ML20050C010

Greater Ny Council on Energy (Gnyce) Amend to Contentions & Response to NRC 820211 Reply to Gnyce 820115 Answer to Objections to Contentions Re Economic Impact of Shutdown. Certificate of Svc Encl

ML20050C010
Person / Time
Site:	Indian Point
Issue date:	03/29/1982
From:	Corren D AFFILIATION NOT ASSIGNED, GREATER NEW YORK COUNCIL ON ENERGY
To:
References
*SD, ISSUANCES-SP, NUDOCS 8204080009
Download: ML20050C010 (5)

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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ATOMIC SAFETY AND LICENSING BOARD N /

Before Administrative Judges: , ,

- Louis J. Carter, Chairman - " 1,' s o.

E87 32 Dr. Oscar H. Paris Frederick J. Shon g 'dgy

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' 03 In the Matter of: )

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Consolidated Edison Company of New York, Inc. ) Docket Nos. 50-247 SP

) 50-286 SP (Indian Point Unit Number 2) ~  ?

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Power Authority of the State of New York ) March 29,.1982

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(Indian Point Unit Number 3)

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GREATER NEW YORK COUNCIL ON ENERGY AMENDMENT TO CONTENTIONS AND RESPONSE TO NRC STAFF REPLY '

TO GNYCE ANSWER TO O'BJECTIONS TO CONTENTIONS I. NRC STAFF ARGUMENTS AGAINST CNYCE CONTENTIONS ARE ILLOGICAL GNYCE wishes to re-emphasize that it is confident that its con-

, tentions lie entirely within the scope of the Commission's questions. The impression given by the NRC Staff's second round

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1982) is that of arguments against our contentions (February 11, Staff did not read our reply to objections (January 15, 1982),

since, in its discussion, it,only reiterates its claim that the .

only costs of shutdown are positive costs. We believe we have l argued-persuasively that this_makes no practical sense,.and is L a. spurious grammatical misinter'pretation of what must be considered OC p f.DR t ,

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< 2 an algebraic tabulation. That is,. costs and benefits (negative costs) of shutdown must be analyzed for any accounting to be of -

any practical use. Ignoring the financial benefits of shutdown is improperly prejudicial to the licensees' efforts to keep the plants operating at any cost.

In spite of itself, the Staff argues correctly that the "Com-mission's sixth question ~ clearly does not call for a discussion of alternate energy sources except to the extent it may contribute to the cost of shutdown." As we have argued earlier, in this proceeding, we only wish to discuss alternate energy sources tct the extent that they contribute to the cost of shutdown. Staff infers that our position is weaker because the alternate energy saurces are " unnamed." If not entirely obvious, they include most significantly,, conservation, cogeneration, coal, gas, oil, and hydro. We find the Staff's professed innocence to be dis-ingenuous.

i Staff also chooses to misunderstand our second contention. Again, it argues correctly that the "Cpmmission's sixth question does not.

call for the determination of the costs of an accident at Indian Point ... and then a balancing of such cost with the costs of a shutdown." We entirely agree, but this point is not relevant to our contention nor does it militate against it. Our contention l involves the argument'that there is a cost to the assumption-of u

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the risk entailed in operating the plants. and this cost is not zero whether or not it is actually paid or whether or not an accident actually ever occurs. In the hearings we intend to bring expert testimony from the insurance industry to support this argument. Staff, in its responses has not even addressed diis argument which has been clearly made before. As Staff admits, the Commission has clearly asked for the " costs and other consequences of a shutdown," and we insist that the removal of the risk of operation is an important consequence of a shutdown.

II. AMENDMENT TO CONTENTIONS

( GNYCE wishes to inform the Board that in all likelihood it will be able to produce for the record in this case, an economic study of the shutdown of Indian Point that will be unprecedented-in quality and scope. This is by arrangement with Energy Systems Research Group, Inc. of Boston, Massachusetts, a firm widely recognized and accepted as a leader in such analyses. Given the situation in which the economic analyses relied upon by tho' licensees, including those by the GAO and the NRC Staff have been effectively criticized as inaccurate and incomprehensive, we believe this opportunity to develop a thorough and defensible record should be welcomed by the Board, and GNYCE's recent enhancement of its capabilities by this association argues strongly l in its favor with regard to its status as an intervenor.

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III. CONCLUSION .

GNYCE believes that it is clear that its contentions completely survive the arguments against them raised by the NRC Staff, and furthermore, that it is uniquely able to add to the record,in this case in the area of the economic impacts of a shutdown of the

• Indian Point plants. ,

Respectf611y Submitted, r- ,

93 Dean R. Corren Director, GNYCE

- c/o Dean Corren

,- New York University 26 Stuyvesant Street New York, N.Y. 10003

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Louis J. Carter, Chairman

- Dr. Oscar H. Paris Frederick J. Shon

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Iti the Matter of: )

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Consolidated Edison Company of New York, Inc. ) Docket Nos. 50-247 SP.

) 50-286 SP (Indian Point Unit Number 2) - -

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Power Authority of the State of New York ). March 30, 1982

. (Indian Point Unit Number 3) ) ,'

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CERTIFICATE OF SERVICE .

I hereby certify that copies of GREATER NEW YORK COUNCIL ON. .

ENERGY AMENDMENT TO CONTENTIONS AND RESPONSE TO NRC STAFF REPLY TO GNYCE ANSWER TO OBJECTIONS TO CONTENTIONS in the above-captioned proceeding have been served on the members of the service list as attached, this 30th day of March, 1982.

I Dean R. Corren ,

Director, GNYCE l

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