ML19289E923

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Submits Supplementary Answers to Applicant'S Second Set of Interrogatories.Affidavit Encl
ML19289E923
Person / Time
Site: Zimmer
Issue date: 03/13/1979
From: Kosik L, Rigberg S
KOSIK, L. S., MIAMI VALLEY POWER PROJECT
To:
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ML19289E924 List:
References
NUDOCS 7905290464
Download: ML19289E923 (6)
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Text

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MAR 3.91973>SI q;;ffiW ,[,

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NUCLEAR REGULATORY COMMISSION In the Matter of  :

THE CINCINNATI GAS & ELECTRIC COMPANY, et al. Docket No. 50-358 (Wm. H. Zimmer Nuclear Station)  :

MIAMI VALLEY POWER PROJECT'S SUPPLEMENTARY ANSWERS 'IO APPLICANT'S SECOND SET OF INTERROGATORIES The Miami Valley Power Project submit the following answers to the Applicant's second set of interrogatories. These responses were prepared by Saul Rigberg, a member of the Miami Valley Power Project. Mr.

Rigberg's address is 536 Howell Street, Cincinnati, Ohio 45220. Mr.

Rigberg's occupation and employer are irrelevent to these proceedings, and therefore the Miami Valley Power Project objects to these questions.

INTERROGATORIES 1-3 The Miami Valley Power Project is not required to answer interrogatories 1 through 3. See order of the Atomic Safety and Licensing Board dated February 22, 1979.

INTERROGATORY 4 The Council on Economic Priorities has recently reported that the United States can double its GNP by the year 2000 without appreciably increas-ing energy usage. The U.S. government has also stated that by the year 2000 2053 305 79052 909ff 8

solar energy will provide 20% of the nation's energy needs. Jicrny Cart.er has stated that energy waste in generating electricity is 65%.

Implementation of conservation measures would serve to provide any additional energy needs.

5. No. This is presently being studied and will be reported when the infonnation has been obtained. The answer to this question will be affected by the potential use of conservation measures.
6. The Project contends that no capacity additions will be required for any year between 1978 and 1985. Conservation and most important,1y alternate sow ces of space heating will alleviate the need for additional capacity. See attachment 1.
7. According to the Edison Electric Institute a 20% reserve margin is sufficient for operating utilities. See the Institute's report for methodology, assumptions, and calculations.
8. The expert witnesses have not yet been detennined. This answer will be updated when the determination has been made.

9 Preliminary i formation shows that uranium is a limited re-source, that no new ore-producing areas hwe been discovered in the past 17 years so that uranium will run out, that the potential supply from known reserves of uranium is insufficient to satisfy project demand in the Western world as a whole beyond 1979 and that very large shortfalls in supply may be anticipateo in the first half of the 1980's. Source:

Friends of the Earth, 529 Commercial, San Francisco, California 94111.

Also, a 1975 Government repc- t said there is not enough uranium to support the atomic industry for more than another 15 years.

10. No infonnation for foreign or worldwide nuclear power generation stations.

2L: 3 306

11. See the answer to question 9 Over the past several years the

i price of uranium has increased 600% since 1973 and is now over $40.00 per ,

pound, a

12. See the answer to q2estion 9 ,

13 Estimates of the price of uranium were not utilized in the' '

Project's projection of available fuel supply.

14. The Project has no information that'uraniun has already been 3

purchased for the Zimmer Station. Furtherm de, recent legal action in regard to Westinghouse Electric Co. as a supplier of uranium shows that such purchase contracts may be in danger of breach. .

15. See the answer to question 8.
16. The original estimated cost of building the Zimmer Station was

$201 million. The estimated cost has already ' risen to $700 million.

Other problems recently discovered by the NRC will pmbably increase those costs even further. Furthemore, the costs of waste disposal and decom-missioning the plant must be considered.

17. See the answer to question 16.
18. Decomissioning the plant; cost of uranium; waste disposal; unforeseen problems that occur; the lower-than-estimated level of effi-ciency of the plant's output.

19 The only way the applicant will have the financial capability tr operate the plant is through rate increases. Bate increases cannot be assumed because it would not be justified to rbss onto the consumer inefficiency and cost overruns. ,

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20. , Because of the constant addition of rrowic bsts to the estimated costs of construction and operation (see the answer to question 18) it is impossible for the Project to estimate the complete coats at this time.
21. See the answer to question 8. 2[ jQ[
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42 to Saul Rigberg, being sworn, says that he is a member of the Miami Valley Power Project, that he has been chosen by the MiamiValley Power 

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Project to respond to the foregoing interrogatories on behalf of the 

    - rilami Valley Power Projects, that the foregoing answers to the interroga-tories are true as he believes and according to the information known and available to the Miami Valley Power Project.
         .                                             k%Y ,'$          fic.

SAUL RIGBCRG p,// 

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Sworn to and subscribed to in my presence this / ~iday of k e .A , 1979. s i hg)' f f NO Y PUBLIC WF FLD?f AN, JRe ~ j ot

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Nmarv . I'i bl.c. siste of Ohio My Cummi n o tu, no expiration date AS 'ID OBJECTIONS: 3,ui.,o 14 7 03 E. C. h M% N' $ 'n:c:,3 

                                                             ~b LEAH S. KOSIK
                                                                                ':    f.                   t Attorney for Miami Valley Power Project 3454 Cornell Place Cincinnati, Ohio 45220 j                                            ;; 5 508 s

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