ML19289F050

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Response in Support of Commonwealth of Ma Second Motion to Suppl Record on Need for Power Issue.Requests ASLB Allow Addl Testimony Be Filed by 790518.Supporting Documentation & Certificate of Svc Encl
ML19289F050
Person / Time
Site: 05000471
Issue date: 04/25/1979
From: Beverly Smith
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
References
NUDOCS 7906010144
Download: ML19289F050 (15)


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UNIIED STAIES OF AMERICA NUCLEAR REGULATORY COMMISSION 4/25/79 FRC PUBLIC DOCGIEV2 BGCM BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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BOSTON EDIS0N COMPANY, et al.

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Docket No. 50-471 (a;

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(Pilgrim Nuclear Generating

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Station, Unit 2)

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e NRC STAFF RESPONSE IN SUPPORT OF SECOND MOTION OF THE COMMONWEALTH OF MASSACHUSETTS TO SUPPLEMENT THE HEARING RECORD ON THE "NEED FOR POWER" ISSUE The Commonwealth of Massachusetts through its Attorney General filed a "Second Motion of the Commonwealth of Massachusetts to Supplement the Hearing Record on the "Need for Power" Issue. (Motion) The Staff has conducted its ownindependentreYiewofthisissueandforthereasonsfoundbelowsupports the Commonwealth's Motion.

The Staff agrees with the Applicant's position that the Comonwealth's Motion is improperly characterized as one to supplement the record. Theehidentiary reccrd in this proceeding has been closed on the need for power issue since July 1, 1977.

(Tr.8804,8805). Therefore, the Commonwealth must meet the standard for reopening the record.

The question is what standard should be applied in this case where an initial decision has not been rendered. The Applicant's standard for reopening the record is will the new information likely result in a difterent conclusion.

(Applicant's Response pg. 4).

This is the appropriate standard 790601014I y

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' when a decision has been rendered. NorthernIndianaPublicSerUice Company (Bailly Generating Station Nuclear-1), ALAB-227, 8 AEC 416, 418 (1974), See also: Public Service Company of New Hampshire, ej al.

(Seabrook Station, Unit 1 and 2), ALAB-422, 6 NRC 33, 81 (July, 1977).

The Staff position is that where an initial decision has not been renderer!

on an important environmental issue, the record should be reopened to receive updated testimony if "there is good reason to believe that there may have been an appreciable, and material, change in the factual situation." (Footnote omitted) Commonwealth Edison Tompany (LaSalle County Nuclear Station, Units 1 and 2), ALAB-153, 6 AEC 821, 824 (1973).

The Staff does not agree with all of the reasons offered by the Commonwealth for reopending this record. Specifically, a changa in the growth rate alone is not a material change when considering the need for the plant.

However, if this change suggests a significant change in the time frame for bringing the unit on line, then a Board should take this i.nformation into account prior to rendering its initial decision.

In June 1977, the Staff concluded that Pilgrim Unit 2 will be needed in 1985.

(Pg. 11 following Tr. pg. 8150). The material change in the factual situation n this proceeding is that the Staff's independent forecast now shows that Pilgrim Unit 2 is now less likely to be needed in 1985.

The mostly likely date that Pilgrim Unit 2 will be needed is the winter of 1988-89.

(SeeattachedaffidahitofDr.Feld). The forecast is based 2234 193 s

on the capacity plans presented in the NEP00L For.ecast for New England 1979-1989 and on the regional econometric forecasting model developed by the Oak Ridge National Laboratory (ORNL). This model is described inDr.Feld'saffidavitanditwasprehiouslyusedtodeYelopthefore-cast presented by the Staff in June, 1977. Since that time, it nas undergone further refinements.

(See Feld Affidavit).

Dr. Feld presents a range for projected growth in electricity demand for the NEP00L System. Each scenario is based on an assumption concerning the price of electricity. The scenarics reflect the fact that forecasts are subject to uncertainty. The uncertainty of demand forecasts,has long been recognized by the Appeal Board. Niagra Mohawk Power Corporation, (Nine Mile Point huclear Station, Unit 2), ALAB-264,1 NRC 347, 365 (1975).

Because there is a range of forecasts, the Staff's prior conclusion that it is prudent to plan to add Pilgrim Unit 2 as scheduled is not changed.

(FeldAffidahit).AlthoughtheconclusionsoftheStaffregardingneed hahenotchanged,theresultsofthenewdemandforecastdorep' resent

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a material change in the factual situation relating to timing of the plant.

Since the Board has not issued a decision on this issue, it is incumbent upon the Board to allow the record to reflect the most up to date information.

If the Board rules in favor of the Commonwealth's motion,.the Staff can provide updated testimony by May 18, 1979 and make a witness available on May 30, 1979. Although this is not within the filing requirements of the rules, the Staff requests, pursuant to 10 CFR 62.743(b) that the 2234 194

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Boardwaihethisrequirementinlightofthefactthattheparties haveinhandthe!1EP00Lreport,andtheStaff'saffidahit. The Staff and Applicant may supplement this chaluation but the majority of testimony would be in the hands of tr.a parties and Board well before May 18, 1979.

In conclusion, the Staff supports the Commonwealth's Motion and requests that the Board allow additional testimony to be filed by May 18, 1979.

Respectfully submitted,,

7 Barry H. Smith Counsel for f1RC Staff Dated at Bethesda, Maryland this 25th day of April, 1979.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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BOSTON EDIS0N COMPANY, et al.

Docket No. 50-471 (Pilgrim Nuclear Generating

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Station, Unit 2)

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AFFIDAVIT OF SIDNEY E. FELD I, Sidney E. Feld, being duly sworn, do depose'and state:

1.

I am a Regional Environmental Economist with the Cost-Benefit Analysis Branch, Division of Site Safety and Environmental Analysis, U.S. Nuclear Regulatory Commission.

2.

My Professional Qualifications are found following Tr. pg. 8150 in this proceeding.

3.

As a part of my duties, I have prepared an analysis of the need for Pilgrim Unit 2 in light of the latest data submitted by NEPLAN (New England Load and Capacity Report, April 1979) and the independent assessment of demand growth based on tne Oak Ridge National Laboratory Regional Econometric Model for Forecasting Electricity Demand by Sector and by State. My review is found below.

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4.

In June 1977 the statt presented testimony at the P1 melm Unit 2 hearings on the need frr additional capacity on the New England Power Pool (,'1EP00L) system. At tnat point in time the staff concluded that "the entire range of peak load projections reviewed show that the unit will be needed by the winter of 1985, or about one year later than presently proposed." And that this was... "within a reasonable time frame of the proposed operation date such that it is prudent for the applicant to bring the unit on-line as scheduled."

5.

The January 1977 submittal by New Englan'd Power Planning (NFPLAN) which sets forth the NEP00L demand projections and capacity planning was heavily relied on in the preparation of this testimony.

3l 6.

In the beginning of 1978 the staff received a similar NEPLAN submittal and reviewed it for factual changes and possible impacts on our earlier conclusion. Based on that review the staff concluded that the unit was still needed by the winter of 1985.

.7.

In April 1979 the staff received a copy of NEPLAN's 1979 submittal on load and capacity.

The NEPLAN report still supports a 1985 commer-cial on-line date and in fact indicates that from a reliability perspec-tive the need for Pilgrim Unit 2, is even greater than that estimated in their 1977 and 1978 filings.

8.

The major changes between the 1979 and 1978 NEPLAN reports are; 2234 197

' 1.

Pilgrim 2 has officially been delayed another one-half year --

from June 1985 to December 1985.

2.

Total planned NEP00L capacity for the winters of.1985/86,1986/87, and 1987/88 has been reduced by 349 MW, 2082 MW, and 464 MW, respectively. The major elements contributing to these changes are depicted in the table below:

MAJOR CHANGES EFFECTING NEP00L PLANNED CAPACITY FOR THE WINTER 1985/86 THRU 1987/88 CHANGE YEAR 1985/86 1986/87 1987/88

!E.

1-Retirement of Edgar units

-267

-267

-267 2-Rerating of Pilgrim Unit 2

- 30

- 30

- 30 3-Schedule Slippage of Sears Island

-568 4-Schedule Slippage of NEPC0 #1

-1150 5-Schedule Slippage of Cold Steam #1

- 83.3 TOTAL 297 2015 380.3 3.

Winter peak demand is now forecasted to grow at an annual com-pound rate of 3.8% for the period 1979-89, which compares with a 4.5% growth rate in the January 1978 report. However, because NEP00L is projecting faster growth over the first-half of the forecast period, (1979-84 = 4.5% per annum, 1984-89 = 3.1% per annum) the actual peak load forecasts in the 1985-86 to.1987-88 period are not appreciably different.

Latest projections for the winters of 1985/86,1986/87, and 1987/88 are 22 MW greater, and 173 MW and 451 MW less than those projected in the previous report.

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.a-9.

A.-i aiculation of estimated reserve margins based on NEP00L's latest peak demand forecast and capacity planning (without Pilgrim Unit 2 and New England Power Unit 1)follows.

It should be noted that from 1985 thru 1987 a reserve margin of 23% of peak load will be needed to meet NEP00L's system reliability criteria. Thus, from NEP00L's perspec-tive, Pilgrim Unit 2 will still be needed by 1985.

NEP00L WINTER PEAK, CAPACITY & RESERVE MARGINS 1985/86 thru 1937/88 RESERVE MARGIN AS PEAK DEMAND (MWe)

TOTAL CAPABILITY (MWe)

A~ % OF PEAK DEMAND YEAR NEP00L PROJECTIONS WITHOUT PILGRIM UNIT 2 (WITHOUT PILGRIM 2) 21502 24719 15.0 1985/86 1986/87 22267 25654 15.2 1987/88 22989 26121 13.6

10. Staff Analysis Since the NRC's previous review of Pilgrim, Unit 2, the staff has further refined its independent forecasting capability. The staff's forecast of demand for electrical energy is based on a regional econometric fore-casting model developed by the Oak Ridge National Laboratory (ORNL).

The ORNL model, which forecasts electricity demand and price through 1990, uses a system of simultaneous equations and contains submodels for residential, commercial, and industrial sectors. Structural para-meters were estimated for nine census regions, including New England, using state level data for 1955 through 1974.

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Electricity demand and price are forecast for each State within the 11.

New England region by inputting economic and demographic variables to the model. Assumptions of growth in population, residential customers and real per capita income are based on projections made by the National Planning Association. Growth of value added in manufacturing is based on projections made by the Federal Energy Administration while projections of commercial and industrial customers are based on extrapolation of historical trends. Assumptions on future fuel prices were varied to capture the uncertainty inherent in forecasting future demand for power.

The base case assumptions of future fuel prices are derived from the Hudson and Jorgenson projections. of fuel prices.

The model also considers forecasts of electrical energy demand resulting from higher and lower fuel costs relative to those assumed in the ORNL base case projections.

In the low price case it is assumed that energy prices will increase at the same rate as the cost of living index, and in the high price case, all price and cost components relative to the base case are assumed to double in real terms. The results for the NEP00L service area are annual compound growth rates in electrical energy re-quirements between 1977-1990 of 3.4% under the base case, 4.1% under Staff the low pice scenario, and 2.7% under the high price scenario.*

has projected peak load to grow at the same rate as energy requirements using the NEP00L assumption of 61% load factor.

As derived in the New England Power, Units 1 and 2, PDES, April, 1979 NOTE, the staff views this entire forecast range as a reasonable index of future growth.

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12. Contrasting the Staff's peak load forecast with Nepool's latest planned capability indicates that Pilgrim Unit 2 will be needed for reliability purposes by the winter of 1985/86 only if the high end (low price scenario) of the Staff's forecast range is realized. Under the base case scenario need occurs by the winter of 1988/89,3 years later than proposed, and at the low end of the Staff's range (high price scenario) need occurs by the winter of 1991/92. This assessment assumes all NEP00L planned and authorized additions through the winter of 1989/90 come on-line as scheduled, with the excegtion of Pilgrim Unit 2 and New England Power, Units 1 and 2 (NEP 1 and 2).

NEP 1 and 2 have been excluded because these units are still in the construction permit li-censing stage and are scheduled to be added subsequent to Pilgrim 2.

13. The Staff's peak load projection, NEP00L capability as discussed above, and resulting reserve margins follows:

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. TABLE 3 ---- NEP00L WIllTER PEAK, CAPACITY AND RESERVE f1ARGIflS 1985/86 TilRU 1991/92 k

<m PEAK DEMAfl0 (MWe)1 TOTAL CAPABILITY (MWe)4 RESERVE MARGIN AS % OF PEAK DEMAND N

(WITHOUT PILGRIM UNIT 2 AND NEP 1 & 2)

N HIGH PRICE BASE CASE LOW PRICE (WITHOUT PILGRIM UNIT 2 HIGH PRICE-BASE CASE LOW MI"@

f*

YEAR SCENARIO SCENARIO SCENARIO AND NEP 1 & 2)

' SCENARIO SCENARIO SCENfy),

1985-86 18,478 19,510 20,592 24,719 33.8 26.7 E0.0 1986-87 18,977 20,173 21,436 25,654 35.2 27.2 1). /

1987-88 19,489 20,859 22,315 26,121 34.0 25.2 17.1 1988-89 20,015 21,568 23,230 26,122 30.5 21.1 12.4 1989-90 20,556 24,182 24,182 26,124 27.1 17.1 8.0 1990-91 21,111 25,174 25,174 26,124 23.7 13.3 3.8 1991-92 21,681 26,206 26,206 26,124 20.5 9.6 0.9 1 Source-Based on Regional Econometric Model for Forecasting Electricity Demand by Sector and by State, Oak Ridge National Laboratory, Oct.1978 - Peak Load projections are as reported i

in New England Power PDES, April,1979, Chapter 8.

2 Source-New England Load and Capacity Report - 1978-1989; NEPLAN, April, 1979-Note-No capacity cha,nges are reported for the period after 1989/90.

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14. The Staff concludes that the most probable time of need will be the winter of 1988/89 but that there is a reasonable but less likely possibility the plant will be needed as early as 1985 or as late as 1991. Based on this review, the Staff still believes it is prudent to plan to add Pilgrim Unit 2 as scheduled.

/

m Sidney E. Feld

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Subscribed and sworn to before me this 4.[ day of hn.t((

,1979

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$be km vW

.// Notary P0blic

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My Commission expires:

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FCOTNOTES 1/

N.R.C. Staff Supplemental Testimony of Sidney Feld and Darrel Nash relating to Chapter 8 of the Pilgrim FES and the previousltestimony of Darrel Nash on Need for Power, June 1977, page 11.

2/

New England Loaa and Capacity Report, 1976-87, NEPLAN, January 1, 1977.

3/

New England Load and Capacity Report, 1977-78, NEPLAN, January 1, 1978.

4/

New England Load and Capacity Report, 1978-79, NEPLAN, April 1, 1979.

j/

Regional Econometric Model for Forecasting Electricity Demand by Sector and by State, Oak Ridge National Laboratory, NUREG/CR-0250, October, 1978.

f/

E. A. Hudson and D. W. Jorgenson, "U. S. Energy Policy and Economic Growth, 1975-2000," Bell J. Econ. Manage. Sci. 5: 461-514 (Autumn 1974).

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UtlITED STATES OF N; ERICA fiUCLEAR REGULATORY C0:1:415S101

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BEFORE THE ATOMIC SAFETY AtlD LICEilSIt!G BOARD

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In the Matter of

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BOST0:4 EDIS0:1 COMPNiY, et al.

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Docket flo. 50-471 (Pilgrim fluclear Generating Station, Unit 2)

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CERTIFICATE OF SERVICE 1 hereby certify that copies of "flRC STAFF RESP 0tiSE Ill SUPPORT OF SEC0fiD MOTI0l10F THE C0:i'0fNEALTH OF MASSACHUSETTS TO SUPPLEMEflT THE HEARItiG RECORD Oil THE.'tiEED FOR POWER' ISSUE", in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the fluclear Regulatory Commission's internal mail system, this 25th day of April,-1979:

  • Edward Luton, Esq.

Henry Herrmann, Esq.

Atomic Safety and Licensing Board Room 1045 U. S. fluclear Regulatory Commission 50 Congress Street Washington, D. C. 20555 Boston, Massachusetts 02108 Dr. A. Dixon Callihan Mr. and Mrs Alan R. Cleeton Union Carbi.de Corporation 22 Mackintosh Street P. O. Box Y Franklin, Massachusetts 02038 Oak Ridge, Tennessee 37830 The Board of Selectmen

  • Dr. Richard F. Cole Town of Plymouth Atomic Safety and Licensing Board Plymouth, Massachusetts 02360 U. S. liuclear Regulatory Commission Washington, D. C. 20555 William S. Abbott, Esq.

50 Congress Street, Suite 925 George H. Lewald, Esq.

Boston, Massachusetts 02109 Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Michael B. Meyer Assistant Attorney General Dale G. Stoodley, Esq.

Utilities Division Boston Edison Company Public Protection Bureau 800 Boylston Street One Ashburton Place Boston, Massachusetts 02199 19th Floor Boston, Massachusetts 02103 2234 205

2-

  • Atomic Safety and Licensing
  • Docketing and Service Section Appeal Board Office of the Secretary V. S. fluclear Regulatory Commission U. S. fluclear Regulatory Commission Washington, D. C.

20555 Uashington, D. C.

20555

  • Atomic Safety and licensing Board Panel V. S. fluclear Regulatory Ccmmission Laurie Burt, Esq.

Washington, D. C.

20555 Assistant Attorneys General Commonwealth of Massachusetts Mr. Lester B. Smith Enviror. mental Protection Division Director of Conservation One Ashburton Place,19th Floor Massachusetts Wildlife Federation Boston, Massachusetts 02108 P.O. Box 343 fiatick, MA 01761 Francis S. Wright, Esq.

Stephen M. Leonard, Esq.

Assistant Attorneys General.

Environmental Protection Division Public Protection Bureau One Ashburton Place, 19th Floor Boston, Massachussetts 02108 Barry41, 5mith Counsel for flRC Staff 4

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