ML20083D405

Forwards Testimony of TS Laguardia on Behalf of Util Re Data Requests

ML20083D405
Person / Time
Site:	Seabrook
Issue date:	09/10/1991
From:	Haffer E SHEEHAN, PHINNEY, BASS & GREEN, P.A.
To:	Smukler L NEW HAMPSHIRE, STATE OF
References
NUDOCS 9109300263
Download: ML20083D405 (8)

Text

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SHEEHAN PHINNEY BASS +

GnEN PROFUMAL AWTsMC%

! OI l L . . _ l. . . . . 3 + __..m AT TORN E 15 AT L AW September 10, 1991 100n Eut Stetti P.O. Box 3701 MucHrsita VIA HAND DELIVERY Niw HAstrssixt 03105 3 01 Larry Smukler, Chairman ro cca.or.sa Nuclear Decommissioning g333g3gg Financing Committee i

N.H. Public Utilities Commission 1 Hanor: Putt 8 Old Suncock Road Sur 3:3 Concord, New Hampshire 03301 Nn s es; a RE: NDFC 91-1 03501-3 6 gu y,gg,

Dear Hr. Smukler:

W343}2111 - I enclose for filing the Supplemental Testimony of Mr. Thomas S. LaGuardia on Behalf of New Hampshire Yankee.

Sincerely, -

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g[,/,/ -k ~Mh:d-Edward A. Haffepf /

EAH:dl Enclosures

CC with enclosures:

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2 SUPPLD{ ENTAL TESTIMONY 3 of 4 Mr. Thomas S. LaGuardia '

5 on Behalf of New Hampshire Yankee 6

7 8

9 Q. HAVE YOU REVIEWED THE DIRECT TESTIMONY OF MR. JOHN S.

10 ROHRBACH OF THE STATE OF NEW HAMPSHIRE'S OFFICE OF TIIE 11 CONSUMER ADVOCATE AND HIS RESPONSE TO THE DATA REQUESTS 12 OF NEW HAMPSHIRE YANKEE?

13 A. Yes.

14 15 Q. DO YOU WISH TO COMMENT ON ANY ASPECTS OF MR. ROHRBACH'S 16 DIRECT TESTIMONY, OR HIS RESPONSES TO NEW HAMPSHIRE 17 YANKEE'S DATA REQUESTS?

18 A. Yes. I would like to take issue with Mr. Rohrbach's 19 suggestion that a commercial nuclear power plant's 20- capacity factor generally declines with age.

21 22 Q. HAVE YOU REVIEWED MR.- ROHRBACil'S ANALYSIS OF THE PREDICT-23 ED CAPACITY FACTORS FOR YANKEE ROWE USING HIS COMPUTER 34 MODEL AS PRESENTED IN- RESPONSE TO "EW HAMPSHIRE YANKEE'S 1.

l_ 25 DATA REQUEST NO. 8?

26 A. Yes.

27-28 Q. DO YOU HAVE ANY COMMENTS?

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Mr. Thomas S. LaGuardia 1 A. Yes. I believe it shows the great difficulty, if not 2 futility, of trying to predict capacity f actors using the 3 statistical-based progran that Mr. Rohrbach describes.

4 5 I have attached a curve of the capacity . actors that were 6 predicted by Mr. Rohrbach's program for Yankee Rowe 7 versus the plant's actual capacity factors. There is 8 little correlation in Mr. Rohrbach's analysis as his 9 computer model predicts Yankee Rowe's capacity factor is 10 negative in the year 1978, then begins to increase again.

Il such unexplained drastic reductions and subsequent 12 increases in calcu1~ted capacity f actors suggest that the 13 code may not have been validated and verified, and 34 certainly should not be relied upon for rate regulatory 15 purposes. The actual performance of Yankee Rowe shows no 16 such anomalies. In fact, Yankee Rowe's capacity factor 17 increases in its early years, leveling of f at an industry 18 high level in excess of 75%.

19 20 Q. HOW HAVE THE NEW ENGLAND NUCLEAR POWER PLANTS PERFORMED, 21 AS MEASURED BY CAPACITY FACTOR?

22 A. I have attached a graph depicting the average of the 23 reported capacity factors for the seven (7) New England 24 nuclear units (Yankee Rowe, Vermont Yankee, Connecticut 2

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Mr. Thomas S. LaGuardia 1 Yankee, Millstone Units 1,2 and 3, and Maine Yankee).

2 This group includes some of the oldest plants in the 3 country. The data for these units does not support a 4 correlation of decreasing capacity over a plant's 5 operating life.

'6 7 Q. WILL NHY OR TLG BE OFFERING ANY OTHER TECHNICAL WITNESSES 8 IN REGARDS TO THE DECOMMISSIONING COST STUDY SUBMITTFD TO

-9 THE . STATE OF NEW HAMPSHIRE NUCLEAR DECOMMISSIONING 10 FINANCING COMMITTEE?

11 A. Yes. Mr. William A. Cloutier, Jr., will be available 12 during my appearance before the Committee. Mr. Cloutier 13 is the Manager of Decommissioning Projects at TLG and was 14 instrumental in preparation of the study. His edLca-15 tional and professional background is provided as an 16 attachment to my supplemental testimony.

17 18 Q. DOES THIS CONCLUDE YOUR SUPPLEMENTAL TESTIMONY?

19 A. Yes.

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TLC ENGINEERING,INC.

NAME: William A. Cloutier, Jr.

POSITION: Manager, Decommissioning Projects EDUCATION: B.S. Mechanical angmeering, Worcester Polytechnic Institute, Worcester, MA, U.S.A.,1977 EXTERIENCE:

Mr. Cloutier has over thirteen years of experience in the areas of decommissioning planning and radioactive waste management. His current position is as Manager of Deconumssiorung Projects with TLG Encineering. inc., located in Brookfield, Connecticut (U.S.A). lie is responsible for the company's technical and financial studies involving the decommissioning of nuclear power stations, both current and future. These studies address all the major issues associated with disposition of both high-level and low-level radioactive waste.

Mr. Cloutier is currently lending support to the Sacramento Municipal District in the decom-missioning planniny, for the Rancho Seco Nuclear Generating Station. This activity has required the identification of both radiological and hazardous / mixed waste at the site, devel-opment of a long term site remediation plan, disposal / treatment aiternatives and develop-ment of site sampling / verification program and the investigation of volume reduction alternatives.

He has co-authored several papers on the issues surrounding reactor decemmissioning, radioactive waste management and was a contributing author on a study for the Atomic Industrial Forum to standardize the estimating of decommissioning cost.

1980 - 1983 Mr. Cloutier was employed with Nuclear Prior to his Inc, Enercy Services. current position as a Waste Management at Eng TLG Engineering, ineer. He provided tech the planning and engineering of nuclear facility decontamination and decommissioning as well as developed methodologies and cost-benefit approaches in facility dismantlement. At NES, Mr. Cloutier participated in the initial planning and engineering for decommissioning the Western New York Nuclear Service Center, a fuel reprocessmg facility. This effort included an on-site phase where assessments of both waste volume and disposal options were performed. He also participated in the engineering planning for decommissioning the Shippmgport Atomic Power Station,in areas of waste management and control, as well as led the mitial technical assessment for decommissioning the ilumboldt Bay Unit 3 genera-ting station.

1977 - 1980 As a lead Radwaste Engineer at ERASCO Services, Mr. Cloutier was responsible for the development, engineering and hardware procurement of radioactive waste treatment and associated cleanup systems. These activities were in direct support of commercial nuclear power plant construction.

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, TLG ENGINEERING,INC.

NAME: William A. Cloutier, Jr.

PUBLICATIONS:

' Impediments to Nuclear Decommissioning Due to the Presence of Spent Fuel On Site,"

with Francis W. Seymore, presented at the ASTM I.as Vegas meeting, January 1990.

Influence of Decommissioning on Radioactive Waste Stream", with J. Adler and F.W.

Seymore, presented at the 1988 ANS Topical Conference: Radiological Effects on the Environment Due to Electrical Generation. July 1988.

" Decommissioning of Commercial Power Reactors: Rationale, Impetus, Execution and Con-seguence," with Francis W. f;eymore, presented at the Low Level Waste Forum, January 1958.

AIF/NESP-036," Guidelines for Producing Commercial Nuclear Power Plant Decommis-siomng Cost Estimates," with Thomas S. Laduardia et al, May 1986.

TESTIMONY EXPERIENCE August 1989, before the North Carolina Utilities Commission, for Duke Power Company, Carolina Power & Light, and Virginia Power Company on decommissioning costs and waste volumes for decommissioning the Catawba Nuclear $tation and Brunswick Steam Electric Plant, docket E-100, Sub 56.

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