ML20067A855

Interrogatories & Request for Production of Documents on Stamiris Cost/Benefit Contention,Per ASLB 821029 Memorandum & Order.Related Correspondence

ML20067A855
Person / Time
Site:	Midland
Issue date:	11/26/1982
From:	Stamiris B STAMIRIS, B.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8212020343
Download: ML20067A855 (4)

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'; .U. S. Nuclear Regulatory Commission Docket Nos.

In the matter of -

50-329 OL CPCo. Midland Plant Units 1 & 2 50-330 OL BEFORE THE ATOMC SAFETY AND LICENSING BOARD DISCOVERY ON STAMIRIS COST / BENEFIT CONIENTION TO THE NRC STAFF 11/26/82 Pursuant to the Board's 10-29-82 Memorandum and Order, Intervenor Stamiris submits the following interrogatories and document requests to the NRC. Intervenor requests that answers be provided within 30 days.

1. Explain in detail the NRC's analysis of information supplied by CPC regarding the effects of the Dow Steam reservation change on the cost / benefit analysis

(#22, A-31 FES). How does this affect your FES assessment of:

a. Replacement energy costs

b. Reduced generating costs

c. Electrical capacity factor

d. Any other elenents of cost / benefit analysis

2. Explain the basis for your 6.4.3 concluding sentence changes (6-5 DES, 6-3 FES} from 1310 me to 1357 E'e.

3. Explain the increase of electric.a1 energy from DES 7 billion kw/ year to FES 8 billion kw/ year.

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• b 4 Why isn't the increased Dow steam reservation (#22, A-31, FES) reflected in a reduction in electrical capacity?

5. a.* Why did the NRC use a (1310 MWe) design rating in assessing additional

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generating capacity in the DES, but a (1357 MWe) gross nameplate rating in the FES (tables 6.1 6-2 DES, 6-4 FES)? *

b. If a design rating had been used in the FES, would it have remained at 1310 MWe? If not, explain.

6. a. How can the NRC Staff justify the selective application of the Commissions 4-26-82 ruling on "need for power" issues so as to dismiss all "need for power" considerations on the c~ost side of their analysis (sec. 2) while

- maintaining the "need for power" considerations implicit in the cost savings of the benefit side of their analysis (sec. 6)? (p. 2-1 FES, concluding sentence)

b. Considering this imbalance (7a), does the NRC judge their "large" assess-ment of benefit for reduced generating costs (table 6.1 FES) to be a valid and fair representation of plant operating costs and benefits to the public?

If yes, explain. In no, how will this be rectified.

c. Considering the exclusion of other construction cost impacts, does the NRC judge their "large" assessment of benefit (table 6.1 FES) for local property taxes to be a valid and fair representation of plant operating costs and benefits to the public? If yes, explain. If no, how will this be rectified.

7. a. In what manner and to what extent did the NRC rely on revised CPC cost forecasts (#3 p. A-28 FES) to revise their cost / benefit analysis?

b. What were the " latest cost forecasts" provided to the ::RC for their FES cost / benefit analysis?

8. a. In what manner and to what extent did the NRC consider soils remedial measures such as:

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1. Permanent dewatering systems -

2. Pipe monitoring systems

, 3. Structural monitoring systems (cracks or stress analyses)

. 4 . Any'~dth'er's in estimating their plant operation maintenance etcpenses?

b. If these were not previously considered, does the*hTC intend to consider them now? Explain.

9. a. Explain the analysis perforned by the h3C of the proposed FES replacement energy and "redt!ced generating cost" information supplied by CPC.

b. In assessing reduced generating costs based upon CPCs replacement energy cost submissions, to what extent were the capital or construction costs of replacement energy facilities considered?

c. Why does the NRC accept CPC's reliance on the higher priced " purchased power" (FES subtable 2.1, p. A-32) instead of basing replacement energy costs on the most economical alternative?

d. How did the h1C confirm the validity of the proposed changes in the FES cost / benefit analysis.

10. a,Why did the h7C use an averaging approach to compute " reduced generating costs" over 1984-88 but use 1984 data alone to represent production costs?

b Does the Staff believe that a consistent methodology or approach should be used in computing costs and benefits of plant operation?

c,. If yes, explain how the necessary changes will be implemented. If not, explain.

11. a. Upon what basis did the h7C determine the validity of CPC's 12-14-82 load forecast revision (subtable 2.1, p. A-32 FES) which resulted in the DES to FES increase in cost savings and table 6.1 reduced generating costs?

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b. What was the load forecast revision data provided to the NRC in support of this suggested FES change?

. 12. Prbvide any documents.other than those supplied by CPC upon which changes from

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the DES to h5S cost / benefit analysis were based, noting how and where they were used.

Respectfully Submitted,

, o Barbara Stamiris 5795 North River Road Freeland, MI 48623 cc: ASLB Judges W. Paton, NRC M. Miller, CPC Secretary, NRC

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