ML20065H758

Motion to Compel Answers from Util to 820830 Revised Interrogatories Re Contention 1b.ASLB 820814 Ruling on Decommissioning Supports Need for Comparative Analysis of Decommissioning Estimates.Related Correspondence

ML20065H758
Person / Time
Site:	Midland
Issue date:	09/30/1982
From:	Stamiris B STAMIRIS, B.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8210050240
Download: ML20065H758 (3)

Text

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD MorION TO COMELL ANSWERS FROM CPC TO REVISED STAMIRIS INTERR0GATORIES 1

, 9/30/82 l Questions 6-10 from Stamiris 8/30/82 Interrogatories regarding Contention i' Ib are objected to upon the grounds that they deal with collection and financing plans for decommissioning outside the jurisdiction of the ASLB (CPC 9/20/82 Response).

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r I submit that the Board's 8/14/82 Ruling that litigation of the decomission- i ing subpart of Contention 1 "will at least permit up to have the apparant discre-pencies in various-figures clarified" supports the need for a comparitive analysis between Consumer's Big Rock and Palisades (B. Rock and ?) decommissioning estimates j and those for Midland which thess interrogatories address.

Consumer's 1981 decommissioning pamphlet (attached) indicates a $111 million ,

(1980 dollar) cost to decomission B. Rock and P, 63 We and 635 We, or $159 thou-sand per We. Yet Midland's decommissioning estimate is $235 million (1984 dollars)

T for 1704 We capacity, or $137 thousand per We.

The 1704 We is determined by assuming that the twin reactors were both pro -

ducing the full 852 We capacity of Unit'II, since for decommissioning purposes -

l the reduced electrical output of Unit I due its supplying steam to Dow cannot be taken into account. The full radioactive core. capacity regardless of its end use,

,j must be decomissioned. - This full We capacity assumption is essential to a com- j parative an.alysis of B. Rock and. P on a decommissioning cost per We basis.

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To further validate a comparison between the B. Rock and P decommissioning estimates and those for Midland, the dollar values must be converted to the same year. Thus the 1980 $111 million B. Rock and P estimate is converted to a 1984 dollar value by using the 7.5% annual escalation rate (CPC 9/20/82 Re'sponse, P. 7) to become $148 million in 1984 dollar values. 'Ihis represents $212 thousand per HWe in 1984 dollars ($148 million/698 m), for B. Rock and P. while Midlands esti-mate is $138 thousand per MWe in 1984 dollars ($235 million/1704 MWe).

'Ihis method of, comparing Midland's decommissioning estimate to the B. Rock and P estimates eliminates any need to discuss the financing cnd collection plans to which Consumer's objected. Therefore I seek to replace 8/30/82 Interrogatories 6-10 with these revised requests which seek a straightforward compari$on of B. Rock and P decommissioning estimates to Midland's, leaving aside ratepayer considerations.

Revised Interrogatories on Contention Ib, replacing 6-10:

1. Explain in detail how the $111 million (1980 dollar) decommissioning estimata for B. Rock and P was determined.

2. To what extent is Midland's decommissioning estimate based upon the model descrited in 1 above for B. Rock and P (explain any differences)?

3. How would you convert B. Rock and I $111 million 1980 dollar decommissioning cstimate into 1984 dollars, and what would the 1984 dollar estimate be for B. Rock and P.

, '.. Explain in detail the apparant discrepancy between B. Rock and P 1984 dollar decommissioning estimate on a cost'/MW basis, with the Midland 1984 dollar decom-missioning estimate on a cost /MW basis, and provide the relevant calculations or other documentary bases for this explanation.

8/30/82 Interrogatory 11 regarding decommissioning taxation rates is dropped.

8/30/82 Interrogatory 18: " Explain any contingency economic plans for shortened life expectancy of Unit I, in terms of electrical production and related costs

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to ratepayers, and in terms of inability to produce steam for Dow according to l contractual obligations. What will happen if Unit I must shut down af ter 10 years?"

Consumers 9/20/82 response to the last part of Q.18 indicates that if Unit I cannot provide steam to Dow, there is a contractual obligation that Unit II would provide that steam. If that hat,pened the whole cost / benefit analysis of the FES i

would be invalid, as the cost / benefit analysis is based upon an assumed 8 billion kwh annual electrical production (p. 6-2 FES).

In light of the Unit I beltline weld life expectancy uncertainties, and the 1973 decision to switch Units I and 11 so that II could come on line first at Dow's request (CPC 9/20/82 Response to Q. 26 and 27, p.15-17) it, appears that the i

dependability of Unit I is questionable. The possibility of a significantly reduced electrical output from Midland should Unit I fail to operate at any' time should be taken into account.

Therefore I seek to focus the Q. 18 request on the effects of a possible Unit I failure on Consumer's input to the cost / benefit analysis of the FES, as opposed to effects on ratepayers.

Revised Q.18: " Explain the effects of a postulated Unit I failure and shortened life expectancy of Unit I in terms of electrical production and the related costs and benefits of Midland plant operation."

Respectfully Submitted, Barbara Stamiris 5795 N. River Road Freeland, MI 48623 h, ,

AS' .B members . .

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