ML19312C916

Statement on Why CPs Should Not Be Suspended

ML19312C916
Person / Time
Site:	Oconee
Issue date:	10/18/1971
From:	Thies A DUKE POWER CO.
To:	US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML19312C906	List: ML19312C905 ML19312C912 ML19312C916
References
NUDOCS 8001140578
Download: ML19312C916 (17)

Text

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O .A,  % ,s UNITED STATES OF AMERICA [

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ATOMIC ENERGY COMMISSION ,J L -

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In the Matter of ) YOs, f

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DUKE POWER COMPANY ) Docket Nos. 5'O h 57d.,

) 50-2R7 (Oconee Nuclear Power Station ) Q". , t~', ?

Units 2 and 3) )

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STATEMENT BY THE DPLICANT WHY THE CONSTRUCTION PERMITS SHOULD NOT BE SUSPENDED I l

I l

Introduction Duke Power Company (" Applicant") submits this statement in I

accordance with provisions of Section E.3. , Appendix D,10 CFR Part 50, as to why construction permits CPPR-34 (Unit 2), and CPPR-35 (Unit 3) should not be suspended pending completion of environmental review.

Applicant has been committed for many years to a policy of l 1

meeting an ever increasing demand for electric service by providing reliable, l l

low-cost electric generation while at the same time preserving and, where j possible, enhancing the environment and quality of life in the area it serves.

All steam-electric generating plants, either nuclear-fueled or fossil-fueled, release heat to the environment as an inevitable consequence of producing electric power, and Applicant has designed these facilities to minimize the im pact . Applicant has been particularly concerned for the quality of the air and water which might in any way be affected by the operation and enlargement of its system. Applicant's Keowee-Toxaway Project, of which the Oconee Nuclear Station is an integral pan, has been planned and is being developed based on numerous cudies and analyses with respect to potential environmental effects.

8001140 b 4518

Moreover, before operation of the Oconee Nuclear Station commences, licenses, permits, contracts, agreements or understandings relating to environmental matters will have been received from some 66 governmental bodies. Binding commitments as to environmental concerns have been made to this Commission and to other Federal, state and local agencies.

Applicant has made every effort to meet all reasonable suggestions and requests of responsible authority to make the Oconee Nuclear Station com-pletely acceptable from an environmental standpoint. As presently designed, this facility is a far preferable alternative as a source of electric energy to any other which might be available. Its continued construction and operation will not give rise to any significant adverse impact on the environment but, rather, will enhance the environment and the quality of life in the surrounding area. The pub-lic interest requires that there be no delay in construction of this facility and that it be completed as rapidly as is technically feasible.

II

Background

i By application dated November 28, 1966, and subsequent amendments, l l

Applicant requested of this Commission authority to construct and operate the Oconee Nuclear Station, Units 1, 2 and 3, consisting of three pressurized water reactors manufactured by Babcock and Wilcox, with a rated capacity of 2658 Mw(e) to be located in eastern Oconee County, South Carolina. The town of Seneca, popu-lation 6,027, is approximately 8 miles southwest of the Oconee Station. The general area is characterized by its inclusion in the economically depressed Appalachian area and a relatively sparse population on a present and pr'ojected basis. Following I an exhaustive review concerning matters of radiological health and safety by the Commission Staff and the Advisory Committee on Reactor Safeguards (the "ACRS")

and a public hearing before an Atomic Safety and Licensing Board l 1

2

in August and September,1967, the Director of Reactor Licensing issued con-struction permits CPPR-33, CPPR-34 and CPPR-35 for Units 1, 2 and 3 respec-tively on November 6,1967.

On June 2,1969, Applicant filed a Final Safet' Analysis Report with respect to all three units. After further review by the ACRS, the Commission gave notice of its intent to issue an operating license for Oconee Nuclear Station Unit 1 in the Federal Register of January 8,1971, which provided opportunity for public hearing. No hearing was requested.

On July 10, 1970, Applicant filed with the Commission an environ-mental report for the Oconee Nuclear Station pursuant to the provisions of the National Environmental Policy Act of 1969 and to the Atomic Energy Commission's Regulations in effect at that time. Such report included an analysis of the alter-natives to the Keowee-Toxaway Project. It also included an analysis of (a) the cooling water and thermal effects of the Oconee Nuclear Station, (b) downstream water quality, (c) environmental radioactivity, (d) recreation, (e) soil conser-vation, (f) preservation of virgin timber, (g) historical salvage, (h) fishing re-sources, (1) wildlife, (j) public health, (k) water supply, (1) flood control, (m) education, (n) scenic beauty, and (o) residential, commercial, industrial and economic development expected to result from the project.

A notice of availability of the environmerital report, along with the request for comment from appropriate state and local agencies, was published in the Federal Register on July 25, 1970. Copies of the environmental report were transmitted to, and comments received from, various Federal and state agencies including the Departments of Agriculture, Commerce, Defense, Health, Education and Welfare: Housing and Urban Development, Interior, Transportation, and the Federal Power Commission. None of these agencies have raised any questions concerning the environmental impact of the Oconee Nuclear Station which has not been satisfactorily resolved.

2 On this date, a Supplemental Environmental Report was filed with the Commission in accordance with revised Appendix D to 10 CFR Part 50 dealing vith, among other things, a cost-benefit analysis and the environmental effects of transportation, transmission and accidents with respect to the Oconee Nuclear Station. In order to avoid unnecessary repetition of pertinent facts, it is requested that the environmental report, as supplemented, be incorporated herein by reference and made a part of this Statement as though fully set out herein.

III Continued construction of the facility will not have a significant adverse impact on the environment and will not foreclose subsequent adoption of any alter-natives which could result from environmental review.

It is expected that the three Oconee Nuclear Station units will begin service in late 1971, late 1972, and late 1973, respectively. Construction of Units 1 and 2 are essentially complete, and construction of the other unit is in an advanced stage of construction. The present construction, exclusive of nuclear fuel, reflects an expenditure of $283,000,000 to August 31,1971 repre-senting a substantial and irretrievable commitment of economic resources. The basic design of the Station is fully committed and the construction work remaining to be performed will not, in and of itself, adversely affect the environment. Con-struction has continued on Oconee since 1967, and the photographs in Applicant's Oconee Supplemental Environmental Report show the status of construction in August of this year. As stated in the Introduction of the Supplemental Environ-mental Report, construction on the three units has progressed too far to permit changes in the basic design. During the next six months , the maximum period estimated for completion of NEPA review, work will be virtually completed on the exterior of all of the structures. The concrete dome of the Unit 3 reactor building, the Unit 3 auxiliary building and the siding on Unit 3 turbine building will be completed. Construction damage to the surrounding terrain will be

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redressed. Roads and parking areas will be paved and grass will be planted on all slopes and flat areas on the construction yard. This worhwill enhance the appearance of the site, and when viewed from the surrounding areas the effect will be to remove the derivation of construction. Moreover, completion of the external construction will bring the station to the aesthetic standard established by the architects to harmonize the structures with the surrounding environment.

The majority of work remaining to be done is inside the structures of Units 2 and 3.

During this period work will continue on the installation of equipment, piping and electrical power, control and instrumentation for Unit 2 and will be started on the same systems for Unit 3. This includes the turbine generators, for both units, the reactor pressure vessel, steam generators and reactor coolant piping for Unit 3, condenser for Unit 3, piping and equipment for auxiliary systems of the nuclear steam supply systems for both units and the construction of the 500 kv switching station.

In view of the construction already completed, the work to be done in the next six months will not have a significant adverse impact on the environ-ment, but on the contrary will have a beneficial effect.

Continued construction will not negate the adoption or backfitting of alternatives in facility design or operation of the type that might result from any environmental review contemplated by the National Environmental Policy Act of 1969.

The design of the plant has been under continuing review since the issuance of the construction permits. Consideration has been given to any change developed l by Applicant or recommended by the supplier or the Atomic Energy Commission which might enhance the safety of the plant. Those changes which were mutually agreed l l

upon have been included. Among these are- 1 l

a) installation of additional instrumentation sensing reactor building pressure to provide diverse means of assuring reactor trip, b) provisions for keeping in-core thermocouples in service during full power operation, and l

c) provisions for restraints on reactor coolant piping to present pipe whip following a pipe rupture.

Similarly, Applicant has considered ways in which any adverse environmental impact from the plant could be lessened. On this basis Applicant, among other things:

a) constructed a skimmer wall to provide hypolimnetic water for cooling, b) designed intake structure for low velocity cooling water flow to protect marine life, and c) gave maximum consideration to aesthetic effects in the design of buildings and landscaping.

The care taken to assure the least environmental impact is des-cribed in detail in the Supplemental Environmental Report. Applicant has consi-dered, however, such additional modifications which could theoretically further reduce radioactivity in the plant such as additional sprays, filters and cryogenic systems . Applicant is convinced, however, such improvements would be of negligible value and will not be required as a result of the NEPA review. In any event, space and capability for pipe connections have been provided to l ensure that new radioactive material treatment systems, when proven, can be ,

l incorporated at a later time even though construction proceeds to completion. i l

Continued construction and operation during an environmental review period would not foreclose the subsequent adoption of such presently available alter-natives in facility design or operation.

l IV l The Oconee Nuclear Station is the best available method of providing the electric power requirements of Applicant's service area. ,

l The Federal Power Commission issued a license for the Keowee-Toxaway Project, effective September 1,1966, which includes pumped-storage

and conventional hydroelectric generation as well as authority to utilize the Keowee reservoir as a source of cooling water for the Oconee Nuclear Station.

The Oconee Nuclear Station is expected to provide medium-capacity pumped-storage generation, and the Keowee and Jocassee developments, supported by stream flow, will be utilized as hydroelectric peaking capacity. In its Appli-cation for a Federal Power Commission license, Applicant stated that each of i

these purposes is essential to the economic justification of the total Keowee-Toxaway Project. It was tus6er stated that Applicant would not undertake the project unless the Federal Power Commission license permitted the use of Lake Keowee as cooling water for the first thermal plant, which is the Oconee Station.

During proceedings in 1965 and 1966 leading to the Federal Power Commission license, Applicant and the Federal Power Commission Staff explored more than 50 alternatives to the Keowee-Toxaway Project. None of these alter-natives were found to be as desirable as the current project. The more realistic alternatives are discussed in the Supplemental Environmental Report. The only feasible alternative would have been a high-head pumped-storage project to be

located elsewhere in the southern Blue Ridge Mcuntains to develop 750 Mw of peaking capacity plus a large thermal plant to be located on an unimpounded river elsewhere in the Applicant's service area with cooling water to be recirculated through several large cooling towers. During the Federal Power Commission licensing procedure, it was first clearly established that the Keowee-Toxaway Project offered advantages of economics and of environmental quality when compared to the alternatives. Such advantages include downstream flow augmen-tation in periods of dry weather, extensive recreational opportunities, soil conservation measures , and substantial fisheries resources , wildlife preser-vation and propagation , public water supply , flood

control, opportunitms for enjoyment of scenic beauty, and substantial economic benefits to the northwestern portion of South Carolina.

Applicant considered a fossil-fueled plant as an alternative to the Oconee Nuclear Station. It concluded that nuclear generation was more desirable both from an economic and environmental standpoint. Severe shortages of domestic supplies of natural gas arid coal and continuing world shortages of low-sulphur residual fuel oil have substantially increased the cost of fossil fuels and have threatened their availability in sufficient quantities for large power plants. In considering the environmental report originally submitted by Applicant for Oconee, the Federal Power Commission found with respect to the environmental effects of a fossil-fueled plant:

"Any fossil fuel plant as an alternative to the nuclear Oconee Plant would necessarily add to the particulate or gaseous burden of the South Carolina atmosphere. At the present time all of the steam-generating stations of the Duke Power Company depend on coal as the principal fuel. This coal comes from Virginia, West Virginia, Tennessee and Kentucky mines, and has a sulfur content in the range of 0.5 to 1.5 percent, and on an annual basis averages 1.0 percent. Since low-sulphur oil is virtually unavailable, the planning of the Oconee Power Plant as a nuclear facility offers important environmental advantages with respect to air quality in the State of South Carolina."

(Letter, Chairman, Federal Power Commission, John N.

Nassikas to Chairman, United States Atomic Energy Com-mission, Glenn T. Seaborg, August 20, 1970)

Hydroelectric generation as an alternative to the Oconee Nuclear Station is not feasible because of the lack of sites with potential power genera-tion large enough to satisfy the energy requirements of the service area population.

Hydroelectric generation is practical only for peaking purposes in the Duke system.

Cooling towers were rejected as an alternative to using Lake Keowee as a direct source for cooling water for the Oconee Station only after extensive studies established that the waters of Lake Keowee could be utilized without any adverse environmental impact as detailed in the Supplemental Environmental Report.

The results of such studies were reviewed by the South Carolina Pollution Control

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Authority, the United States Fish and Wildlife Service and independent con-sultants for the United States Department of the Interior. The Secretary of the Interior concluded that the thermal effects of the proposed nuclear plant, would

" produce no detrimental effects upon the fishery resources" within Applicant's proposed lakes and would not "be deleterious to the recreational resources."

(Letter, Secretary of the Interior, Stewart Udall to Federal Power Commission, April 7,1966) . As shown in the Supplemental Environmental Report, the environ-mental impact of cooling towers on the Keowee-Toxaway system would be detrimental.

For example, the consumptive loss of water resources through the use of cooling towers would far exceed that which would result under existing plans. (Supplemental Environmental Report, Benefit-Cost Analysis) .

Failure to provide additional generating capacity was rejected as a feasible alternative. In its review of Applicant's environmental report, the Federal Power Commission stated:

"The 1970 summer peak load on the Duke Power Company's  ;

system is expected to reach 6,390 megawatts. During the i following winter season a peak load of 6,398 megawatts is expected. Between the summer of 1970 and the winter of 1973-1974 the Company's summer and winter peak loads are expected to grow to 8,390 megawatts and 8,405 megawatts respectively, an average annual growth per year of 9.5 percent. To provide 4 for this anticipated increase, the Company is planning a number i

of additions to installed generating capacity in addition to the l three nuclear units at the Oconee Power Station. In 1973 the i Company expects to have available 7,364 megawatts of installed l capacity, not including the three units of the Oconee Nuclear Power Plant, one of which is planned to be in service each year beginning in 1971. Thus, it is evident that the Company will suffer a deficiency of installed capacity of more than 1,000 megawatts, if the scheduled units of the Oconee Nuclear Plant are not available to serve the 1973 peak load. There is no doubt, therefore, of the need for the generating capacity which would be made available by the three nuclear units of this power plant." (Letter, Nassikas to Seaborg , supra) .

This statement confirms Applicant's own belief that should the Oconee Nuclear Station not be placed in service a severe power shortage will result in its service area, as sufficient power from outside sources will not be l

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available to meet anticipated demand. The Federal Power Commission has addressed itself to this point as follows:

"This conclusion is based on a review of the present load-capacity situations of the surrounding utility systems and operating pools from which imported power would have to come. At the present time the Pennsylvania-New Jersey-Maryland Interconnection to the north is operating under a narrow reserve margin of 8.3 percent. The Southern Company's systems to the south are in a more precarious situation with only 7.7 percent reserves. To the west the Tennessee Valley Authority's system has a reserve margin of 13.1 percent and to the northwest the American Electric Power's systems have a reserve margin of 16.8 percent. In each of these outlying areas, the reserve margins are such that none of the systems is in a position to export large blocks of power on a firm basis.

Because of the trend to larger generating units and the problems associated with plant siting and transmission line routing, it is unlikely that the reserve situation in 1973 will differ to any extent from that of 1970. Thus , the power supply situation would hardly be improved in the time available even if the Duke Power Company departed from generally accepted utility practice of relying principally on construction of its own generating capacity to provide for its own loads and sought to buy power from others instead of completing the construc-tion of the Oconee Nuclear Units.

"Even if time were available for new construction these neighboring systems and operating pools would be hard put under the present conditions of popular environmental con-cern, to find the sites for plants whose principal purposes )

i would be to export power to distant utility systems. These 1 systems in common with utility systems everywhere are '

having difficulties in timely construction of new capacity to improve their own unsatisfactory reserve margins. Even though it is highly desirable to have a strong transmission network interconnecting regions for purposes of improved diversity and reserve backup, such interconnections to- j gether with out-of-the-area generation would not lessen the overall impact of facilities on the environment.

"It is evident, therefore, that if the Duke Power Company and the Virginia-Carolinas Reliability Group are to meet expected loads in 1973, reliance cannot be placed on the import of required firm power from neighboring systems and pools to the north, south or west as a substitute for the pro-posed Oconee Nuclear Power Plant." (Letter, Nassikas to Seaborg , supra) .

On September 22, 1970 Applicant was required to reduce its l

load 75 Mw because of unavailable capacity. This was accomplished by a l voltage reduction averaging 3 percent. On June 16, 1971 another load

reduction of 75 Mw was required and accomplished by a voltage reduction averaging 3 percent.

The most recent voltage reduction remained ir effect for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and was terminated, not by available power from interconnected companies, but because the weather moderated and the capability was satisfactory to meet the remaining load.

In summary, Applicant submits that the entire Keowee-Toxaway Project has been carefully designed and is being developed in a manner that is entirely compatible with the environment. It is Applicant's belief based upon numerous studies that the project will in fact have highly beneficial ecological effects and will enhance the quality of life in the surrounding area. The project has been reviewed by many interested Federal, state and local agencies. Their comments are contained in the original envi-i ronmental reports and clearly establish that environmental effects of the Keowee- l Toxaway Project have been considered from the project's inception, and no l l

question concerning any environmental matter has been raised which has not l been satisfactorily resolved.

V Suspension of construction of the Oconee Nuclear Station will have a severe adverse impact on the economy in the area.

As shown above, the on-schedule operation of the Oconee Station is urgently needed to meet a growing demand for electric energy in the region.

Applicant anticipates a system peak load of approximately 7005 megawatts during the winter of 1971-1972. If the generating capacity represented by Oconee Unit 1 I is not available at that time, Applicant will have a total generating capability, including all available purchased power resources , of approximately 7340 megawatts.

Applicant's reserve margin would be approximately 335 megawatts , which is less 1

than 5 percent and is also less than the capacity of each of Applicant's four most recently installed generating units. The loss of any one of these units or a combination of other capacity on Applicant's system at the time of system peak load could render system resources incapable of meeting the load. Appli-cant's 1972 summer peak load is expected to exceed the 1971-1972 winter peak, and unless the capacity of Oconee Unit 1 is available by that time Applicant's power reserve situation will be even more critical. Inadequate power reserves can lead to continued power outages which could severely impair the public health and safety.

The impact upon the United States from power outages is the subject of a recent report by the Edison Electric Institute. This document graphically depicts the overall effect of power shortages upon this nation.

The effects of power outages in this report are applicable to the public in j Applicant's service area. For this reason, they will not be restated here, i

Moreover, it is most important to keep in mind that control of pollution in its j l many forms depends to a large extent upon the availability of electrical power. The net effect of reducing electrical energy resources is to maintain and even increase  ;

i the existing levels of pollution which exist in the United States today. i l

In addition to the consequences of inadequate power supply, delays in construction and operation of the Oconee Nuclear Station would inevit-ably result in substantial additional expense which ultimately must be borne by Applicant's customers. Interest on funds used in plant construction is charged at an annual rate of 71/2 percent. Each day that operation of the Oconee Nuclear Station should be delayed would add $73,000 in interest to the cost of the plant.

These additional expenses would increase the cost of service which would be l

borne by Applicant's customers through increased rates.

In addition to increased capital costs, the consumer would also have to bear the substantial increased cost of fuel for energy, to the extent i

1 it would be available, to replace the unavailable capacity of the Oconee Station.

The incremental cost of burn-up of nuclear fuel in the Oconee Station is expected to be approximately 12 cents per million BTU, which will make Oconee the lowest cost energy producer of any generating plant on Applicant's system. Because of its low operating cost, Applicant plans to operate the Oconee Station at full load continuously when available, with fluctuations in electric demand being handled by other generating facilities. At 12 cents per million BTU, and assuming a heat rate of 10,000 BTU per net kilowatt hour, each of the 886 megawatt Oconee units will have a daily fuel expense based on full load operation of approximately $25,500.

During pertads of milder-than-normal weather in the winter J 1971-1972, capacity at older fossil-fired units could be expected to be available to generate energy to replace that which would not be available should operation of the Oconee Station be delayed. These units are Applicant's Riverbend, Lee, Buck, Cliffside and Dan River steam stations, which have an average heat rate of 10,674 BTU per kilowatt hour and a current fuel cost of 45.7 cents per million BTU. Generation of 886 megawatts for one day with this capacity would consume fuel costing approximately $103,700. Thus, each day that each unit of the Oconee Nuclear Station should be delayed during periods of relatively mild weather results in increased fuel expense to Applicant of approximately $78,200.

During periods of normally cold and extremely cold weather, full load operation of all generating units on Applicant's system, including several high cost combustion turbines, plus purchase of additional capacity, if available, from neighboring utilities utilizing their highest cost generating facilities, would be necessary to meet peak load. Combustion turbines have an average heat rate of approximately 15,650 BTU per kilowatt hour and a winter time fuel cost of approximately 83.3 cents per million BTU. Utilizing combustion turbines with a generating capability of 886 megawatts for one full day would result in a fuel cost of $277,500. Thus, having to replace energy that could be generated by the Oconee

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Nuclear Station with energy generated by combustion turbines during cold weather would cost Applicant an additional generating expense of approximately $252,000

($277,500 less $25,500) each day.

All of these expenses would have to be passed along to the con-

sumers as a part cf Applicant's necessary cost of service through increased rates.

This area is a part of the economically depressed Appalachian area.

Delay in operation of the Oconee Nuclear Station will result in a substantial loss of property tax revenue to Oconee County ranging in the hundreds of thousands of dollars . (Supplemental Environmental Report, Benefit-Cost Analysis). Additionally, there are some twenty-one hundred construction workers at the Oconee Nuclear Station and a severe economic hardship would result for these workers from any layoff. This, in turn, would effect the economic health of the entire local area which is presently geared to the construction activity at the site. In the event of any significant delay in construction, some of the personnel will have to be discharged.

Others may be retained within the Company and other work sought for them. However, it will be impossible for Applicant to absorb any large percentage of these people. I Four years of extensive recruiting and on-the-job training have been 1 I

required of Applicant to create a labor force to construct the Oconee Nuclear Statiori.  ;

Some of the personnel at the Oconee job site came to the work as unskilled laborers and have been trained on the job and are now skilled workers. It should be noted that this is not ordinary constmetion, in that the construction requires people with many special skills. Seventy-one percent of the employees at the Oconee Nuclear Station were residents of the four neighboring counties of Oconee, Pickens, Green-ville and Anderson prior to employment with Duke Power Company. Twelve percent of the employees moved into the four-county area after employment with Applicant.

Applicant's construction personnel, unlike most other utilities, are regular full time i

employees of Applicant and are not contract personnel.

In face of existing unemployment in the area now, any large termination of employment by Applicant will have severe effects on the economy.

The general payroll for the construction force, not including the permanent operating staff, is $2,800,000 per month. Applicant would be in a very diffi-cult position in deciding whether to retain these employees and pay their salaries until work is continued or to release the employees. If the salaries are paid, then this expense must be eventually passed on to the rate payers. Upon termi-nation of the suspension period, a minimum of three months will be required to assemble a new construction force, assemble supplies, and recover equipment. )

i Some of the employees, if discharged will disperse from the area. If the con- l l

struction force cannot be reassembled, Applicant must train new personnel and move experienced personnel into the area. This requires considerable time and will substantially increase the total cost of the Oconee Nuclear Station.

An additional expense would be the cost of maintaining Oconeo 1 in an operational status even if no power is produced. The cost of maintaining Oconee 1 in a ready-to-operate status during a suspension period would cost Applicant approximately $5,400 per day. This figure remains constant and must be considered in arriving at the total cost for failure to operate the Oconee Nuclear Station on schedule. 1 VI Conclusion In conclusion, it is submitted that the record in the entire Commission licensing proceeding with respect to the Oconee Nuclear Station clearly establishes that this project is a complementary power generation and~ resource development and will have no significant adverse environmental effects. The entire Keowee-

Toxaway Project will enhance the environment and the quality of life in the area.

As Applicant's Supplemental Environmental Report will show, downstream water quality will be improved; numerous facilities for parking, camping, boating and other recreation will be developed; soil conservation will be improved through a continuous forest management program (in the past 30 years Applicant and its real estate subsidiary have planted over 38 million trees on 49,812 acres) and soil stabilization program (Applicant currently buys over 100,000 pounds of seed and over 1,000,000 pounds of fertilizer to provide cover and food for rabbits, quail and other small game under its transmission lines); a substantial increase in the aquatic habitat available both to fish and fishermen will result from the impounding of Lakes Keowee and Jocassee; public health will be improved through an exten-sive mosquito control program; fresh water will be made available to cities and towns in the area in sufficient quantities to supply their needs for many years to come; and the tourist industry generated by the project will increase local income by an estimated $1,284,000 annually.

The electric power needs in Applicant's service territory and in the surrounding area are critical. Any delay in placing the Oconee Nuclear Station in service will greatly increase the cost of electric revenue provided by Applicant if, indeed, adequate replacement power is available at any cost. No off-setting envi-ronmental benefits would be gained from suspending construction, as basic design and components have been committed. Applicant has stated in its PSAR and FSAR that it will comply with all Federal l and state regulations applicable to the Oconee Station which are designed to protect the public health and safety and the environment. That commitment is reaffirmed here. Further, if any adverse environmental effects attributable to the operation of the dconee Station were to become evident at any time, appropriate remedial steps will be immediately undertaken by Applicant. Applicant's ability to take such steps would not be enhanced by cessation of construction.

. 1 l _

I For the foregoing reasons, Applicant respectfully requests that i construction permits, CPPR-34 and CPPR-35 for the Oconee Nuclear Station 4

not be suspended, the public interest requiring that construction of the Oconee Nuclear Station be permitted to proceed to its scheduled completion and operation.

DUKE POWER COMPAh7 Ao f

By hS j

1 OCTOBER /P ,1971 l

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