ML20071M556
| ML20071M556 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/18/1982 |
| From: | Stamiris B STAMIRIS, B. |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-OL, NUDOCS 8209270170 | |
| Download: ML20071M556 (5) | |
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'82 SEP 24 PI :42 0FFICE OF SECRETA.h -
U. S. Nuclear Regulatory Commission hfC In the Matter of Docket Nos.
CPC Midland Plant 329-OL Units 1 & 2 330-OL BEF(RE THE ATOMIC SAFETY AND LICENSING BOARD STAMIRIS PISPONSE TO NRC 8/31/82 IN'IERROGATORIES 9/18 /82 Q 1a 1.
The basis for my statement that Midland's decommissioning costs have been underestimated at $235 million is a comparison between CPC estimates decommissioning estimates for Big Rock and Palisades and those for Midland.
2.
Big Rock (63 W) and Palisades (635 W) are estimated by CPC to cost
$111 million to decomission in 1980 dollars (CPC decomissioning pamphlet MP 6/81-50M). Consumer's thus tells us that it would cost $159 thousand/W to decomission a nuclear plant in 1980 Yet Consumer's estimates Midland (2452 m) decommissioning in 1982 dollars to be only $235 million.
By this estimate Consumer's tells us it would cost $95 thousand/W to decomission a nuclear plant in 1982.
3.
k' hen the 1980 dollar estimates are converted to 1982 dollar values o make the comparison valid, the discrepency is even larger.
Big Rock and u..i sades decomissioning costs were projected by CPC in 1978 dollars to be
' 90 million (1/21/80 Saginaw News).
The inflation rise between the 1978 attube4 590 million estimate and the 1980 $111 million estimate represents an annual increase of 11%. So using that same 11% annual inflation rate to estimate the inflation rise between 1980 and 1982, the $111 million 1980 estimate becomes
$136 million in 1982 dollars for Big Rock and Palisades.
By this extrapola-8209270170 820918 PDR ADOCK 05000329
o eis,n, the hin Rock and P411sades' decommissioning cost s are 51')5 thousand/Mh,
wl.i le Midlan!'s are only $95 thousand/MW in the sare year. Even allowinn for a hinhor p*r MW deconard stioning cost for smaller reactors such as Big Rock, con: pared t o duel react ors like Midland, this large discrepancy is not accounted as f or.
4 Consuner's estirates they will need $526 million to decommission hin Rock and Palisades at the end of full life expectancy in the years 2000 and 2007 (MPSC case U-60tl, A/S exhibit 1) due to inflation.
This represents a year 2003 cost of $753 thousand/MW. At this rate Midland's decommissioning would cost the public $1.8 billion if it took place in the year 2003, af ter 20 years operation.
5.
Big Rock cost $25.8 million upon completion in 1962, Palisados cost
$180 million upon completion in 1971, for a combined $205.8 construction cost.
' So their $526 million ultimate decommissioning estimate represents 200% e of their origina1 construction costs.
Y'. the public is told Midland can be decommissioned for 7% its construction costs. '
6 In using such widely divergent standards to represent decommissioning cost s t o the public according to Consumer's various purposes (ie promotion vs. collection) Consumer's Power Co. is deceiving the public and proving all their estimates to be unreliable.
7.
Aside from Consumer's estimates for decommissioning. I presently have knowledge of one decommissioning experience.
The Elk River Reactor (22.5 MW) cost $6.148 million to decommission in 1973. Elk Rivers $6 million decom-missioning cost represents 28% of Elk Rivers $12.million construction cost, al'owinn for inflation.
%n.y;. tiscovery and on my own, I hope to obtain more decommission-or which to base my analysis.
I will supplement this discovery response 3 c.rcly.
3 Q Ib REASONABLE ESTIMA*IE & MIDIAND'S DECOMMISSIONING COSTS 1.
According to Conswner's own current decommissioning cost estimates for Big Rock and Palisades (par. 3. q. la), Midland's decommissioning cost should be at least $478 million in 1982 dollars.
2.
A more accurate representation of Midland's decommissioning costs would be $952 million (1982 dollars) at 28% its original construction cost (based on the Elk River Experience, par. 7 q. la).
3.
The most accurate decommissioning estimate is one which reflects what the actual cost will be to the public of decommissioning at the end of the full life expectancy.
4.
In computing the " benefits" to the public operating the Midland plant, inflation increases over the years for replacement energy (coal, oil, and purchased power) are taken into account to result in an increased cost savings (table 2.1 (4) p. 2-3 DES, table 2.1 (d) p. A-32 FES).
5.
Therefore, in computing the " costs" to the public of operating the Midland plant, actual decommissioning costs at the time of decommissioning should be projected taking inflation into account.
6.
I do not presently have a basis for projecting Midland's ultimate decommissioning ccst taking inflation into account other than Consumer's Big Rock and Palisades model, as presented to the MPSC in case U-6041, by which Midland's ultimate decommissioning would be about $7 billion at full life expec-I am uncertain of the validity of this model.
tancy.
The calculations as explained in b are my own based upon CPC or Elk River Q Ic data as cited.
Respectfully Submitted, Barbara Stamiris 5795 North River Road Freeland, MI 48623 ASLB memberst M. Miller, CPC; W. Paton, NRC; Secretary, h3C cc.
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Second front page a
Costs may hit S1 billion for NKlarit dismantlin s
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"have absolutely no'thirig to do with office and consumer groups, including Some 227.000 regional custom'ers of change, Consumers Power Ca. In 14 area coun,.The $121 million includes restoration the Michigan Citizens Lobby.
Midland."
ties will be hit by more than $1 billion la d of an 8804crf cooling pond to the same While hearings have been under way, As part of its environmental report costs sought by Consumers into the next condition prior to construction. Decom-the PSC has not acted on the final rate submitted two years ago, the company -
century to pay for dismantling nuclear missioning of the Midland plant itself increases. And the hearings thus far was required to submit a decommis-
, powsr plznts in Michigan ~ when their hasbeenestimated at381 million.
have involved on!y the two plants and sioning statement outlining how the Consumers went to the PSC tast sum ; not the Midland plant.
nuclear reactor can be deactivated and
- time comes.
. Joseph Tuckinsky, director of Michigan Citizens Lobby, was quoted making sure pperating parts, fuel or Any increases for dismantling the Big mer to propose rate increases of $115 '
Mc:k nuclear plant at Charlevoix and million over 30 years to pay for retiring s te won't poseany threat to humans.
i.
the Palisades plant near South Haven.. the Charlevoix plant in the year 2000 during the weekend as saying that if the and then the Midland nuclear plant in' and the Palisades plant in 2007.
PSC approves Consumers' plan.
The Midland plant's lic'ense, if ap-l the year 2012 or later, will hinge on rate A company spokesman today said Mict:igan customers might have to pay : proved, would be for 40 years, after sncreases on which hearings for decommissioning costs for PalisCes an.other $10 million to close the Midland which decommissioning plans would be operating plants are pending before the are estimated at $60 million while BIE plant and Detroit Edison's Fermi Two used.
M ichiga r. Public Service Commission.
Rock is $30 milllorL plant at Monroe scheduled to start While that is not expected to happen At the Midland nuclear plant, for ex-
~~llut those are 1978 dollar figures and operation in 1982.
ample. Consumers. in an environmen-current estimates, plus inflation and The state and consumer groupsetaim prior to the year 20I2, "and probably
~
t tal report submitted two years ago.
technology, make it " accurate to say" Consumers' figures, based on a shut. much later" according to a spokesman, down estimate of 20 percent of con. a plan must be submitted to t he Nuclear estimated total decommissioning and that in the 21st century the company is -
oite re>toration will cost $l21 million for looking at a $1 bl!!!on cost to shut down struction costs, are too low and 200 per-Regulatory Commission.
.i ppnt expected to cost $167 billion to the two plants, the spokesman said.
cent of construction costs will be need-Roderick Coy. an assistant attorney wnst ruct The proposed charges of $1 billion ed to shut the plants down.
general at I.ansing. said today he had no idea when the PSC will act on the it6t that $121 melhon figure for the over the next 20 years have come under The local spokesman said pending
%tignd plant is preliminary, and could attack by the state attorney general's hearings on estimated shutdown costs rate mcrease.
Every nuclear power plant must be decommisslaned at The decommissioning funds would not be simply the er.d ofits useful lifetime, placed in an escrow fund to wait until it's time to Decommissioning can be donc in several different decommission a plant. Instead, as the money was col-ways: mothballing(put ting the plant in protective stor.
lected, we would invest it in new-and necessary-age), entombment, dismantlement (taking the plant utility facilities. That way, our customers would get apart), or some combination of those three, the most for their money. When the time comes for decommissioning a plant, we would sell securitics to We Will Dismantic rafsc the money we needed. That procedure is typical Consumers Power Company plans to dismantle both of how business operates.
Its Big Rock Point and its Palisades nuclear plants at We believe that our plan for decommissioning our the ends of their lifetimes. Dismantlement is the only nuclear power plants is the best for our customers.
method which allows unrestricted reuse of the land on MPSC consideration of decommissioning financing which the reactor was sited.
methods is proceeding. Prompt approval of a plan to We plan to start dismantling our Big Rock plant after provide the necessary funds is crucial.
the year 2000. We estimate dismantlement of that plant will cost 838 million in 1980 dollars. We plan to dismantic Palisades beginningin 2007 at a cost of 873 million in 1980 dollars.
Who Will Pay?
Because decommissioning is a necessary part of operating a nuclear reactor, in the long run all our customers-they're the ones who benefit from <.lec-tricity generated at Big Rock and Palisades-rnust end up sharing the costs of dismantling the plants.
Recovering the costs of dismantling a property is nothing new.Just like any other business, Consumers Power Company normally recovers, through deprecia-tion, the total cost of any project-including dis-mantlement cost. But the depreciation rates we use now-by order of the Michigan Public Service Com; mission (MPSC)-do not take into account any of the costs of decommissioning our operating nuclear fa-cilitics.
We belicyc it to bc in the best interest ofour customers to allow us to recover the decommissioning costs in rates over the next 20 to 25 years. We believe they would bencilt most if cach year we collected and in-vested some of the money to cover the costs.
The MPSC must approve such a plan before we can im.
plcment it. The Commission is currently conducting a proceeding to consider the funding of nuclear plant decommissioning.
Ilow the Comimny's Plan Works Under the Company's recommended plan, cach year we would collect an amount ofmoney equivalent to the total needed to dismantic the plant divided by the num-ber of years of remaining plant life. Anticipated infla-tion would be added in.
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