ML20028D516

Initial Interrogatories & Request for Production of Documents Re Admitted Contention 15.Certificate of Svc Encl. Related Correspondence

ML20028D516
Person / Time
Site:	Harris
Issue date:	01/15/1983
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
References
ISSUANCES-OL, NUDOCS 8301190215
Download: ML20028D516 (10)

Text

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magggymumuer;3 UNITED STATES OF AMERICA ggTG NUCLEAR REGULATORY COMMISSION January 15, 1983

,9 g\\8 H70 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of

) Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 and 2) )

)

Uells Eddlenan's Initial Interrogatories and Request for Production of Documents relating to admitted Eddlenan Contention 15 Under 10 CFR 2.740, 2.7h0b,10 CFR nart 2 Apnendix A IV (a) (b) &

(c ) and the Board's Order of 9-2P-82 admitting Eddleman Content'on 15 and the Board 's Memorandun and Order dated 1-11 83 which did not defer or modify the 9-22 Order uith respect to Eddleman 15, I now serve unon Carolina Power and Light and NC Eastern Municinal Power Agency, through their attorneys, the followirg f nterrogatories.

l I also include herewith a recuest to the sane narties for nroduction of certain documents in o-der that I nay nake conies of sane, under 10 CPR 2.741, which documents relate to Eddleman 15 and t.hese photo-interrogatories. I understand that conying of certain of the ccnnuter runs involved is contractually prohibited, and renuest the o,nortunity to nhysienlly inspect said runs and cony rele vant innut data and numerical results by hand.

INTERROGATO9IES

1. Please state succinctly all significant bases for CP&L's adontion of a n=ojected 80% canacity facter for all Shearon Harris hp C

NO O O O PDR OM3

-2 nuclear units, as stated in NCUtilities Commission Docket No.

E-2 sub 203 (1971) by nrincinal CP&L witness Wilson Morgan in the matter of a certificate of convenience and necessity to construct the Harris clant.

2. Please state any other information known to CP&L which significantly contributed to this 80% cauacity factor figure.

3 Please list all doouments fren which the above information and the 80% caeacity factor number were dn_ rived, 4.ndicat'og for each how the information was used in arriving at the 80$ canacity factor. L

h. Please list all experts, consultants or other ne" sons consulted by Mr. Morgan or CP&L in arrivit:g at the 80% canacity factor nunber. For each, clease 4.ndicate whether the nerson is emnloyed by CP&L, and the current or last address of said nerson known to CP&L.

5. Please explain briefly how and in what terms Mr. Morgan suonorted the said 80% capacity factor figure unon cross-examination in NCUC Docket No. E2 sub 203

6. Please indicate whether CP&L intends to e all Mr. Morgan as a witness in this NPC operating licenairg proceedirg, 50-h00 etc. O.L.

7. Please state succinctly all cignificant bases used by CP&L or its witnesses in NCUC Docket No. E-100 sub h0 (1981 load forecast) for Shearon Hanris units to arrive at the 70% canacity factorj used by then therein.

8. Please list all docrnents used in arriving at said 70%

capacity factor; indicating for each how it was used and tihat weight, if any, was given to the infornation contained therein, citing the page(s) where such 4.nformation is contained.

9. Please list all experts, consultants and/or CP&L emnloyees ennsulted by CP&L or its emnloyees in arrivirg at said 70% canacity used in '

factor figure Docket No. E-100 sub h0, and the current or last l

3 known address of each such person.

10. Please indicate whether CP&L exnects to call Bobbly L.

Montague as a w itness in this N90 licensing proceeding,

11. Please state all significant bases, including units ' canacity factors (listed by unf t), fo"ced outage rates, availability factors, planned maintenance and/or reclueling operations in terms of days or hours outage in each year, planned repair or refit operations in terns of days or hours outage in each year, discount rate, fixed charge rate, levelized fixed charge rate, niant cost escalation rcte, pa"tial forced outage " ate, fuel cost, fuel cost escalation rate, fixed O&M (nonfuel) cost, variable O&M (nonfuel) cost, O&M cost escalation rate, and any other inouts to P90 MOD or other connuter nrograns or calculations used to derive the avoided fuel cost data nresented by CP&L witness G. Wayne King in NCUC Docket No. E-100 sub h1 (December 1982 hearing). Please provide the discount, fixed charge and fuel escalation rates (for oil, coal, nuclear and any other fuels used in conputing or deriving said data) on a systenwide basis unless they vary fron clant unit to niant unit; nicase trovide all other data rencested chova for each unit for each year 1983-3996.

"Each unit" means each gene =ating unit (coal or nuclear) CP&L has or exnects to have in onoration in any of the years 1983 through 1996.

Data for IC turbine units need not be provided individually if there or other anulicable itens above is no substantial variation in costs amorag same,

12. Please give a full nathematical derivation of the discount rates, levelization rates, fixed charge rates, fuel cost escala tion rates, O&M (nonfuel) cost escalation rates, and clant cost escalat5cn rates used in the preparation of Mr. King 's said test'nony and exhibits.

13 Please identify all docunents used in prenaring the f&Q VfLGiBb infornation in interrogatories 12 and 11 above, indicatin6 fo" each z

.h.

what pago(s) ' were used, how tho data was uced, what weight was given to it, and whether the docunent is in the possession of CP&L.

14 Please identify all consultanty experts or CP&L ennloyees who were consulted in preparing the information used to calc ulate or comnute the information nresented by witness King in Docket No.

E-100 sub 41, listing for each a current or last known address and stating whether each is currently ennloyed by CP&L.

15. Please state whether CP&L intends to call Mr. King as a witness in this NRC 0.L. nroceeding.

16. Please state the source (s) and the way the houvly loade nrojected for the CP&L system, which were used in deriving the information on avoided fuel costs presented by Mr. King, were derived. Please explain concisely how hourly loads were devived from peak load, total sales, total generation, or other data, and specify what other data was used to com,ute hourly loads projected, and how this data was used to nroject then.

17. Please state whether CP&L hac approved a new or different load forecast since December 1981; if so, state what the grouth rate of sales, winter neak, and sunmer peak are nrojected to be th ough 1995 1.n such forecast. Plense also lint the total systeh generation requirements, wintev neak load and summer neak load 'or each year I

as projected in such forecast or forecasts.

18. Please nrovide a statement of how any such forecast or forecasts a s referred to in Interrogatory 17 above were der. Ired.

Please include any assumntions as to anpliance saturations, growth in numbers of residential, commercial, and industrial customers, change in vower use per custoner, cost increases of electricity and competing fuels, inflation rate (s), and other significant factors l assuned in naking such forecast. (Please provide rov each forecast.)

19. Picase state any assunntions about NCEMPA lond growth, peak loads, or nower demands of NCEMPA custoners used in deribing s any forecast infornation is reouested on in InterroEatory 17.

20. Please state what, if any, warranty, guarantee or prouise CP&L has provided to NCE'4PA as to the canacity factor (s) of Harris nuclear units or othe" CD&L nower niants NCEMPA purchased an interest in. .

21. MCN, Please state j- '

if any, nrojected canacity factors for future operat5cn of CP&L's Rob 3nson, Brunswick, Roxboro, and Harris units were trovided by CP&L to NCEMPA or NCEM"A's consultants R.U.

Beck and Associates in connection with studies conducted for NOEMPA ao to nrobable costs and benefits of NCEMPA's uurchase of interests in CP&L generating units. If such vrojected canacity factors vary fron year to year or unit to unit, please lista then each year for each unit, bcE i nning in 1982.

22. Please state the actual DER and actual MDC canacity factors achieved by each unit at CP&L's Robinson, Brunswick, and Roxbovo nlants for the calendar year 1982. Please aire provide for each such unit, forced outage rates, fixed O&M costs, va=iabla O&M conb s per kilowztt-hour, and venair costs 'o= the year 1982. 5 23 Please explai n how the "R Anendment 5 fuel cost savings were connuted, listing all significant assumntione CP&L used to derive sane. If the assunntions were the same for each cf the 5 sensitivity cases, please so state; if they differ fron case to case (anart from the number cnd C.F. of Harris units therein),

please state precisely how the assunntions differ In each case.

2h. Please state how, if at all, the assunntions used in the computation of fuel savings in EP amendment 5 (filed December 1982) differ from the assumptions used by CP&L to derive o" connute

I

_6 the avoided fuel cost data presented bf C"&L witness King to the d

UC Utilities Connission in Docket No. E-100 sub 114 in December 1982

25. Please state how CP&L arrived at each of the items of 30

" production plannin6 information" filed by CP&L 63 -82 under FET Order No.18, 4 PURPA Section 133, particularly iten 22, Net Generation-GWH; Iten 21, Hours connected to load; Itens 16 and 17, Plarned Maintenance, Days / Year and Ecuivalent Fovced Outage 9 ate %; item 15, Non-ruel variable o&M g/kwh; Iten 6, Estinated Unit Life; and itens 10,11 and 12, Fixed O&M $/KW/Yr, Full Load Fuel cost g/KWli, and Average Costor Fuel @/MBTU, each for each unit listed in said renort for PURPA section 290 302(b)(1_2h).

26. Plcase state whother the PPOMOD III connuter vrogran referred to in CP&L's 6/30/82 FWC Order 148 filing under section 290 302(d) was used in deriving the fuel cost savirgs connuted fop Mr. King's testimony and exhibits in Docket No. E-100 sub 141, and rhether the same program was used in co$nuting the fuel cost savings projected in ED Amendment 5

27. Ples.se state (if known to CP&L) the lifetime can a city each factor in comercial oneration of4 Uentinghoure VU9*. over 800 hNa in des.ign ele etC eal rating, to and including the following dates:

7/31/82; 9/30/82; 12/31/82; and the nost recent auarter. If CP&L doe s not have the informat".on , nieasc st'at e " unknown".

28. Please state (if known to CP&L) the lifetime canacity factor in conne rcial operation of each Westinghouse "*<.'R in the wofld which has Westinghouse model D steam generators. Please list plants with D-14 steam generators (e.g. Krsko Yugoslavia) senarntely and state " unknown" if CP&L does not nossess the information.

29. Please state conscisely, fcr each unit CP&L onerates,for each of the yenes 1986 through 1995, the assumed capacity factor, forced outage rate, f uel cost in //kdH or //M3TU, fixed O&M cost, variable O&M cost, planned days or hours of outages for maintenance, nianned days or hours of outages for repairs, and all other significant including system load data datagused in order to derive or connute the fuel cost savings in the 5 senstivity cases in ER amendment 5. If this data is exactly the sane as that used for Mr. King's testimony in Docket No. E-100 '

t sub h1 (December 1982) including that used to connute on derive ,

his exhibits, please so state. ,

30. Please state the discount rate used to comnute the Harris f f

estinated fuel savings in constant 1986 dollars in each sensitivf ty I case noted in ER Amendment 5. If dL1 are the same, please say so. .

studies of systen oneratin costs, fuel costs !

31. PleasestatewhetherCP&Lmadeanyotherfrsensiftkvitystudies W

of fuel savings with other assumptions concerning the canacity factor, O&M costs, fuel costs, or other significant variables affecting ,

Harris onerating costs or total system onerating costs, than those whose results are stated in E9 anendment 5, in connection with uve-paring ER A9cndnent 5, or in connect? on with thin licensing procending.

3P. If the answer to Interrogatory 31 is yes, niease describe fully what assunntions were used in the other sensitivity studies nv othov fuel cost studies or system operating cost studies nade, giving such t a descriution for each such study. -

33 Please indicate whether CP&L has ever connared PROMOD projections of systen operating costs with actual systen onerating costs for any period urojected ureviously by a PROMOD run.

3h. If the answer to Interrogatory 33 is yes, please list all such conoarisons CD&L has ever made, stating for each the neriod projected, the projected fuel cost, the actual fuel cost, the nrojected total system onerating cost, the actual total systen

i j .. o onerating cost, and the actual nuclear canacity factor for each CP&L unit during the period. If there is not data for any of these itens for any such connarison, nicane state "no data" under that iten if in fact CP&L does not nossess that data.

35 Please state how accurately Po0 MOD connutations of systen fuel costs are when the actual data for a one year, 5 year, or 10 year period are used as inouts to the urogran and then connared with actual results for one year, 5 years, or 10 years resnectively.

If CP&L has no data or no oninion concerning this natter, niease so state. If C?&L has not conducted such a comparison for a one year pc*iod, on for a 5 year neriod, or for a 10 year neriod, please so state.

36. Please identify the individual (s) at C"&L who make PerMOD runs for CD&L, and the individuals who provide the innut data for those runs.

dIbidi$ed predtoas&)

37. Please identify all witresses CP&L intends to call or is considering calling in this NDC oroceeding with resnect to Eddlenan Contention 15.

38. Please state whether CP&L has ever considared the effect on systen operat$ng costs of Harris cauacity factors love" than 50%.

39. Please describe or state succinctly all significant reasons why CP&L's estinate of narris capacity factor declined fron 80%

originally (as testified to by Wilson Morgan) to 704 as stated by CP&L in Docket No. E-100 sub 40. For each such reason, state whether its effect le continuing or has ended to CP&L's knowledge.

40. Please state how CP&L connutes the cost saving for small nower production and co-generation of nowe" that results

• rom (a) lower fuel inventories; (b) less transnissf on nient reouired:

9 (c) less transformers and distribution niant required, e.g.

as submitted by witness King in his exhibits in Docket No. E-100 s

sub 41.

41. Please state whether there would be any savings in cost of transmission plant, distribution plant, transformers, or fuel inventories, . costs of nreparing renorts to NRC and other (a) federal agencies,/ g\if CP&L's load did not grow in terns of energy delivered to customers, as nrojected in ER Anendment 5 sensitivity case with zero load growth; and (b) if CP&L's neak load did not grow, even though more D!H night be delivered to custoners.

14 2 . Please state wh6ther any savings referred to in interrogatories 10 and h1 above have been taken into account in t he connutation of 4

systen costs with or without the Harris units, at varying canacity factors, as presentei in ER Amendment 5.

I believe CP&L has the above information, and it is needed to nrenared my case and cross-examination re Contention 15.

REQUEcT TOo PD0 DUCTION OF DOCUIETTS I hereby request that CP&L nake available to ne for nhotoconying all docunents requested in Interrogatories kh l GibDl/E ao tLa Eg csmedanae.t 5 -fuel SMw eshwtes Vefent)h 4 b5e u54J b bove. I further renuent that they nake avaflable to me the original PUOI!OD or other conputer runs referred to in Interrogntories flj ((p 2 3 2 N j33,37;]f for hand conying or nhotoconying of information, whichever is pernitted.

This 15th Day of January 1983 Wells Fddle man

,,..e_... n ._ -

• " - ~"~~~~~-eweenw'~- ,

UNITED STATES OF AME9ICA l NUCIJAR REGULATOFY C0!C4ISS10N  :

l In the matter of CAROLINA PO'iER & LIGHT CO. Et al. ) Dockets 50-LOO .

Shearon Harris Nuclear Power Plant, Units 1 and 2 ) and 50leh01 0.L.  !

CERTIFICATE 0F SERVICE I hereby certify that copies of h d b 4 Cd 1 NS3 00- Athh44J2U(1stft?$0C[W Dh D W sm b f S/lk* M Qknh  ;

HAYE been served this [6 ^ day of 76N kGru 1982.bydepositin the US 14 ail, first-class posth6e Prepaid, upon all parties whose names are listed below, except those whose names are marked with an asterisk, for whom service was acconplished by Judges Ja tes Kelley, Glenn Baight and James Cavnter (1 cony each)

Atonic Safety und Licensing Board US Nuclear Regulatory Commission Washington DC 20555 George F. Trowbridge (attorney for Anplicants)

Shaw, Pittman, Potts & Trowbridge 1800 M St. NW Washington, DC 20036 Office of the Executive Legal Director Phyllis Lotchin, Ph.D.

Attn Docke ts 0 50-14 0/401 0?L. 108 Bridle Run USNRC Chanel Hill

~ NC 2751h Washington DC 20555 Dan Read Docketing and Service Section CHANGT/FLP i Attn Dockets 50-1400/h01 0.L. Box 52h Office of the Secretary Chapel Hill NC 2751h USNRC Washington DC x 20555 Pat & Slater Newman CAMP John Runkle ,

2309 Weynouth Court CCNC Raleigh NC 27612 307 Granville Rd .

Chapel Hill Nc 2751k A g Q ,g E fcg g Travias Payne E'C'WGM Nt4 NVAd Edelstein & Payne pega[ J4/p;L (f-JL R e C 27605 0WI W W?' M Sibb2 Richard Wilson, M.D. Certified by 729 Hunter St.

Apex NC 27502