ML18347B252
| ML18347B252 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/20/1979 |
| From: | Sinclair M Great Lakes Energy Alliance |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| Download: ML18347B252 (21) | |
Text
{{#Wiki_filter:UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSUMERS POWER COMPANY Docket No. 50-255SP (Palisades Nuclear Plant) GREAT LAKES ENERGY ALLIANCE RESPONSE TO CONSUMERS POWER CO., NRC STAFF AND NRC LICENSING BOARD We wish to respond to the questions raised by the 1\TRC Staff, Consumers Power Company and the NRC Licensing Board as to the validity of our position in petitioning to intervene in the hearing dealing with steam generator replacement at the Palisades Nuclear Plant. The whole purpose of a hearing is to make sure that all of the facts of a particular action involving a nuclear facility are made known to the Licensing Board and ultimately the Nuclear Regulatory Commission,
' We will provide documentary proof that the Licensing Board cannot depend on either the NBC Staff or Consumers Power Company to provide them with all the facts they need to have to make a determination.
This proof is the result of a number of licensing actions in the past in which the NRC Staff and Consumers Power Company have been involved in which only the citizen intervenors brought into the record very important facts about which the NRC Licensing Board and ihe public needed to be informed. The following is a chronicle of a series of these kinds of events that we are able to document:
- 1) In the suspension hearings of the Midland Case in ;1976-77, Consumers Power Company attorneys deliberately attempted to conceal important facts and new developments in the Midland Case that were essential for the Board to consider.
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- As a consequence, the NRC Appeals Board has reopened the construction license pro-ceedings of the Midland Case to consider the reprehensible conduct of Consumers attorneys in that action which should, in fact, call for their disbarrment. (Notice of Pre-Hearing Conference, April 9, 1979 - Remand Proceeding - Docket Nos. 50-329 CP; 50-330)
In preparation for the suspension hearings in 1977, Consumers Power Company attempted to conceal the fact that the management of the Dow Chemical Company had serious misgivings about linking the operation of the Midland Division of Dow to the Midland n-plants which were being built by that utility. The threat of a $600 million law suit by Consumers Power Company against Dow Chemical Company was the major reason why Dow Chemical has stayed with the contract, according to the sworn testi-mony of Paul Oreffice, President of the Dow Chemical Company. The attorneys for Consume:cs Power Company also asked to manipulate and edit the testimony of Joseph Temple, manager of the Michigan Division of Dow J to make it appear that he still favored the n-plant connection. The Applicant's attorneys also asked Dow to send witnesses to the hearings who did not know the changed attitude of Dow's top manage-ment toward the Midland n-plants. This Dow Chemical refused to do. They sent in their key management people, Joseph Temple and Paul Oreffice, to provide sworn testimony for Dow. Furthermore, Consumers Power Company assumed that the Intervenors' attorney would not appear because of lack of funds, and that without cross-examination and discovery, Consumers Power would be able to "finesse" the Dow-Consumers dis-pute and prevent the Licensing Board from finding out about it. (These facts are described in attached Exhibit I.) Joseph Temple had, as a matter of fact, decided that the n-plants would be "disadvantageous" not only to the Midland Division of Dow, but to their employees and the community. (See Exhibit II.) The Company had secured a consultant's report indicating that for $350, 000, 000, Dow could build their own coal-fired plants that would supply all their needs for steam and power and meet all air pollution controls.
- It should be made clear that the NRC Staff was privy to all these developments prior to the suspension hearings through discovery, but made no effort to get the in-formation to the Licensing Board. Those attorneys should also be disbarred for fail-ing in their primary professional duty, to get all the important facts before the Board and on the public record.
- 2) In the Palisades construction h~aring, the grave quality control defects Attorney for Intervenors, in the construction of that plant were brought out only by Myron Cherry,/who introduced the log of Combustion Engineering, one of the contractors at the n-plant. In that log, Combustion Engineering detailed the short-cuts and sloppy work of Bechtel Corpora-tion in the construction of that plant. They did this to protect themselves. Palisades has had serious operational difficulties and has operated at only 44% capacity since it began in 1972. All the contractors were subsequently sued for a huge sum ($300 million).
Consumers Power Company charged them with negligence and installing defective equip-ment. Consumers recently settled for a fraction of that amoLmt. This is a fact that citizen ratepayers do not view as in their best interests since this money should have been remitted to ratepayers who are bearing the costs of poor quality control in the construction of Palisades and a substantial share of the costs of power that must be purchased.
- 3) In the Midland Case, neither the NRC Staff nor Consumers Power Company told the Licensing Board of the failure of the six pilot ECCS tests in Idaho in the win-ter of 1970-71. The record shows that Myron Cherry, Attorney for the Intervenors, made that fact known to the Board in his efforts to pursue the safety questions of the Midland n-plants.
- 4) In 1972, when the Palisades n-plant first went on line, Consumers Power Company could not make their rad waste holding tanks to work at all. They released the rad waste to the biosphere and continued operation, They not only did not disclose this to the NBC Regulatory Staff, but lied about it to them and claimed that they had always been able to stay within their licensing requirements. (Exhibit III.)
These facts show that the Licensing Board cannot rely on either Consumers Power Company or the NBC Staff to disclose the important facts that will be develop-
ing in the steam generator replacement at Palisades. The NRC has called steam gener~tor degradation a serious, unresolved nuclear safety problem raquiring the highest priority effort for resolution. (Letter of March 2, 1979, to S. Howell from D. G. Eisenhut.) The people in the vicinity who are bearing the risks and who belong to groups that are a part of the coalition of the Great Lakes Energy Alliance and are deeply concerned about the safety problems at the Palisades n-plant include: Catherine Benner Sharon Wilson 2800 S. Lake Shore Drive 1221 Lane Drive St. Joseph, Michigan 49085 St. Joseph, Michigan 49085 Paul Gillespie Frank Lahr 407 North St. Dunham Ave. St. Joseph, Michigan 49085 Stevensville, Michigan 49127 Joe & Marge Hartwig Elinor Morloch 1226 Riverwood Terrace 700 Rosehill Rd. St. Joseph, Michigan 49085 Berrien Springs, Michigan 49103 We are deeply distressed that citizens whose lives and property are at risk have no funds to pursue issues of the magnitude that are clearly a part of nuclear power development. Our lack of funds for attorneys and expert witnesses will make it difficult to provide the kind of record that the Licensing Board should have. But with-out citizen intervention, we have proved that the Licensing Board may not secure any of the pertinent facts that they should have, but may1 in fact 1be provided with deliberately false information, as the previous actions of Consumers Power Company and the NRC Staff indicate in the instances we have described. Respectfully submitted,
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Mary Sincl~(, Vice President Great Lake Energy Alliance Dated at Midland, Michigan April 20, 1979
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
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CONSUMERS POWER COMPANY Docket No. 50-255SP
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(Palisades Nuclear Plant) ~~~~~~~~~~~~~~~~-
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CERTIFICATE OF SERVICE I hereby certify that copies of "GREAT LAKES ENERGY ALLIANCE RESPONSE TO CONSUMERS POWER CO., J\1RC STAFF AND NRC LICENSING BOARD" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 20th day of April, 1979:
- Charles Bechhoefer, Esq., Chairman Michael I. Miller, Esq.
Atomic Safety and Licensing Board Panel Martha E. Gibbs, Esq. U.S. Nuclear Regulatory Commission Isham, Lincoln and Bea le Washington, DC 20555 One First National Plaza Suite 4200 Chicago, Illinois 60603 Docketing and Service Section Office of the Secretary U. S, Nw:!lear Regulatory Commission Washington, D. C. 20555
'AIR, Vice President, Energy Alliance
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MEETING HITH CONSlnIERS POWER, SEPTEMBER 21, 1976 AT Present Consumers: 1. Judd Bacon Dow: 1.
- 2. Re.x Renfro 2.
- 3. James Falahee 3.
Hearings called by Licensing Board. I. A.* Brief to be filed September 29. Brief shall be on the issue of suspension of the construction permit while all the remanded Midland issues are being considered in an evidentiary hearing. Parties shall include comments on the timing of the hearing on the merits, discovery and the length of time estimated for .the hearing. B. Hearing on issue of suspension pending hearing on merits - October 6~ 7 and 8 - issue being heard will be suspension of permit pending resolution of substantive issues. Written direct test:inony shall be filed prior to the hearing and witnesses shall be made available for cross-examination. Similar to ~fPSC proceedings. Consumers said that the best way to explain the i@portance of the suspension hearing and the issues to be covered the.re was to talk first about the hearing on the substantive issues or 11 big 11 hearing. .. II. A. Issues to be covered at the substantive hearing (5). 1 *. ACRS issues - primarily safety issues - some' have been resolved since 1972, others mus't be proved up in hearing - there are 16 "other" matters to be considered, some of which will require expert testimony - no "lightening rod" issues here that are currently* being hotly contested in other hearings.
- 2. Energy conservation - not a big issue - see Diablo Canyon and Niagra :Mohawk (A.EC-NRC cases) - Consumers not overly concerned about this particular issue - claim they are loaded for ~ear - may need some Dow input on electric conservat:Lon by Dow since 1972, which, although showing lessened demand, will still show need for electricity by Dov -
(current contract 300 megawatts). .
- 3. Changed circumstances in contract with Dow - ~on't be an inquiry just to the contract change (1974) allo~ing Dow to continue to power houses after the nuclear plant co~es on - this issue goes the original cost/benefit analysis which included shutting down Dow's power houses as one of the factors in cost/benefit - have to talk about conditions between Dow and Consumers as they are today - Consumers claims this can't be covered hy a Consume.rs ,.,.ritness - has. to be covered by a Dow witness - Dow (Hanes) asked if that Qea'1t. Dow~intent
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or the current factual situation - Consumers replied "both" - Consumers asked what Dow planned to use for back-up (1,000,000 lbs./hr.) ~Dow really didn't answer - Consumers said this too will be a part of the cost/ benefit analysis, particularly if different than package boilers included in original cost/benefit analysis Consumers said main issue is "Does Dow really need the steam."
- 4. Cost/benefit analysis - mostly covered above Consumers said question is "What is Dow's position on steam? On electricity?" What is Dow 1 s current position?". Consumers said a Dow witness will be needed to testify on this - Dow referred Consumers to the con~ract negotiations~
including Temple 1 s June 30 letter.
- 5. Other unaddressed fuel cycle issues transportation of radio-active wastes - also, site storage of nuclear was tes these must be considered.
B. Factors to be considered in suspension hearing (5) - Consumers assumes Cherry will not appear because of lack of funds - Consumers says suspension hearing most critical - they believe that since there is no discovery, and probably no intervenor cross-examination - will be able to finesse Dow-Consumers continuing dispute.
. *1. Significant adverse effect in environment - Consumers believes interim rule will allow further licensing - neither interim rule nor final rule will affect Hidland construction - Consumers must prepare t'W.o cases.
*a. Until interim rule comes out - impact of suspension or non-suspension.
b~ Until final rule comes out*- impact of suspension or non-suspension. Must consider adverse environmental impact of either continuing construction and halting construction.
- 2. Reasonable alternatives foreclosed.- will continued construction foreclose modification of plant that may be ordered as a result of the promulgation of interim rule - Consumers said one of alternatives that may be foreclosed by continued construction is Dow generating its own steam, and this would affect configuration of Unit {fl - maybe now is only time Dow can put in new unit. (Note: don't really understand this oint.)
~3. Effect of delay electric - Consumers must put an entirely new 1-:;;eed for power" case to replace that done originally - will discuss shut-off of Canadian crude to Bay City power house and other factors affecting reserves - will also have to put on testimony as ta the 300 er,awatts Dow must take under current nuclear electric contract - Dow Ewitness \./ill have to testify .JS to Dow's intL'~nt to take JOO m~gaw;:itts -
will discuss increased costs to Consumers - four month suspension will .._i- ,.
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result in eight month delay and increased construction costs of $130 million (doesn't include purchased power) - one year suspension means eighteen month delay - Consumers said didn't have cost figures yet on one year suspension. Q Effect of dela.y st~am, and cost/benefit analysis tilted - Dow becomes very important because here tvo issues (above) can come together ex suggested that Dow witness might be_someone from Dow Chemical U.S.A. Uor Corporate area who is unaware of .Midland Division recommendation to Oreffice - this ~erson would testify as to effects of further delay upon Dow - if Dow accepts division recommendation and takes that position in suspeniion hearing, then construction license will be suspended for at least one year - no doubt about it - Falahee added that Consumers may ose its construction permit entirely - Consumers said that as long as onstruction continues, Consumers has a lever and will drag feet in earing on meri_ts - if construction stopped, intervenors have lever and will drag feet in hearing on merits - Consumers further pointed out that final FES (environmental statement?) states that if construction permit for }1idland is cancelled, Consumers will cancel one Unit and transfer i other to Palisades - this was one of basis for issuance of construction license - Consumers threat - Falahee brought up the point that Dow has an obligation (Bacon interjects "Section 3") under the General Agreement to support Consun:.ers in the licensing proc-eeding. Falahee said "If Dow takes this posture, Consumers and Do" will have a helluva legal problem" (Note: strong icplication that Consumers would regard us in breach if we went too far in our testimony) - Hanes replied that Dow's witness would tell the truth as he honestly believed it to be, whoever the Dow. ~ witness - Falahee then made.naked threat that if Dow testim.ony not supg_:>rtive of Consumers (Note: no longer just if we go too far) and that results in suspension or cancellation of permit, then Consumers will file suit for breach and include as damages cost of delay, cost of
~iT canceTiec1and ,ali damages re~iti~g-trciill- ca~~-;;ii~tio~--~f proJe-C-tititcaus-~;-~*;;~~-rable-*f:Ln~ncial-narn-*t-o*--co~~ls_(Ji~;_k~p_tcy).
- Note: pretty damn close to blackmail)
- 5. General policy concerns - main case will be jobs - jobs at* site, in Midland, and affect on economy of .Michigan - Stan Arnold of AFL-CIO will testify for Consumers.
Summary Above issues discussed in Consumers' September 7 brief - Rex said he wanted to know Dow's position before he files his brief on Sept~~ber 29 - Nute replie9 that they.were inconsistent, threatening - a massive lawsuit on one hand if Dow takes hasty position, yet demanding illII!lediate statement of position on the other - Dow replied that it would state its position as soon as able, but. may have to go before the Board of Directors - Rex said he wanted an outline of Dow witness testimony to use as basis for prepping witness on October 4 and 5 - no response from Dow - Dow committed to get back to Rex before September 29, one way or other. .('
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NICHIGAU DIVISION Paul F. Oreffice U.S.A. Adz-llnistration 20 20 Building cc: J. H *. Leathers RE: NUCLEAR-STEAM - HIDLA:.""1D PLANT As we discussed last evening, I nm.; have a serious co~ccrn as to whet....~er the nuclear-project and. our curr-=nt co;:-it!:"acts with Consu.-:i.ers Power Compan.::z* aren't *indeed in the process of becoraing deterrents to our ability to assure th~ SL:ccess-ful and reliable operation of the HiG.le.:-td Plant:. in the future_
!*ie declared publicly last f~ll that .for :tJlan!1ing pur9oses the Division was no longer considering the cost and av3il-a::i.i.li ty of nuclear-steam to be an advc.ntag-=. to this location.
Since January of this year, we have been negotiating with Consu.~ers for contract changes that would accoLlplish the~e o~jectives:
- 1. Reduce to an absolute mini~um our cepe~dence upo~ the Cons ur..2rs Power Company .
- 2.
- Gain complete freedor.i. to generate 0 1..ir 0;*1n power in any way that we may choose.
- 3. Gain the ability to make steam in any wa:::;t and in any quantity that we may choose.
- 4. Re.r..ove all restrictions on what we can do with the steam we purchase from Consu.-n-=rs Pm.;er Corr.pany. *
- 5. Increase Consu.u.ers Power Company's responsibility for Dow plilnt shutdowns resulting from their inability to deliver contract quantities of stea~.
- 6. Establish a tirnatable for the completion of k~y aspects of the plant and provide that no-.., r..ar ter minu. te the steam ~ontract if-it becomes a~parent tha~ Consu~ers will be unable to provide steam by the end of 1984_
AN O?!!flA T:~c UNIT o;; TH:. C'O'.'J CHC:.*,:IC.l\L CO'Jl,'"> ..\.\J*r
Paul F. Oref £ice - 2 -* 1~ very si~;nificant 2ve~1t occuc.l'."t..,,d o:-. :Tul:,* 21, 1375, \*:hen t ~:;--::;;-.:;*.,,~ . .; ~r.'-o
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- e~~-3.:-i cu the N.R.C. the question of wheth~r the constr~ction license for the ~-!idla-:i.d. Plant should in~22c:. !i::i.".'<:: '.Jee!"\ issu-2C.. 'I~e N.R.C. was order2.._;. to ri.:::o;.i-:2:-. h-::.ari:-:.;;3 o;-: four s~)2ci~ic
~ues~ia~3 -- o~e of which involv0~ t~e dispos~l Of nucle~r
- a5 tes and D:) tenti<Llly iw.-:iiJ.c ts a.l l nu;;::!.ear-olc.:.:-i ts in the U.S.; anc three other que~tionsthat relu.te- sp2cifically to the Hiciland case. The N.R.C. has reconstitut~d the licensing board; and briefs on one initial question, regarding the disposal of nuclear-wastes, were C.ue in to that board yesterday.
One of the issues to be rcexa:t1.ined is the cost-benefit analysis, whicI'.. is based on the purchase of stea~ by D:>w fro8. t.."-ie nuclear-plant. Consul'.'.ers has always m.:ii.n-tc..ined that Do*.1 s coP.'.mitrnent to pu:t"chase ste2m is critical 1 to their retaining a valid constru~tio~ license. We are nea:r-ly positive that we wil 1 be req ui ::::-ed, dt:!:"ing some p3.::-t of the upco~ing proceedings, to state our cu~re~t position; e.g., Is the nuclea?:"-plant and nuclea.~-s tear:i. essential to Do;*;'s Hidland Plant? Is i t w.dvar.!::ag2ous? Do~s the evidence in 1976 de::.?.Onstrate 2. consi<le::-able cost advantag:: of nu:::le2.r eve-;: coal or oil? Is D:J*.-1 1 s growth in Hidland de92nde.-it u.90!:1 the availaoility of nuclear-stean? Hill DO'.*T continue to operate and build in Mid::!.and if nuclear-stea~ is not gotng to be available? I believe that answers to these kinds of questio:is are going to be required, or at the ve::-y 182.St that ~e, Dow, need to have well thought-out answe~s to t~e~ upon which to base our response, o~ res~onses, to either a for~~l request from the N.R.C. or to questio~s from the attorney .for the intervenors -- Myron Cherry -- ~ho is dedicated to stopping the Midland Nuclear-Plant. In our judg~ent, the July decision by ~~e Court of hooeals has dramatically *and adversely affected the oC.C.s that Consur.iers will co1u.plete the plant by their ne*.*;, target completion-operation date. The:::-e is a ne\*i, officiu.l cost: eitimate of $1,670M; an<l we are also a~are that there are . unofficial, internal cost estimates fro~ B~chtel of $2,CJO~*t. This information became known to us on August 5th. Decisions arc beirtg made at the present ti~c by the N.R.C. on serious "re tro-f:i. t" ques ti ens Hh ich, if ad vers-:3 to Co~s u-;:i~:;:-s , co.~ add sig~ificantly to costs. All of this m2y also ~£Ecct the cas*t-b2ile fit analysis upon Hh ich ~he c::> ns true:~ i.o;) 1 icons e
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As of now, construction on th8 site continues. Russ Youngd::i.!:.l tolcl ffic on Augu3t 5, 1976 I thi...:. ccc-:isior~ is subj~ct. to cha.n9?. 0:1 very short n-:itic~ <l!~d co~~ld .:.il1~ost ~~
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,j . . e Paul F. Oreffice. - 3 - September 8, 1976 con3idered "day-t:o-d:.:i.y." . N8 hc.*.:c had no \*/Ord from Cons u..--aers si r.c2 ea.rly August on their plans for coping with the July 21.st Court of Appeals decision -- or of their assessment o.f the
~ituation which we believe is very fluid and very critical.
I believe that the:::-e are no re unr~nO\*:ns for us to clay than perhaps at any time in the history of the Eidland nuclear-proj ect. Our deliberations he:::-e -- and rr.y o*.*m j uc1gmen t - - cause rae to conclude that *unde:::- today's conditions and considering the history of this project, that the n~clear project will be most likely to be dise.clvantageous to Dow and to the Hidland Plant and to our e;:;:;ployees in this
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corr.:nuni ._y
- Therefore, I reconu."end the follo~ing:
- 1. When we meet with Consumers on Honday, Septerrber 13, 19 76 ,* that we get, and then give full considera tiou. to their analysis of the situation, to their plans and to their projections for the future.
- 2. Using *what they tell us, decide wh2t...'i.er our conclusion as described in the previous paragraph is still a valid one.
- 3. I£ our concl usio.n is still a valid o:ie, I recorr.m.:nd th:;t t this is an important enough issue that you, personally,*.
call for a corporate review of the entire question. Such a review would be designed to evaluate all aspects of "the conclusion that we have reached here in the Division and the potential probler;i..3 that arriving at such a conclusion could cause for others. Such a review should start as soon as p-:)ssible after our session with Consumers and be completed in approximately one month. Until such a review is complet~C!. to your satisfaction, Do;.1 should avoid taking any position. I have some ideas on questions that I think need to be addressed in this review and plan on discussing them with you nezt *week when I knm...-
. the results of *anr scheduled meeting *with Consumers.
It is important that a minimum nu.:.Tber of people know the Division's {my) co.nclusio:i and that thos~ who do consid-2~ i t very much "Dm*1 confidential" because of its pote.-itial
. ir.i.p.:i. on the com.11unity. Please let r.te kr~ow i f you ha\.*c any qut s tions .
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- h. -fi_ .. j n,.* 1)( Af ~Lo; 0 -:-:-:-::;~ , Temple hlmselt recommended to the i oncler continuous review by the com-*; hearing with' the Mlchi~an Air Pollution ..
. , \: .mltmenl, lo use process steam 1 from1 1.'corpora le board. of dlrecto.rs the com-,:. pany and "Dow w_lll continue to keep. Commission (MAPC), m which the com-,
-.:"';.' *: ~ldlond s n~cleor power plant under pany abandon nuclenr power because -J all of Its options open." . . : pony must Indicate how It wlll co"'.ply
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- c 0 n Cl u de d l t w o u Id b_e d ls:~; Temple snld the company Is now "ac- . with air quality standards by 1980. *
. \ :_; *;The threat was revealed Wednesday._.:-* advantageous to Dow, the Michigan DI-~ t1v*e1y .considering" several alternative . Temple said the MAPC has allo':led_
- ... :::ay Mlchlgnn Division gcnernl manager*.r+vlslon and Its employes. *. * . *:i power sources Including a new power delays In the company's solving the air
* ', :9'0seph G. Temple Jr., who said Ir ~here ....
- His conclusion Is still the position of. plant at lhe Michigan dlvl~lon. *.
- quality problem caused by the old pow-
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'***":~ ;;as no chance or.~ law~ult, Dow would *~'.the Mlc~lgan division, !emple testllied,1 If the nu~lear plant cnnrtot provide n: ,;er plants, because of its pl.an to swl.tch..
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- go Its own way and not.use steam. *and no one /rom Dow U.S.A. hns dls-*1 reliable supply or steam* by 1984, "to nuclear power In 1982.
. produced by nuclear power to op~rate. agreed with him. . * . f Temple said, "we reel .we ~ave been dis- But the date Is loo uncertain, Temple
*;*,Its plant. * .'" * * : . *:~ 1~.- ,However .. he said *corporate bonrd of*. *charged or our obligations" to Con- believes. "We have been promised a lot
.. (***,,, ..Temple. lesltrled Consumers boar:4 '.,"lldlreclor Paul* F. Orertice, also pres I-.~ Burners .. :, .. J * .. *: * * .
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* *: ... :* *" of other things) (by Consumers) and it*
- :-_.i 0 chairman A.H. (Al) Aymond told Dow,i\t-derit of*Dclw *u-.S*,A.', dedded the com-J . The two parties currenlly are renego- has slipped and sflpped and slipped."
*. ~~ olllclols the utlllty*could go_bankru]Jt_ I!*,,, pnny would honor Hs. contract for~ tinting n contract for the steam. Con- Temple called his conclusion that the *. } . the plant Is shut down permanently.. -. -~ ~:\ steam from the plant nrter two meet-;: sumers claims .Dow is bound by a 1974 nuclear plnnt "Is not going to be a good
- . , . *He; said ~ymond e~tlmated :*Corl~.J,,,;lilgs Wit!\ Corisutrters or~ltlals, when the L contract pending the negotiations. =. **
- deal for Dow" one of the most dlrrlcult
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- sumers' poten\lnl losses at $600 million . Jnw5uli.!I were threntencd. * . . _ But Temple snld Aymond told Dow oC- decisions of his career,
. . d.nd .toid Dow: oWclals .Conilum~rsJi~!f!:*11iif coiripliily iilso ..condticled ii vast~. tlclals they could get ~ut of the. contract Under questions by. Intervenor at-*
would pursue "any avenue to recover,*: tevle-it of the nuclear project, nssesslng,l, In 1984 unless. Dow. s abandonme~t torney' Myron Cl:Jerry, Temple mid the* full damage Crom Dow." * * **,; ~ Jmpnct of Dow's abandonment on the; would .. Jeopardize the_ nuclear plants decision was based on several factors:
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~ -*The subslrintlal lncrMses In cost of and several: Dow corporate officers who I * ,*: *.*
*~.the plant, Crom $256 million to $1.67 bl!- were aware Tcmf?le's confldenpn~*.i .. ,-_:
\* lion, since .c<'lnstructlon bcgnn. , * * *. 1 memo. . - *' * ,.... * * * * : * . ;* 'i
*- ~ Num~rous delnys which pushed The. Chlc.ap,o attorney, wh~ tepre~' * : :;*
; . back the start-Up date ot the plant from< sen ts the Saginaw Intervenors In the'" : ,/
( 1974-75 ti> 1982. * '* . * .. * *.. "* r * \ ,.'.'~ proceedings, sa Id he plan,ned to ques- ; '._
\: ',1 **I**, ,.- "' . * .* * ** ' * * * * **'. * * !,,. lion the men about factors that led to
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i'~/.~ t~nsumers; ability to tlnance c:on!'.'J .OrerrJce's rejection or Te"_1ple's reco.m". . 1 "
~ strilctlon or the plant which "ls qud- .mend_otlon. *. ._. - :*."!.**** ... ), *. .
- 7* tlonable In our minds .." ... * * . '*': . ; Tetl]ple's testimony was given during. -~*i;_;*
; - .Skyrocketing costs of m~clear.tuel-. lhe second. day of ~~~rings held .a~}..,h~ .*-,. ).
~**. ...:. Hie assessment .that.the level. of. ~oll.day ~.~n._ * . .-:.:::,, *...; ... * ..,.<'.I ~* :: ~, .** .:_.
tcohtldence. llf Consumers lsc "quite\~:* *' * ' * * .. :;. *'. *. * '.' 'A *~ '"
'*low." -.; *,:~ "~ * ** * .* : * .*:. * * : *~~ '.* The hea\lng was scheduled lollowlng 1
~*, - Dow's concern of becoming tolally 'fa U.S. Court of Appeals ruling that the
*dependent on Consumers for p'rocess Atomic Energy Commission (AEC),
*steam. . . * . :* predcc~ssor of the Nuclear Regulatory During Wednesdny'a cross *exam~ ' Commission (NRC) did not properly In~ .
- fnatlon, words flew among attorneys,:. vestlgate Cull Impact of nuclear pla~t .
who .were reprimanded by the pre-, construction In Midland.* . . . * * ,!
*r,... siding Atomic Safety and Licensing The basic Issue Is whether complete ,.
Board (ASLD) several times. .. *
- consideration wa! given _to nuclear nl- , *
. Cherry announced he plans lo call ternatlves and whether tho plant will se'veral more witnesses Including Oref- be needed with recent emphasis on .
flee,' Aymond; Consumers executive energy conservation, according to an _ vice president Russell C. Youngdahl, NRC spokesman. . , ... . ,._,,
. '\
- rn rna.11 P.on.d
- '...rir.::h 16, 1972 fulisndcs Haste Gns SystcrJ.
L?*:'ib.uslcr, Covert GS:\cclcy, ?-~ichic;an :\venue* RC.G,.-:.u.r.:;.n, Eichicc:.n JI'~chaub, Michigan In reference to your letter to Bechtc:l Corpora ti on C.2. tcd l*~rc:h 9, 1972, o-;,crnt.ions Dcpart.--:1ent t;;.kes s.erious exception to h:o points #hich *1c h£~vt: not been nble to reconcile in a r.i.2ctin3 *..:i th R. C. Bo.w1:an and J. R. Sch2.ub. The itcin on the , . . aste eas decay tank inlet and outlet v<J.l \"Cs states t~~t neither a second isolatio~ valve nor a test co~ncctio~ and v~lve are nec-c:ssilry. He feel they a.re necessary for- the follo....,ing reasolis:
.l. We bclic.ve these valves 'rlill only be n.ccc::;siblc durin~ r.::fUclin~~ _ ,,
shutclm:ns d.ue to radi2.tio-:-i fro:-:1. c<:.s ~;to~*ed in the r.clj<:!ccn.7. tanb:;. Thercfo::*e, a. sccor.d v:.l vc is neces [;~ ry CL~~ n b~ckup to i a::;'.11*c r:. reli~blc rnctho:l of' isolc.tion \-:ill be nvailalJlc fi*o:;i rc~\1clinr:; to r.;:f'ueling.
- 2. Lcab:i.g~ throue;h cc:-t<!.in vn.l\*es in thi::. sy"tcm :is intolen1~>lc; in the case of t~c outlet valves, the result would be leak~gc out the st2.c'r;. (GV-1123, located down.s~reo.m,- 5s not a ['/*s-ti~h~ valve).
Jn the ca~;e of the in~e:t valves, J.cn.'t;.<J.[~e duri~~3 r;.:'.!intc:;~:1cc of relief vr.lves (;1hich :::i:s been n frequi.!nt rn<i:ir:te:;-,::-~::cc it:::.--:-: in t)10.
})Q.st) \:ould -:-c;,;ult in lcu.kac;e fro~ thL! hic;r~-prc:.ssurc Jli'..r7- of trH:
- sy.s tc.'";'. to u'c=o.spi"ier.::.
3.. It i:-; 1~r.ce.:.sr..r:,* to he.ve so:-:-.c ;:;crtns of detect.inf~ 1£~t*::::r;c :frc.'71 tlic syste:1 to the envira::..;.e:it before sit,;1:i.fica:n:. n;:cY.1n;.,~ _o;- i~-S hf~vc
- been lo.st. Lcc.ko.CTe to at:~:osp:-rerc cu.n be detected by oubblc tc.c;ts.
Ji.it 1(;2.~~.'.lgc thro'213h valve'.; co.n or:ly 11c d.ctcctcd. oy a t12.st co:-ir~cct:i Ob.<:crvl11c; p:::-<:::;surc cl*:::c.!'..y j s not an nccc:pto.blc n:f:thocl bt::C'F'c'..l:.;c, by the t_i::-.c tlle l)rc:.ssUY*~ d.:-ori i:; 11J.q:c cnou;)1 to ~:e o\J.ser*red, too m~\c;1 r;:-.. s h<"~ b cc::. lost.. '..Lo tnl [;ll ~; lo~;_:; in b 0 tl1 ~iUr[;c "'~~n'.-{ Ztnd. d.nCf~ ... .,_,'t-r r:*""t \U. r-. lr*t"C- '*1'"'1 4<' 1.',0 ) 0
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* *.. * '. 04 TC* .. ' * .; March 22, 1972
.~ ,, :. _suri.;{c:*+*
*-.fi Palisades Plant
- --<.,*:. ,; .:/.~.~.Waste Gas System
.*, .'*.'\' * ....,_...;,
~* Raterence l) CPCo letter to Bechtel dated 3/9/72
'"J' . 2) RLHaueter memo to KASYarts dated 3/16/72
.. , CC :.~:-r* I
..... RCBauma.n, Michigan Ave GSKeeley, Michigan Ave
.. . ~ . AKCrockett, Parnall Rd GBMatheny, Michigan Av~
.~ia.us...Lg r 1 Site JRScha~ichi&_J;LA.R
. 'l\lo areas ot concern a.re still unsettled as noted in you:r :::.ez.o ot*
~h
- J.6 11
- 1972. They are: .~ ...
l) Whether or not tvo valves e.nd a teat ccnnection shoul.d
~- be added to the inlet and outlet or the gas decay ta.nk.e * '
- ":* :~*.; ~ ~. ' :_ and J\ \-~~<,1
* . _..,
- 2) Whether or not the :filter !'rom the gaa decay tank.ci (F-58) . il-""
should be changed to the charcoal variety. f.;. . .,;, *'
;
We feel that the additional valveG a.nd test connection e.re :.vt ~e-eded.
,,~.I ...
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~. tor tlla folloving reasons:
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~~ ...t_ <-.v~~ n~ \/. ;" GJY l~ecostot$10,000-$20,0001sprohibitivaP
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?-t/iL~ ~ 2) The present valves vU.l be repl_a~.ed by \air tibht va.lv~::i V :,,~ *'-
"'-\w~i..~"""'"'6-J\\:.4J~ which vill leak vith such a~ov fr~q1Jenc:r)that t*,.ro vslvea ... -
t ~ 1 J I /J are not justified; . --;-.,.,____,, 11 { ~ -,; '~(., h~ "---t/ \ L\JJ.,,/ I* ,> .).._,M,)' I <.C., .i I h ,l- ~~~ J~-"llh ~ *
"':f l~l.\.\Jl~"<&.t-~> .If it is postulated that the first valve vould leak, t.t.e / c,v*~:...}- J
~ ~.-~i. . . proper solution vould be to replace the valve vith a bette.r .
. '6 \>..'-\\.) ~ val.ve, not add another le~y valve;
~-i ~~ ,~-iLl
'.ll...l\~~ ~ 4) ~hree nev tanks ill be added so that one could easily ~W-.!.)~h-~ iver~ the gas .from a leaking tank and then keep the 77' ) . J. leaking tank out of service until the next refueling period; "
'"'.': -l : * .i ...
. . , 5) The~e are backup valves dovnstream of the outlet valves
/,_,. ~-*,...._-¥) M lJresently; +i_,,J /Q..ij}{,
liJ t~~- s:;*c* t , r,:*>~ 4 o Leakage vill be: detectable by RE-1113 before any l i mi tl!l ...L
*~)-4 / /.. ~):"-'~ I **---ii.re even approached; No+ fvlle..! P..-c..s~.J ,..,**.tJL.fP-'V 1i:~~-<l~~ ~G-1-1 I" 1-V
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*'(J.J /'.'. . . ~:<; 5 ~ cJ;,~ .J> The relief val vu are being fixed so that they vill r.ot
- 1..': *,.. **j /* -f* *
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~' t.h 1.c l.-1 t'<'l../<q 1< v1ll. only recirculate in th~-.s~.t~~-~~:_g~~~~-e -~b.o-J .j .. ', ........
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Vo 11 Il']\llflr l r. It v t r:, n 'l r \; Cu.1q.u.ty fuli!inclc;, Plnnt File 3:,00
*c..c HL1kiuctcr JI.~ Sir.ipson Atto.chcd for your infon:mt"ion is o. copy of the recent mcrr:o .f?*o;;i .K.A.
to R! L. Ifnuctcr* on the Gus !*.'nstc ~:i[;tcw. vrl tl1 plu11t stnf f cor:i;:-:cnts.
- You r.iust be mro.rc 0f the fnct th::i.t nlth02.'._C_},!....Qllr li_~~nse stf\t.c" vc
'r:U.l hold. _..____ -un c!ll rnclioaclivc ... -* --
r,nscs far u r:;inir.:ur.. i1criod fc.::: t not b2c:1 ~l.Jlc to r.12Ct thi:-; rcmiircr::~nt to t:!! ~~- >.'"' of 7 dnys *r1c ho.vc in
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Co:-:1plinncc u:i.11 cc~*tninl~' bore in on Uris nrca in the ncnr 'future v.:-i.t.."ri. us n nininw:-i o. slop on the \Irist citation fat* the record."
\-le nrc i_t:l dccn tro~11J.l~£~. ?J.sUbc. sooner c~G1-11ccrinc; 011d J1ec11tcl ~dni. t~
it the soo:r;cr we can find.*n solution~
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I Gono;al Orticcs: 212 Wost Mlcnl.~a'.' Avenue, JuCl<.!'-On, 1-!lc.hlunn 4g201 * /\rOO. Coda G\7 70£.l*O~::;o January 26, 1973 Mr. Boyce H. Grier He: Docket Ho 50-255 Uni tccl States Atomic ?~aera License Ho DPR-20 Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Hr. Grier:
Your letter of Dcce~ber 21, 1972 sto.tcd that the P2.lisaclcs Plant was in noncompliance vi th AEC rcquire:~cnts; n2.J:::cly, th2.t g2s-eous \taste nuy have be.en dis char~ed directly to thC:! stack for c.. p8riocl of several months which exceeds the tl.lmrai>lc time for di:::;cha1*Gc of the waste gc:1s Sill'GC! to.nk directly to the st.a.ck. 'l'his le~ter vill app:d.S<'! you of the- action t1:e.t has b-2en t2.ken to ir~proy,~ the was.te gc.s s:{~d.. ei:1 pe:rfornancc such th<.i.t the reauirc:::2i:.ts of J\i*ticlr; *3. 9. lT of the Techni-cal Specificuticns can consistE!ntly be adherc<J. to. Durin~ *the c2.rly opcr<ltion of the PaJ.j~;:~clcs Plant (Junu<wy a..'1cl :F'c:bruary 19'(2)) evalu::d,ior: of the pcrfor;:in.:1c:~: o'r the waste [;2..S systcr.i was difficult. bcc2.usc of exc'3:;sive e;a.:; ccllcci..i.on from* sy:.:~tf::::,:; rcq\.1i:rinr, t11'3 u~c of cover r.nsr:.:s as ..,~ell as C:2.s col1 ection fro::: the * / rn~my i11c.mt start-up;; an cl sh u~ C.mms. During this t :i.!:'.e, i 't W2.S di f ri c.; t~J. t to nchi8ve the rcqui!"cd scve!1-cl:.:~y f;ol(lup tir.:8 in the dcc::!y t2.nl-:s r.L:1d, in .::.ddi t.io11, it w~1.s su.spcctc~d that the decuy t~~n1.~ relief Y2-l vc::, -,.-en~ lcru~ing. The relief V<d.vc :i n:::i..:.112-tion '\-T2.S r::odi fie:d ta rirov:i.d~ ~o.sc of rna:i ntcn:rnce a.:-id the re lie t vtl ve::; were reset 2.n(l latipecl. A.1 so durine; this pcrio(l, the e:-:ccs:;:ivc C"-5 collcctio:1 pro 1JlCL1 we:~::*. rcd',;.cC:cl sc:-:icr1h~tt. FollmrinL; the \.:01*}: o;-i t::e relief v<~]'.*t:.~s, it \.!0.S cor:clurlcd th<~t lecl_(![!:C still c:xistt:.:C. l'rc;::i ti!c ci.ccny t~~n\s. In April J.9T2, all nine decay t<::..nl*: isol<.:.tion 'i :il *rcs ve:rc rcn:o*1-::c1, rc*,rorkc'l. a.1:<.l re-ins t.£.lilcc.l in on attc:r.~;t to stop ti;?. l(~~il:c.c;..::~. Dtff.i.ng M:.cy i:_nd Ji.me 19'(2, I \rn._l"'._rc })QC}:i:1cs \,!ere:: co:'".i~.:i.:11.i.Gi..!SJ:r 1j~i:2~: l'C~.,"or}:~d Lo prC1.'Cr:t 10c..~l~c:. ze. ~ Gas co llc! L: t ion r.:::. tc*s >:e: i*~ :; Li 11 e;*: cc::,::; i Vt! , bu L r: CJ t ;;.s GI~C<.'. L ~~.s c;.:p(: :* i-eP..ccd early in the yea.-::. E*:e;-i so> r2..ci.io~ctivc Gns collce;ti0:1 071ly . rcprc:.scntc<l ~ esti:::;c..te:l ~~Gj, of t.hc GC.sc:s ',W '1-:C:n: tr:tinc; to hold up. Tnc tot.cl c:;::i.seous activity relc~scd tlurinb t.hc fin;t h<llf of i9*r2 vus vc-:..-y low. Jff t/ 3 o Di"J
..,* Mr. Boyce H. LJ1A* January 2G, 19'{,.,- By July, va.lve lclli:,1sc:. pn*blc-ns were D.Ga.in bcGinnin~ to reduce hold.up tir:*cs. Continuous val v*: n<~i r:tc~no..ncc r:10..dc no r. icni fico..nt ir:iprovc-ments in. decay t2nk holdup pc::rf'on:.2.11 :.. ~. 11 I! 11 sl.~r:ip cliaphrLl.[~:.1 va.lvc::; *..;ere placed on orclcr to rcplaCL: the: rn*~:c*11:,.1y inst;!.Jlcd inlc:t, outlet and 11 11 drain vo..lvcs on each of t/1(' t:1rc:c* t:e:c;*y tanks; ho*.,..~vcr, due to the Ii struup, delivery is not expcct*:,t utitil }'c:bruary of 1973* Durinc 11.ur,ust nnd Scptc;::ber 1972, the execs~; i '.'f'}. r:,:l.; collc:ction ::.'ate problem~; were overcome; ho;rcver, leaka.sc f .ro:r. tl':e (~ccay t[!.nts bc*c:..Llnc worse '..!i th valve usoee. In October 19'{2, Ll. S*?con°l v'd \'*.: \..'~S adckd on the inlet' outlet n.nd drain lines to the decay t;u1:*.:;, i,,*11i ch rcsultc:cl in improved sy~3tcm pcrforr.1.:u1cc. 'l'he system lr,~d-:a,~1: t l'li(kd to increase with time nnd usasc of the:se valves. During December 19"(2, i~l":1**1: valves of a type used in natur~:..l gas. systems i*cre acquir~cl and irn;L.;,) 1 ::.L 'l'hi s has minimized. the r;as leak.or,~ to a point where th~~ ;:rL:;tc t:,:1:; system is operating fully in accordwce with Tccbnical S_:1 ~ci:i'ic<~t i. \ *:~ rcquircm~:ats. At the first opportunity follmring rccei1)t; of the c:j
- 1 ~i1r~{?il t:r:rie vo.lves, they vill be installed. This will p**o':i.d.c <.trldi t i-rn~l rcli2.bil i ty with respect to decay tank holdup tirr.c!;.
In sumnary, * *we.s l.c gas sys t0m pr:! :*forrn~.ncc was ma:q;inal through-out most of 1972. 'l':ic:rc >>rcrc inst<:i:cc.:s '.-:lwn dcc£.!.Y tc.nks have not been held up for the requi.rcll .**:";en de.;:,*::. ..:;:1c Li' lca}:2~:~; ho<1cvcr, _!l~~-n::i.=-
.*~oritr_~- the t:iJ-:-,c* ?_the ~-2.:~:..::!_-(!:~:;r_.£;*~*~ ~2-~1__1_'_<~~'..!*i~~~~~- hCJ.s bee::! <Lci;ic*"~cl.
ln acldi tio:1, w.:: no.vc 11cy~~2JJ. br~:i.:s_~:_;. ~'._l:::*.:.:,::2:.9.cu__!:l.~S~-~:~L...:tan 1 :E._....:1_C2. clisch*u:r~ ci.:r.:ci..lv to the E.!;~_:0~_&L~~2.:..:.li.'?.!_'2..~.J:.~-~~cer -~~a.:a seven cle!.¥2_* Throu::;:10ut 1972, the c.cU.\*j ti*~J of ;:.c.*~*::. r**lc~tsed have e.l\;ays been low 0..."1d 1.;cll within release li.r:1i1..~*..
- It is sic;nific2nt to note t1:~~t t:-1crc 1:crc od.r,inalJ.y nine
*valves t:!.Ssociatcd directly 'I-Tith th*: c>:C':c~* t..~~1.::s. 'l'he efforts to :re-duce the lc:J.;age rate~; Of GELSr::; :fr1::. \.h.: t.:~:J*.S hClVe resulted in 16 addi tion~l val vcs being i nst.::..1.J t:*d. i."t* ;:r ~ co:. fi dent tf.e.t these efforts have iJ:i.prov~d. the waste gas sy~t.,:'.: ~;-..ci1 t:1~.~. it will allo*,;r full com-pliance with. all Technical Spec .i 1.i c:,t ir.11: ~-,_ qu.i i*cr:-.cnts.
Yours -.**.*1y ~ruly, RBS/dmb Rulpl1 i:. ~>(*",.;f'll 1/uclcar L i.c( :1si11c; Aw:i.ini strator
UNITED -STA'l'.ES or* AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
CONSIT:1ER.S POWIR CO~Il' ANY ) Docket No. (s) 50-255SP
)
(Palisades Nuclear Plant) )
. )
)
)
)
CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing docULilent(s) upon. each person designated on the officia 1 s_ervice list. compiled by the Office of the Secretary of the Commission in this proceeding in accordance with the .requirements of Section 2. 712 of 10 CFR Part 2 - Rules of Practice, of the Nuclear Regulatory CoGOission's Rules and Regulations. Dated at Washington, ~{is
.d.J/tfl day of -~-+--~-197£.
f the Secretary of the 1 Commission
- UNITE:Q STATES OF AMERICA NUCLEAR RE~'Ot.ATORY- COMMISSION In the Matter of )
)
) Docket No.(s) 50-255SP
)
(Palisades Nuclear Plant) )
)
)
SERVICE LIST Charles Bechhoefer, Esq., Chairmar" 1'~. I. Yiller, Esq. Atomic Safety and Licensing Board Isham, Lincoln & Beale U.S. Nuclear Regulatory Commission One First National Plaza, Suite 4200 Washington, D.C. 20555 Chicago, Illinois 60670 Dr. George C. Anderson Hs. Mary P. Sinclair
- Departnent of Oceanography Great Lakes Energy Alliance University of Washington 5711 Summerset Drive Seattle, 1fashington 98195 Midland, Michigan 48640 Dr. H. Stanley Livingston 1005 Calle Largo Santa Fe, New Hexico 87501 Counsel for NRC Staff Office of the Executive Legal Director U.S. Nuclear Regulatory Commission
\*iashington, D. C. 20555}}