ML20064C456

Response to J Riley Affidavit Re Trends in Util Base Load. Util Contends That Affidavit Should Not Be Received by Board

ML20064C456
Person / Time
Site:	McGuire, Mcguire
Issue date:	09/28/1978
From:	Porter W DUKE POWER CO.
To:
References
NUDOCS 7810200007
Download: ML20064C456 (5)

Text

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aEI.LT2D CCanESPONDENCE Of

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$N UNITED STATES OF AMERICA 6 g737 NUCLEAR REGULATORY COMMISSION gg1 ]

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In the .yatter of NRC PUBL C DOCMENT ROOM /g n <

DUKE POWER COMPANY ) Docket Nos. 50-369

) 50-370 (William B. McGuire Nuclear ) j Station, Units 1 and 2) ) /[ 74 APPLICANT'S RESPONSE TO "AFFICAVIT OF JESSE RILEY CONCERNING TRENDS IN CUKE POWER COMPANY BASE LOAD" On September 13, 1978, Intervenor filed the " Affidavit of

/ ) Jesse Riley Concerning Trends in Duke Power Company Base Load."

Such affidavit appears to be a supplement to the testimony Mr.

Riley gave at the recently concluded hearings. Applicant submits that such further testimony is inappropriate inasmuch as the record has been closed. Further, the record does not reveal that Intervenor was extended an opportunity to provide such an affidavit.

Accordingly, the subject affidavit should not be received by - - .

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j this Board. _

In the event this Board does receive the subject affidavit h- ,,

I of Mr. Riley, Applicant attaches hereto the affidavit of 'D. H. -

Sterrett, dated September 18, 1978, which serves as Applicant's response to the substance of the Riley affidavit. Applicant requests that the Sterrett affidavit be received by this Board as evidence only if the subject Riley affidavit is so accepted. _

Cated: September 29, 1978 Respectfully submitted,

$ !+ I$ h William L. Porrer ~.:r ~g

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1974 1975 1976 1977 19N8 ,

May Temperature exr,remes (*F) 45-90 49-91 40-86 39-91 42-88 Eeating degree-days 36 12 68 36 72 Cooling degree-days 152 188 76 191 132 Where both heating and cooling are required during the same time period, inconsistent patterns of temperature sensitivity inherently result. Consequently, the determination of the true base load is impossible.

Applicant followed the procedure outlined by Intervenor for determining the base load "by inspection," and found such a wide range of values in the resulting curve that Applicant can neither agree nor disagree with Intervenor's choice of values. There is no basis for selecting the values used by Intervenor any more than for selecting any other of a wide range of numbers.

It is Applicant's opinion that the effects of conservation, peak load pricing and other means have not yet been determined inasmuch as insufficient data exists at this time fcr such a judgment.

Dated: September 18, 1978 , ....

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D. E. Sterrect Sworn to and subscribed -.

before me this 18th day of September, 1978.

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Notiary Public u My Cor.;nission Expires: /o.//-79

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J. Michael McGarry, III, Esq.

< Debevoice & Liberman

.' 700 Shoreham Building 806 15th Street, N.W.

Washington, D. C. 20005 f h in X. M u William L. Porter .

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