ML20080U117

New England Coalition on Nuclear Pollution Contention VII Re Financial Qualifications of Util to Operate & Decommission Facility.Certificate of Svc Encl

ML20080U117
Person / Time
Site:	Seabrook
Issue date:	02/29/1984
From:	Curran D, Jordan W HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8403020173
Download: ML20080U117 (15)

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DOCKETED UOnc UNITED' STATES OF AMERICA '84 IM -1 m :53 NUCLEAR REGULATORY ~ COMMISSION. m n --

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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Public. Service ~ Company of New )

Hampshire, et al. ) Docket Nos.

) 50-443, -444

-(Seabrook Station, Units 1 and 2) ')

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NECNP dONT2NTION VII: FINANCIAL. QUALIFICATIONS

, 'OF PUBLIC SERVICE COMPANY OF NEW ~ HAMPSHIRE TO OPERATE E AND DECOMMISSION THE SEABROOK' NUCLEAR POWER PLANT

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. Introduction.

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On. March 24, 1982,:the Nuclear Regulatory Commission

' amended its' financial. qualifications rule to' exempt public Lutilities from-the requirement'that they demonstrate their financial qualifications to operate and decommission their

. plants .as -a condition of receiving an operating license. 47

. Fed --Reg.113750, March-31,;1982. The Commission promulgated the amendment of the 'fihancial qual'ific$tions rule shortly

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beforefthe ini,tial - y period for' filing contentions in the

'Seabrook proceeding' closed on April 21, 1982. Thus, NECNP was

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unable to raise:a contention-challenging the. adequacy'of i Applicants' . financial qualifications to operate and

-decommission the'Seabrook plant.

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f Ia :a1 recent ' decision, the United' States Court of Appeals

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forithe District of< Columbia" Circuit' overturned the March 24

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T 9993020173 840729

,% PER ADOCK 05000443

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- r-amendment. New England Coalition on Nuclear Pollution v.

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.: Nuclear Regulatory Commission, No. 82-1581 (February 7, 1984).

The Court's determination that the~ amendment was invalidly promulgated has the effect-of reinstating the original- .

financialiqualifications rule. NECNP therefore takes the opportunity,=formerly denied by the. illegal amendment, to file m Ethis challenge 'ta) Applicants' financial-qualifications to operate.and decommission Seabrook.

The Financial Qualifications Rule Pursuant to110 C.F.R. S 2.104(c)(4), the scope of issues that can be raised in an operating license hearing includes:

Whether the. applicant is technically and financially qualified to engage iir the activities to be authorized

-by'the operating license in accordance with the regulations in-this-chapter....

-See also 10 C.F.R. SS 50.40(b), 50.57(a)(4). To obtain an

operating: license, an applicant'must submit to the NRC "information sufficient to demonstrate to the Commission the financial qualifications of the applicant" to carry out the

. activities for which the license is sought. ~ 10 C.F.R. S

-50.33(f). 'This'information includes a demonstration FM that the applicant-possesses the funds necessary to cover estimated operating costs or that the applicant has reasonable assurance of obtaining the necessary funds, Eor a ccmbination of the two.

Id 1 1Moreispecifically,-the operating license applicant must 1

show-that it

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'k:y possesses or h'as reasonable 2 assurance of-obtaining the

funds necessary to cover 1the. estimated costs of 3 ". 4 doperation for the period of.the license or for 5 Jyears, .whichever is ; greater,- plus the estimated costs J of permanently shutting the' facility.down and

maintaining it in a safe condition.

Ordinarily, itLisDsufficient to show that an-applicant can

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obtainithe.necessary funds to. operate the plant for the first

- fivet years of operation,- plus the . estimated costs of permanent-shutdown..'10 C.F.R. Part150,xAppendix C, S -I .

. The Jestablishment of adequate ~ financial qualifications ,tur a o

' u'tilityLisiessent'ial to a finding that a nuclear plant can and nwill be operatedisafely during its life. As the Licensing

Board recognized in Cleveland Electric Illuminating Co. (Perry

' Nuclear ~ Power Plant,LUnits.1-& 2),-LBP-81-24~, 14 NRC1175, 196

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4(1981): 7 Thecurrent'rulerhas[animportantpurpose. It is

,possible forLanLapplicant toiscrape-by financially

'during the construction? stage.. That is,ldue to Lunanticipated costnincreases-and backfit-requirements, itDmight barely manage to complete construction. If itidoes just scrape by, then tho^ company's-financial

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straits' Lcould interf ere with. its sound judgment in safety. matters.- SafetyEmeasures that might.be taken byf aifinancially healthy l company ~ might not be taken.

Thus,: the. financial health of a utility is integrally related

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t'o its ability'to operate a plant safely.

. Contention VII 5[ $ Applicants-have not demonstrated thatLthey are financially' t

qualified to operate andl decommission the'Seabrook nuclear tpower plantiin compliance -with 10 C.F.R. SS 50.33(f), 50.40(b),

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'50.57(a)(4), and Appendix C to Part 50.

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?Public Service. Company; of New Hampshire (PSCO), the major '

' Astockholder!(35%) sand lead. owner of.the Seabrook plant, is A' number of

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7E teetering on'theLbrink of financial disaster,

factors,iincluding mushrooming construction cost estimates, the

, suspension of construction on Unit 2,f f altering commitments by

, other, investors to the project, and loss of investor' confidence 2 ' i'n1Seabrook,_have' dimmed and.all~but extinguished the prospect J - ,

{thatzPSCO will be able'toisuccessfully complete and operate the

Seabrook facility. TherefisEthusino reasonable assurance that

' Applicants will have the financial resources _to operate the

'M' ;Seabrook plant cafely th'roughoutLits life,sor even for a period

• yof several. years.

-  ; -When PSCO ?first undertook the construction of the Seabrook-

-plant, it estimated'the cost at"lessEthan a billion dollars.

c' LNewfHampshir'e' Public Utilities Commission, "Public Service

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. Compan'ybofENew Hampshire,-Investigation into-the Supply and

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L^ LDemand for^ Electricity," Docket: No fDE 81-312,; April 29,1983 (hereaf ter "DE f 81-312") , ::at II-1.- The Ecompany now estimates l'

the:costi of- the plant at $5.24 billion , and the New CHampshire'Public~ Utilities l Commission recently set the. cost at

$8-9' billion,; depending on the timing.of completion of~ Unit 1.

DE81-312 at-II-2,-II-39. The Maine Public Utilities Commission c ihasimade ra simi-lar finding. cDE 81-312 - at II-39. More 1

- #1 PSCO liscscheduled to submit an-.updateo cost estimate for the-plant on March 1, 1984.

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recently,-Central Maine Power Company' submitted to the Maine

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PUC'a1 consultant's report containing a cost estimate of $10.3 billion:for the.Seabrook plant. National Economic ~Research

- Associates, cInc.~,1" An -Evaluation of . Capacity Planning and Load Forecasting for Central' Maine. Power Company," February 17, J 19 34, : at I-6.

As-construction cost estimates increase, PSCO's debt-equity ratio also' increases, creating serious financial risks for the l fcompany.- Assuming the PUC's cost estimate of $8-9 billion, PSCO's total,Seabrook investment will equal.80-90% of its assets.. DE 81-372 at II-4. According to the PUC, this degree of1 asset concentration in one project is the heaviest within the electric utility' industry. I_d. Moreover, the PUC found

-th'at the level.of' external' financing being used to fund the enormous project.is " unsurpassed in.the industry." DE 81-312

at.III-4.- As the PUC

concluded,-

In light :ofi this greatly increased construction program, 'it:is~likely.that further financial problems

will arise for a utility with'one of the worst set

[ sic] of financial-ratios in the country.

DE j 81-312 - at II-39.

PSCO's decision of September 8, 1983 to reduce construction on' Unit .2 to the " lowest feasible level" has further

jeopardized the financial health of the company. Before the decision to'stop Unit 2 construction, the New Hampshire PUC

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predicte'd-that Unit 2 would not be completed until March of

1990, 2 years later-than PSCO's prediction. DE 81-312 at N I

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jIIh33. ~ WithLthe postponement of construction on Unit 2 until

.- g (Unit:1 dis completed, Unit. 2's 1 completion date will be pushed  :

Joffcevenifurther.1 This lengthy'and open-ended-. postponement of

Unit- 2!s t completion. will only increase 'the eventual 1 cost of the fplant,.due to.the; inefficiency of_ separate construction efforts r -

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andithe'barden' of increased 1 interest payments.  !

Pressurestby other investors-to cancel Unit 2 create a af ' Estrong possibility; that Unit 2 'will be never be completed, thus Jraisingjeven"graverifinancial problems for Applicants. As PSCO

- fadm'its . inia recentlprospectus, New Hampshire's : anti-CWIP hConstructionLWorkfinProgress)=statutemight. prohibit. recovery

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iforJmosi?of'the $279,700,000' invested in Unit 2. Prospectus

?fsh saleiof:$100,000,000 1n. 7 debentures, November 14,.1983, at

7 (7..' iThe collapse of Unit-2 could well11ead to^ bankruptcy for

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Jtheyentireicompany. LIn PSCO's'own-words,

. . . ithe camount- of scharge against earnings would y :probably eliminat'e the1 Company._'s retained earnings,

'" i thereby; effectively (precluding" the Company from paying' ndividendsfon its4 common'and. preferred = stocks and

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' threatening-the continuanceLof the" Company's construction program and. business' operations.

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jIdi ConsideringftheLhigh: level.of pressure against completion

$fiUnitE2 . cancellation is aJ1ikely~ prospect. We understand Ethatithe ?compan'ies mthat own- forty-f our percent of Seabrook, 4 1ncludingiNew' England. Power 1 Pool, United--Illuminating, l Northeast Utilities,1 Central Maine Power, Eastern Maine tElectrih cooperative and Maine Public Service, want

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t ' cancellation of Unit 2. Some are under order from their state

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governmdnts to divestithemselves of holdings in Unit 2. Two 1 Connecticut utilities have been ordered by the Connecticut Department 'of Public Utility . Control to "make every effort to

' disengage" from Unit 2, including taking active steps to bring Labout cancell tion ef Unit 2. Prospectus at 2. The Maine Public Utilities-Commission has instructed Maine Public Service

' Company to divest itself of half its Seabrook interest (Docket

'81-114, November 30, 1982); and has set long-term cogeneration frates fortCentral Maine Power that are based on the assumption

. that CMP- will end its involvement in Unit 2. Docket 82-174, February 9, 1984. Central Maine Power announced on February 17, 1984,. that it would vote to cance1' construction of Unit 2 at the Seabrook owners' meeting of March '1, 1984, an'd-that it would exert "every_ effort to bring about the termination of

-Unit- 2 without jeopardizing the completion of Unit 1." Central Maine Power,. press'_ release,; February 17, 1984. Other utilities I and electric cooperatives, including Northeast Power Company and Eastern Maine Electrical Cooperative, are attempting to

' sell {their shares in all or'part of the Seabrook plant.

Under these circumstances, it is very unlikely that Unit 2 will ever be completed.

L As' Public Service Company concedes, it will require special administrative, judicial,.or legislative relief if Unit 2 is cancelled, or the cancellation "will have serious consequences for;the_ continuation of the Company's construction program and

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-g-i business? operations." . Prospectus,-November 14, 1983, at 4.

. PSCO--is unlikely toiobt'ain'~ judicial relief for the costs of a

- Unit 12. In 1982, the New Hampshire Supreme Court allowed PSCO to contin'ueEconstruction on Unit 2 over the objection.of the.

- New-Hampshire.PUC;'.but warncd PSCO that the-PUC could deny

-recovery ~of unreasonable costs.- Appeal of Public Service

- Company of.New Hampshire,-454 A.2d 435, 443 (N'.H. 1982)

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, : Public Service Company's financial-problems have had a shatteringLeffect on-its viability in the marketplace. PSCO Jstockcprices have plunged from $20 a share in 1983 to $12 a

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Simison, " Nuclear Utilities' Money _Raisingiis shar e Tin ~ .198 4.

g Disrupted by: Industry Problems," Wall Street Journal, February

^714,f1984', at 35. - PSCO'is now resorting to the- " junk bond" or i high inferest market t'o attract investors. Id. The ' adde d lintereatt points-increase the heavy financial burden on the

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l Company. ~0f the six major. brokerage houses that NECNP Ltelephoned in February, only 1 recommended investing-in Public JService'Companylof New Hampshire.

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' PSCO'sL-l ratingsin the bond market have suffered as a result

.ofd ts,-financial-. setbacks . - According to the New Hampshire PUC,

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PSCO. stock's.were downgraded'"to levels achieved only by the owners of ThreeiMile Island" af ter PSCO revised cost estimates

and predicted further increases.= DE 81-312 at III-1. The PUC ialso" cited ~a repor't by~ Dean Witter Capital Markets, entitled

~ " Electric: Utility / Industry: Financial ~ Handbook" (Summer, 1982),

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4whichirankedlPSCO'at the bottom;among ll6. electric utilities.

The. Dean.Witter study reached the following sobering- 4 iconcl'usions about PSCO

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11k 'Over the:past five years, 1977-1981, no electric

-utility me'asured in the study had a larger construction.

program vis-a-vis .its net plant than did PSNH.

I2..:Over-the past-five' years,- 1977-1981, PSNH's construction program: compared to its net plant was 147%

, . larger than:thetaverage of_the 116 electric utilities measured in.the survey..

. 3.- In 1981,LPSNH's construction program as compared to its

net plant'was;189% larger than the average of the 116

- electric utilities measured in the curvay.

~4._ Over theTpast five.. years, 1977-1981,. PSNH has the worst'

internal-generation'of cash.

15.- -In-1981F-PSNH'had the worst' coverage ratios, both pre-tax andLafter' tax excluding AFUDC2 of every electric

- Lutility measured-except Metropolitan Edison, a subsidiary i c f' GPU , Lthe - owner s of : Three Mile Island.

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. 6. PSNH'and the subsidiaries of General Public' Utilities,

' = the' owners- of :Three Mile Island, have the -lowest bond rating of'the.ll6 electric utilities measured.

-7.s ~ InE 1981, PSNH 'had the, worst ratio of AFUDC as -a % of

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earnings f7 or: common of all the. electric utilities measured.

D E"81-312 at 'III-3. - The PUC concluded that "three downgrades

' inia year'to the/speculatory category, worsening financial

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, ratios and and' expanding l construction: program-all place PSNH in Indeed, PSCO has Id[. at III-4.

- Ja' category:by-itself."

conceded -thatLit is' the " riskiest utility:in the industry."

L"/AFUDC, 2 or ': allowance for. funds used duritig- construction, 2 consists:of the - carrying charges for construction of the plant.

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LDEj 81--312L at 'III -4.

m iNeed foriConsidcrat' ion of-

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Financial Qualifications

The financial information cited-above demonstrates a Lutility perched on1the brink'of financial disaster.. The likely cancell'ationtof[ Unit 2. threatens the icontinued operation of the

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? entire 5 business operationsiofLPublic Service-Company, let alone l'. .Even if. total cf L h'elsmootiiandisafe' operation of Unit Edisaster:'is tav.erted,-.:the . company's serious financial problems '

$ - are/likely to) impinge ~on its-ability.-to manage and maintain the plantlinja:: safe' condition.

- JGivenLtheidireicondition of PSCO's finances, the first' five

. years 1of1 operation:.maytbe:especially' difficult.- The technical 4

) problems tthatsmay bs -expected. during -initial operation may As-

,aeriousik;jeopardizeltheIfinancial'healthoftheplant..

' iPScof:c'oncedeslin11ts November .14,.1983, Prospectus, delays in f th'e Estartup TofiU' nit?lTwould' require the Company to maintain .

~high^ levels:fofffinancing;vand'any outages c after startup V iresultingLineremovalJfrom thefratel base "could impose 3g at 6.

> .fsignificanhfinancial' bur' dens-onLthe' Company."

"Considering the, severity:of its financial crisis, Public

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/ServicefcompanyTeannotiprovide the Commission with a reasonable lassurancefthat itjis':financiallyLqualified to. operate the-E -

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. D- ~ SeabrookJnuclearLlcscility}in. compliance-with'NRC. safety

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"' crequirements. LTherefore, :the Licensing Board should admit 1this p3 ,

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, Leontention:anditake' evidence from-the parties on th( issue of Aphlicants'ifinancial qualifications.

Satisfaction of Requirements

,f or Late-Filed ' Contentions NECNP meets the requirements: specified in 10 C.F.R. SS

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l 2 '. 714 ( b) and 2.714( a)(1) for admission of this late-filed contention.

1) 'NECNP has good:cause for filing this contention after

.theJexpiration of:the original time period for submission of tcontentions. - The Commission removed the financial Lqualifications-requirement in March of-1982, a month before

. NECNPlwas required to fileDits first set of contentions in this case. On February 7, 1984,'the U.S. Court of Appeals for the

District of Columbia held the Commission's action to be invalid

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=inENECNP:v..NRC, No. 82-1581. ' This is therefore the first Lopportunity that-NECNP'has had to raise the financial 7 qualifications issue.

2).'There i's no other means by'which NECNP's interest can

be protected.: .The Licensing Board is the only tribunal o

Tempowered to considerLthe question of whether Applicant.s are

financi~ ally. qualified to operate the Seabrook plant with a reasonable assurance .of; safety.and in compliance with NRC regulations.

3 )- :NECNP;can be expected,to assist.in developing a sound M record i on this case. ~ We have already assembled a substantial

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I quantity'of'information on the financial' health of Public 3 Service _. Company _of New Hampshire. We expect to call on experts to testify!on the issue before the Licensing Board. Much ]

information.hasLalready See.n gleaned from proceedings before

-st'ateLpublic utilities commissions. -NECNP also expects to use lthese-. excellent resources.'in presenting its case.

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.4)?iNECNP's interest-in-this issue is.not represented by anyLother/ party,;since the Board has'not accepted contentions

- on financial qualifications.by any other party.

5) NECNP's litigation -of the financial' qualifications dissuec will' broaden'the scope of the_ proceeding into a new

f ield .- Thai field, however,. has. limited scope, and will not

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flead to;further broadening of the issues.

'Thellitigation.of financial qualifications cannot be expected to.substantially~ delay the-licensing proceeding. The ilitigation-of-offsite emerge'ncy planning is still the greatest Llimiting' factor initheftiming of the.Seabrook-hearings. The-Temergency plans for Massachusetts have not yet. been submitted cto the partiesiforLthe preparation of contentions. Therefore,

thefsubmission atithis time of a contention on financial

-.qualificationsicannot be expected-to' delay the conclusion of th'e hearing-past the date when-the Massachusetts plans will be

-litiga ted . .

Although NECNP satisfiesJthe NRC's standards for late-filed

contentions, we contend that under the circumstances,-this

standard.cannot be used to bar litigation of a contention that w

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satisfies the requirements of 10 C.F.R. 52.714(b) for timely j

filed contentions. The only reason that NECNP did not

challenge Applicants' -financial qualifications in April of 1982

was 'that we were illegally barred from doing so by the Commission's amendment to the financial qualifications rule.

The Court of Appeals has now restored the right that was illegally withheld. UECNP cannot legally be penalized now for such-factors as broadening or delaying the proceeding, when those problems ardse simply as a result of the Commission's own illegal actions.

If the Licensing Board is entitled to consider any factor thatzwould mitigate.NECNP's right to litigate this contention, it is the question of whether the litigation could have a substantial effect on the. outcome of the case. NECNP has submitted sufficient-information here to conclude that

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Applicants' severe: financial problems could disqualify them from receiving an operating license; or at the least, that

-license issuance-must be accompanied by strict conditions

. regarding: financial reporting to the Commission. The contention should be accepted..

Respectfully submitted, Diane Curran r&William

- f ". ,W Jorda6, III HARMON, ISS AND JORDAN 1725 I Street, N.W.

Suite 506 Washington, D.C. 20006 February 29,'1984 '(202) 833-9070

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' CERTIFICATE-OF SERVICE- 00( CE

'RnRC

'I ; certify that on February- 29,1984, copies of NENCP CONTENTION VII:f FINANCIAL QUALIFICATIONS OF PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE TO1 OPERATE AND' DECOMMISSION THE SEABROOK*84UCl(l#Ai4 PdNd6 PLANT?were served on:the following by first-class mail or as Jotherwise indicated:- gg y 3gg ;;,

00ChEilFG A SE8Vtu.

~ *Ne len: Hoyt~, Esq., Chairperson Rep. Roberta GEAPWvear AtomicfSaftey and Licensing Board Drinkwater Road Panel .

Hampton Falls, NH 03844 U.S.ENuclearLRegulatory_ Commission 1 Washington', DC,- 20530-

• Dr. Emmeth14.1Luebke' Phillip Ahrens, Esq.

Administrative _ Judge Assistant Attorney General LAtomic Saftey and Licensing-Board State House, Station #6 U'.S. Niclear Regulatory Commission Augusta, ME 04333 Washington,7 DC 20555

<*DL. Jerry? Harbour Robert A. Backus, Esq.'

• : Administrative Judge 111 Lowell Street AtomicfSaftey and Licensing Board Manchester, NH 03105

U.S. Nuclear. Regulatory _ Commission Washington,iDC. 20555-cAtomic. Safety;and-Licensing Board _ ** Thomas 13. Dignan, Esq.

. P anel' .

R. K. Gad, III, Esq.

LU.S. Nuclear Regulatory _ Commission Ropes and Gray Washington,LDCE.20555- 225 Franklin Street Boston, MA 02110 Atomic. Safety and. Licensing Appeal _ '

Dr.1Mauray Tye, President 7 Board Panel- -

Sun Valley Asociation iU.S. Nuclear Regulatory Commission 209 Summer Street-

Washington,;DC 20S55 Haverhill', MA 01830

Docketin'g and Service *Roy.P. Lessy, Jr. Esq.

.U .S.x Nuclear 6 Regulatory Commission ~ - William F.- Patterson, Esq.

Washington,:DC- 20555' Office of.the Executive

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Legal Director TTown Manager's Office U.S.-Nuclear Regulatory

' Town' Hall - Friend St. Commission

- Amesbury,19e 01913 Washington, DC . 20555

Mr~. Angle MachirosJ Anne Verge, Chair Chairman- _

Board of Selectman sm.___ LBoard of Selectmen Town Hall "l" Newbury,.MA 09150 South Hampton, NH 03842 k

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'Jo Ann Shotwell,.Esq. George Dana Bisbee, Esq.

Assistant Attorney General Edward L. Cross, Jr., Esq.

. Department of.the Attorney Asst. Atty. Generals

-General State House Annex

. 11Ashburton Place, 19th Floor Concord, NH 03301 Boston,-MA -02108

' John B.'Tanzer Letty Hett, Selectman Town of Hampton Town of Brentwood .

-5 Morningside Drive RFD Dalton Road Hampton, NH ~03842 Brentwood, NH 03033

'.W Edward F. Meany Sandra Gavutis

-Town'of Rye Town of Kensington

- 3 'i5 Washington Road RFD 1

. Rye,;NH' 03870 East Kensington, NH 03827

. Diana'P. Sidebotham' Diana P. Randall

'R.F.D.2 70 Collins Street Pu tney, VT 05346. Seabrook, NH 03874 Donald E. Chick

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Richard E.-Sullivan, Mayor

City Hall Town Manager Newburyport, MA 01950 10 Front Street Exeter, NH. 03833

= Alfred V. Sargent, Chairman Brian P. Cassidy, Esq.

Board'of Selectmen FEMA Region I Town of Salisbury, Mh. 01950 J.W. McCormack Post Office and Courthouse Boston, MA. 02109 Senator Gordon J. Humphrey Senator Gordon J. Humphrey

.U.S. Senate 1 Pillsbury Street Washington,'D.C. 20510 Concord, NH 03301 (Attn: Tom Burack) (Attn: Herb Boynton)

Selectmen of'Northampton- Calvin A. Canney

. Town of Northampton City Manager New Hampshire 03862 City Hall 126 Daniel Street.

Portsmouth, NH 03801

• - By-Hand

• • By Express Mail .

Diane Curran

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