ML20028C867
| ML20028C867 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/07/1983 |
| From: | Corren D GREATER NEW YORK COUNCIL ON ENERGY |
| To: | CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| ISSUANCES-SP, NUDOCS 8301140247 | |
| Download: ML20028C867 (7) | |
Text
-
c.
UNITED STATES.OF AMERICA NUCLEAR REGULATORY COMMISSION Uf 0
ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
James P. Gleason, Chairman y.Q],]fjg Frederick J.
Shon Dr. Oscar H.
Paris
- gn;gg
)
In the Matter of:
)
)
CONSOLIDATED EDISON COMPANY OF
)
N EW YORK,. INC.
)
Docket Nos. 50-247 SP (Indian Point, Unit No. 2)
)
50-286 SP
)
POWER AUT110RITY OP THE STATE OF
)
)
-January 7, 1983 (Indian Point, Unit No. 3)
)
)
RESPONSE OF GNYCE TO INFORMAL LICENSEE REQUEST FOR SUPPLEMENTAL INTERROGATORY RESPONSES IN LETTER DATED DECEMBER 3, 1982 GNYCE herein responds to a request by licensees for supplemental responses to some of their interrogatories as listed in a letter dated December 3, 1982, a copy of which is attached.
The original interrogatories are to be found in " Licensees' First Set of Interrogatories and Document Request Under Commission Question 6," dated June 9, 1982, and the original responses by GNYCE are in " Response of GNYCE to Interrogatories of Licensees Under Commission Question 6," dated July 14, 1982.
Supplemental information anticipated for the following inter-rogatories is still not available to GNYCE at this time: 22-24, 26, 48, 55-59, 95.
Interrogatory responses that we consider satisfactory as originally stated are as follows: 28-31, 33-41, 45, 49-54, 60, 62, 64, 65, 69-72, 81, 83, 87, 88, 92, 96, 101, 103, 105, 106, 108-110, 113, 116, 122.
00047 O
3O PM
I . Pollowing are supplemental responses to the remaining inter-rogatories cited by the licensees in the December 3rd letter. 27. The ESRG economic study cost model was used previously for a study of Maine Yankee. GNYCE is unfamiliar with whether or how the model may have been changed for this study. 61 GNYCE does not have this information. 63. The outline mentioned was merely conceptual, except-to the extent that it was jotted down on a piece of s' crap paper during the conference. When the Board did not request the outline, it was not prepared, and the scrap paper was discarded. 67. An estimate will be made of the premium rate appropriate to the estimates of potential damages from an accident at Indian l Point. To the extent that such premium estimate is avoided by the licensees as a result of the Price-Anderson Act, it will be taken to be borne involuntarily by the society at risk. Please see " Response of GNYCE to NRC Staff Interrogatories and Document Requests Regarding Question 6," dated November 3, 1982, pages 1-4. 73. It is still unclear what the licensees wish to learn j by this interrogatory. It is understood that utility rates l will continue to increase steadily, both for those customers who use offsetting projects and for those who do not. Obviously, the sooner a project operates commercially, the sooner its operater will be more or less independent of utility rates and thus experience savings. ^ 74. Our original response still applies with the following additions. First, non-cogenerating ratepayers cannot be bur-dened by others' cogeneration during the cogenerators' con-I s truction, since those cogenerating are still ratepayers ducing i this period. Second, depending on Public Service Commission regulations _and tariffs, optimal cogeneration economic's may well have cogenerators remaining utility customers to some degree. Third, as should be obvious, the level of cogeneration implemen 4 tation discussed is cost-effective cogeneration. Investment in it is market-motivated and voluntary, not involuntary as is monopoly utility inves tment. 75. Costs of interconnection equipment must be included for grid-connected cogeneration facilities. 85. GNYCE has no detailed information. o
p . 86. GNYCE has'no-detailed information. 89. GNYCE has no further information. 93. GNYCE has no further'information. 121 Please see " Response of GNYCE to NRC Staff Interrogatories and Document Requests Regarding Question 6," dated November 3, 1982. Re p t ully Submitted, / w r ' Dean M. Corren Director, GNYCE l
y, POWER AUTHORITY OF THE STATE OF NEW YORK-to COLUMous CincLE NEW Yonk. N. Y. tool 9 42126 397 6200 LERow e NC L AlR v o.,EE. .e.........e.e - A L=,1.ge i ~,,. ,o .. o v.o
- .:t".t J.~;.*,...
- ~~~~~
8' r ec e s GEOMGE L. ING A LLS wsce seasema# JOSEPH R.SCH DER '8 8 H*8 "? 4 twea e M8CH A RD M. FLYN N NORE NT I. MILLONIl s= m ae e seerst '^" ^"***^ December 3, 1982 (BY IIAND) Greater New York Council on Energy c/o Dean R. Corren, Director New York University 26 Stuyvesant Street New York, New York 10003 j 1 l
Dear Mr. Corren:
i l As I indicated to you in our conversation of November 29, 1982-the Licensees have reviewed the responses to Licensees' First Set of Interrogatories under Question 6 received on July 14, 1982, from the Greater New York Council on Energy. We have found that some of the responses require supplementary answers while some were deficient in other ways. In an effort to resolve the problems informally, as provided in the Board's July 6, 1982 order, the Licensees request that GNYCE give further answers to the questions listed below. GNYCE stated or implied in its initial responses to interrogatories that supplementary answers to a number of interrogatories would be available at a later date. The Licensees request that GNYCE provide supplementary responses to the following interrogatories: 22,23, 26, 27, 33, 41, 45, 48, 50, 51, 52, 55, 56, 57, 58, 59, 61, 62, 67, 68, 69, 70, 71 72, 85, 86, 87, 92, 93, 95, 96, 103, 106, 108 and 121. This obligation,aside from being explicitly undertaken by GNYCE, has been established by the Licensing Board with respect to discovery in this proceeding (see Board Order, dated June 3, 1982, p.
- 2).
In many instances GNYCE ignored requests to provide documents. Therefore, GNYCE should provide documents requested by interrogatories numbered 22, 23, 24, 27, 28, 29, 30, 31, 33, 30, 39, 53, 55, 67, 92, 95, 106, 109, 110, 116 and 122. In addition, to dxse biterrogatories, many of Licensees' interrogatories were unanswered, were incompletely answered
D:nn Corren D cember 3, 1982 Page 2 or were misinterpreted. The following interrogatories fall into this category: 27, 29, 30, 31, 33, 34, 35, 36, 37,- 38, 39, 40, 41, 49, 50, 51, 53, 54, 56, 57, 58, 59, 60, 61, 62, 64, 65, 74, 75, 81, 83, 88, 89, 92, 101, 105, 106, 113, 121 and 122. _ Licensees seek to obtain correct and complete answers to these interrogatories. Finally, GNYCE stated that interrogatories numbered 63, 73, 74 and'75 were too broad, puzzling or somehow unclear. Therefore, the Licensees restate these interrogatories. 63. During the prehearing conference on April 14, 1982 Judge Carter and Mr. Corren discussed the operation and maintenance costs which may be avoided once the Indian Point Nuclear Plants are shut down. The pertinent portion of the conversation which can be found on page 898 of the transcript for April 14, 1982 is quoted below. Provide the outline mentioned during the April 14 prehearing conference and any other documents which may support your assertions. JUDGE CARTER: Would you call that further maintenance and capital expenditures to operate the plant? MR. CORREN: Right. And there are other minor things like the fact that Con Edison would no longer need a nuclear. department and they would not need to litigate for nuclear fuel and minor things like that, and anyone who is familiar with the art of doing these economic analyses could take any costs associated with operating at any point and reasonable predictable i costs that will be in the next several l years and factor all of those in. And I l am simply concerned that however we word the contentions, we are not ruling out those salient costs. JUDGE CARTER: Well, then you should say l them to give them notice so that they will be on notice that they are going to talk i about maintenance and capital improvements i and legal expenses and nuclear staffing.
e
- Dern Corrcn D:ccmber 3, 1982 Page 3 MR. CORREN:
I have an outline I could sub-mit on that. l 73. Did you consider that the cost of energy rates charged to ratepayers (residential and industrial consumers) will increase during the construction and initial period of use of cogeneration projects and con-servation measures? 74. During the Cogeneration Rate Case, Case No. 27574, the Administrative Law Judge stated that in the short run, in the three to six years required to install 1500mW of cogeneration, remaining customers would suffer because they would have to absorb greater portions of fixed costs. Did you consider that the initial costs of construction 1500mW of cogeneration may be a substantial or even crushing burden for ratepayers? If you failed to consider such a question, state the reason for your failure. 75. Have you or others known to you performed either calculations or studies which include the costs of interconnection equipment (between cogenerators and the utility grid) in the capital costs of the 1500mW of economically feasible cogeneration? If such calculations or studies have been performed, state the grounds and provide documents in support of your answer. If no calculations or studies existi state the reason.for your failure to study or calculate such costs. If there are any questions regarding the listed interroga-tories, you may call me or Jennifer Tolson. If you do not plan to submit further responses,.please inform me of your position by Wednesday, December 8, 1982. Otherwise, your response to this informal request for further answers should be submitted to licensees by December 17, 1982. Sincerely, 0 l sl d Charles M. Pratt Assistant General Counsel cc: Brent L. Brandenburg
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: James P. Gleason, Chairman Frederick J. Shon Dr. Oscar H. Paris ) In the Matter of ) ) CONSOLIDATED EDISON COMPANY OF ) Docket Nos. NEW YORK, INC. ) 50-247 SP (Indian Point, Unit No. 2) ) 50-286 SP ) POWER AUTHORITY OF THE STATE OF ) l NEW YORK ) January 7, 1983 (Indian Point, Unit No. 3)- -) ) CERTIFICATE OF SERVICE I hereby certify that copies of " Response of GNYCE to Informal i Licensee Request for Supplemental Interrogatory Responses in Letter Dated December 3, 1982" in the above-captioned proceeding have been served on the of ficial service list by deposit in the United States mail, first class, this 7th day of January, 1983. 7 Dean R. Corren Director, GNYCE E Sv) %d, naar9 10,4 oanup6% Nwn -- _}}