ML20125B865
| ML20125B865 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 11/19/1969 |
| From: | David Nelson NORTHERN STATES POWER CO. |
| To: | Ramey J US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 9212100193 | |
| Download: ML20125B865 (28) | |
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NORTHERN -STATES POWER C O M P A_N Y 414 NICOL LET M ALL MIN N E APOLIS. MIN N E SOT A 5 S40%
LAW DEPARTMENT TELEPHONE 330 8800
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November 19, 1969 The Honorable James T. Ramey Commiseioner U. S. Atomic Energy Commission Washington, D. C.
20545 Re:
Northern States Power Company
- v. The State of Minnesota et al.
Court File No. 3-69-185 Civ.
Dear Mr. Ramey:
I very much appreciated receiving your letter of November 14 with enclosures.
You may be interested to know that attorneys for the parties to the above litigation are scheduled to meet with the Honor-able Edward J. Devitt, Chief Judge, United States District Court, on November 26, 1969.
The purpose'of the pretrial conference is (1) to discuss the possibility of limiting the issues raised by the pleadings by excluding evidence on the defense apparently raised by paragraph 6 of the_ defendants' Answer that the regulations of the Atomic Energy Commission.
are inadequate to protect the public health, and (2) to-dis-cuss with the Court possible trial dates'.
In connection with=
the.last item, it is possible that the case may be tried in January.
Judge Devitt'has indicated to us that he will not be available for trial during the month of February.
I shall endeavor to keep you advised of all-significant developments.
My best personal wishes.
9212100193 691119
~PDR ADOCK 05000263 Sincerely, j
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Northern States Power Companyi.
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File No. 3-69-185 Civil
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Plain tiff.
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The State of !!!nnesota,
'PLAll!r7FF'S ANSP"RS TO l'
The 111nnesots Pollution Control Agency end I:obert Tuveson, DEFFNDMp n ' 1 rir.R110CM 0l!!ES 4
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h OF OCT0hrP. 7, 1969 Howard Andertsen, John Eorchert,
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Milton J. Fellows, Steve J.
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1,uick, Mrs. R. C.1:elson and h
F.. Wayne Packard, individually 4
1-and as membcrc of the ::innesota
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Pollutica Cont rol Agency, and John P. Badalich as executive director und secretary of the liinnesota Pollution Control Agency, beiendants, Plaintiff, for its ansvers to defendants' interregatories, states as follows:
t iL 1,
State the names and addresses of all persons plaintiff intends calling as vitnesses at the trial at this matter, or intends calling at any pre-t rial or hearing.
ANsur.R, As of the date of these answers, no doeision has been c.ade by the plaintif f concerning the identity of the witnesses to be called et the i
ttial. Flaintiff vill, at the pre-trial conference, exchange with the defendants 1
f lists of witnesses to be called.
x 2.
State in detail what testimony each of those named in 709 to interrogatory 1 will give on dircct exaraina tion.
tr ANSLTR lio answer necessary 3.
State the names of all consultants, contractors and sub. contractors -
utilized in the design and construction of the nuclear fueled, ele-etric generating plant' located on the !#ssissippi River near ilonticello, Wright 3
County, Minnesota (hereinafter referred to as "lionti cello"), and that part of the design er. construction for which each as responsible, ANSWI@ Cencral Elect ric Compan-has contracted to supply, under turnkev
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3 Bechtel Corpo ation Chicago Eridge & Iron Company 1
(architect-engineer and
-(rcactor vessel and containment constructor) system)
A great number of sub-tier contractors has been employed by Ceneral Cloctric and the above two major subcontractors. Decause of the turnkey nature of the 4
contract, Northern States Power Company does, not have a list of the names of the many sub-tier contractors. Northern States Poser Company has engaged the Dechte.
Corporatkon to construct the circulating water system.
4.
State and describe in detail all the materials and equipment re-ferred to in paragraph 11 of the Coinplaint, ANWEil Major plant equipncnt includes a nuclear stcom supply' system, n
turbine generator, a containment system, tugether with a vast amoun t of associt equipment such as purps, valves, piping, etc.
Eccause cf the turnkey nature of.
the contract. Northern States Power Company does not have a list of all of the materiale and equipment utilized in the construction of the plant, except that description of the systems to be included in the plant is included in the final Safety Analysis keport, This document consists of reven Icoscleaf volunes whic.
precently are about twenty inches thick and which is in the possession ef the defendants, and is hereby incorporated by reference, Major components of the turbine were manufactured in Schenectady, New York. The nuclear fuel elenentr are being manufactured in Wileington, Nerth Carolina, Nuclear inst rumentation was manuf actured in San Jose, California. The segments of the reactor vescel were manuf actured in Dirminghan, Alabama. Other materials and equipment undoubtedly were manufactured in other states, 5.
State the name and address of cach manufacturer, distributor end sales office from ehich the material cnd equipment, referred to in paragraph II of the Complaint, were ordered and received.
ANSWER -The t'urbine, the nuclear fuel clonent and the nuclear instre-mentation were ordered from Concral Electric Company, 175 Curtner Avenue, San Jose, Cal'ifornia 95125. The supplict of the reactor vessel is Chicago Brid;c
& Iron Company ordered f rom 901 W. 22nd h sunt, Oak Drook, Illinois 00521. Ti place of manufacture is os stated in the answer to Question #4, from which place the material and equipment is received..
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- Power Company does not have the names and addressen of the many sub-tier supplicts involve d in f urnishing -the plant equipe.ent and material, most of whlch has been furnished in interstate commerce.
6.
State the present total generating capacity of all existing generating plants owned by plaintif f or one of its subsidicries, naming each plant, its location and its particular capacity.
ANSWER The antwcr is contained in the at tached five-page summary, marked Exhibit A and identified as " Northern States Power Co::pany (:linn 4 Subs) Tabu-lation of 1:lectric Cencrating Plant Capabilities". The summary is used for Upper Mississippi Valley Power Pool activitics. Shown on this tabulation is cach plent (future and existing), its location, and four associated capabilities.
Since each generating unit must have associated auxiliary equiprent such as fans, pumps, and conveyors to keep it in operation, it has an effective et net rating which is determined by subtracting the demand of its.aur.iliary equipment f rom its gross rating. Also, the capab;11ty of each genetating unit varies seasonally because the couling unter temperature, quantity of cooling water available, and air temperature affect the operation of plant equipment. Eecause Northern States Power Company experiences its highest demands during the senmer and winter months, the plant capabili ties are mos t inportant du;ing these two se asons, 9
,Therciore, f out ratings: vinter gross, vinter net, summer gross, and sumnat net are shown on the tabulation. The tabulation also summarizes the plant capabiJities according to cach state in Northern States Power Corpany's service area, 7.
State the portion of the total given in answer to interregatory 6 which is transmitted, distributed, or scId to each of states referred to in paragraph II cf the Complaint.
ANSWER The riaximum 1969 system peak demand of Northern States Power Company 's customers betueen January 1 and October 20, 1969 was experienced at 1:30 PM on Kugust 29.
Since Morthern States Power Company has been experiencing its annual peak demands during the summer ninths, the Aucunt 29 peck in einorred be the minum der.und for the year. The 1969 tiaxir..am denand can be at t ributed to custoracts in racii of the four states of the company 's service area as foJJova
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_ Maximum Demand in no Maximum Domand Minnesota 2319.6
. Wisconsin 80.8
,339.5 South Dakota 11.8 93.7
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- v 2B72.5 100,0 The enert;y requirement for Northern States Power Ccipany customers in each state for 1965 was as follows:
Thousands of State filowett-hourn
_% of Tota 1 Minn3sota 10,504,216 Wiscene n 78.3 I'
1,922,520 14,4 South Dakota 380,532 North Dakota 2.8 005.l.64 4.5 13,412,752 100.0 I
8.
State the present dinte consumption by each of the existing generating plants owned by plaintifftotal elec or one of its subsidiaries.
AMSLTR The total electric power generated at 1orthern States Power Company's g,ene rating plants varies f rom ins tant to instant. The total amount of generatirig capability installed is based on the system annual maximum demand
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i which occurs on Northetn States Power Company's system during the sum:ner months The at tached tablation (Exhibit B) shows the electric power being generat ed at each of !;orthern States Tower Company's generating plants at the time of the 1969 maxinum system demand, on August 29,1969 at 1:30 Pt!.
9.
Interrogatory 6 and theState whether the difference between the total given in answer to total given for a particular purpose er purposes,in answer to interrogatory 8 is commit ted and if. it is so committed, describe in detail said purpose or purposes.
ANSWER The tubulation answering question ~18 (Exhibit B) shows that additional power totaling 512,000 tw was purchased to serve I:orthern States Fower Company 's customer requirc:nents.
Thus, the difference was a negative
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At the time of the system maximum demand over 100,000 kw of Cencrating capability was out of service due to equipment shut-down. The remainder of the, total capability was held in reserve to protect against f urther equipment shut-down and forced plant shut-downs.
10.
State the names and addresses of all electric utilities to which plaintiff has sold, transmitted or distributed electrical pcwcr since 1950, State the total amount of power in necewatts or kilowatts s.
sold to cach of said utilities since 1950 b.
State the total amount of power actually t ransmit ted or dis-tributed to each 9f said utilities since 1950.
12.
State the names and addresses of all electric utilitics from which
. plair.tif f has purchased or received electrical power since 1950.
l State the total amount purchased from each said utilities for a.
,,__ -- each of the years since 1950.
b.
State the total amount actually t ransmit ted or dis tribut ed to plaintif f f rom each of said utilities for each of the years since 1950.
ANSVT.R The Upper Mississippi Valley Power Pool A reement and other agree-E ments provide for many different types of power (demand) transactions between i
Northern States Fower Co=pany and other Midwest elect ric utilities. The purchases
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and sales of-electric pcwer have been categorized to satisfy certain needs 9
inherent to electric utility operations. The categories are based on the r
availchility (reliability) of the power desired by the purchaser er seller, the length of time the power is to be made available, and the associated cost of making the power available. The categories include firm power, participation power, general purpose power, short-term power, peaking power, replacement power, reserved power,- and banked power and arc defined in the various agrecrants, f
a.
A separate contract is written f or each transaction with another utility I
based on agreements which contain provisions for entering into power exchange f
transactions. The other utilitics involved include more than 30 municipal systems (which are included as.an inherent part of Northern States Power
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valley Power Pool, excluding Northern States Power Company '(Wi.sconsin). and.
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the Iowa Power Pool, members of the Eastern Visconsin Utilitics, the Union Electric Company, and the United States Dureau of Reclamation. ' The transactions with utilities outside the Upper Mississippi Valley Power Pool'are possible mainly because of coordination agreements associated with programs to jointly construct interconnecting transmission lines.
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~,7 Since the time period covered in a transaction usually varies from one week to one year and since several agreemer.:s are sometimes executed with a single utility in one year,- over 1,000 agreements have been written to cover power transactions since 1950. There is no single document or small number of documents
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vhich suntarize all of the transactions. Theref ore, a complete summa ry would require a review of more than 1,000 agreements. However, summaries of major transactions with other utilitics outside NSP's service area and with other Ppper Mississippi Valley Power Pool members are availabic for the period of the annual maxirum d wand since the early 1960's when such Pool transactions were initiated. These transactions are shown on Attachment 13-A. -(Exhibit C-1) b.
The power actually transmit ted frem one utility te another varies from instant to instant. The power (demand) transactions explained in Part a.
above specify the maximum pcwer that may be scheduled for delivery cr receipt.
Tne amount of electric energy transmitted is a function of the length of time a given amount of power is transmit ted from one utility to another. Electrical energy transactions between Northern States Power Ccapany cnd other utilities are available in monthly or annual summaries. Annual summaries of purchases and sales of energy are available f rem Company records and at: reported to the Federal Power Co=tssion in Form No.1 and Form No.12.
Many of the energy transactions occur under the coderponding agreements for electric power (demand) transactions explained in Part a above. However, the Upper Mississippi Valley Power Pool Agreement and others provide for special purpose energy transactions without separate written agreements for each trant. action. Examples include econo y em e,s. -.~14 w.gu er.: r gy, emes p uty energy, operational control energy, dump energy and maintenance energy. A definition of cach category Ah included in
' the Upper !!1ssissippi Valley Power Pool Agreement and others. Tbc attached copics *
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of Company records (Exhibits C-2 through C-32) summarize annual caerty trans-actions with other utilitics for the years 1900-68. Because the North Dakota
- records (Minot and Targo-Grand Fe:ks Divisient.) are kept separately f rom records for the remainder of the system-(Interconnected System), several pa. ? are required to summarize one year. The addressen of utilities not included in the
- answer to Questior #13, outside of ;he Company's scivice arca, a re:
Central Power-Elcetric Co-op, Inc.
liighway 2 4 52 Eypess West Minot, 1: orth Dakota SS702 Iowa Electric Light & Power Company Security Build 1ng, Cox 351 Cedar P.apids, Iowa 52406 Iowa-1111noh Gas & Electric.'ompany 206 East Second Street Davenport, Iowa 52505 Towa Publi c Se rvice Corapany P. O. Eox 778 Sioux City, Iowa 51102 Icwa Southern Utilities Corpany 300 Sheridan Avenue Centerville. Iowa 52544 Nodak Roral Electric Cocperative, I r.c.
1405 First Avenue North Crand rarks, North Dakota 58201 Union Elect ric Coppaay P. O. Box 149 St. Louis, M.issouri 63166 United States Lureau of Roela. cation Departrent of the Interior P. O. Box 2553 Billings, Montana 59103
- Western Power and Gas Compar.y 114 South 12th Street Lincoln, Nebraska Wisconsin Elcetric Pover Company 231 West ;;ichigan Street Milwaukee, Wiscensin 53201 Wisconsin Public Service Ccrporation 102f ? erth Ma rshall St rec-4.i r auks e. wiscunu n auul Formerly Central Elect ric and Can Comp:my
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11.' State the names and addresses of any and all:cicctric utilitiesL-to vuich plaintif f is presently commit ted to sell, transmit or distrit,ute powcr
.in the future.
- s. - State the total amount of power comitted to each of said utilities through 1980.
TNS L'ER Because !!orthern States Power Company experiences its annual waximum.detaand during the summer months, sales for the summer period are the only sales of significance for generation planning. 6!c anticipate that the Company will have an increasing amount of excess capability during the winter 1
months.
This capability will be sold to the extent that other Midwest power sys tems desire additional winter capability.
The Company is conr.itted to the fc11owing sales d2 ring the summer periods: _.
Utility Purchasing Megawatts Year From Comoany Purchased 1970 MinnLota Power Co-op 19 Iown-Illinois Gas and Electric Co.
46 1971 Northwestern Public Service Co.
33 1972 Minnesota Power and Light Co.
56 The sales tabulated above are all banked transactions, i..e., power which is being returned to repay an earlier receipt of power, or power which the receiving.
i utility will return at a future date. A total sale of 65 ru is indicated for the 1970 summer period, which in turn is being purchased from other, utilities.
The attached summary of l'pper tiississippi Valley Power Pool transactions (Exhibit D)..
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- shows that the Conpany nust also purchase 76 nw to-cover its own supplemental regufrement.
The addresses of Minnketa Power Co-op, Northwes tern Public Service Co.,_ and
_ Minnesota Power and Light Co. are given in the ansver to question f13.
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address of the remaining utility is:
Auwa-illinois vos one u cctric Company 206 East Second Street Davenpott, Ioua 52805
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13.
State the names and addresses of each member and/nr parcicipant utility in the Upper Hississippi Valley Power Pool,
- s. -State the present total capa:ity of each of the said members and/or participants, b.
State the present total actually being generated for immediate consumption by each of said members and/or partio4 pants.
c.
State the total generating capacity held in reserve by cath of said ecebers and/or participants, d.
State the reserve requ! red by each of the nembers and/or parti-c1 pants t>y said Pouer Pool and describe in detail the necessity of said requirements, Describe in detail the purpose of the Power Pool, its authority e.
over individual me-Lets and/or participants, and the nature of the relationship between the various ncmbers and/or partici-pants.
_A.NS LT R The parties to the Upper Mississippi Valley Power Tool Agreement dated Tetruary 10, 1961, as supplcner.ted, consist of the following 14 elect ric power suppliers :.
Cooperative Power Association 6700 Prance Avenue South Minneapolis, Minnesota 55435 Dairyland Peocr Co: perative 2615 East Avenue South Lacrosse, Wiscensin 54602 Interstate Power Company 1000 Main S tree t Dubuque, leva 52001 Lake Superior District Fever Ccepany 101 West Second Street Ashland, Wisconsin 54S06 Minnesota Power & Light Company 30 West Superier Street Duluth, !!ienesota 55E02 Minnkota Pcwer Cooperative, Inc.
P. O. Eox 1315, State Mill Road Grand Forks, North Dakota 5E201 Montana Dakota Utilities Corpany 400 North Fourth St reet Bismarck, Ucrth Dakota 58501
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_.;. m P. O. Box 160 Crand Rcpids, linnesota 55744 Worthern Statcs Pouer Corrany (Minnesota) 414 Nicollet Hall Hinacapolh, Minne.,cta 55401
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Northwestern $ccurity National-Bank Building liuron, South Dakota 57350 s
Otter Toil Power Company 215 South Cas cade S treet -
Fergus Falls, Minnesota 56537.
Rural Coo;>crative. Power Association Elk River, Minnesota 55330 United Power Assc ciation Elk River, Minnesota 55330
.The determination.of capability is based on the two seasons of a.
the year in which the utilities experience maximum system demands:
Summer period:
May 1 through October 31 Winter period:
November 1 through April 30 (The maximum demand for a particular utility may be either during a sucmer period or a winter period.)
The total generating capability of each member associated with the 1969 sue.er period is as sheen in the attached tabulation (Exhibit E).
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The amount actually generated varies from instant to instant.
However, Exhibit E shows the purchase or sale of capability that each member has arranged to date to meet 1969 naximum estimated sunmer demands. Such figures are subject to an "after-the-fact" verification of actual maximum. system demand, c.&d.
Exhibit E Jndicates the relationship of the capability of a party-to the Pcol Agreement to its system demands including itsreserve capacity obli--
gations. - The -answer to Question 13, Part b as to an "af ter-the-f act" verificatior, is also applicabic to this answer. The reserve obligations are based on 'a capa-bility margin equal to 11% of its seasonal maximum demand. This margin was accepted by the parties to the Pool Ac.canant tha1Eeia nf a nrn M 414 M a -h-
an of generation plants of such parties and the acceptable level of risk that th'cre may not be collectively sufficient generation to meet the total maximum syst'em
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denuinds of the parties to the Pool Agreement,
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The general purpose of the Upper. Mississippi Valley Power Pool Agreement is to facilitate the interchange of power and energy between the inter-connected generation and tiansmission systets of the parties to said Agreement.
The detailed purposes and the contractual relationships between the parties thereto are as provided in the Upper Mississippi Valley Power Pool Agreement dated Februa ry 10, 1961, the 12 supplcmental agreccents thereto, the agree 7 ants between the several parties providing fcr the interconnection of their respective systers and the agr verco ts for specific exchanges of power and energy pursuant to the i
Upper Missicsippi Valley powcr Pool Agrcement.
14.
State plaintif f's generating capacity for each year since 1950, indicating each of the then existing plants and its generating capacity.
ANSWER The attached tabulations (Exhibits T-1 through F-23) show Northern j
States Power Corpany generating plant capabilitics for the 19-year period 1950-1955.
For the years 1950-1960 the grens capabilitics (defined ir. the answer to Questien
- 6) are shown.
For the years 1961-1968 the net capabilities (also defined in the answer to Question 6) are shewm. All capabilities are f ar the winter months.
15.
State the electrical pouer generated, bv nonths, for ir.aadiate l
consumption ty each of the then existing plants fer each year since 1950, ANSUER Attached are annual summaries (Exhibits G-1 through c-35) showing the total electric energy generated for the years 1960-68 at cach electric 1
I generating plant and the maximum demand on each plant. Note that maxieum demands on the plants occur at different times. Because the North Dakota records (Minot and Fargo-Grand Forks Divisions) are kept separately f rom records for the remainJer of the systen (Intercennected System) several pages are required to sunmarize one ye.a r.
A'.
State tf.e total projected electrical demand by months for each yea r f rom f aauary, 19 70 to January, 19S0.
,ANSUER The attached tabulation (Exhibit U) shows prqjected monthly maximum demands on Northern States pow Cczpany 's sys t en for the period March, 1909 sur vugi. uc cccbe r, PJsa.
included in the tchulation are the historic edxinum eenthly denande experienced for the period January, 1957 through September, 1969. - -
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4 17.
State and describe in detail the extent to which Honticello will produce electric power for t ransmission, dist ribution and sale to the public and interstate commerce.
ANSWER The plaintif f owns and operates an interconnected system of high voltage transmission lines in Minnesota, Wisconsin, North Dakota and South Dakota which functions to transport electric power produced in various generating stations er received through fr.terconnectic.r.s with other power suppliers. The j
plaintiff's system is part of an interstate extra high voltage (CHV) transmisrion system located in several midwestern states which in turn is interconnected with similar systems to the ecst.
This system for the midwest area as contemplated for 1970 is illustrated by Exhibit I, attached hereto and made a part hereof. This system, commonly ref erred to as a grid system, will provide fcr the interstate purchase and : ale of elect ric power between major power systers. These systems assist cach other in times of emergency by delivering large blocks of power over this grid.
By bcIng able to rely on the grid system, a company can better cope with unusual weather conditionc or loss cf ger.erating equipment and thus greatly reduce the likelihood of experiencing power blackouts The Monticello plant, as well as other generating plants, will contribute electric pever to this inter-state system. It is inpossible to 3dentify the electric energy being consue.ed at a particular Iccation in terms of the particular generctor which produced it.
Therefore, it is impossibic to state either in quantitative or relative terms the extent to which the Monticello genera:cr. as distinguished f rom other generators, will produce electric power for transmission, distribution or sale in interstate ccrnerce It can be said that the Monticello plant is one part of-an integrated and interconnected systen which contributes to the production of electricity scid in interstate connerce.
18.
State and describe in detail any and all information utilized by plaintif f in calculating the anticipated electrical demand for the bummer of l
1970 and succeeding years.
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Power Company in forecacting tbc annual maxieum syntem demand for 1970 and beyond in concral is that used by most electric utilitics, described as follous:
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The historie demands are first analyzed for abnormal conditions that are not l
representative fur the future.. On the basis of past heather, expected vcather conditions at the time of she maximum demand have been calculated, 'The conditions i
are related to humidity and temperature and are conbined into a Terperature-Humidity Index -(TdI). Historic demands are c;rrected to correspond to the normal veather conditions. Atiy unusual customer demands are also corrected in the j'
historical data. The unusual denands could be caused by su.5 unusual events as a strike or vacation at a large industrial customer's plant or unusual defense activitics. Also, if the maximum demand occuts on other than a lionday, the i
historical data is corrected to correspend with a demand that would have occurred i
on this more likely weekday. The five-year corrected (normalized) historical
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demands are then extrapolated into the future using the analytic technique l
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of curve fitting. The curve-fitting technique used to fit the historical data by Northern States Pouer Company and many other utilities is called the method of least squares and is a common analytical tool. The resulting curve can be defined by a constant grow th rat e, i. e., the growth in demand of one year over
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the next is a constant percentage of the preceding year. Our experiente confirms t
l the validity of this apprcach.
Modificatiens are then made to the prcjected (extrapolated) maximum der 2nds to account for other expected changes. The unusually high gewth rate of the sumner maximun demand can be attributed in part to the expanded use of air conditioning.
It is likely that the pace of the high grovth rate will decrease as more and more homes become air conditioned. The long-range future projection of Forthern States Poker Cocpany's maximum denands has been modified (decreascd) to recognize this air conditioning saturatien effect l
It is isportant to nate that the summer maximum demands on Northern States Powe r Compay'ssystemarebecomincmoreandmoresensitivetoveaHyerchannes cie 4 fcrccasts are based on expected normal conditicos, abnornally hot weather can
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increase the dcmand significantly. An abnormal hot spell in 1970 could increase -
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'the maximum demand morcithan 200 megawatts over the forecast. Also, depending-
- upon the-extent of the South Vietnam conflict,-defense production in Northern?
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- States Power Company's service area is likely to continue' beyond 1909. tThe '-
- existing forecast for-1970 made noEallowance for this continued _ activity. ' The a (,-7
-present' level of defense activity'could increase the'1970 maximum deman'd by.an additional 75 mw.
19.- Stato and describe in detail the nature, extent and consequences of-the possible impairment of the electrical service if Monticello-is not in operation by June, 1970, c)
ANSWER buring the summer of 1970, the Upper Mississippi Valley Power Pool is forecasted to have 258 mw of excess capability.if the Monticello s
unit -and a 50 mi nuclear unit at Genos, Wisconsin are.both in service. Thus, if the Monticello unit is not in service for the summer of'1970, the power poci
,will be deprived of 460 nw capability initially expected' f rom Monticello resultingt
- in a shift from 258 mw excess capability to 202 mw deficient capability. The F
NSP load is forecasted upon median weather -conditions. -but if unusually hot weather occurs during the summer of 1970, t e NSF load cJuld increase by 200 ma above the present forecast, If the present Icvel activity of defense production.
continues, an additional 75 na of load must be added to the NSP forecast. -Tho power pool shortage with abnormally hot weather and with continued defense
_ production activity would then be about 500 pe, a
For the summer season of 1970, RSP has previously arranged for a purchase of r
76 ma to satisfy its capability obligation. The ability of NSP.-to purchase q.
additional power f rom other pool members' to replace the Nonticello genera [ing capability and to cover increased demands is limited to the excess generating
. capacity of these pool members. The ability of NSP. to purchase additional' power from utilities outside the pool during the _ summer. of 1970 is limited-by the anticipated failure of other generating units in the midwest 1-to
-P t Af ?
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,r arrangements with otherf sources of powcr including the United States Bureau' of
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Reclamation and the Manitoba Hydro-electric Board which are primarily hydro-electric systems. Any arrangements with those systems for daytime capability probably will require some type of firming arrangement involving replenishing the other systems' reservoirs which may be cxtremely difficult to accomplish.
]
The consequences of inability of NSP to purchase sufficient power to replace
- Monticello include increased probabilities of curtailment of load to sone customers A study of the critical June 1 through August 31, 1970 period indicates that the
~
chance that MSP would be required to curtail load _ to some customers is approxi-mately 14 times greater if the Monticello unit is not available than it would be with the unit available. A high risk of load curtailnent resulting from the unavailability of the Monticello unit in 1970 ceans an increased probability that a remote occurrence could cause a major f ailure of the power system to maintain operation. While such a black-out condition is expected to occur only as a result of the occurrence of_ highly recote events, a " brown out" is more likely. The term " brown out" teans a power system f ailure to maintain operation or interruption to a lesser degree and extent 'than " black-out" If power were available to be purchased by NSP during the sumcer of 1970, the projected costs of one month's delay include increased fuel costs (including t
' maintenance penalties) of $1,181,000, increased energy purchase costs of $10,000, and increased operation and c.aintenanco costs of $60,000 for a subtotal of
$1,251,000 plus interest on nuclear fuel fer Monticello of $54,000 for _ a total increased cost of $1,305,000 for one *anth's delay at Monticello. Thus, the
~
costs of delay would be $42,000 per day for the first month.
Further delays beyond one month would not cause additional maintenance penaltics becausa revamping the scheduled maintenance for 1970 oculd require a revised schedule whether Monticallo is delayed one month or more than one month.
liowever, increased costs for the energy generated at otl er plants or purchased would continue at $450,000 per. month.
In nddition,. demand charges for purchases from other ' sources would be necessary at an estimated cost of $542,000 for the second month's d-: mand char es and $1,006,000 for the sum of the scennd g
1 34 +*
I 1
li
5 I
ind thitd konths' den.ond charge 6.
The demand chartes would continue at a high level through the autmer period and would decrease by about one-third during the winter period.
20.
State the annual percentato rate of increaste f or t he $ utume r peah dennand since 1950 and the anticipat c d pu ccntare rate of incrcase 1er peak demands t hroeg,h 1900.
ANnT F, fee Fxhil.it J and F attached hereto.
21.
Ltute whcther the t a rin " plaint if f 's." t r uted in ; aragt e;.h 11 of the Cor ;,laint includa at y elt t t ric ut ilit it t.
gaf Ur, the ramc r peat derand of plaintif f'c corteter s, including lo c a l rua n i c i p a l r y t. t e ra s; s:.mrt ir es Lnwr a t. utilities, i t.
Incit tsing at a ttite of over eight per(cot annually.
22.
If t he sin c ve r rive n to int e r rogetcr y 21 is in t he af firmat ive,
- tatt the nsres and addleta-s of saic utilitiet and the amount of electrical power j uvolve d f c t each yeer $1nte 195 0 t r> cath of said utilities.
, M@iQ No anwer r.ee ded.
23.
State and descrite plaintiff'6 past trcject3ont c f rewt a-tu n d s and the extent t o whic h they ore ;reven t o be acc urste.
ANu?Tr The attached tal,ulatjon (1. t h il l t L) r.Lews, itrtcastr, of Urrthern T,tates l w et 0:4 p an y ' r. r y r t t tn ma x 1tua d c a n i r t: e y e a r l e f o r e, thrct yearc 1.cfrre, and f he ye as t lefore the dato (f actual ecturrence. There ferecast6 Shes that for the t ru, t f r w years rna3rr revitaienc hrve ht en r,ade upunt o in the f o r e t e s. t r, a s a res ult cf the t aridly inc r ea ;irt r urme r e manJs The actual historic rea4 Dium t' mand i s rAown olenr. with t i e wea the r-cc r rr M ed I in d.
The weat'ie r-cor rec t e d demand in t he ac t ual drnsr.d rc rre t t e d f c r at r -
.al conditions va der,c ribed i n t he ont we r t c Ques t ion 18.
24, State In detail all factr. underlying the all y,ation that AIC r eg ula t t ent; t ecardinh Ji t c hat t e:; et radievotive cfflucnts limit s e, aid uit t Lar6FF to a level which will not endanger the public health and saf e ty ar, allep d in par 6 graph 111 cf the Ccmplaint.
AMTR Title 10, Part 20, c f the Code of lideral i:etulat h ns centain standntds f er I rrtectien against radiatice. Sec t ient. 20.105 and 20. lN in par ti-
,, $ n t "a n e c tn ei-
+
L'.
BTdo a n y a r L /1 dot fotellDiled by the 11( CDSee f or purpC 5f't. Of p!Otection O[
~ 10 -
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a 1
i individuals from esposure to radiation and radioactive materials, and therefora
%ntestricted atecs" are all areas occupied by :he general public, as distinguished i
from persons employed in or who regularly enter the plaut area itself. The ultimate r
listitation inposed by such reguistions is that the proposed litnits of radioactive relcens shall not cause any individual to receive a dose to the whole body in any t
calendar year in excess of 0.5 rein. A rem, as defined by Section 20.4(c), is a peasure of the dose of any lonising radjation to Lcdy tissue in terru of its estimat ed t iological ef f ect.
Part 20 in its entirety dernonstrates that the AEC has, as alleged in 1, agraph III of the conlaint, exercised its statutory duty by limiting radios.ctive discharge to a level which it has deterstined will net endanger the public health and safety.
In addition, defendants said in paragsaph 15 of the Special Conditions Relcting to Radioactive Vastes of the pctmit dated May 20, 1969, issued to the plaintiff:
"The generally accepted 1.C.R.P. { International Comission on Radiological Frotection) litnits are designed to restrict indiation exposure, on a enntinuous basis and over a lifetirre, to levels that will not produce detectable or significant sortatic or Eer.c tic harm." /IC regulations, as applied to Lascous nstes, are identical to 1.C.K.P. limits (i.e., 0.5 rern per year) and as applie:' to liquid wastes are enore stringent than I.C.R.p. lin.i t s.
25.
State and describe in detail what alteratiens in the design of Monticello would be mede necessary by plaintif f's compliance with the P.C. A.
termit negarding radioactive discharges.
ANSWR An atteg t to corgly with the PCA perrait regarding radioactive discharge vculd require thtee besic system additions to the Monticello flant.
The radioactive-gas waste system would have to be expanded to include recer.biner equipment, a charcoal adsorption system, together with associated auxiliary eqt.p-and'hontrola The addition would also involve building expcosion' and altera-cent tions. Secondly, the liquid radioactive vasta svet m would have to ha <* w m u to include a concentrator, an additional demineralizer, substantial additional tanhanc and handling equipment, toccther with assocInted building additicns and alterations.
Thirdly, a low Icvel radloanalyris Inboratory would be required and.
-m
g e
would include the developent of presently nonexistent precision equipment located in a new separate building to insure a low level of background radiation, plaintif f is unable to conceive of any changes in the dcsign which vc.old snake it possibio to demont,trate torpliance with paragraphs 4, 7,nd 10 of the re-mit relatieg to radioactive wastes.
26.
State in detail the inc reased c es t end tic.c invcived for each alleged item of niteratitr li s t e d in unr we r t e in t n t r ot a t o ry 2'..
AhWIP lt is irtpest.itle to antwe r t:41s qur t tien as it is written bec:4use the conterplat ed c%np c de s c ribed in tla atsver to question 25 have only been antaly n d on a conceptud lesis. This is. explained ly the fact that s y s t e mr. r u t h conctived cl in question 25 do not (Aist in their entir.ty in any pinnt in the en world, nese systen vould have to 1.e designed crocifically for thic plant cod un t t i t h e< d e s i gn i s corpleted, it is not certain that they will accot*plith their intended re sult nor can plaintiff 14 certain of their exact costs. 110 wever, based upnn estinat n of the cost of anticipated cc rp:ner:ts and research and development activitter, it tr. ;rrrentl lelieved that the plant additions descrih d in Quution 2$ will (est a total of $9,500,000.0D Thiv ir. divided occerdin(; to the following tubulation.
Cas Waste-Lystem Additions
$7,0D3,0lO Liquid htte Addi t t er s 2,0D0,003 Low l evel Labor tt ery LD(OH TOTAL
$9,50D,003 This cott estin. ate is for co; ital plant additier.s only and does not incluje addi-tional operating conts.
Uor doet it include Inner which vould result because of periods of time when the plant would be out of operction while at tempting to intehrate there syster.s into the plant. Such costs would be extrenely high and depend upon a nua.her of vorfables, s uc h as the duration, the season and thu ycnr that the, plant would be out of cperation, f r om the time of cuthorization it is estinatcJ that tvu y e a r t. will elcpse before t he above-rantioned plan t rojifica.
tionn,evare4 c a s n v. n--
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operational integration into the other plant systems. It is questionabic whether instrumentation suf ficient to den.onstrate coepliance with the permit conditions relating to individual radioisotope concentrations can be developed in the fore-sceabic future. For a two year period of lest rtoduction at Monticello, if power were available t o be pu. chased t y fiSP, increased demand charges way exceed
$9,000,000 and increased enercy costs may exceed $11,000,000, 27.
S t a t t-in detail all f acts underlying and necessitating the alle-ration thet (c+plianc e with the P.C. A. perrit retarding radioactive discharget would teruit in a substantial delay in the cornencer.ent cf the operation of Monticello.
A'GhT R Cce,e n c e me n t of operaticn at !!onticello is scheduled for the spring of 1970, and even if the plant nodificatiens describted in Questica 2$ were to be authoritto tcday, a delay of at least it months veuld be incurred in the coraencement of !!cn ticello ope ratic ns. In adiition to these time intervals, s eutttentiti tine interval must be allcred for licensing review and approval of these nodifications ly the United States Atenic Energy Ceratission. '!htse time estimat es at sune that the ef forts would be successful. If they were not sucecssful, then the plant woeld r.ot be able to cot-ence o;arations without violation of the permit conditions.
28 State ard describe fcr each of the itens listed in ansaer to interretatory 25, the c> tent to which the applicable portion of !!ontirello has already been cerpleted, l
ANShTR The curt (nt ;1c.nt gaseous and liquid waste systerr have been completely desitr.cd and all cf the cquiprocut involved is either installed or is under manufacture. Act ual cons t ruction and installation is about 50% complete for the t.as was t e r.yst em and about 60'. comple t e f or the liquid vast e rys tem.
The low ' level radioanalytic laberatory would be a complete new installation and therefore no wcrk has been undertaken for it.
29.
If in answer to interrogatory 46 these e;; applieah:In portions of Monticello less than fully (crplete, state and dtscribe in detail the rcasons i
why thc alteraticos thcroin involved cc uld not be acconplir bed at the ; resent I
time.
l im s
~
l_ p.e n; o ;..;i.
.,..ua cererreu to ar.the answer to s
Question 26 are tc.mpletely designed and all equirrent is crecified and tither i I
i 1
l y
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w aircady installed or in the advanced stages of nanunacture. A substantial redesign would be necessary in order to accerne.date the additional equirn.cnt rcquired to con, ply with tettain PCA pern.it conditions regarding r adiosttive discharges.
Building additione and alterations would be involvcd to accunodote the additional eq uip e,e n t and it is likely that the er.isting equiprent would have to be relocated to acco udate the installation of the noditional equipment required for conpliance with the pCA J e r r. i t.
30.
State and decerite in detail how c ce; 11 anc e wi th t he P. C. A. Pe t rai t regardirl radiva:tive dis char t'.s would ahersely c f f ec t f uel ccor.orties of the plent.
ANSI g If the plant is forced to shut devn to r(n.ov: leaking fuel between normal scheduled ref ueling outares pursuant to cor.dition 2(e) of the p e r tni t, the fuel that is t uoved would 1-ot have produced its (xpected energy quantity. NET scm1d then be incurring, on a per kv-br. t roduction cost basis t incavored ItLiitatien costs, increased eenversien cos t o, increaud new fuel ship;ir.t costs. Increated refrocetsir.g certs, increased interest costs and inc r< ned capit al cos ts for stare fuel.
31.
State and deteribe in det ail the quantitier, of f uel lost ac g e n e r a t ir, g capabilit ies duc to ccr;111ance with the P.C.A. perrtit reprding radicactivo dis charp s,
32.
Stnte cnd dcscribe in detail the auunt of elect rical pwer 1c st by tramn af the quantitler given in annwr to intertopton y 31.
ANSWF3 UTP cannot state srecific quantiticr. at this tit-e since it cannot predict the ficquency or duration of shutdams 12r renoval of leaking f uel as require d 1-y the pernit.
33.
State and describe in detail whether in nor mal operation c f plant there is any anticipated f uel lor.s ever ar.d above that aller.ed to result from compliance with the F.C.A. pttnit.
ANSUFR No.
34.
T, t a t e and der crit,e in detail all adane ef fcet e cn the reliabilit of Menticello'r. pv cr systen. whic h veuld c>ccer if plaint if f cceplied with t he F.C.A. p r n.i t regardf rig radioac tis e dis chntges, n g re i me m.o e
,u
.,t, the TCA Ptmit will have f.cVeral adverse effects en the reliability of the - - -..
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t f
}ionticello plant and therefore of the Northern States power Company electrical i
sy,s t em.
The availability of the Monticello plant would be considers.bly reduced, 1
r niainly occasioned by f eque nt and lengthy abutdavns to eicet the pCA litnits on 2
radioactive cas discharges. The gas v.n, discharges occasioned by very slight i
r i
f uel leaks vould be allowable under the /IC limits and the plant could continue l
to run a nd rupply power to the NSP power nyt, tem.
Operation under the PCA partrit a
will further reduce the rellt.bility ci the Monticello plant because of the f requent shutdowns, causinE extra therrnal stressing of plant equiptnent and increasing the potential for equiteent dan: age.
This added thermal stiess will require tnore down tipic for maintenance, equipment checks and calibrations, as well er shortening the useful life of the plant, a
35.
State the total additional dollar expenditure required to comply with the P.C.A. pettit regarding radioactive discharges.
a.
State how much of said additional expenditure is for excess construction costs..
P i
b.
State the items of construction which vill tequite additional costs, the cos t at t ribu',6bic t o each of said iter:.s, and why a
5 each cost in t.ecessit ated by the P.C. A. perm t.
c.
State how much of the total aJditional expenditure is for excess operating costs.
I d.
State the items of eperation which will requite additional costs, the cost attributable to each of said items and why
- r each cost is necessitated by the P C A po rtr i t.
i.
c.
State the additional cost per )!!owatt hour represented by the total alleged additional expenditures.
4 AN WFR a.
See answer to Question 26 with respect to capital
, expenditures and costs of shutdown time.
l b.
See a'nnver to Question 26 with respect to capital 1
expenditures and costs of shutdown time.
c.
The excess operating cc.sts are estirnated at ?1,250,000.00 per year, excluding carrying charges on the capital investmen*
M cve)n h cosen of do+4~~
cer *.;d
- n the answer to Question 26 f or production delays caused
)
by alterations and addftiens.
d.
The followint operating costs are estimated.
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Car. Vaste System Additions 100.000.00 Liquid ti.u t e Sys t ens Additic ns 1,000,000.00 Lw-Lev 1 Radicanalysis Lot oratcry 150,000.00 TOTAL
$ 1,250,000.00 t o c h c e r. t is necessitated by the TCA perrait for additlens1 r.anpruer, naintenarice, s.upp l i e s cnJ other c o s t r. incidr nt al t o opt:t at ion of the added equip ent listc d in the eau er to Nstic: 25 e
e.
The t c til r>; c ndit ut e f et c7m ec l et t r ;. t i r:1. u po n s e s e n d carryirt. chatic: ca the capital Irwe: t tm n t is t5.ti'ated at
$2,750,t00.03 Jer year.
It en ir;ct*At}e tu Flate the addi-tional ccst pe r L t ic-s t t-br ur w2 the at Itcairy tle tctal nu W t of hilt att-M r
e.cr rLith t h e r, < ettets costs ole to be t p r e z. d ; that is, Aether the : (Ltt twald be spiced evcr the plair. tiff's entitt ! car-bt&te 'ytttr, over the fthte cf Minnetcta, or c et t rcrt Jart of the State of MirneActa.
Morer.n t, the ; t c hetir n J cralties f c r t he rys te, es t i fta t e d in the m.er to Ques tion M at ( 20,0N,000 f er a tro ye ar hlay p(fitd. 4. r e c x c l o h ' f i. the !?,73D,003 esti n te for Mnnticelle pla t unl c pt ra t : r4 ( x;.c sts and cetrying chatget 36.
NE of thc offiricls of the !! cit o f "i t -'d !
't wh o h tW P publicly stated that strict ancitrce to the u dities:
li:. i t a t i c n r of the P.C.A.
4 i I.e t tn i t will be It.:,uirtd of N.'.F.
_A? M L: hh:
1.
tedalich, cv July if, 19f;, i n 4, rectier eith u veral r<ttt ur' utis s e ( f the ; htntiff, stated that if the rodic ac ti ve telcM et nt the Mu t ic tll plant ( tcceJed the 11 ru t a in the J e rsi t, the PCA vould chet d cun the plant.
In r en t al ( t her ra t t i m, hebt t ! 7 ta ( r.on h a r,ndr sohrtentially tlx seu otate nt, t ot l '. r t laintiff cm t i t eu nt ly ticall the nac t time et cin(un teu rt ( f such rti.tenents.
Ti e ant <ct filed ty t he dt f tnht t r, a:.hi t s t he allegatf( - that officials of the State of t'in a r vt a han 5.utlicly stated that strict edu t c ce to the ccnJiticr cf the ICA pmit vill l e t equi r e d of !:EP.
37 Icr each cf the off!ric1r im cJ 4 - tr
..'e r ri ve r t e i n t e n t or a t ery 36, give the date, plate and cctual lar.ru ge un d of s aid s t at er: ent s.
m s.e _- m m
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?
38.
twr c r i t e 3d e, plain in detail any addi tic nal raf et y haut ds centca-plate d i f il,,intiff tc slic=.cith the F.C.A.
pet ri t retarding radleact2ve di r4 L a r g e:
A,'i d[ R Cc ;,1 i a r :
eith al1 pCA petnit
- e. r t-iAI e
em 448 ic" C " ' ' ' ' ' ' '
radioattlae v,
tee s.ruld t<sult in s ig n i f i t r_n t addittnaal ra di ol e;.i c al t i pos ur e j
of plant J erso: el, in h andlirq c f great er trountr cf radicactive vaster, and in t
w t hw.im.
J v
t substantial overall dcgradation of the safety f actors in the plant equipitent.
An instance of additional radiological uposure of plant getsonnel would 1e the frequent star t-ups and shut-do 'ns to search f or einer 1 cats in f uel rc.de and the attendant detection procedures.
39.
Dncribe and explain in detail the riature and txtent of other subt.t ant ial advc ts e cc ntequences as allt ged in paratroph Vll of the Corplaint.
ACT R The plaintiff is a public utility cf the State of Minnu eta, as well as a litenu e of thr. At or.ic Ener t;y Co nis s ic and a supplier cf electric power for int rM t at e and int e rs t at e cre a ctce.
As t.uch, it does ne't desire to violate the regulations of any povern:cr.t al atency of the State of Minnesota, if thure trgulation: are valid.
Lut, as such, it airo has a duty to each of its cus tome rs t o supply ade:;uat e cicetric power to ttet t}cir needs In tht' absence of a prapt declaratc ry decree as to their validity cr invalidity, the riaintiff would le in the intolet+ble penition cf thcesirg whether to violate the PCA perstit end terve its tu t c ~.e r s o r at tempting t o c or ply with the PCA permit and not adequately rtrve its customers.
40.
State and describe in detail the interrclaticnship tetwun Manticello and plaintiff's existing ccrcrating plants.
MM E 0 The benefjts of nuc] car-f ueled elect ric cenerating plants tainly are the les ccst of pr oJucing elect ric cncrgy nnd the elimination of the corabus t ien by pt c.d uc t s es cociated with ccal t>urnitic planto. However, the 1cu operating cost cen cnly le ettaincd by raking a relatively lorge expenditure (capital investtent) in plant facilitits. The hrge capital investoent is nocus.ary t ecaur.e of the design and ccnst r uctica ef the nuclear steae supply, There f ore, t o be ec ononically feasible, a nuclemt generating plant should le operated contirunusly nr a high output level.
Such an operation vill r,inirige the con.bined total of c.pcrating and capital costs Cenerating capability associatcd with a high repital ccmt an.1 low fuel or operating cett is r eferred t o as "L.ase-loa d" c apab ili t y.
Ancther example of l'ase-load capability is a large, hi.h prenure stea-plant fucled with coal such cc the A 0 F.ing generating t
flant ncar Stilh;ater, M3nnegegg, ~
____7-.___
O O
i
.s 1
The nuclear plant operation can be contrasted with another type of generating plant operation referred to as " peak-shaving" or peaking operation. Peaking
)
capability can be installed at a lover capital cost, but the corresponding fuel test is relatively high. Examples of peaking capability include jet-engine powered plants (such as the !!SP Taribault riant), and diesel-cr.gine powered plants (such as the NSP Zudrota plant). To be economically feasible, peaking plants must operate unly for stort tire periods.
The lowest cot,t of producing electricity is achieved by combining peaking-type generating ccpability with base-load type generating capability in an c;stinal saanner called the optimal mix.
The optimal eix de;sonds on the nature of the customer's dcmand.
i.e., the nu.mber of hours per year the customer has high demands and the number of hours per year the cus toner has low demands. This varies sunong utilities. For Nc,rthern Stat es Tower Cempany's system the eptituum mix occurs when about 20% of the capability is of the reaking type and the remainder is of the t-ase-lead t); e plus older coal-fired s team plants.
The Monticello plant will be connected to the LHV grid system and will operate in synchronism with the existing operating plants. Future operation of the Monticello tent rating plant can be accurately predicted by simulation using models of the customers' demand end of gent-rating capability as it is expected te exist in the future. This simulated operation shews the following results with tespect to other tenerating plant capabilities.
Mrfavatts (Suge_r Ca g ility)
Nonticello as a Total System Monticello Percent of Total Year Carnbility Capability
{y gem C y ahi g ty
- 1970, J 357 4f,0 13.7 1971 3 405
$08 14.9 1972 3 935
$08 12.9 1973 3 %D m
IA 4 490
$33 11.9 The abovc table shows that the capability of the Monticello plant vill increase with timc. This in becau e the design alleres f or future increase in the output ~ ~ -. -. - - - -
A-4 of the nuclear steam supply. - Relative to capability, simulation studies show that the Monticello plant will he more prominent in producing electrical energy, as follows:
Hillions of Kilowatt-hours Monticello at a
's
Total System Monticello percent of Total lea [
Aequirements Output Output 1970 15 526 2 290*
14.8 1971 16 773 3 788 22.6 1972 18 302 3 794 20.7 1973 19 969 3 691 19.5 1974 21 BCB 3 983 18.3 The Monticello output for 1970 is lower than 1971 because the plant is scheduled to be in operation only for eight nonths during the first year.
41.
State and describe in detail the interrelationship between Monticello and the existing generating plants of the Upper Mississippi Valley power pool.
AN$VER. Interconnection agreements among participants in the Upper Mississippi Valley Power Tool allow for the exchange of capability and energy.
Exchanges of capability are usually made to meet some Lemediate need or' to
-coordinate major generating plant additions.
Energy transactions among Midwest utilitics, made in association with demand transactions, account for a major portion of energy exchange. Another signi-ficant exchange has as its purpose to minimize energy production costs of the entire. pool.
Economy energy transactione rinimtre production costs by allosing a member with high-cost generation to reduce that generation and buy from a member with~ a lower proiuetion cost. The resulting savings ere then split equally between the two participants. During of f-peak hours, the Monticello plant vill displace energy production on higher cost units, thereby reducing the icvel'at which economy energy transactions are made.
As a result the entire pool production costa will be reduced.
42.
State and describe all reasens why plaint e f f ca-nnt enerata 'a*b ends. die i+'.n. ; ;. :. 5 requa a.mmutw regaruing radioactive discharges as well as within the standards promulgated by the AEC, ANSUPR It is impossible to comply fully vitti all requirements of the l'CA permit requirements regarding radioactive vaste dischargos, although plaintif f '
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could operate well within the standards promulgated by the AIC. A specific illustration of positive interference by a pCA pe; wit condition with AEC require-ments relates to plaintiff's emergency plon submitted for AEC review and approval which provides for inmediate notification in the event of accident to a number of agencies and of ficers including state agencies. The qualifications of the plant personnel who vill, in emeri.cney situations, administer the plan, are described in detail in the plan. These personnel do not include state officials as having authority to enter the f acility to direct eperations in the event of an emergency, while the Final }-eport on Radioactive Tollution Control in Minnesota, as incorpora-ted in paratroth 13 of the Special Conditions F. elating to Radioactive b'astes of the TCA t ermit, does contemplate such state direction of operations.
43, state and describe how much fuel leakage is anticipated under present desip and how much is anticipated if the P.C. A. permit requirements are met.
ANSWEE The amount of fuel leakage at the Monticello Plant has no relationship to whether the TCA permit requirements are r.et.
The secunt of fuel leakage vill be a given amount, depending upon a variety of dif ferent factors, such as the quality of naterial and vorhaanship involved in the manuf acture of the fuel assemblics, The FCA permit can have no effect upon such factors.
44 If the antuer riven to interroCatory 43 is greater under the F.C. A.
pe rmi t, state in detail any and all reasons f or the anticipated increase.
ANSVER See antver to Question 43.
45.
State at what percent of AEC discharge If mits plaintif f intends to operate both as to gaseous as well as liquid radioactive vastes, State whether the intention exprensed in answer to interrog-a.
atory 45 vill be exceeded at any time'and if so for what periods of time and at what levcis will there be such discharges.
ANSWER Horthern States Power Company intends to control operation of the Monticallo plant so that radioactive liquid and gas releases will be held to the lowest Icvel that is attainabic vj'hin the liititations imposed by techno-Ihricel feasibilftv, erennute t e r-a e -b 1 -m e +
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and well within the limits crpccted to be set by the AEC for the protection of public health and safety. It is impossible to answer this question in any other
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4 way, since the plaintiff does not have an intention which is reinted to any given percentate of AEC limits, e) The foregoing intent will not change f rom time to time.
Dated this 20th day of October, 1909.
Arthur V. Di r e.ha r t Assistant Vice President Northern States Tower Cottpany 414 Nicollet Hall Hinneapolis, Minnesota 55401 Subscribed cnd tworn to before ne this day of Oc t.tter,1969, botary l'ublic e I i
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