ML20054H260

Reply to NRC 820526 Interrogatories

ML20054H260
Person / Time
Site:	Indian Point
Issue date:	06/17/1982
From:	Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20054H261	List: ML20054H260 ML20054H263
References
ISSUANCES-SP, NUDOCS 8206230166
Download: ML20054H260 (3)

Text

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UNITED STATES OF .M1 ERICA NUCLEAR REGULATORY COMMISSION i .

- 'e ATOMIC SAFETY AND LICENSING BOARD g.ggir -

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Administrative Judges: '

Louis 3. Carter, Chairman

.v3 J- wil ?? 'm 30 Dr. Oscar H. Paris ggg[ 5 r

In the Matter of Frederick 3. Shon

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CONSOLIDATED EDISON COMPANY OF NE'# YORK Docket Nos. 50-247-SP [

(Indian Point, Unit 2) 50-236-SP POWER AUTHORITY OF THE STATE OF NEW YORK June 17, 1982 (Indian Point, Unit 3) i WEST BRANCH CONSERVATION ASSOCIATION'S REPLY TO INTERROGATORIES FROM NRC STAFF OF MAY 26, 1982 WBCA finds it burdensome to type the questions above each answer. Staff will please refer to its docu-ment and read it side-by-side with this one.

ANSNER TO #1

1. The main source of information for WBCA con-

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tention 6.1 is the " Report of the Member Electric Sys-tems of the New York Power Pool, pursuant to section 5-112 of the Energy Law of New York State" 1982,"Vols.

1 and 2; 1981, Vols.1 and 2 and 1980, Vols. 1 and 2.

We may also refer to earlier editions issued un-der Article VIII of New York State Public Service Law.

2. Excerpts from" Opinions and Orders" and tes-timony in rate cases of Orange and Rockland Utilities numbers 27909 - 1981, 29553 - 1979 and 27094 - 1977,

' o t- WEST BRANCH CONSERVATION ASSOCIATION, INC.

443 Buena Vista Road g$,${J, '

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New City, N.Y. 10956 _,

914/634-2327 by Zippor ah S. Fleisher Secretary

_1-8206230166 820617 PDR ADOCK 05000247 d ' ['Y G PDR

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i bef ore the New York State Public Service Commission. , g The Power Pool Reports are public dog'cuments and if need be could be inspected at 443 Buena Vista Road, New City, N.Y. by appointment, and where there are no copying facilities. We assume that all members of the Pool have copies and which includes the Licensees in dbove dockets. i Additional copies should be available from the New York Sate Public Service Commission and the New York State Energy ,

t Of fice both at Albany, New York.

" Opinions and Orders" and testimony we will use are available at WBCA as noted above. The complete records of the cases are available at the NYS Public Service Commission.

ANSWER TO #2

a. Walter L. Fleisher, Vice-President of WBCA.

b. 443 Buena Vista Road, New City, N.Y. 10956 is trained as a Mechanical Engineer.. with 44 years experience in manufacturing, installation and design of mechanical sys-tems. He has participated as an intervenor and/or witness in 19 rate cases, generic cases before the NYS PSC on the relative merits of nuclear vs fossil fueled electric genera-ting plants; Site Selection, nost of the hearings on long range planning under Article VIII, 149b, and 5:112 of the NYState Energy Law, etc. A ccmplete resume will be provided with Mr. Fleisher's testimony. (It has already been sent to the Licensees under a WBCA interrogatory.)

c. Walter L. Fleisher.

l ANSWER TO #3 g (a) (b) (c) (d) i years MWE Fuel alt. Prod. cost 1981 [

Lovett #3 NA 61 Resid. oil, gas , 42.10 mills 1;-

1. 4 NA 170 1/

1. 5 UA 202 1/

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" " " 55.20 30% E B owlinc#1 NA 201 "

1. 2 NA 200 " " " 35% E 1/ Application for permit to burn coal is in pro-cess. Has been approved by NYState Dept. of En-

)E vironmental Conservation. Still requires EPA E li approval. E ANdhR TO #4 i

If and when Lovett #4 and #5 are converted to coal, j r

testimony during the hearings by ORU stated they would be base I loaded for the customers of ORU and would not be available ..

I The excess capacity would come from Bow- 4 to Coned and PASNY.

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line Units #1 and #2. Note that Coned owns 2/3 of the Bow- I n

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E line plane, that is 800 of the 1200 MWE. ORU's share of 5

Bowline #1 operated at 30% CF and #2 at 35% CF in 1981. If g the capacity factors of these plants were raised to a rea- )

i sonable range production costs would be reduced as well as [

f capital costs per KWH. In our opinion there is no way that E E

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production costs per KWH will be increased.

ANSWER #5 In the last ORU rate case, Opinion and Order 81-24, E net interchange sales under economic dispatch were set at I

$1.8 million not benefit to the New York customers of ORU. h

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We have not made an estimate of the benefits to ORU at this  :

E time but expect that they will be well in excess of the  ;

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figure given above.

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