ML19330C558

Statement of Matl Facts to Which No Genuine Issue Exists. R&D Re Feasibility of Biomass Production & Conversion Technologies Not Yet Accomplished.Affidavit Encl

ML19330C558
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	08/01/1980
From:	Woodson H HOUSTON LIGHTING & POWER CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19330C554	List: ML19330C553 ML19330C558 ML19330C560
References
ISSUANCES-CP, NUDOCS 8008080496
Download: ML19330C558 (4)

Text

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

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit'l) S

' Statement of Material Facts As To Which There Is No Genuine Issue Based upon the attached affidavit of Dr. Herbert Woodson and other facts on the record in this proceeding, Applicant. states the following material facts as to which there is no genuine issue:

1. When completed and placed into operation the Allens Creek Nuclear Generating Station will provide 1,200 megawatts of base load electrical power for use in the Applicant's system. The scheduled date for commencement of operations of this nuclear power plant is 1988.

2. The 100,000 acre marine biomass farm proposed by intervenor Potthoff will not produce the energy equiva-lent of a power plant the size of Allens Creek. By just assuming the energy output figures postulated by the inter-venor, one can show that the marine bicmass farm would have to be at least four times the size of the one proposed, or 080

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'some'624 square miles. However, this estimate fails to account for preprocessing energy requirements.

3. Utilizing current conservative. estimates of the anticipated energy conversion potential of a marine biomass farm producing crops with the highest energy yield obtainable from a marine plant which can be grown on a large scale, a marine biomass farm of over 900 square miles (576,000 acres) would be required to produce the energy equivalent of the ACNGS. - This number is even higher when preprocessing-activities are considered, i

4. No biomass farm of this size or a significant ,

fraction of this size is now in existence or known to be under development.

5. Years of research and development of marine biomass' production and conversion technologies will be required to produce conceptual plans for a commercially viable marine biomass farm of this size, and there is no assurance that the commercial' viability can ever be proven until such research is complete. Once this is accomplished,

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it will take many more years to complete the plans for an actual marine biomass farm which-can produce a substantial L size crop. Even if.it proves possible to develop a com-mercia11y feasible marine biomass farm-of the size needed to

replace the energy output of ACNGS it will'not be in the i l-time frame that ACNGS;is to be put-into operation.  !

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6. .In order to have a marine biomass farm large enough to replace ACNGS, HL&P would have to have exclusive control over 15 to 20 percent of the usable acreage of the Gulf of Mexico from the mouth of the Mississippi River to Mexico.

7. There are currently no legal means of ob-taining title to or exclusive use of the substantial amount of sea space required to build a marine biomass farm suf-ficient to replace ACNGS.

8. The environmental impacts believed to arise from a marine biomass farn of the required size to replace ACNGS are numerous and potentially extremely significant.

There is no existing evidence that such a biomass farm would be environmentally preferable to a nuclear power plant and, in fact, it now appears t.at the impacts from the farm would be significantly greater than the impacts from construction and operation of ACNGS.

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

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 5

(Allens Creek Nuclear Generating S Station, Unit 1) S AFFIDAVIT OF HERBERT H. WOODSON STATE OF TEXAS S S

COUNTY OF TRAVIS S I, Herbert H. Woodson, of lawful age, being first duly sworn, upon my oath certify that I have reviewed and am thoroughly familiar with the statements contained in the attached affidavit addressing intervenor F. H. Potthoff, III's contention regarding biomass conversion and that all state-ments' contained therein are true and correct to the best of my knowledge and belief.

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Herbert H. Woodson Subscribed and sworn to before me this /-;*

day'of_ Ou d , 1980.

/ M 2hY Notary Public in and for Travis County, Texas l

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