ML20087P970
| ML20087P970 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/05/1984 |
| From: | Kanoff R, Zaleski M MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL, NUDOCS 8404100161 | |
| Download: ML20087P970 (29) | |
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D UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.g BEFORE THE AER -p ATOMIC SAFETY AND LICENSING BOARD I ISD
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PUBLIC SERVICE COMPANY OF
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50-443 OL
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50-444 OL (SEABROOK STATION, UNITS 1 AND 2
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ATTORNEY GENERAL OF MASSACHUSETTS CONTENTION CONCERNING THE FINANCIAL QUALIFICATIONS TO OPERATE AND DECOMMISSION THE SEABROOK NUCLEAR PLANT INTRODUCTION On February 7, 1984, the United States District Court of Appeals for the District of Columbia Circuit set aside the Nuclear Regulatory Commission's financial qualifications rule as set forth in 47 Fed. Reg. 13,750, March 31, 1982.1/
New England Coalition on Nuclear Pollution v. Nuclear Regulatory Commission, No. 82-1581 (February 7, 1984).
This rule had exempted electric utility applicants from the requirements of the Commission's financial qualifications regulations.
Prior to the rule, the Commission's regulations 1/ -This rule was entitled Elimination of Review of Financial
.Uualifications of Electric Utilities in Licensing Hearings for Nuclear Power Plants.
4 8404100161 840400 gonAoOcn05000;y4
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required that applicants for licenses to operate nuclear power plants provide the following information:
Information sufficient to demonstrate to the Commission the financial qualifications of the applicant to carry out, in accordance with the regulations in this chapter, the activities for which the permit or license is sought.
If the application is for a construction permit, such information shall show that the applicant possesses the funds necessary to cover estimated construction costs and related fuel cycle costs or that the applicant has reasonable
~ assurance of obtaining the necessary funds, or a combination of the two.
If the application is for an operating license, such information shall show that the applicant pcssesses the funds necessary to cover estimated operating costs or that the applicant has reasonable assurance of obtaining the necessary funds, or a combination of the two.
With respect to any production or utilization facility of a type described in $50.21(c) or $50.22 (facilities for industrial or commercial purposes), or a testing facility, the following specific requirements shall apply:
If the application is for an operating license, such information shall show that the applicant possesses or has reasonable assurance of obtairiing the funds necessary to cover the estimate costs of operation for the period of the license or for 5 years, whichever is greater, plus the estimated cost of permanently shutting the facility down and maintaining it in a safe condition.
-10 C.F.R.
550.33(f) (1982).
The NRC Staff informed all parties to this proceeding that the mandate was to issue on the D.C. Circuit decision on March 23, 1984.
While the Commission issued a policy statement indicating that it would be enacting a new rule by that date again eliminating the-financial qualifications requirement, it <
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has not in fact done so.
That being the case, a detailed consideration of Public Service of New Hampshire's financial ability to operate the Seabrook project is now appropriate.
4 There is simply no lawful basis for rejection of a contention challenging Public Service's compliance with 550.33(f) at this time.
CONTENTION 4
e The Applicants have not demonstrated that they are financially qualified to operate and decommission the Seabrook Nuclear Power Station in compliance with 10 C.F.R.
SS50.33(f),
50.40(b), 50.57(a)(4) and Appendix C to Part 50.
FACTUAL BASIS OF CONTENTION L
The Seabrook Nuclear Construction Project has suffered a series of cost overruns and in service delays virtually since its inception.
The latest of these escalating estimates shows a total cost of the Seabrook project in excess of $10 billion for both units.
(See Appendix A entitled Seabrook Joint Owner's Meeting Presentation Baseline Cost Estimate and Schedule Evaluation.).
_. _. _., _ _ _. _ _ _ _ -.. -..~ _. ~. _ _...
The cost increases and delays were cited by Moody's Investor Service, Inc. in a recent announcement that it lowered the ratings on several securities of PSNH.
The debt rating service expressed its concerns about the ability of PSNH to finance the project in view of the additional costs and delays.
Explaining the PSNH downgrading, Moody's said:
The cost increases and delays at Seabrook Nuclear Plant.placed an added burden on PSNH and the company's ability to finance both Seabrook units is being severely tested.
Recent cost estimate increases for Seabrook were much larger than expected.
Project costs however, remain uncertain, since PSNH is disputing the estimate.
For project participants and their ratepayers, this may mean shouldering a larger share of Seabrook costs, perhaps over the long term.
Moody's Bond Survey March 19, 1984, Vol. 76, No. 12, at 4448.
Moody's also noted that the Company's financial condition is abysmal.
As stated in Moody's:
Company financial measurements remain at depressed levels.
Internal cash generation which was negative in 1983, is not projected to improve until completion of Unit 1.
The interest coverage ratio excluding AFUDC at 1.2 times in 1983 was also below desired levels.
The Company's $1.1 billion investment in the Seabrook project at year-end 1983 represents over 150%
of total common equity, obviously a large concentration of assets.
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k,Thedebt rab['!ng agency cut its ratings on PSNH debentures and it[ Eurobond-guarabteed notes tc Single B-1 from Ba-3.
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reduced the rating on the utility's preferred stock to single 1
.3-l'fiom Ba-3..
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s The Company's financial condition is so precarious that
' bankruptcy has been suggested.
As the Wall Street Journal J
recently reported:
sublic Service Company of New Hampshire, lead owner of the saabrook nuclear project, reported that its independent au titors said the utility,riaay be forced to seek protection of the bankruptcy court'if it doesn't fino back-up sources cre4tt within three weeks.
Wall Street Journal, April 3, 1984 Page'7,*
All of these problems',' i.e.
the cost overruns, the project delays, and the " depressed" financ;tal condition
- ' represent a signiE cant change in circu:1 stances since the case a s was originallynfilgd before the Licensing Board.
The Attorney GeneralsubmitsthtPSNH'sffling,isdutofdateandprovides no indication' of current ' financial' condition or ability to construct the Seabrook project.2/
The changes in the Seabrook project and in the financial health of PSNH, as set forth herein, canno.t be ignored; Consequently, it is imperativethattheNRh[cobsider,inviewoftherecentcost N
in, creases and delays 'in):hh Seabrook project and in view of t
s 4
4 st..
i 2/ Jhe filing of PSNH'Aa this case c'ontains no information of-s
< Tinancial qualifications beyond (1991. See Vol.1, General &
Financial Information, Seabrook Station, $1, p.5.
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the questions raised by Moody's, and by the financial community, whether PSNH " possesses or has reasonable assurance of obtaining the funds" necessary to operate Seabrook I and II as required by NRC regulations. !
It is respectfully requested that the Licensing Board allow this contention and require an examination into the financial qualifications of PSNH and the other joint owners to operate Seabrook.
THE COMMISSION'S LATE FILED REQUIREMENTS HAVE BEEN SATISFIED The Attorney General meets the requirements specified in 10 C.F.R. SS2.714(b) and 2.714(a)(1) for admission of this late-filed contention.
1.
The Attorney General has good cause for filing this contention after the expiration of the original time period for submission of contentions.
The Commission removed the financial qualifications requirement in March of 1982, a month before the Attorney General was required to file its 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 in NECNP V.
NRC, No. 82-1581.
3/
PSNH's financial shortcomings were further described in RECNP Contention VII:
Financial Qualifications of Public Service Company of New Hampshire to Operate and Decommission the Seabrook Nuclear Power Plant.
The Attorney General of Massachusetts hereby adopts and incorporates by reference the financial information set forth therein concerning bond ratings the Dean Witter Study.
NECNP Contention VII, at 8-9.
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j We were advised by the NRC Staff that the mandate would not issue invalidating the Commission's removal of the financial qualifications requirement until March 23, 1984.
This is
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therefore the first opportunity that the Attorney General has had to raise the financial qualifications issues.
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2.
There is no other means by which the Attorney General's~ interest can be protected.
The Licensing Board is the only tribunal empowered to consider the question of whether the Applicants are financially qualified to operate the j
Seabrook plant with a reasonable assurance of safety and in compliance with NRC regulations.
3.
The Attorney General can be expected to assist in developing a sound record in this issue, as he had done in the o
9-area of emergency planning.
The Utilities Division of the Department of the Attorney General consists-of lawyers, economists and financial analysists with experience in all facets of utilities law including financial qualifications.
The Utilities Division appears regularly before the state
-Department of Public Utilities,and'the Federal Energy i
Regulatory Commission.
The Division as part of its representation of Massachusetts ratepayers employs expert witnesses'and expects to doiso in this case.
The testimony will indicate how PSNH has not shown its ability to finance,
'perate and decommission the Seabrook Project at present cost o
fh levels.
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The Attorney General's interest in this issue is not represented by any other party, since the Board has not accepted contentions on financial qualifications by any other party.
5.
The Attorney General's litigation of the financial qualifications issue will broaden the scope of the proceeding into a new field.
That field, however, has limited scope, and will not lead to further broadening of the issues.
The litigation of financial qualifications cannot be expected to substantially delay the licensing proceeding.
The litigation of off-site emergency planning is still the greatest limiting factor in the timing of the Seabrook hearings.
These hearings have not yet been scheduled, and the emergency plans for Massachusetts are not yet ready for submission to the Board a
and parties.
Therefore', the submission at this time of a contention ~on financial qualifications cannot be expected to delay the conclusion of the hearing past the date when off-site
~
' emergency planning issues will be litigated.
Although the Attorney General satisfies the NRC's 1
standards for late-filed contentions, we contend that under the circumstances this standard cannot be used to bar litigation of l
a contention that satisfies the requirements of 10 C.F.R. 52.7.4(b) for timely filed. contentions.
The only reason that the Attorney General did not challenge the Applicants' financial qualifications in April of 1982 was that he was illegally barred from doing so by the Commission's amendment to ~.
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the financial-qualifications rule.
The Court of Appeals has now restored the right that was illegally withheld.
The Attorney General cannot legally be penalized now for such factors as broadening or delaying the proceeding, when those problems arose simply as a result of the Commission's own illegal actions.
If the Licensing Board is entitled to consider any factor that could affect the Attorney General'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.
We have submitted' sufficient information here to conclude that the 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, W1 N(-
AY Marg ret A.
Za eski Assistant Att ney General Public Protection Bureau Dept. of the Attorney General One Ashburton Place Boston, Massachusetts 02108
/) Ll ichard A.
Kanoff Assistant Attorney General Utilities Division One Ashburton Place Boston, Massachusetts 02108 Dated: - -...,
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ATTACHMENT A SEABROOK JOINT OWbERS hEETING PRESENTATION BASELIFE COST ESTIMATE AND SCFEDLLE EVALUATION March 1,1984 Prepared By Manag'e'rnent Analysis Company 11095 Torreyana Road
, San Diego, California 92121
'bo~ ject Nutr.ber: MAC-83-1074
2103-4
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. O AENDA i
1.
8 ASELINE DOCUMENTS 2.
PROBABILISTIC COST / SCHEDULE EVALUATION (PCE) 3.
CONCLUSIONS 4.
CONCERNS 5.
RECOMMENDATIONS 4
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' 2103-4 2-BASELDE DOCUMENTS SCWDULE
- 1 JANUARY 16,1984
- 2 JANUARY 24,1984
- 3 JANUARY 31,1984 *
- 4 FEBRUARY 17,1984 - FEBRUARY 23,1984
- 5 FEBRUARY 28,1984 COST
- 1 JANUARY 31, 1984 *
- 2 FEBRUARY 28,1984
- BASELINE
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BASEll>E DOCUENTS BASELINE SCTDLA.E AND COST EVALUATED RUN DATE:
JANUARY 31,1984 PROGRESS STATUS DATE:
JANUARY 23,1984 UNIT 1 FUEL LOAD DATE:
SEPTEMBER 18,1986 COMMERCIAL OPERATION DATE:
APRIL 17,1987 UNIT 1 ESTIMATED COST:
$5.07 BILLION ($10.1 BILLION TOTAL PROJECT) me
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2103-4 BASELINE PRODUCTS EVALUATED SCHEDu_E l
e ASSUMPTIONS PERCENT COMPLETE CURVES e
e MANPOWER CURVES e
COMMODITY CURVES e
LOGIC DIAGRAMS o
CPM CRITICAL PATHS e
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- 2103-4 BASELINE PRODUCTS EVALUATED COST ESTIMATE e
ASSUMPTIONS e
ALLOWANCES '
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QUANTITIES e
CRAFT MAN-HOURS e
NON-MANUAL MAN-HOURS e
OWNER'S COST e
AFUDC e
ESCALATION e
CONTINGENCY
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2103-0 PROBABILISTIC COST /SCWDu.E EVALUATION (PCE) FOR SEABROOK LNTT 1 AND COMMON APPROACH MAC TEAM ON-SITE TO GATHER INFORMATION AND REVIEW UE&C e
BASELINE SCHEDULE SUBJECTIVE PROBABILITY ASSESSMENTS OF DURATIONS OF VARIOUS e
SCHEDULE ELEMENTS PROBABILITY TREE CALCULATION OF SCHEDULE MILESTONES e
PREPARATION OF COMPUTERIZED COST MODEL e
e SUBJECTIVE PROBABILITY ASSESSMENTS OF SIGNIFICANT COST CATEGORIES COMBINE SCHEDULE AND COST UNCERTAINTIES IN COST MODEL e
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. REVIEW AND SUMMARIZE RESULTS DOCUMENT METHOD, DATA AND RESULTS e
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PCE ASSUMPTIONS AND CONSTRAINTS e
NO CASH FLOW CONSTRAINTS NUCLEAR FUEL COSTS EXCLUDED e
NO QA/QC PROJECT DELAYS AS AT ZIMMER, MARBLE HILL, MIOLANDS, e
WPPSS LIMITED TIME AVAILABLE FOR PERFORMANCE OF PCE e
INFLATION RATE AND AFUDC RATE UNCERTAINTIES BASED ON RECENT o-MAC STUDIES 4
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JULY 1986 TO JANUARY 1987 30 %
JANUARY 1987 TO JULY 1,987 35%
JULY 1987 TO JANUARY 1988 15 %
AFTER JANUARY l'958..
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2 ESTIMATED COST PROBABLITY - N #1 AND COMMON l
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$4.80 BILLION TO 5.10 BILLION 20"'a
$5.10 BILLION TO 5.40 BILLION 10 %
ABOVE $5.40 BILLION 108o 6
2103-4.
TAR &TS OF OPPORTUNITY IMPROVE PROJECT MANAGEMENT e
IMPROVE PROJECT PLANNING AND CONTROL e
e REDUCE MANPOWER ESTIMATE COM3ARISONS UE&C BASELINE ESTIMATE AND SCHEDULE (4/17/87 C.O.)
5.07 BILLION
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MAC PROJECTED COST WITH BASELINE SCHEDULE 4.84 BILLION
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MAC PROJECTED COST WITH 50% PROBABILITY SCHEDULE (2/15/87 C.O.)
4.68 BILLION
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MAC PROJECTED COST WITH 10% PROBABILITY SCHEDULE (7/1/86 C.O.)
4.19 BILLION
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POTENTIAL NET SAVINGS 880 MILLION
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l CON _CLUSIONS THE APRIL 1987 COMMERCIAL OPERATION BASELINE SCHEDULE DATE e
HAS A 60 - 65 PERCENT CUMULATIVE PROBABILITY OF BEING ACHIEVED.
e THE $5.07 BILLION ESTIMATE ASSOCIATED WITH THE APRIL 1987 COMMERCIAL OPERATION DATE HAS APPROXIMATELY A 75 PERCENT CUMULATIVE PROBABILITY 'OF BEING ACHIEVED.
THE JULY 1986 TARGETED COMMERCIAL OPERATION DATE HAS A e
10 - 15 PERCENT CUMULATIVE PROBABILITY OF BEING ACHIEVED.
e THE $4.4 BILLION ESTIMATE ASSOCIATED WITH THE JULY 1986 COMMERCIAL OPERATION OATE HAS A 20 - 25 PERCENT CUMULATIVE PROBABILITY OF BEING ACHIEVED.
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THE IDENTIt'ICATION OF REMAINING
- SCOPE, INTERDISCIPLINE RELATIONSHIPS AND CONSISTENCY OF DETAIL IN THE SCHEDULE REQUIRES FURTHER IMPROVEMENT.
REWORK FACTORS WERE NOT DETERMINED OR APPLIED TO SCHEDULE e
ACTIVITIES ON A DETAIL BASIS.
WHILE MANPOWER LOADING IS MORE REA! ISTIC THAN THE 1982 SCHEDULE, e
HIGH MANPOWER DENSITIES ARE STILL REQUIRED IN THE RCB AND PAB.
e REPORTED STATUS OF CABLE AND HANGER INSTALLATION IS QUESTIONABLE.
RATE OF START-UP TEST ACTIVITIES PER MONTH APPEARS AGGRESSIVE.
e DETAILED COST ESTIMATE WAS BASED ON MARCH 1986 FOR UNIT 1 AND e
DECEMBER 1989 FOR UNIT 2.
THE COST
SUMMARY
PRE.SENTATION'S COMPILATION WAS DIFFICULT TO e
EVALUATE WITH ERRORS AND INCONSISTENCIES STILL UNRESOLVED.
TOTAL CRAFT MAN-HOURS ARE HIGH.
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2103-4 --
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CONGRNS (CONTINLED)
RATIO OF INDIRECT AND NON-MANUAL TO DIRECT CRAFT ARE VERY HIGH.
e TO DATE TO GO TOTAL INDIRECT CRAFT 64 %
85 %
69 %
SITE NON-MANUAL 56 %
105 %
68 %
ENGINEERING /HOME OFFICE 50 %
65%
53 %
THE GROWTH OF NON-MANUAL, ENGINEERING AND HOME OFFICE MAN-e HOURS IS DISPROPORTIONATE TO GROWTH OF TOTAL CRAFT MAN-HOURS.
TOTAL CRAFT 27 %
SITE NON-MANUAL 64 %
ENGINEERING /HOME OFFICE 67 %
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2103-4.
RECOMNENDATIONS e
DETERMINE AN APPROPRIATE CONTINTNCY AND MANAGEMENT RESERVE FOR THE TARTT SCHEDULE AND ESTIMATE FOR FINANCIAL PLANNING PURPOSES.
MAKE SUBSTANTIAL IMPROVEMENTS IN THE PROJECT ORGANIZATION.
e DEVELOP A MORE CONSISTENT AND DETAILED SCOPE OF REMAINING e-WORK AND PLAN TO REACH UNIT 1 TARET MILESTONES. CONSIDER MILESTONES SUCH AS:
e ECCS FLOW TEST e
REACTOR COOLANT COLD HYDRO e
HOT FUNCTIONAL TEST e
DOCUMENTATION REVIEW AND TURNOVER TO OPERATIONS e
BUILDING / AREA TURNOVER TO OPERATIONS e
FUEL LOAD e
COMMERCIAL OPERATION DEVELOP A DETAILED ESTIMATE REFLECTING THE TARET SCHEDULE e
AND SIGNIFICANT IMPROVEMENT IN MANPOWER UTILIZATION AND
"~
EFFICIENCY.
EVALUATE CURRENT OPERATIONS TO MAKE SIGNIFICANT MANPOWbR e
REDUCTIONS OVER CURRENTLY PLANNED OPERATIONS.
1 ?
e DEVELOP A MOR,E STRUCTURED SCHEDULE AND COST CONTROL PROCESS.
DEVELOP A SPECIFIC DETAILED PLAN AND ESTIMATE FOR UNIT 2.
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CERTIFICATE OF SERVICE I, Margaret A.
Zaleski, Esquire, counsel for Massachusetts Attorney General Francis X.
Bellotti, hereby certify that on April 5, 1984, I made service of Attorney General of Massachusetts Contention Concerning the Financial Qualifications to Operate and Decommission the Seabrook Nuclear Plant by mailing copies thereof, postage prepaid, to the parties named below:
Helen Hoyt, Chairperson Rep. Beverly Hollingworth Atomic Safety and Licensing Coastal Chamber of Commerce Board Panel 209 Winnacunnet Road U.S. Nuclear Regulatory Commission Hampton, NH 03842 Washington, DC 20555 Dr. Emmeth A. Luebke William S. Jordan, III, Esquire Atomic Safety and Licensing Diane Curran Board Panel Harmon & Weiss U.S.
Nuclear Regulatory Commission 2001 S Street, N.W.
Washington, DC 20555 Suite 430 Washington, DC 20009 Dr. Jerry Harbour Edward L. Cross, Jr., Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Dana Bisbee, Esquire U.S. Nuclear Regulatory Commission Assistant Attorney General Washington,-DC 20555 Office of the Attorney General 208 State House Annex Concord, NH 03301 Atomic Safety and Licensing Appeal Roy P.
Lessy Board Panel Deputy Assistant Chief U.S. Nuclear Regulatory Commission Hearing Counsel Washington, D C 20555 U.S.N.R.C.
Washington, DC 20555 3
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Atomic Safety and Licensing Robert A.
Backus, Esquire Board Panel 116 Lowell Street U.S. Nuclear Regulatory Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Dr. Mauray Tye Assistant Attorney General Sun Valley Association Department of the Attorney 209 Summer Street General Haverhill, MA 01830 Augusta, ME. 04333 Carole F.
Kagan, Esq.
Thomas G.
Dignan, Jr.,
Esquire Atomic Safety and Licensing Robert K. Gad, III, Esquire Board Panel Ropes & Gray U.S. Nuclear Regulatory Commission 225 Franklin Street Washington, DC 20555 Boston, MA 02110 Charles Cross, Esquire Ms. Olive L. Tash Shaines, Madrigan, & McEachern Designated Representative of 25 Maplewood Avenue the Town of Brentwood P.O. Box 366 R.F.D.
1, Dalton Road Portsmouth, NH 03801 Brentwood, NH 03833 Roberta C. Pevear Edward F. Meany
-Designated Representative of Designated Representative of the Town of Hampton Falls the Town of Rye Drinkwater Road 155 Washington Road Hampton Falls, NH 03844 Rye, NH 03870 Mrs. Sandra Gavutis Calvin A.
Canney Designated Representative of City Manager the Town of Kensington City Hall RFD 1 126 Daniel Street t
East Kingston, NH 03827 Portsmouth, NH 03801 Richard E.
Sullivan Jane Doughty Town Hall Field Director Newburyport, MA 01950 Seacoast Anti-Pollution League 5 Market Street Portsmouth,.NH 03801 Docketing and Service Section Office of the Secretary U.S.
Nuclear Regulatory Commission Washington, DC 20555 _
4 Brian P. Cassidy Representative Nicholas J. Costello-1st Essex District Regional Counsel FEMA Region 1 Whitehall Road John W. McCormack Post Office Amesbury, MA 01913
& Courthouse Boston, MA 02109 Mr. Angie Machiros, Chairman Diana P.
Randall Newbury Board of Selectmen 70 Collins Street Town of Newbury,.MA 01950 Seabrook, NH 03874 Patrick J. McKeon Anne Verge, Chairperson Chairman of Selectmen, Rye, Board of Selectmen New Hampshire Town Hall 10 Central Road South Hampton, NH 03842 Rye, NH 03870 Donald E. Chick Maynard B. Pearson Town Manager Board of Selectmen Town of Exeter 40 Monroe Street 10 Front Street Amesbury, MA 01913 New Hampshire 03833 Selectmen of North Hampton Mr. Daniel Girard Town of North Hampton Civil Defense Director New Hampshire 03862 25 Washington Street Salisbury, MA 01930 Senator Gordon J.
Humphrey Senator Gordon J.
Humphrey 1 Pillsbury Street U.S. Senate
- Concord, NH 03302 Washington, D.C.
20510 (Attn:
Herb Boynton)
(Attn:
Tom Burack)
Signed under the pains and penalties of perjury, this 5th day of April, 1984.
% CLil Ma'rg a'r e t A. Zalespi Assistant AttocM y General Public Protection Bureau One Ashburton Place Boston, MA 02108..
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