ML20031C590
| ML20031C590 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/02/1981 |
| From: | Silberg J ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20031C591 | List: |
| References | |
| NUDOCS 8110070327 | |
| Download: ML20031C590 (2) | |
Text
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October 2, 1981 co Cb UNITED STATES OF AMERICA POCKETED
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OCT, 51981>
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING B 4 LD WUMMh8SU M 1%s?r3&S3513
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PENNSYLVANIA POWER & LIGHT COMPANY M
I and Docket Nos. 50-387
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50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC.
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(Susquehanna Steam Electric Station, )
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Units 1 and 2)
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M APPLICANTS' SUPPLEMENTAL ANSWER TO NRC STAFF MOTION FOR l
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SUMMARY
DISPOSITION OF CONTENTION 4
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Applicants' letter of September 28, 1981 informed the[tdi~
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i Licensing Board and the parties of Pennsylvania Power & Light Company's adoption of a new forecast.
The letter also stated that, as a result of the new forecast, Applicants were withdrawing portions of two affidavits submitted wit!1 Applicants' Answer to NRC Staff Motion for Summary Disposition of Contention 4, dated September 23, 1981.
Those portions, in the Affidavits of William F.
Hecht and Grayson E. McNair, refer to the results of the prior PP&L load forecast and relate only to Contention 4b.
Attached hereto are supplemental Affidavits of Mr. McNair and Mr. Hecht, dated October 1, 1981.
Mr. McNair's Affidavit describes the changes made by PP&L's new peak load and sales i
forecasts.
Mr. Hecht's Affidavit provides the results of an t
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analysis which show that even under conditions of zere growth in peak lead and sales, the operation of the Susquehanna units produces a net benefit in the billions of dollars.
Both Mr. McNair's and Mr. Hecht's Affidavits observe that zero growth in peak load and sales ia extremely unlikely to occur.
The Supplemental Aff!. davits demonstrate that the conclusion expressed in Applicants' September 23, 1981 Answer is not changed by PP&L's new forecasts -- operation of the Susquehanna units will result in very substantial savings to PP&L and its customers in comparison to not operating Susquehanna.
- Thus, for the reasons set forth in Applicants' earlier response to the Staff's motion and those stated herein, Applicants believe that there are no genuine issues of material fact as tc Contention 4 and that the Staff's Motion for Summary Disposition should be granted.
Respectfully submitted, SHAW PITTMAN POTTS & TROWBRIDGE o
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Jay.y. SilbergTravieso-Diaz/
Matias F.
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Counse for Applicants 1800 M Street, N.W.
Washington, D.C.
20036 Telepleae : (202) 822-1000 l
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