ML20065F381

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Suppl to Chapel Hill Anti-Nuclear Group Effort/Environ Law Project 820713 Renewed & Reformed Motion to Postpone Proceedings,Originally Submitted on 820316.Suppl Based on New Info.Certificate of Svc Encl
ML20065F381
Person / Time
Site: Perry, Harris  Duke Energy icon.png
Issue date: 09/24/1982
From: Read D
CHAPEL HILL ANTI-NUCLEAR GROUP EFFORT
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8210010337
Download: ML20065F381 (7)


Text

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UNITED STATES OF AMERICA 82 EP 30 A10:31 NUCLEAR REGULATORY COMMISSION p.U?!S# Ndt _.

i~r s. g ;-~ p BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of

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Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al.

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50 401 OL (Shearon Harris Nuclear Power Plant,

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Units 1 and 2)

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September 24, 1982 SUPPLEMENT TO MOTION: NEW INFORMATION On July 13, 1982, Chapel Hill Anti-Nuclear Group Effort (CHANGE)/ Environmental Law Project (ELP) served on parties and the Board in this proceeding a " Renewal and Reformation" of a "MotiontoPostponeProceedings"origincllysfpittedonMarch 16,.1982 New information has come to the attention of CHANGE /

ELP, which is attached. is an excerpt of testimony given by Edward G. Lilly, executive vice-president of Applicant CP&L, before the N.C. Utilities Commission on July 21, 1982 in Docket E-2 Sub 444, under cross-examination by Jerry Fruitt, Esq., of Eller and Fruitt, Raleigh, N.C. The attached are pages 83 to 85 of Volume 8 of the transcript.

CHANGE /ELP believes Lilly's assertion that CP&L will "not spend any money on or any substantial amount of money on Harris Unit Number II until absolutely necessary" supports its contention that consideration of an OL for Harris 2 be deferred until such time as there is in fact reasonable ass-0210010337 820924 PDR ADOCK 05o00400 3G G

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Page 2 urance that it will in fact be completed, in such time that consideration at'this time is appropriate. is a statement by executive vice-president William E. Graham, Jr. of CP&L in response to the Utilities Commission's order in Docket E 2, Sub 444. It is reproduced as reported in The News and Observer, Raleigh, North Carolina, Saturday, September 25, 1982, at page 7A.

CHANGE /ELP believes that Graham's assertion that the order "probably means an immediate cessation of all work on Harris nuclear unit number 2" further supports its motion and urges e

the Board to grant the r11ef requested.

4 CHANGE /ELP submits this information as new information in support of its motion already filed.

Respectfully submitted, s

MO Daniel F. Head President, CHANGE P.O. Box 524 Chapel Hill, NC 27514 e

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Amcher 1 p.1 83 A.

Yes.

Q.

Sir, does that take into account the revenues that are paid by the ratepayer prior to the in-service date of the plant?

A.

Yes, it does.

Q.

It does?

A.

I think it does.

I'll have to check but my impression is that it does.

Q.

And I think.you have agreed to provide those workpapers?

A.

Yes.

Q.

Sir, at the present tim H believe you discussed ~the construction program and financial needs.

At the present time do you know what.the projected cost of Harris II is, sir, total cost?

A.

I have it.

I'll get'it-fc9 you in ju.St a moment.

(Pause)

It's around $2 billion.

While I'm getting that, go ahead with something else.if you wish and I'll get that for you in just a moment.

Q.

Well, I'd rather just' wait a second if that's okey l

if you think you can readily find it because I was going to ask you a couple of questions along that same line.

l l

A.

S1,959,000',000.

l Q.

That's the projected total cost?

A.

Yes.

(

Q.

$1,90 T,DD0',0QQ.what?

A.

$59 million.

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Artukm:11-p 4 84 QT ~

And, sir, on that same page possibly, do you have what has been expended?

A.

As of Decerber 31, 1981, S 1', 0 5 6 ',0 0 0 ', 0 ~0 C.

Q.

This is Harris II?

A.

Harris I was what I. thought you asked me about.

Q.

Well, I may have.

If I did I was in error.

I meant Harris II.

I'm sorry.

I may.have said Harris I.

A.

On Harris II the expenditures through December 31 had been $233 million and.the toral cost -- I have a figure here which I'm not sure is correct, frankly.

The figure is roughly

$1.4 billion and I'm not sure.that that is an accurate figure.

It may be slightly higher than that but I will check that figure.

Q.

Well, sir, you have a $2 billion construction progr.am over the next two years, do you not?

A.

That is correct.

Q.

How much of that is attributable to Harris II?

A.

Over the next two years, three years?

Q.

Three years I believe is what your S2 billion figure covered.

A.

At the present time the company is devoting its principal construction effort at the Harris site to Harris Unit Number I.

Very modest 750s.ts of money are being expended on Harris Unit II ber*T:

0.

construction people feel and management obvious *.y cours that it is more effective, more cost effective to complete Harris Unit I in the most efficient

ATTMWnt J.J 'd0 l

85 manner possible an'd the most rapid manner; bring that en line, make the energy generate, rake the generatien available to our customers and, of ccurse, not spend any money on or any substantial amount of money on Harris Unit Number II until absolutely necessary.

Beginning during the calendar year 1933 we would start spending larger amounts of money on Harris Unit Number II and for the next three years we would spend in the neighborhood of 5250 to 5300 millien en that unit.

Q.

In what time period?

A.

Three years.

Q.

Three years?

A.

Yes, sir.

Q.

That was S250 to S300 million?

A.

Yes.

I believe you asked me the 1982 to 1934 timeframe which would be somewhat less than that.

Total expenditures would be -- no, the figure I gave you is correct.

Q.

For '82?

A.

'82 through

'84, yes.

Q.

Sir, if the company, I believe as was discussed with Mr. Snith, if the company should this f all elect to delay that unit one year that would tend to reduce your construction budget, would it not, sir?

A.

It would tend to def er.the expenditures, the heavier expenditures for that unit by a period of 12 months if the deferral

Attach nt 2 The News and Observer, Raleigh, M. C., $st., Sept. 25,1982 Statement by CP&L official responding to ruling

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"Therefore the net effect is that we have received a substantial Following is a statement by Wil.

revenue decrease.

Ilam E. Graham Jr., executive "As to company management, vice president of Carolina Power &

although the costs of producing Light Co., issued in response to the electricity have risen in recent ruling Friday by the N.C. Utilities years, and rates have had to rise Commission cutting CP&L's pro.

as a consequence, our rates have posed revenue increase from remained lower than in other simi-

$160,5 million to $8.8 million:

lar areas. For example, the aver.

"We have not seen the order, age price per kilowatt hour to resi-and obviously it will take some dential customers for the 12-month time for us to review it. However, period ended June 30,1982 in Mi-if it is as negative as reports indi.

ami, Jacksonville, Savannah, cate, u is ;udeed devasting and Charleston, Norfolk, Baltimore will have far-reaching impact on and other cities along the Atlantic our customers, the company and seaboard was higher than in our the economy of our service area.

service area.

"We expect to appeal the order "For a number of reasons, some to the courts and we have to file related to__ regulatory modifica-another rate case as quickly as we tions, others not, we acknostedge can.,

that our. Brunswick plant has not "This probably means an imm,.

consistently met our performance diate cessation of all work on expectations in recent years.

Harris nuclear unit number 2 and "We are sparing no effort to turn on Mayo coal. fired unit 2. It may that situation around, and. to im.

mean the layoff of some workers,

Prove the plant's performance. We at the Harris site as early as next ' i are confident that we have the week.

management team at the plant to "At this time, we will try to min.

do this.

Imize layoffs by concentrating all-

" Completing the necessary mod-work on Harris Unit L If we are ifications and reliability improve-not able to go forward later with a ment measures at the Brunswick lP ant willtake a couple of years or minimum construction program, electric service in future years so. But we will do it,.and custom-I will be cut back.

ers will enjoy substantial savings

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"We are concerned about the over the life of the plant.

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impact upon economic growth and

" Publicity focusing on problems future jobs. We expect to notify at a single generating facility can i

our large customers and the ap.

easily distort your perception, as a l

propriate government develop.

consumer of CP&L's total opera-ment officials that requests for tions. Electricity rates are not long-term service from new or ex.

based on production costs at one lP ant, but on the operation of the panded industry will have to be closely reviewed by our corporate entire system.

system planning department, and "Even with the increased down-that.we may not be able to accept time at our nuclear facilities, our new requests for long-term service total operating and maintenance from large loads at our standard expenses last year -including fu.

(power) rates, el, purchased power, mainte-

"If our information is correct, nance, wages and salaries and ev-the ultimate effect of the order is erything else - were the second to decrease rather than toincrease lowest in the group of eight major revenues. The smallincrease cited Southeastern utilities.

by the commission is attributed "More importantly,look at what solely to increased fuel costs, and CP&L customers pay for electrici-it appears that will leave a short.

ty in comparison with rates up and fall of approximately $30 million down the East Coast frem Boston

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over the next year.

to Miami.... CP&L's rate are low

Nn:i E-UNITED STATES OF AMERICA UN' NUCLEAR ' REGULATORY COMMISSION

~22 SEP 30 m fDocketa In the Matter of CAROLINA POWER & LIGHT CO.

j 50 400,n et al., Shearon Harris Nucicar Plant, Units 1 & 2 ) 50 401 ocddiji:ff W CERTIFICATE OF SERVICE cRANCH I hereby(certify that copies of *SbkewntAl mCwt bWin Aqk.Al 1

GMm1Gw', 'hppkmenf $ M*A* Mhepe 'Yerved this 2.'fd day T

9W5 of Scot 1Mk,198 2., by deposit in the U.S. Mail, first-class postage prepaid, upon all parties whose names appear below, except those whose names are marked with an asterisk, for whom service was accomplished by hand cit lMj Mkld, g

mul James L. Kelley, Licensing Boa:dEsq./Mr. Glenn O. Bright /Dr. James Carpenter ggg Atomic Safety &

(one each)

U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the Executive legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 Thems Aam e tsj..

Docketing and Service Seetion S P P t' T Office of the Secretary j g c o M s r,V W U.S. Nuclear Regulatory Commission Washington, DC 20555 g,'gigg> p.

jg y M r. John D. Runkle

$Dr. Phyllis Lotchin Conservation Council of North Carolina 108 Bridle Run 307 Granville Road Chapel Hill, NC 27514 Chapel-Hill, NC 27514 M. Travis Payne, Esq.

Mr. Wells Eddleman Edelstein and Payne 718-A Iredell Street P.O. Box 12463 Durham, NC 27705 Raleigh, NC 27605 Dr. Richard D. Wilson Patricia / Slater Newman 729 Hunter Street CANP Apex, NC 27502 2309 Weymouth Ct.

Raleigh, NC 27612 Daniel F. Read President Chapel Hill Anti-Nuclear Group. Effort i

P.O. Box 524 Chapel Hill, NC 27514

.