection Div . Mr C R Stephens 720 Law Building Chief, Docketing & Services.

Lansing, MI h8913 U S Nuclear Regulatory ConmL Office of the Secretary -

,Myron M Cherry, Esq ' Washington, D C 20555 One IBM Plaza ^

Suite 4501 Ms Mary Sinels.ir Chicago, IL 60611 -

5711 Su=merset. Street -

Midiand, MI h8640 Mr Wendell H Marshall t' -

RFD 10 .

William D Paton, Esq .

Midland, MI.h86h0 , ~ Counsel for the NRC' Staff U S Nuclecr Regule. tory Cc:=2 Ch'arles Bechhoefer, Esq '

Ws.shingten, D C 20555 -

Atomic Safety & Licensing , .

. Board Panel . Atcmic' Safetr & Licensing U S Nuclear Regulatory Ccx=a Bot.rd Panel Washingten, D C 20555 'U S Nuclear Regulatory Ccmm

. Vashington, O C 20555 Dr Frederick P Covan -

6152 N~ Ver:le Trail ,

Barbara Stamiris .,

Atp B-125 .

5795 Korth River Rcad l

Boca Raten, FL 33h33 Rt 3 )' #

Freelaal, MI h8623 , -

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Jerry Harb'our j

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Atemic Safety & Licensin/ g '

. Lo'ard Panel '

i l Carroll E Mahaney U iS Nrplew Reguhtorp Cr.J:2 h,'

Babcock & Wilecx Washington, .D C 2C555 /

PO Box 1260 '

Lynchburg, Virginia 2h505 Lee' L Bishon

• Hanne6 & Velns 7 j James E Brunner, Esq 1727/ "I""St'reet , NW #506 I Consumers Power Cc=rany Wash 21ston, DC 20006 212 West Michigan Avenue l' Jackson, MI L9201 M I Miller, Esq Isham, Lincoln & Beale Mr D F Judd  :' tree !!aticnal Plaza Babcock & Wilcor 526d Flocr PO Box 1260 Chicago,'IL 60603 i Ignchburg, VA 24505 r l

John ' Demeester, Esq Steve Gadler, Esq Dev Che:1 erd Blds 2120 Carter Avenue Michigar.< Division St Paul, MN 55108 Midland, MI h86h0

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, UNITED STATES OF AMERICA NUCLEAR REGULATORY CO.T!ISSION ATOMIC SAFETY AND LICENSING E0ARD In the-Matter of Docket No 50-329 OM CONSUMERS POWER COMPANY 50-330 OM l (Midland Plant, Units 1 and 2). Docket No 50-329 OL

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) December 22, 1982

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AFFIDAVIT OF PHILIP L BICKEL My name is Philip L Bickel. I am the Director Corporate Planning for ConsEnersPowerCompany. In this capacity, my responsibilities include supervisingth5.developmentofelectricalloadforecastsforConsumersPower Company.

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i I am primarily responsible for providing a response to Questions 4b and 4e concerning Barbara Stamiris' cost / benefit Contention. To the best of my

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, knowledge and belief, the above information and the responses to the above i

interrogatory (ies) are true and correct.

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M Sworn add S.ubscribed Before Me this 22nd Day of Dec.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0t!!!ISSION ATOMIC SAFETY AND LICENSING BO.GD In the flatter of Docket No 50-329 O!!

CONSUMERS POWER C0?!PANY 50-330 OM (Midland Plant, Units I and 2) Docket No 50-329 OL 50-330 OL December 22, 1982 AFFIDAVIT OF PHILIP C WEBB My name is Philip C Webt. I am Senior Staff Engineer in the Midland Project Administration Department. In this capacity, my responsibilities are coordination with Dow Chemical Company in administration of the contract for steam service.

I am primarily responsible for providing a response to Questions 1 and 2 concerning Barbara Stamiris' cost / benefit Contention. To the best of my knowledge and belief, the above information and the responses to the above interrogatory (ies) are true and correct.

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Sworn and Subscribed Before Me this k Day of [ m 198Q.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket No 50-329 OM CONSUMERS POWER COMPANY 50-330 OM (Midle.nd Plant, Units 1 and 2) Docket No 50-329 OL 50-330 OL December 22, 1982 AFFIDAVIT OF ASHISH D SARKAR My name is Ashish D Sarkar. I am Section Head of Cost EnF ineering. In this capacity, my responsibilities are to estimate, forecast and monitor the total capital cost and other costs associated with the Midland Nuclear Project.

I am primarily responsible for providing a response to Questions 6b through e and 7 concerning Barbara Stamiris' cost / benefit Contention. To the best of my knowledge and belief, the above information and the responses to the above interrogatory (ies) are true and correct.

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Sworn and Subscribed Before Me this 23 Day of Dec 198_2.

t Notary Public Jackson County, Michigan My Commission Expires ge n - be,- 8 , 1o81 i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1

ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket No 50-329 OM CONSUMERS POWER COMPANY 50-330 OM (Midland Plant, Units I and 2) Docket No 50-329 OL 50-330 OL December 22, 1982 AFFIDAVIT OF DOUGLAS K WOOD My name is Douglas K Wood. I am a General Engineer in the Power Resources and System Planning Department. In this capacity, my responsibilities include performing economic analyses with respect to Consumers Power Company's generating system.

I am primarily responsible for providing a response to Questions 3, 4a and 5 concerning concerning Barbara Stamiris' cost / benefit Contention. To the best of my knowledge and belief, the above information and the responses to the above interrogatory (ies) are true and correct.

i KU Sworn and Subscribed Before Me this 23 Day of See 198L.

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UNITED STATES OF A'IERICA NUCLEAR REGULATORY COMMISSION i

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In the Matter of Docket No 50-329 OM l CONSUMERS POWER COMPANY 50-330 OM (Midland Plant, Units 1 and 2) Docket No 50-329 OL,'

j 50-330 OL i

December 22, 1982 AFFIDAVIT OF GARY L SCHWASS My name is Gary L Schwass. I am the Director of Financial Planning and l

Projects for Consumers Power Company. In this capacity, my responsibilities 3

include directing development of plans for financing the capital requirements ,

j of Consumers Power Company as well as the preparation of other financial and economic studies.

i I am primarily responsible for providing a response to Question 6a concerning

. Barbara Stamiris' cost / benefit Contention. To the best of my knowledge and belief, the above information and the responses to the above interrogatory (ies) are true and correct.

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//G6hyL.Schwass v-Sworn and Subscribed Before Me this 23 Day of Dec. 1982.

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