ML19290B828

Response to Third Set of Interrogatories.Submits Info Re Sale of Conservation Retrofits,Sale of Eletricity by Applicant,Passive Solar Technique & Cost of Passive Retrofit.Certificate of Svc Encl

ML19290B828
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/07/1979
From:	Clay Johnson TEXAS PUBLIC INTEREST RESEARCH GROUP
To:	HOUSTON LIGHTING & POWER CO.
Shared Package
ML19290B819	List: ML19290B818 ML19290B828
References
NUDOCS 7912140188
Download: ML19290B828 (6)

Text

. . .

NUCLEAR REGULATORY COMMISSION, UNITED STATES A.S.L.B.

In the Matter of <

Docket #50-466 HOUSTON LIGHTING & POWER CO. }

(Allen's Creek Unit 1)

)

TEX PIRG RESPONSES TO HL&P INTERROGATORIES TexPIRG, an intervenor in this proceeding, herein

. files the attached Responses to Third Set of Interrogatories from the Applicant, Houston Lighting & Power Company.

Respectfully Submitted, James Sc ott, Jr. ,

)

)

CERTIFICATE OF SERVICE On this the [htday of September,1979, I, James Scott, herein certify that the Board and all parties to this proceeding have been served with this document in person or by deposit in the U.S . Mail Sys tem.

1574 183 7912140

/fP

. m. .,

Response to Third Set of Interrogatories and Requests for Production of Documents from Houston Lighting and Power to Texpirg ,

1. Attached ( ApphoM 0"lj 0 1 C c P k C.o d ) ,

a

2. Attached ( o u o n

)

3. Applicant is free to examine files of the Texas Energy Extension Service, Room 107, College of Technology, University of Houston, 4800 Calhoun Boulevard, Houston, Texas 77004

4. Energy Future, edited by Stobaugh and Yergin, 1979*(TexPIRG uses library) Bonneville Power Admin. Elec-tric Energy Conservation Study. _/ *

5. Answer to the previous question was positive.

6. Texpirg has not relied upon applicant's Environmental Report and Environmental Statement and Supplemental material in forming its determination that energy, conservation has not been adequately considered except to the extent that such consideration is generally absent in the Environmental Report and Environmental Statement. **/

7. It is Texpirg's contention that sales of " conservation retrofits" would constitute a shift by applicant from the exclusive provision of " power" or current to the more useful provision of " light" and energy services.

Therefore:

a. The applicant can make these investments on the same basis it makes generation investments with rates of return to be established by those cognizant governmental entities which supervize its operations.

b. Customers should be selected by applicant based on maximum conservation opportunity. That is, applicant should target for retrofit those of its customers whose operations are most inefficient and therefore offer the greatest potential for savings to offest '__

additional generating capacity.

• Available for inspection in TexPIRG office. Please make appointment.

• • In general, TexPIRG disagrees with the Section S.8 of the FS-FES because it considers " conservation" as a ' circumstance 8 and not an active alternative. TexPIRG does not agree with the implications and facts of App. SH, p. SH-100 (ER) and ER Supp. Table sl.1-3 However, TexPIRG is still attempting to research the accurate assessment of the need for power.

i574 184

c. Applicant generates profit based on a regulated rate of return for capital investment in generating capacity and other fixed plant. Therefore, any market:ing of energy conservation materials, techniques, and services will produce the same regulated profit and/or rate of return.

d. Texpirg contends that any scheduling of additional on-line capacity from the Allen's Creek Project is speculative in view of the project's specific history and the broader construction history of large nuclear generating stations in the United States, nearly all of which have experienced extensive delays. Therefore any alternative action or strategy undertaken by applicant would have immediate and incrementally increasing impact. Any date assumed for completion of ACGNS will continue to be delayed into the future, rendering time-oriented comparisons meaningless, except, it should be noted, for the fact that conservation investments could begin making some level of contributions much sooner,

~

e. Total reduction in demand is still under study by Texpirg. .

8. Study by Gregory Skie entitled "Some Environmental and Economic Aspects of Municipal Solid Waste Materials and Energy Recovery Systems" in files of the Texas Energy Extension Service, Room 107, College of Technology, University of Houston, 4800 Calhoun Boulevard, Houston Texas, 77004,

9. Revisions still under study by Texpirg. %4g '"/(f),

10. Any specific self-generating plans underway by petrochemical manufacturers in the Houston Area is proprietary information. However, applicant may wish to canvass member companies of the Gulf Coast

. Energy Conservation Society, an organization of Houston Area . Industrial energy consumers, most of whom are have investigated in-plant use of both fluidized bed technology for coal-fired boilers and gas turbines through presentations at Society meetings and specific follow-up with vendors. -

11. Exact amount'.of reduction under study by Texpirg.

..,, ,3 . .

1574 185

• a '.

4'

12. Electricity is sold by applicant through a rate structure which rewards larger industrial users with lower prices per Kwh than those paid by smaller residential customers. This does not necessarily contribute to mystem inefficiency but it clearly encourages some overuse and inefficiency by the larger user who is subsidized by the homeowner.

If these declining rates were flattened or reversed, demand could be substantially reduced. Inefficiency, on the other hand, is institutionalized through a second feature of the rate structure which allows all residential customers to pay equally for electricity which is seasonally and diurnally varying in generating cost and efficiency. Time-of-day and seasonally based pricing for electricity can be implemented to flatten these " peaks" and retain more of the system load on the most efficient generating equipment.

13. " Passive Solar Technique" ,

a. refers to the provision, in buildings, for maximum use of " environmental energies." He ating ,

cooling, and lighting is derived in whole or in part.

from environmental sources. The technique is applicable to both commercial and residential use. The cost per square foot is comparable to conventional construction and, in fact, may be less in some cases due.to the availability of Federal Income-Tax Credits,

b. I don' t know. TexPIRG, however, would refer you to to the Govt. Operations CommitteefNuclear Power Cost' Study

14. This testimony relates specifically and exclusively to the first sub-secti6n on the conservation contention.

15. Testimony is in preparation.

16. This work is still in progress.

- 17. Applicant may refer to the library of the Texas Energy Extension Service, Room 107, College of Technology, University of Houston, 4800 Calhoun Boulevard, Houston, Texas 77004

18. No. -

19. This work is still in progress.

• / Sub-committee report of the Energy and Environment Sub-Com-mittee of the House of Representatives Government Operations Committee, 1978. In particular, see figures cited by Amory Lovins testimony. TexPIRG has not determined if the figures utilized therein are feasible yet, but submits these as our current informed guess.

1574 186

20. This information is available in the library of the Texas Energy Extension Service, Room 107, College of Technology, University of Houston, 4800 Calhoun Boulevard, Houston, Texas 77004.

21. The cost of passive retrofit is comparable to the per square foot building cost in Houston at the time construction occurs,

22. Passive Conservation Retrofit:

a. by definition must be tailored specifically to Techniques for individual buildings and sites.

natural ventilation are the most promising for energy savings in Houston,

b. In view of'the above, costs will vary with each application.

c. I don't know, although'all customers utilizing electricity for space heating and cooling.would theoretically be able to use some passive solar techniques. . .

d. This is still under study,

c. This is still under study.

23. This information is available at the Texas Energy Extension Service library, Roon 107, College of Technology, University of Houston, 4800 Calhoun Boulevard, Houston, Texas 77004.

24. Attached. (AP pUwt D - d Gpgg Cosd G

1574 I87 .

M 0

.4 . , ,

,0UNTY OF HARRIS STATE OF TEXAS I, Clarence thao Johnson, herein affirm before the undersigned a u thority this attached RESPONSES OF TEXPIRG TO APPLICANT'S OF T INTERROGATORIES was prepared under my direction as Executi ve Director of TexPIRG and that the to the best of my knowledge and belief. statements made therein are true accurate and On this_ day of September, 1979.

'e l/f}~ dir/L NOTAR'Y PU$' L IC i

=

a

H:tyri+ s, 115 Cccut.. , ..; ,

Jgl e

9 1574 188

-