ML18108A679
| ML18108A679 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/19/1976 |
| From: | Bivans E Florida Power & Light Co |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| Download: ML18108A679 (21) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION tl-lf BEFORE THE ATOMIC S2G'ETY AND'ICENSING BOARD In the Matter of
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FLORIDA POWER
& LIGHT COMPANY
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(St. Lucie Plant Unit No.
2)
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DOCKET NO. 50-389 APPLICANT~S ANSWERS TO INTERVENOR~S INTERROGATORIES TO APPLICANT SET NO.
5
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APPLICANT'
RESPONSE
TO INTERVENORS INTERROGATORIES TO APPLICANT SET NO 5
Question 1:
Are electricity and competitive fuel prices of significant relevance in determining electricity usage as a general matter?
Answer:
Yes.
See testimony of Louis A.. Guth, P. 6, follows TR 381 (hereafter Guth, page 9).=
Question 2:
Is it possible to make an assessment of the impact of elec>>
tricity and competitive fuel prices on the future growth of demand for electricity in the FPL system?
Answer:
Yes.
See Guth, P. 9.
Question 3:
Have electric utilities such as FPL traditionally conducted studies designed to consider the potential scope of the impact of energy prices of future consumption'2 If affirmative, please identify any such studies conducted by FPL, by title, authqrp and author'-educational and experiential qualifications.
Answer:
No.
See Guth, P.
9.
Question 4:
If the response,.to No.
3 is negative is this a serious failure on the part of FPL? If not, why not?
Answer:
No, traditionally, prior to 1973, electric demand was increasing at such a rapid predictable rate that such studies were not necessary.
See Guth, P. 10.
Question 5:
Has FPL performed or do they have available to them studies that indicate at what rate. personal incomes may be expected to rise in relationship to costs of electricity' Answer:
No.
Question 6:
If the response to interrogatory 5 above is affirmative, has FPL experience in the past. three years 1973-1976 confirmed or negated the findings the FPL studies and projections on rate of increase of personal
- incomes, as they relate to electricity costs?
Answer:
Not applicable.
Question 7:
Is it true that available economic studies of electricity demand are generally seriously flawed?
Answer:
Unless the specific studies in question are identified, we cannot answer this interrogatory.
Question 8
If affirmative to 7 above has FPL or its.consultants prepared a review of such studies or innovated their own accurate studies so as to accurately project consumer demand for elec-tricity?
Answer:
See answer to interrogatory 2(a), Answers to Intervenor's Interrogatories to Applicant, Set No. 3.
(
Question 9:
At what date was the review referred to in 8 above prepared.
Does it accurately represent trends in demand occurring the FPL system'ince 1973 till the present date'?
Answer:
The most recent study was completed in October, 1976.
See Answer to Interrogatory 2(a), Answers to Intervenors Interrog-atories to Applicant, Set No. 3.
Question.10:
Does FPL have available to it or have any studies been performed by FPL or its consultants that show the effects of personal income on electrical consumption?
Answer:
The effects of personal income on electrical consumption are deteimined asan integral part of our forecasting effort.
No study as such is performed external to the forecasting process.
This method of assessing the impact of personal income on energy consumption is used nationwide by many utilities and consultants.
Question ll:
Xf affirmative to 10 above, what do these studies show and who authorised them?
Answer:
The official 1976 net energy forecast incorporated as an explanatory variable an economic index comprised of real per capita income (in constant 1967 dollars) and employment.
The elasticity of this variable with respect to net energy was estimated at 0.7 for the 1975 through 1985 period.
Richard P. Sergei, Supervis'or of Load Forecasting was responsible for the net energy forecast.
Question 12:
Does FPL have available to it or have studies been performed by FPL that include a variable for price of competing fuel?
Answer:
No
Question 13:
Does FPL have available to it or'do any studies performed by FPL on projecting rates of growth of electrical consump-tion including:
a) climate variables in their analysis b) urban-rural differance in consumption c) climatic changes presently occurring Answer:
a)
Yes b)
No
')
We are not aware of any climate changes presently occurring which we nave not considered in (a)
Question 14:
What is the rate of sales per customer for the FPL system for each region in 1975, the regions being Northern, Western,
- Eastern, Southeastern and Miami?
Please constrast these rates with those that have-occurred for each respective year since 1970.
Answer:
AVEEQ,GE KWH PER CUSTOMER 1970 1971 1972 1973 1974 1979 Northern 179236,18 ~543 199315 219166 209028 209937 North Central 23,961 23,898 23,628 23,595 21,011 21,318 Western Eastern Southeastern r Miami 16,516 17,093 17,746 18,786 17,805 18,153 17,670 18,385 189769 19g091 17,720 17,896 15,881 16,672 17,673 18,598 17,522 17,349 20,134 21,229 22,348 22,987 22,117 22,164
.Question 15:
s In which of the above regions is the service area for St. Lucie 2?
Answer:
On general power from St. Lucie 2 will be consumed in the Eastern Division.
However, through its interconnected transmission system it is also available to FPL's entire system.
Question 16:
To what do you attribute the rate of change if any between 1972 and 19757 Answer:
It is unclear as to what "rate of change" refers to.
Question 17:
50.69 49.11 45.02 44.85 I
How do FPL rates compare with those in other states' Answer:
COMPARISON OF FPL'S RESIDENTIAL RATES FOR 1000 KAH WITH THOSE OF OUT-OF-STATE UTILTIES*
I 1.
Consolidated
- Edison, New York
$ 77.56 2.
Public Service Electric
& Gas, New Jersey
. 54.31 3.
Philadelphia Electric Co., Pennsylvania 4.
The Cleveland Elec. Ilium. Co., Ohio 5.
Long Island Lighting Co.,
New York 48.62 6.
Atlantic City Electric Co.,
New Jersey 48.28 7.
Pascoag Fire District.-Electric, R. I.
47.00 8.
=- City of Dover (McKee Run), Delaware 46.28
,9.
Delmarva Power
& Light Co., Delaware 45.42 10.
Delmarva Power
& Light Co., Maryland 11.
Boston Edison Co., Massachusetts 12.
Delmarva Power
& Light Co., Virginia 44.60 13.
Arizona Public Service Co., Arizona
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43.57 14.
Commonwealth Edison, Illinois 42.36 15.
San Diego Gas
& Electric Co., California 42.34 16.
City. Public Service, Texas 40.86
17.
Detroit Edison Company, Michigan 18.
The Connecticut Light & Power, Conn..
19.
Baltimore Gas
& Electric Company, Maryland 20.
- Water, Gas
& Light Company, Georgia 21.
Dallas Power
& Light Co., Texas 22.
Public S'ervice Company of New Hampshire, N.H il 23.
Union Electric Co., Missouri 24.
Florida Power
& Light Company, Florida 25.
Southern California Edison
- Company, Cal.
26.
The Hartford Electric Light Co,, Conn.
27.
Monongahela Power Co., Nest Virginia 28.
Western Massachusetts Electric Co., Mass.
29.
High Point Electric Dept., North Carolina 30.
Department of Water
& Power, California
- 40. 85
- 40. 76 40.31 40'8 37'9
.37.45 37.38 37.37 37.17 36.66 36.65 36.64 34.52 33.21 i
- F3.gures are for October,
- 1976, and do not include taxes, or franchise fees.
Fuel adjustment charge is included.
31.
Mississippi Power Company, Mississippi 32.
Appalachian Power Co., Virginia 33.
Alabama Power Co.
< Alabama 34.
Bangor Hydro-Electric Co., Maine 35.
Georgia Power Co., Georgia 36.
Houston Lighting
& Power Co., Texas 37; Pacific Gas
& Electric Co., California 38.
Electric Power Board of Chattanooga, Tenn.
39.
Memphis Light, Gas,
& Water Div.; Tenn.
$32.28 31.68 30.40 30.16 29.79 29.47 28.31 26.80 26.18 AVERAGE RESIDENTIAL RATE =
$ 40.07 Source:
Jacksonville Electric Authority, COMPARISON OF RESIDENTIAL ELECTRIC RATES, October, 1976
QUESTION 518:
How do FPL electric rates compare with other Florida utilities?
ANSWER:
COMPARISON OF RESIDENTIAL RATES FOR 1000 KWH FOR FLORIDA UTILITIES*
2.
3-4 ~
Clay Electric Cooperative (Clay Gainesville-Alachua Reg. Util.
City of.Leeshurg Kissimmee Utilities 5.
City of Tallahassee 6.'ity of Green Cove Springs 7.
Florida Power Corp.
8.
City Electric System (Key West) 9.
City of Vero Beach 10.
Sehring Utilities ll.
City of Jacksonville Beach 12.
City of Bartow Electric 13.
Tampa Electric Company 14.
City of Pt.
Meade County)
$46.27 44.33 44.29 43.93 43.49 43.40
- 43. 16 42.74 42.53 42.49 42.25 41.46 41.25 41.07
+Figures are for October p
1976$
and do not include taxes f or franchise fees.
Puel adjustment charge is included.
15.
City of Clewiston 16.
City of Ocala 17.
'Okefenokee
- REA, (N.E. Fla.,
& S.E.
Georgia) 18.
City of Lakeland 19.
Jacksonville Electric Authority 20.
Florida Power
& Light Company 21.
Orlando Utilities Commission
$41.00 40.45 39.25 38.&7 37.38 37.37 34.8&
AVERAGE RESZDENTXAL RATE =$ 41.52 Source: 'acksonville Electric Authority, COMPARISON OP RESIDENTIAL ELECTRIC RATES, Coctober, 1976
QUESTION 019:
How will FPL's
$ 349 million dollar rate hike request before the Florida Public Service Commission (PSC).- affect their standing in comparison with other Florida and National utility rates if'it be granted by the Florida PSC?
ANSWER: FPL's proposed residential rate for 1000 KHH would be
$40.89.
This figure does not include franchise fees and taxes, but does include a fuel adjustment credit of $2.01 for nuclear<<generated power.
FPL's rate would still be below the average for Florida of $41e52 and on a par with that for other states of $40.07.
(See answers to interrogatories 17 and 18 above.)
By the time FPL's increase is gxanted, these averages may well have risen since some, of these other utilities have pending rate increases, and others will be asking for them.
Question 20:
Xn 1974 Mr. Gerber testified for FPL that "average annual growth in residential customers through 1980 of 7 percent is not an unrealistic expectation."
Zn light of the recent rates of growth experienced by FPL from 1973 to 1976, what rate of growth of residential customers is projected from 1977 to 1987 by FPL?
Answer:
'he average annual growth rate of residential customers is prospected by FPL to be 4.4 percent for the years 1977-1987.
Question 21:
0 Please constrast the relationship of the forecasted range of growth of electrical sales to the growth of peak load as stated in Response 02 of Applicants Answers to Zntervenors Interrogatories Set No. 3.
Answer:
The following shows the net energy for load and peak load forecast.
Net Energy/For Load
" (N.119.on ma)
Peak Load (Me awatts)
Year 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 Low 37,900 39,330 41,100 43i070 45i270 47 i440 49i580 51,660 53i670 55,600
~HI.
37,,900 41,110 44t450 47,870 S1,360 54,910
'58,470 61,580 64,580 67,420 Low 7>598 7i950 8g3SO 8,780 9,210 9,640 10,060 10,470 10,870 11,250 7,598 8,230 8 F880
',540 10,200 10,860 lli500 12,120 12t710 13,270
Question 22:
Xn Response 021 of Applicants Answers to Xntexvenors Xnterrogatoxies to Applicant Set No. 3, FPL states the earliest possib2.e in-service date St. Lucie Ho.2 at Butchinson Xsland is now late 1982.
What is the earliest possible in-service dates for the following sites of a comparably sized nuclear plant?
a.
DeSoto site.
b.
South Dade site.-
c.
Martin County site, a. fossil units,
- b. nuclear units.
d.
any other FPL sites?
Answer:
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The earliest possible in-service dates for a compaxably si.zed nuclear unit at different locations, assuming that the sites axe suitable for nuclear units and there
- delays, axe as follows:
a.
DeSoto site - Late 1988 to early 1989 b.
South Dade Site - Late 1985 to early 1986 c.
Martin County site - Fossil Unit - Early 1984 Nuclear Unit - Late 1988 to early 1989 d.
Any other FPL sites-FPL owns no other sites at the present time which, can accommodate a nuclear unit.
Question 23:
PPL refers to a rescheduling of oil burning generation which is now under construction which might have occurxed had not there been a delay in securing permits and licenses to start construc-tion of St. Lucie No.
2 in the Response 021 of Applicants Answers to Intervenors Interrogatories to Applicant Set No. 3.
Please explain both the current construction schedule commitments of rescheduled fossil uni,ts such as Palatka and Martin and how any delays of St. Lucie No.2 have affected the fossil plants construction schedules'nswer:
The Martin Plant has been a;ffected by the delay of St'. Lucie 02 from late 1979 to late 1982.
Zf St. Lucie 02 had not been delayed, unit
.1 at our Martin Plant would not be needed until the peak of 1982.
Question 24:
Please state and identify all fossil generating plants presently under deferral in the FPL system.
Please indicate projected in-service dates and identify the plant by name, location and generating capacity.
Answer:
See Intexrogatory O5 of Appli,cant Answers to Intervenors Interxogatori,es Set No. 3.
FLORIDA POWER
& LIGHT COMPANY ByErnest L. B3.vans, V3.ce-Pxes3.dent System Planning Department STATE OF FLORIDA
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COUNTY OF DADE
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II ERNEST L. BIVANS, being first duly sworn, deposes and says:
That he is Vice President of System Planning of Florida Power 8 Light Company, the Applicant, herein; That he has executed the foregoing document, that;the statements made in this said document are true and to the best. of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Applicant.
Subscribed and sworn to before me this day of November, 197 NOTARY PUBLICA an State of Florida LCy commission expires:
or th County of Dade, NOTARY PU5UC STATE QF iLCNGh AT LOGS AÃCOLVAL55ChlEXttR5 NOV, 30 1979 bQHOED TH
CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Interrogatories to Intervenors, etc.,
has been served by mail, this W day of November, 1976, to the following:
Edward Luton, Esquire
- Chairman, Atomic Safety
& Licensing Board Panel U. S. Nuclear Regulatory Commission.,
Washington, D. C.
20555 Michael Glaser, Esquire Alternate Chaixman Atomic Safety
& Licensing Board Panel 1150 - 17th Street, N. W.
Washington, D. C.
20036 Dr. Marvin M. Mann, Technical Advisor Atomic Safety 6 Licensing Board Panel U. S. Nuclear Regulatory Commission
'ashington, D. C.
20555 Dr. David L. Hetrick Professor, Nuclear Engineering University of Arizona Tucson, Arizona 85721 Dr. Frank F. Hooper, Chairman Resource Ecology Program School of Natural Resources University of Michigan Ann Arbor, Michigan 48104 Local Public Document Room Indian River Junior College Library 3209 Virginia Avenue Fozt Pierce, Florida 33450 Mr. C.
R. Stephens, Supervisor Docketing and Service Section Office of the Secretary of the Commission, U. S. Nuclear Regulatory Commission Washington, D. C.
20555
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Mr. Roger S.
Boyd Division of Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Alan S. Rosenthal, Esquire
- Chairman, Atomic Safety
& Licensing Appeal Panel U. S. NucXear Regulatory Commission Rashington, D. C. 20555 Edward G. Ketchen, Esquire Richard K. Hoefling, Esquire Counsel for NRC Regulatory Staff U. S. Nuclear Regulatory Commission Nashington, D. C.
20555 Martin Harold Hodder, Esquire 1131 N. E. 86th Street Miami, Florida 331'38 STEEL HECTOR
& DAVXS Co-counsel for Applicant 1400 S.E. First National Bank Building Miami, Fl rida 33131 '(577-2864)
By:
NORMAN A COLL
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