ML20053E803
| ML20053E803 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/26/1982 |
| From: | Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| Shared Package | |
| ML20053E791 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8206100107 | |
| Download: ML20053E803 (11) | |
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UllITED STATES OF AMERICA flUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIt1G BOARD In the flatter of
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CONSOLIDATED EDIS0!1 COMPANY OF NEW
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Docket tios. 50-247 SP YORK, IllC. (Indian Point, Unit No. 2) )
50-266 SP
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POWER AUTHORITY OF THE STATE OF f4EW
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May 26, 1982 YORK (Indian Point, Unit llo. 3)
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NRC STAFF INTERR0GATORIES T0, AllD REQUEST FOR
. DOCUMENTS FROM C0!150LIDATED EDIS0N COMPANY OF NEW YORK, INC.
IflTRODUCTION The 14RC Staff hereby requests that Consolidated Edison Company of flew York, Inc. (Licensee or Con Ed) pursuant to 10 C.F.R. 5% 2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce or make available for inspection and copying, all documentary material identified in responses to interrogatories below.
INSTRUCTI0f1S AND DEFINITIONS 1.
Information sought in these Interrogatories shall include information within the knowledge, possession, control or access of any agents, employees and independent contractors of Licensee.
2.
Answer the following interrogatories separately (by parts) in writing'under oath or affirmation of the individuals who contributed thereto. Documents produced shall indicate in response to which specific request the documents are being produced, i.e. 1(a).
For all 8206100107 820526 PDR ADOCK 05000247 O
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references requested in these interrogatories, identify them by author, title, date of publication and publisher if the reference is published, and if it is not published, identify the document by the author, title, the date it was written, the qualification of the author relevant to c
this proceeding, and where a copy of the document may be obtained.
3.
In your answer, repeat each Interrogatory set forth herein and then set forth and answer thereto separately and fully.
As to any Interrogatory, section or subsection of said Interrogatory that you refuse to answer for any reason, separately state the grounds for any such refusal. Where a complete answer to a particular Interrogatory, section or subsection of said Interrogatory is not possible, such Interrogatory, section or subsection of said Interrogatory should be answered to the extent possible and a statement made indicating the reason for the partial answer.
4.
Identify any documents used as the basis for the answers to the Interrogatory.
5.
If any Interrogatory or part thereof is objected to, state j
separately (by part) the objection and basis therefor.
6.
If privilege is claimed as to any document, identify what is being withheld, the date of the document, the sender (s), the recipient (s) of all copies, the privilege claimed, the basis for the assertion of privilege, and the present location of the document.
7.
If any document requested is unavailable, explain the circumstances of such unavailability.
8.
In accordance with 10 C.F.R. % 2.740(e) these Interrogatories and requests for documents require prompt supplemental answers should l
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-m the Licensee obtain or identify supplemental information or documents which call into question the correctness of earlier answers.
9.
In the event any word, term, or phrase is unclear to Licensee, it is requested that oral clarification be requested of the undersigned Staff counsel.
Any word, term, or phrase is to have its generally accepted meaning.
10.
" Documents" means all writings and records of every type in the possession, control or custody of the Licensee, its directors, officers, attorneys, employees or agents, including, but not limited to, memorandum correspondence, reports, surveys, evaluations, charts, books, minutes, notes, agenda, diaries, logs, transcripts, microfilm, accounting statements, telephone and telegraphic communication, speeches, and all other records',
written, electrical, mechanical or otherwise.
" Documents" shall also mean copies of documents, even though the originals thereof are not in the possession, custody of control of the Licensee.
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l INTERR0GaTORIES AND DOCUMENT REQUESTS Interrogatory 1 (a)
Provide all documents which relate to estimates of the incremental cost to the utility and its customers for the period extending over what would have been Indian Point Unit No.2's remaining useful life, assuming that the unit was permanently shut down effective mid-1983.
Include in your response to this Interrogatory documents relating to estimates assuming both availability and unavailability of Indian ?oint Unit No. 3 for the remainder of its useful life.
(b)
In your answer to 1(a) above, provide all documents relating to the cost differential for each year impacted and identify total incremental cost on a 1983 present worth basis.
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(c)
In your answer to 1(a), above, provide all documents which identify the cost elements considered, e.g., differential in system production costs, and differential due to changes in capacity expansion plan.
(d)
Identify the assumptions, data, and documents relled upon in calculating the estimates contained '
the documents called for by Interrogatory 1.
Interrogatory 2 (a) Provide all documents which relate to estimates of likely outages to Indian Point Unit No. 2 and any other units (identifying such units by name) as a result of the proposed settlement agreement with EPA and NY PUC (re cooling system operations during biologically important periods).
(b)
If Indian Point Units Nos. 2 and 3 were permanently shut down, would the other impacted units (identified in 2(a), above) still be subject to the same outages?
If not, explain why the outages would differ making specific reference to each generating unit involved.
Interrogatory 3 Provide a copy of your latest submittal to Northeast Power Coordinating Council response to ERA order 411.
Interrogatory 4 Provide latest copy of " Report of Member Electric Systems of the New York Power Pool and the Empire State Electric Energy Research Co rpora tion. "
Interrogatory 5 Provide all documents which relate to estimates of the decommissioning cost for Indian Point Unit No. 2 assuming (a) decommis-sioning occurred at end of useful life, and (b) decommissioning occurred prematurely (i.e., consistent with mid-1983 shutdown).
In your response to this Interrogatory identify all of the data and assumptions used in developing such cost estimates.
Interrogatory 6 Have any provisions or proposals, such as change in the rate base, been made by the Licensee, its agents or consul # ats to recover expected
decommissioning costs for Indian Point Unit No. 2? If so, identify such provisions or proposals and all documents relating to such provisions and proposals.
Interrocatory 7 If Indian Point Unit No. 2 or Unit No. 3, or both, were permanently 4
shut down in 1983, would replacement power generation be needed? If so, identify for the period extending over what would have been the Indian Point Unit (s) remaining life the specific sources (noting the power output for each source) of power generation (whether existing or new construction) that would be necessary to take the place of the Indian PointUnit(s).
Provide for each identified source of such generation all documents that describe the surrounding environment.
Particularly provide those documents which note the description of aquatic and terrestrial biota that might be affected by operation or construction of such replacement sources.
Interrogatory 8 A.
For the year 1980 and, if available, the year 1981 provide the annual fixed charges on the capital investment attributed to Indian Point Unit No. 2 and any other fixed costs of the utility which are allocable to Indian Point 2 (giving the bases for their computation),
including but not necessarily limited to the following:
- 1) depreciation 2) return on investment (excluding interest) 3)
interest 4) income taxes
- 5) property taxes
- 6) other state and local taxes 7) interim replacement allowance 8) property insurance premium
- 9) nuclear liability insurance premium 10) non-nuclear liability insurance premium 11) general administrative costs (excluding fixed operation and maintenance cost)
- 12) other fixed costs (specify if possible)
B.
Indicate which, if any, of the costs in your response to Interrogatory 8 will vary from year to year and the amount of decrease or increase, assuming Indian Point 2 continues to operate.
C.
In your response to 8.A.2) and 3), indicate how the return on investment and interest is computed.
D.
Identify the kinds of state and local taxes attributed to Indian Point Unit 2 paid by Con Ed.
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7 E.
1)
In your response to 8.A.11) explain how general administrative expense was determined.
Z) State whether Con Ed conducts any nuclear related planning or research activity not specifically tied with Indian Point 2, the cost of such activity, whether that cost was included in general administrative expense, and to what extent the shutdown of Indian Point 2 could be expected to affect that cost.
Interrogatory 9 Identify the original book cost and present book cost of Indian Point 2.
Interrogatory 10 Indicate which, if any, of the costs in Interrogatory 8 would cease in the event of a shutdown of Indian Point Unit No. 2 and which, if any, of the costs in Interrogatory 8 would decline, and by what amount if Indian Point Unit No. 2 ceased operation.
Interrogatory 11 Do you expect -the New York Public Service Commission would continue to permit the inclusion of the fixed charges for Indian Point No. 2 in the rate base if Indian Point Unit No. 2 ceased operation.
Provide the basis for your response.
Interrogatory 12 Indicate for Indian Point Unit No. 2 the 1980 real property tax payments to the State and the 1980 real property tax (or in lieu) payments to the following jurisdictions: Westchester County, Town of Cortlandt, Village of Buchanan, Henrik Hudson School District, Verplanck Water District, and the Verplanck Fire Protection District.
In your response to this Interrogatory reflect the value of property exclusive of offsite transmission lines.
Interrogatory 13 Indicate for Indian Point Unit No. 2 all payments to the State l
and to local jurisdictions, other than real property tax and in-lieu payments.
In your response to this Interrogatory specifically identify the amount of each payment.
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w Interrogatory 14 Indicate for. Indian Point Unit No. 2 the number of employees at the site and the number of contractor personnel (security, maintenance) who are regularly stationed at the site.
For the former group, also indicate the job categories of employees, the residential location of each indi-vidual and the 1981 dollar value of each contract.
(Countylevel addresses will satisfy the residential location information request.)
Interrogatory 15 Indicate with respect to operation of Indian Point Unit No. 2 the 1
kind and value of materials and services purchased in Westchester and Rockland Counties and New York City during 1981.
l Interrogatory 17 (a)
Is it physically possible to construct at the Indian Point site one or more coal-fueled facilities generating a total of 1800 MW.
l (b)
If it would not be possible to locate such coal-fired generating capacity at Indian Point, state whether there are any sites i
available within a 10-mile radius of the Indian Point Units that could be used for construction of such coal-fired capacity.
In addition, identify the location of such sites.
Interrogatory 18 Using the most recent " capability period," provide the current operating reserve requirement for the NYPP, and inoicate the magnitude of each member's share of this requirement.
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Interrogatory 19 l
Provide all documents which relate to the NYPP policy regarding distribution of operating reserve.
1 Interrogatory 20 i
i Provide all documents which relate to Consolidated Edison's (Con Ed) policy regarding distribution of operating reserve.
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Interrogatory 21 Provide copies of all agreements between PASi1Y and Con Ed related to providing backup support should either utility be unable to meet its customer's requirements.
Interrogatory 22 4
Provide current status of flYPP coal conversion programl In responding to this question utilize pp. 31-36 of the April 1981 Report of Member Electric Systems of the fiYPP, Volume 1.
Identify all changes in plans and schedules since that information was prepared.
Specifically, indicate how Table 6 must be changed to reflect all units currently planned for conversion, earliest conversion date, and cost to convert.
In your response to this Interrogatory identify all assumptions including any. legal requirements, necessary regulatory approvals, and other factors relevant to the timing and success of accomplishing the conversion.
Interrogatory 23 Provide an estimate of the approximate downtime required to convert a typical unit.
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Interrogatory 24 For each oil unit not included in NYPP's conversion plan (but for which conversion is technically feasible) provide an estimate of the capital cost of conversion and an estimate of the remaining useful life of the unit.
I Interrogatory 25 Identify the difficulties and estimate the costs associated with
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converting boilers not sized to burn oil (i.e., Astoria 6, Bowline 1 &
2, Roseton 1 & 2 and Oswego 5 & 6).
Respectfully submitted, f
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Henry McGurren Counsel for NRC Staff Dated at Bethesda, Maryland this 26th day of May, 1982 n
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Q 7 (/ pu f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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e' CONSOLIDATED EDISON COMPANY
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Docket Nos, 50-247-q OF NEW YORK (Indian Point, Unit 2 )
50-286 POWER AUTHORITY OF THE STATE OF q,g N 09 ;g82h NEW YORK (Indian Point, Unit 3)
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T CERTIFICATE OF SERVICE
,7 88 I hereby certify that copies of "NRC STAFF INTERR0GATORIES T0, AND g
FOR DOCUMENTS FROM PARENTS REGARDING QUESTION 6 CONTENTIONS,"
"NRC STA INTERROGATORIES T0, AND REQUEST FOR DOCUMENTS FROM GNYCE REGARDING QUESTION 6 CONTENTIONS," "NRC STAFF INTERROGATORIES T0, AND REQUEST FOR DOCUMENTS FROM WBCA REGARDING QUESTION 6 CONTENTIONS," "NRC STAFF INTERR0GATORIES T0, AND REQUEST FOR DOCUMENTS FROM POWER AUTHORITY OF THE STATE OF NEW YORK," "NRC STAFF INTERROGATORIES T0, AND REQUEST FOR DOCUMENTS FROM CONSOLIDATED EDIS0N COMPANY OF NEW YORK, INC." in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 26th day of May,1982.
Louis J. Carter, Esq., Chairman Paul F. Colarulli, Esq.
Administrative Judge Joseph J. Levin, Jr., Esq.
Atomic Safety and Licensing Board Pamela S. Horowitz, Esq.
7300 City Line Avenue Charles Morgan, Jr., Esq.
Philadelphia, PA 19151-2291 Morgan Associates, Chartered 1899 L Street, N.W.
Dr. Oscar H. Paris Washington, D.C.
20036 l
Administrative Judge Atomic Safety and Licensing Board Charles M. Pratt, Esq.
i U.S. Nuclear Regulatory Commission Thomas R. Frey, Esq.
Washington, D.C.
20555 Power Authority of the State of New York Mr. Frederick J. Shon 10 Columbus Circle Administrative Judge New York, N.Y.
10019 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Ellyn R. Weiss, Esq.
Washington, D.C.
20555
- William S. Jordan, III, Esq.
Harmon & Weiss
, Brent L. Brandenburg, Esq.
1725 I Street, N.W., Suite 506 Assistant General Counsel Washington, D.C.
20006 Consolidated Edison Co. of New York, Inc.
Joan Holt, Project Director 4 Irving Place Indian Point Project c97 New York, N.Y.
10003 New York Public Interest h Research Group Mayor George V. Begany 5 Beekman Street Village of Buchanan New York, N.Y.
10038 236 Tate Avenue Buchanan, N.Y.
10511 m
, i John Gilroy, Westchester Coordinator Stanley B. Klimberg Indian Point Project General Counsel New York Public Interest New York State Energy Office Research Group 2 Rockefeller State Plaza 240 Central Avenue Albany, N.Y.
12223 White Plains, N.Y.
10606 Marc L. Parris, Esq.
Jeffrey M. Blum, Esq.
Eric Thor,sen, Esq.
e New York University Law School County Attorney, County of Rockland 423 Vanderbilt Hall 11 New Hempstead Road 40 Washington Square South New City, N.Y.
10956 New York, N.Y.
10012 Geoffrey Cobb Ryan Charles J. Maikish, Esq.
Conservation Committee Litigation Division Chairman, Director The Port Authority of New York City Audubon Society New York and New Jersey 71 West 23rd Street, Suite 1828 One World Trade Center New York, N.Y.
10010 New York, N.Y.
10048 Greater New York Council on Ezra 1. Bialik, Esq.
Energy Steve Leipsiz, Esq.
New York University c/o Dean R. Corren, Director Environmental Protection Bureau New York State Attorney 26 Stuyvesant Street General's Office New York, N.Y.
10003 Two World Trade Center New York, N.Y.
10047 Honorable Richard L. Brodsky Member of the County Legislature Alfred B. Del Bello Westchester County Westchester County Executive County Office Building Westchester County White Plains, N.Y.
10601 148 Martine Avenue White Plains, NY 10601 Pat Posner, Spokesperson Parents Concern ~ed About 1
Andrew S. Roffe, Esq.
Indian Point New York State Assembly P.O. Box 125 Albany, N.Y.
12248 Croton-on-Hudson, N.Y.
10520 Charles A. Scheiner, Co-Chairperson Westchester People's Action Coalition, Inc.
P.O. Box 488 White Plains, N.Y.
10602 Honorable Ruth Messinger Lorna Salzman Member of the Council of the Mid-Atlantic Representative City of New York Friends of the Earth, Inc.
District #4 208 West 13th Street City Hall New York, N.Y.
10011 New York, N.Y.
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3-Alan Latman, Esq.
Ms. Amanda Potterfield, Esq.
44 Sunset Drive P.O. Box 384 Croton-on-Hudson, N.Y.
10520 village Station New York, NY 10014
'Zipporah S. Fleisher West Branch Conservation Association Renee Schwartz, Esq.
443 Buena Vista Road Paul Chessin, Esq.
Laurens R. Schwartz, Esq.
New Ci ty, N.Y.
10956 Margaret Oppe.1, Esq.
Judith Kessler, Coordinator Botein, Hays, Sklar & Hertzberg 200 Park Avenue Rockland Citizens for Safe Energy New York, NY 10166 300 New Hempstead Road New City, N.Y.
10956 David H. Pikus, Esq.
Richard F. Czaja, Esq.
330 Madison Avenue New York, N.Y.
10017 Atomic Safety and-Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555
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&b Henry 0/ or'Gur'ren Mc Counsel f NRC Staff M