ML20210S615

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Requests Testimony of Staff at Radiological Safety Hearing in Late Oct 1975.Testimony Required Re App I Compliance & Radwaste Sys Evaluation.T Cox & E Ketchen Should Meet W/ Staff Members by 750918 to Plan Testimony
ML20210S615
Person / Time
Site: Washington Public Power Supply System
Issue date: 08/18/1975
From: Schwencer A
Office of Nuclear Reactor Regulation
To: Heineman R
Office of Nuclear Reactor Regulation
References
CON-WNP-1421 NUDOCS 8605290319
Download: ML20210S615 (4)


Text

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LWR 2-3 Rdg HDenton Docket Nos.: 50-460 e'F D eket Files

) JKastner and 50-513 TCox EKetchen VAMoore JCollins RTedesco PStoddart R. Hetnaman, Director, Division of Technical Revient. NRR Thru V. A. Moore, Assistant Director for Light Water Reactors Croup 2, DRL WNP-1,4 RADIOLOGICAL SAFETY HEARING Testimony by one or more of your steff is requested at the WNP-1,4 radiological safety hearing expected to be scheduled in late October 1975. This memo describes the current anticipated areas of AgLB inquity to provide the maxistsa possible lead time for preparation of appropriate staff testimony. Information related to the detailed hearing schedule and other areas of ASLB inquiry will be forwarded to you as it is developed.

As currently anticipated, hearing testimny will be required concerning:

1.

Appendix I compliance. Staff preparation for this subject is currently scheduled for completion on 10/27/75.

2.

Radioactive Weste System evaluation.

Dr. Marvin Mann stated at the 5/15/ 75 environmental hearing (Transcript, pp. 489-491, copy attached) that he would explore, both generically and with respect to WNP-1,4, the difference between staf f and applicant assusptions and calculations.

The LPH, Tom Cox, and the OELD attorney, Ed Ketchen, should meet with your designated staff member (s) by 9/18/75 to plan the scope and conduct of the testimony. Please have the designated staff member (s) contact Tom Cox, x788f. by 9/15/75.

Mm a!signedt$

F. Fe rus:n A. Schweneer, Chief Light Water Raseters Branch 2-3 Division of Reactor Licensing Attachment Pp. 489-491 of ASLB Hearing Transcript from 5/15/75 in Richland, Washington 8605290319 75001G PDR ADOCK 05000460 A

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DISTRIBUTION:

LWR 2-3 Rdg Docket Nos.: 50-460 Docket Files (2 9 and 50-513 A._

2 7d75 TCox B. Grimes, Chief. Accident Analysis Breach, DTR hru:

A. Schwencer, Chief, Light Water Reactors Branch 2-3. DRL EVALUATION REPORT ON WPPSS/ERDA AGREDENT The ERDA/WPPSS agreement on the WNP-1,4 docket is one of only two outstanding issues (other than Appendix 1 final evaluation) as described in the 8/12/75 note to J. Galla from A. Giambusso (copy attached). Your review and report on the acceptability of this document to assure Applicant authority under 10 C7R 100.3(a) is needed in order to assure that it does not become the critical path work ef fort on the way to a scheduled CP decision or. this docket.

The formal ERDA/WPPSS agreement was docketed and distributed to your branch on 7/18/75. A copy of a 7/24 memo on th$3 subject is also attached.

A draft agreement was given to Len Soffer on 6/13/75. Your response is requested as soon as possible, but not later than 8/18/75.

T. Cox, Project Manager Light Water Reactors Branch 2-3 Division of Reactor Licensing Attachments:

1.

Memo to J. Gallo from A. Giambusso dated 8/12/75 2.

Memo to B. Grimes from T. Cox dated 7/24/75 g/;,n ces V. Moore E. Ketchen

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DISTRIBUTIO*t.

Docket F. es (2)

LWR 2-

.dg Docket !!cs.: 50-460 y',. p 4 n 3 T%

and 50-513

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D. Criaan, Chief, Accident Aus1Vals Ercach,IER

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R.11. I!ouston, Caiof. Inductrial Security 611ergency Planning, DnL

'I* a ru t A. Schwancer, Chief, Lithr Unter Ecactora Erench 2-3, LOL LOOA/UPPSS.V!:'" 2"L'T 03 LEASED Ta0PZ?.Tf FOR k"re-1,4 An c:lficial T"D/d'."/PSS c;reenent ha:s been cuSc.itted by UPPSS for staff revic.i cad nrpro ial (nce U.;p-1,4 S~".. P. 2-2).

<b this approval is repired to e,o to a radloWical cafety hvarin, nc ochedulcl for Septe:Ser 2,1975, I wuld appreciate your t.arly revicu of the agreer. ant, thich han besa distributed f.o your offices.

Ple:ca tote that o rtain right: reserved by L?.DA in the or,rce:.ent t ay undemino tha n.1311 cant'a.cility to en2Icisa coatinuous coatrol ovar l'arconnul cad property tdthin the sclusion crea, or my result in the.

in:.tallation of potential outety hanraa vit.hin the cr.cluaion crea, uithout advaan2 r.otico to eithtr 1.'.-2s3 or tha NRC. I belic ta those considerations are pri::arily uatters for A/Ji and ISEP cvaluation.

O."LD is conducti:;3 its cua evaluatica of the doctrant. A r:ceting uith tha cpplican:'c 4.ttorney la tentatively sch2Juicd for Tiands/, July :U,1975, at thich tina pre 11:iur/ connecto vill be discussed. Overall staff conclusions vill be docucanted in cu sea atpplanent to be iccuad beforo the radiological safety hearing.

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r UNITED STATES NUCLEAR REGULATORY COMMISSION W ASHINGToN. D. C. 20555 Docket 1:os.: 50-460 and 50-513 AUG. I 21975 J. Callo, Chief Hearing Councal, Office of Executive Legal Director IMNAGEMENT ACTION ON WNP-1,4 DOCKET This memo is to request your effort in establishing a rad, safety hearing date for this docket as soon af ter 9/1/75 as possible, but in any case soon enough that an ASLB partial decision or order permitting additional LWA-2 work can be issued before 11/1/75. On 11/1/75, Applicant will have completed all work authorized under the LWA-1 and LWA-2 issued on 8/1/75.

The radiological safety review is complete, except for two remaining outstanding safety issues (not including the Appendix I evaluation) which are expected to be. resolved and documented by 9/2/75. These issues are the ECCS final evaluation and evaluation of an ERDA/WPPSS agreement covering Applicant authcrity to control exclusion area activities. Current staff schedules for Appendix 1 resolutionl/

predict completion no earlier than 11/4/75, a full two months af ter all other rad. safety issuas are closed.

It is my understanding that additional LWA-2 work beyond that already authorized will require the ASLB to convene a hearing.

If a heering is not convened until the Appendix I evaluation is complete, we could not respond to the Applicant's need for additional work authorization by 11/1/75.

I recognize that a full rad. safety hearing held in September may require that the hearing record be held open to achieve final disposition of the Appendix 1 catter. However, all of the rad safety review except. Appendix I could be aired in September and on the basis of that examination the Board could be asked to authorize additional safety-r elated work as described in,10 CFR 50.10 (e)(3). This effort can be expected to result in the desired authorization by the time it is needed, by 11/1/75. It also would avert the two month suspension of construction activitics that would obtain if we simply wait for the Appendix I natter to be concluded on the schedule now forecast before Foing to hearing.

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..The WNP-1,4 facility is a " golden plant".2_/.

This action to maintain the current momentum of the licensing process is, in my view, reasonable and justified in this case.

In addition to the direct benefit to the Applicant and consumer public in eliminating an avoidable construction suspension, there is the recognized benefit of expeditiously completing a licensing action soon after the actual technical review of Applicant's submittals is complete.

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A. Giambu so, Director Division of R Ec~to'r Licensing

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Office of Nuclear Reactor Regulation

References:

1.

Memo, D. Muller to A. Giambusco dtd 7/21/75, Appendix I Priority List 2.

Memo, R. Boyd to F. Schroeder, LWR ads, D. Muller dtd 10/16/74, Schedule / Workload Considerations Resulting from Announced Delays ces:

R. Heineman V. A. Moore N

D. Muller R. Tedesco s

H. Denton A. Schwencer E. Ketchen h

.J. Norris N

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DISTRIBUTION:

3 Docket Files (2)

NRR Rdg Docket Nos.: 50-460 WR.2-3 Mg AGiambusso and 50-513'

":;. 1 2 m3 RDeYoung WR TCs TCox WR BCs J. Callo, Oiief Hearing Counsel, Office of Emscutive Ingal Director MANAGEMENT ACTION ON WNP-1,4 DOCKET his memo is to r,6 quest your effort in establishing a rad. safety hearing date 'for this docket as soon after 9/1/75 as possible, but in any case soon enough that an ASLB partial decision or order permitting additional WA-2 work can-be issued before 11/1/75. On,

11/1/75.' Applicant will have completed all work authorised under the WA-1 and WA-2 issued on 8/1/75.

He radiological safety review is complete, except for two remaining outstanding safety issues (not including the Appendix I evaluation) which are expected to be resolved and dociamented by 9/2/75. Rose issues are the ICCS final evaluatimi and evaluation of an ERDA/WPPSS agreement covering Applicant authority to control exclusion area activities. Current staff schedules for Appendix I resolutiord/

predict cospletion no earlier than 11/4/75, a full two months after all other rad. safety issues are closed.

-It is my teiderstanding that additional WA-2 work beyond that already authorised w'ill require the ASLB to convene a hearing. If a hearing is not convened until the Appendix I evaluation is complete, we could not respond to the Applicant's need for additional work authorization by 11/1/75.

I re' cognize that a full rad. safety'hmaring held in Septembhr muy require that the hearing record be held open to achieve fir.a1 disposition of the Appendix I, matter. However, all of the rad. safety review except Appendix I could be aired in September and on the basis of that examina?. ton the Board could be asked to authorise additional safety-related work as dascribed in 10 CFR 50.10 (e)(3). H is effort can be expected to result in the deeired authorisation by the time it is needed, by 11/1/75. It also would avert the two month suspension of cwatruction activities that would obtain if we simply wait for the Appendix I matter to be concluded on the schedule now forecast before going to hearing.

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9, The WNP-1,4 facility is a " golden plant",2_/.

This action to maintain the current momentum of the licensing process is, in my view, reasonable and justified in this case.

In additiaa to the direct benefit to the Applicant and consumer public in elimiasting as avoidable construction suspension, there is the recognised benefit of expeditiously ooupleting a licensing action soon after the actual technical review of Applicant's submittals is complete.

oridan! Sigsej ti A. Ciambusso, Director Division of Reactor Licensing Office of Nuclear Reactor Regulation

References:

1.

Memo, D. Muller to A. Ciambusso dtd 7/21/75, Appendix I Priority List 2.

Memo, R. Boyd to F. Schroeder, LWR ado, D. Muller dtd 10/16/74, Schedule / Workload Considerations Resulting from Announced Daley ces:

V. A. Moore R. Heineman D. Muller R. Tedesco H. Denton E. Ketchen J. Norris A. Schwencer l

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JUL' 3 B75 l

FIllA!;CIAL QUALIFICATI0 ;S I. : Introduction

-Washington Public Power Supply Syste:u (WPPSS'), a municipal corporation and joint operating agency of the State of D shington, has applied tor construction permits for the WPPSS Nuclear Projects Nos. 1 and 4 (here-a

af ter referred to as WHP and WHP-4, respactively).I' Its membership is made up of.18 operating public utility districts and the cities of Richland, Seattle and Tacoma. -It has the authority, to acquire, con-

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struct and operate plants and. facilities for the generation and.trans-a mission of electric power and energy.

WPPSS does not engage-in the distribution of power to retail customers.

-It does not have rates and is noti under the jurisdiction of any regu-lato' y agency having control over rates and service of the proposed r

activity but is reimbursed for the cost of each project, including debt service, by the participants therein.

In accordance with the Ten Year-

. I Hydrothermal Program of the Pacific Northwest,104 public and consumer-

. owned utilities '(the Participants) and five private utilities (the Companies)haveagreedtopurchase-theentireoutputoftheWNP-1 facility.

The output of WHP-4 has been offered to the 104 statutory preference

. customers (public bodies and cooperatives which have preference and

' priority to power from the Federal Columbia River Power System pursuant

.e (1) The Nuclear Regulatory Commission's regulations relating to financial data and information required to establish financial qualifications for applicants for construction permits appear in Paragraph 50.33(f) 7

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of 10 CFR Part 50 and Appendix C to 10 CFR Part 50.

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.t'o the Bonneville Project Act,-as amended) of the Bonneville Power

-Administration (BPA). As of May,1975, sufficient Participants have signed or have indicated they are in the process of signing to insure subscription of 100% of the project output. Each of the 104 customers

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is a consumer-owned utility in the Pacific florthwest region, of which-Ea are municipalities, 29 are public utility districts and 47 are cooperatives.

j; These Participants will purchase 67.53% of the Wi!P-1 capability during the period 1980 to 1996 and 100", thereafter. The Companies (Portland General Electric Company, Pacific Power & Light Company, ilontana Power Company, Puget Sound Power & Light Company,' Washington Water Power Company) will purchase 32.475 of the WilP-1 capability during the period 1980 to.1996. BPA and each of the Participants have.or will enter ir,to one or more contracts for the purchase.or' exchange of power, the 'oper-at. ion and maintenance of facilities or the transmission of power, from WiiP-1 and Wi P-4, over the Federal Columbia River Power System.

Comercial operation is scheduled for. September 1980 and March 1982 for WNP-1 and WNP-4, respectively.

II. Construction Cost Estimate The' applicants most recent estimate of total cost of WiiP-1 & WNP-4 can be sumarized as follows:

s.- I (dollars in millions)

WiiP-1 WilP-4 Total Nuclear production plant

$932.5-

$935.C

$1,868.4 Transmission distribution and general plant 13.5 10.0 23.5 fluclear ' fuel-first core 44.0 63.1 107.l(A)

Total

$990.0

$1,009.0

$1,999.0 (A) Excludes interest expense The estimated cost of the nuclear production plant has been compared with costs estimated by the Energy Research and Development Adminis-tration's C0iiCEPT costing model. The C0l: CEPT costing model estimated the cost of the nuclear production plant to be.$1,707.0 million, com-pared with the applicant's estimate of $1,868.4 million, or a difference of less than 10%. Accordingly, we find the applicant's estimate rea-sonable.

III. Source Of Funds A.

Financing of Project The entire capability of the Wi4P-1 facility has been sold by WPPSS to the 104 Participants and 5 Companies, who in turn have agreed.

to assign its share of the facility's capability to BPA pursuant to Net Billing and Exchange Agreements. These Agreements provide that each Participant and Company is obligated to pay WPPSS its share.of project annual costs, including debt service on WPPSS's bonds for WitP-1. The WriP-4 facility's output, as aforementioned,

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will~be sold to the Participants who will contract for the specific

. fractions of the plant's lifetime output.

With either WNP-1 or UNP-4, the form of the agreement is the same, a promise to pay a specific share of the Project costs, including debt service, whether or not the Project is completed and it is not depend-ent upon any Project output. Based upon these contractual commitments of each of the Participants and the Companies to pay their respective portions of the projects' annual cost, including debt service, WPPSS will issue tax-exempt revenue notes and bonds periodically, in amounts sufficient to pay the projects' costs. The governing body of WPPSS authorizes the issuance of revenue notes or bonds for each project based upon a system which commits the facilities and assets of that project to the-securities issued to finance its cost.

B.

Security For The Revenue Bonds

- Principal and interest on the bonds are payable solely from the Bond Fund created by the financing resolution and the mdney pledged,to such

Fund are, limited to the income, revenues, receipts and profit derived by_ WPPSS through the ownership a'nd operation of the Project, including all payments to be made to it pursuant to the Net Billing and Exchange Agreements for WNP-1 and Participatton Agreements for WNP a.

No Partic-i>

ipant will be required to make payments to WPPSS except from revenues derivad from the ownership and operation of its electric utility prop- -

i erties. Each Participant has covenanted that it will establish, maintain and collect rates or charges for power and energy and other services

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i. I furnished through its electric utility properties which shall be adequate to provide revenues sufficient to make the required payments to WPPSS.

Subsequent to WPPSS's entering into the Net Billing, Exchange and Participation Agreements, the Federal Columbia River Transmission System Act was enacted and signed into law. The Act authorizes CPA to use its revenues without further appropriations of Congress to make expenditures from the Bonneville Power Administration Fund for any purpose necessary or appropriate to carry out the duties imposed upon it by law. BPA has stated to WPPSS and each Participant that it will pay in cash from the Fund any cost billed to the Participants not paid through net billing credits on a parity with other BPA oper-ating expenses and prior to any payments by BPA to the Treasury for repayment of the Federal investment in the Federal Columbia River Power System. BPA.is obligated by law to charge rates for electric power and transmission of electric power which will recover the cost of producing and transmitting such electric power.

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-Since the Participants and the Companies are obligated to make payments whether or not tt.e project is completed, operable or operating, and not-withstanding interruption or curtailment of output, the source of funds for the payment of project costs is not solely dependent on actual pro-ject revenues, but is insured on a broad base through other revenue producing assets of the Participants and Companies.

In the event of a

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} default of a Participant, other Participants agree to automatic step-ups in their billings (by as much as 25 percent) to satisfy the total Participants' obliga tions.

In the case of default of a Company, the non-defaulting Companies are obligated to satisfy the total Companies' requirements.

C.

Project Revenue Bonds hssued And Projected Outicok For Future Issues.

WPPSS owns and operates the Hanford Project, currently one of the tuo largest producers of electricity generated from nuclear energy in the

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United States.

In 1962, it issued $122 million of Hanford Project Electric Revenue Bonds, of which $60 million were outstanding as of March 31, 1975.

It also owns and operates the Packwook Lake Hydro-electric Project.

In 1962 and 1965, it sold $10.5 and $3.2 million of Packwood Lake Hydroelectric Project Revenue Bonds, of which $13.0 million were outstanding as of March 31, 1975.

WPPSS also has under construction WHP-2 and has issued an aggregate _of

$480 inillion principal amount of revenue bonds in order to pay a por-tion of the cost of acquiring and constructing this project.

It has airtsdy begun preliminary work on WNP-1 and in June, 1974 issued $77 million principal-amount of revenue notes in order to pay a portion of the cost of such preliminary work. WPPS3 has'also begun preliminary work on WNP-3, which will be 70% owned. by it and 30% owned by four investor owned utilities, and it has financed its ownership share of preliminary work in connection with such plant with the proceeds of a

$29 million revenue note issue.

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The bonds issued by WPPSS have all been offered under the laws of the State of Washington. Each issue has been rated by bond rating agencies.

Hanford 11o. 1 bonds were rated "A-1" by Moody's. Packwood bonds were rated "A" by Moody's.

In the issuance of fluclear Project flo. 2 Revenue flotes, Standard & Poor's rated the notes as "AA" and Moody's rates these notes as "A".

The lluclear Project tio.1 Revenue Ilotes were rated "A-1" by Moody's and "AA" by Standard & Poor. The rating on the series 1973 fluclear Project rio. 2 bond issue was "AA" by Moody's and "A-1" by Standard & Poor.

In March, 1975 Moody's revised upward the rating of WPPSS's bonds for WilP-2 from "AA" to "AAA" (bonds rated "AAA" are judged to be of the best quality and carry the smallest degree of investment risk.). Moody's stated that the availability of BPA revenues to this project, the importance of this Project for meeting area power and energy needs, as set forth in the Hydrothermal Power Programs and the net billing agreements combined to support the upward revision in the rating. WPPSS has been advised by its financial consultants that the tax-exempt securities required for financing the contemplated Projects should be readily market-able and very well received by the investment community.

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IV. Conclusior.

Based on the preceding analysis ano our review of the financial infor-mation presented in the application and the amendments thereto, and additional financial information available to us, we have concluded that Washington Public Power Supply System is financially qualified to

_ design and construct WilP-1 ard Wl4P-4. This conclusion is based on our i.

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finding that WPPSS's projected project financing method provides reason-able assurance of obtaining the funds. necessary to design and c:nstruct WUP-1 and UNP-4 over the life of the construction permits.

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