ML20071D232

Public Appearance Statements Received by ASLB on 830301 in Rockford,Il

ML20071D232
Person / Time
Site:	Byron
Issue date:	03/01/1983
From:	Dale J, Edwards C, Galbreath B, Hickey C, Parfitt R, Peters D, Quigg C, Skala J, Skala S, Youhn N AFFILIATION NOT ASSIGNED, POLLUTION & ENVIRONMENTAL PROBLEMS, INC.
To:
References
NUDOCS 8303090273
Download: ML20071D232 (37)

Text

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POLLUTION AND ENVIRONMENTAL PROBLEMS, INC. Y P.O. Box 309 Palatine. Illinois 60067 March 1, 1993 312/381 6695 ,

F2: U.S. Nuclear Regulatory Commission f Atomic Safety and Licensing Board O' FRW: Catherine Quigg, research director Pollution and Brvircasental Problems, Inc.

200 East Wood Street, Palatine, Illinois 60067 i

(312/381-6695) l I

RE: Public Testimony--Licensing of Byron Nuclear Power Plant NUCLEAR REACTOR ACCIDENf Col 6EQUENCES INCREASE AS NATION MO7ES TOWARD HIGH BURNUP REACTS FURL: U.S. NRC BAS YET TO REDEFINE ACCIDENT SOECE TERI6 The nuclear industry is moving increasingly toward high burnup fuel in its lightvater reactors--eeaning the fuel win be more enriched with uranium i and win be irradiated for much longer times in the reactor. The Byron nuclear power plant vill be no exception.

Until recently, standard burnup has been about 33,000 megawatt days per ton of uranium (36td/t), but the nuclear industry now plans to burnup fual toeshighas65,000Mrd/t. Wide-scale application of high burnup fuel is anticipated by 1985. Already license amendments far use of high burnup fuel have been issued to North Anna, Surry and the Calvert Cliffs stations --and more similar amendment requests are expected by the NRC.

Because new high burnup fuel vill contain uranium which is more highly enriched than the . current type of fresh fuel, there is a potential for criticality problems and W question arises whether or not it win be safe to store the high burnup fuel in today's pools designed to hold standard fresh fuel prior to care loading. If, for some reason, it becomes necessary to remove the fuel from the care early in its irradiation cycle--even more significant nuclear criticality problems may occur.

• /uel irradiated for longer time periods in the reactor vin be hrmally hotter and its decay period win take longer than standard burnup fuel, thus necessitating longer storage times in the spent fuel pool. For high burnup fuel--

seven years after removal fra the reactor core--the cooms capacity 2equired per fuel assembly would be a factor of two greater than that needed far existing ]

standard fuels. The heat given off would be 1,000 watts per assembly for high '

burnup Cael versus 500 watts far standard fuel. For long term storage onsite or offsite, there would be a 100 percent increase in cooling capacity requirements for each high burnup irradiated fuel assembly. Moreover it win act be possible, even with longer storage times, to move high burnup fuel in the same transport casks as standard burnup fuel.

The quantity of long-lived radioisotopes (i.e. cesium with a 30 year half-life) in high burnup fuel vill be greater than standard burnup fuel--some almost doubling. (See attached Table 5 fra DOE /EA On8). Most traditional C303090273 830301 PDR ADOCK 05000454 PDR 4 T

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accident analyses follow the U.S. ERC's 10CFR, Part 100 in which h reactor loses just radioactive iodine and noble gasas. The ERC is now obliged to consider ,

Class 9 accidents in which the whole care melt.s and the con

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ruptures. In this case, high burnup fuel with its greater quantities of long-lived i fission products is a much greater problem than today's lower burnup fuel. The production of some long-lived fission products is not linear, but rather the .

snount of transuranics may triple or quadruple and there will be far more alpha and neutron radiation to contend with after an accident. For example, the U.S.

Department of Energy estimates that t,he.25 percent increase in : uthenia-106 alone in higher burnug fuel "would likely lead to an increase in the lung dose of about ten percen5 Slowly but steadily, without public hearings or discussion, utilities are going to high burnup fuel. The equivalent of one reactor care has already i been irradiated to 45,000 Mwd /t in various reactars throughout the United States. ,

All utilities will not go to full core high burnup immediately, but many will increase in increments of 500 mad BWR4 replace 1/k core each year.)/t as they refuel. (PWRs replace 1/3 core a The accident consequences reported in the Reactor Safety Study (WASH-1400) and earlier accident studies were based on very low burnup fuel--with a high burnup of 26,400 Mrd/t. (See Figure VII, F-2 fra RSS, page VII-141 attached.) '

There have been n_o, safety analysas or accident assessments by the ERC available to the public that are based on high burnup fuel. Thus it is impossible to reach a definitivs conclusion regarding the impact of partial or complete cores of high burnup fuel in the assessment of public risk after a core melt accident.

Until these staties are performed, all quantitative analyses of risks from nuclear power plant accidents in all documents, including WWWG-0880 and WASH-1400, must be considered outdated, misleading and irrelevant to UJ. nuclear power reactors currently on line and anticipated in the future--as they continue to increase their fuel burnups and thus N fission products in their reactor cores. New safety analyses should also be required for fresh fuel pools and irradiated fuel pools to determine if there is increased risk of accidents or radioactive releases. All IRC source term documents are obsolescent and must be revised to have any meaning in the real world.

No nuclear reacters should be licenzad in the absence of this vital information... including the Byron Nuclear Power Station near Rockford, Illinois.

199 Intter from NRC dated November 1,1982 attached.

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Ms. Catherine Quigg, Research Director pollution and Environmental Problems, Inc.

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Dear Ms. Quigg:

Your letter of October 11,1982 to Mr. Chilk requesting a report of progresc on your petition has been referred to me for response.

The U.S. Nuclear Regulatory Comission (NRC) staff has been working towards resolution of this matter and a recomendation to the Comission is expected shortly.

! The use of high burnup fuel in comercial nuclear power plants has increased. The program to demonstrate this technology is well advanced i and the NRC staff is evaluating the results. License amendments have been issued to North Anna, Surry and the Calvert Cliffs stations to utilize these fuels and more similar amendment requests are expected.

The staff has indications that the use of high burnup technology will have significant economic impacts, i.e., reduction in uranim mining and milling as well as more cost efficient generation d of electricity. If the impacts of Comission actions in pern.tting the use of this technology are purely economic or social, Section 1508.14 of the CEQ Regulation (40 CFR 55978) indicates that the National Environmental Policy Act

. (NEPA) does not require an Environmental Impact Statement (EIS) be prepared.

The evaluations conducted for the three Itcense amendments granted to date have indicated that no significant safety implications are involved in allowing the use of high burnup fuel at those plants. NRC research pmgrams directed at refining severe accident source tems could possibly modify these conclusions, as they apply to all plants using high burnup fuel.

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l The type of environmental impact analysis appropriate to the question of  ;

general usage of high burnup fuel in comercial nuclear power plants '

will depend on the conclusions reached on overall safety significance. -

You will be infomed of further progress and of any action the Comission takes on your petition. '

Sincerely, 9kIA8)$(gnedgy W F. Ross,Jr.

Robert B. Minogue, Director Office of Huclear Regulatory Research i

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The Honorable Ivan Smith Atomic Safety and Licensing Board Federal Building -

211 S. Court Rockford, Illinois

Dear Judge Smith:

What follows is an abbreviated list of our concerns about the Byron Nuclear Power Station and nuclear power in general.

It is alleged: )

1. that the Byron Nuclear Power Station has pressurized steam reactors of the same design as a nuclear power plant in Yugoslavia. The Yugoslavians have shut down this plant and requested that Westinghouse, the manufacturer of the pressurized steam reactor, rectify the design so i that it will be safe. In a public broadcast on WNIU (DeKalb, March 1, 1983, 7:55 AM), Commonwealth Edison's spokesman replied to this allegation by stating that West-

inghouse isn't sure how to rectify the design, and, further-more, does not appear to have a committment to do so.

Therefore, according to the spokesman, there is no point in waiting for the design to be made safe. This is hardly a responsible or intelligent attitude. In fact, it shows very poor judgement and causes us to question the ability of Commonwealth Edison to administer a plant safely.

2. that there is a lack of a safe evacuation plan even in the minimum 10 mile zone. Commonwealth Edison claims this is not it;s responsibility. Perhaps not, but the utility should bear some responsibility for such a plan.

It is, after all, running the plant. After the experience at Three Mile Island, we don't feel we can believe any statements of a public utility regarding the safety of these plants.

3. that not only are these plants extremely expensive to build, but that maintenance and decommission of them are also extremely expensive. We may be assured that all of ,

these costs will be passed on to us, the consumers. As consumers we have dialed back, turned off, and conserved conscientiously, yet rates will continue to rise meteor- 1 ically as long as Commonwealth Edison is allowed to pursue this form of energy. As lifelong residents of Illinois, a state rich in coal reserves, we don't understand the l necessity of using expensive nuclear fuel when coal is

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abundantly available. There is the fact, too, that coal can be made to burn cleanly and safely.

4. that Commonwealth Edison has given the Committee for Energy Awareness a 3 5 million dollar' grant, out of our pockets to conduct an advertising blitz concerning the safety of nuclear power. If this form of energy is so safe, why is it necessary to spend all this (and more) money to convince us?

5 that despite the Committee for Energy Awareness' advertisements to the contrary, there is still/no guar-anteed, safe, long-term solution to the disposal of nuclear waste. What of future generations to come? Will they be able to survive in a world we continue to contaminate? <

No other civilization, to our knowledge, has had to answer this question. No other civilization has had to consider the safety of future generations. If we are the first to do so, we may not be the last to have a chance.

Thank you for considering our testimony. We would like to add that, contrary to Commonwealth Edison's allegations, there are many people who believe as we do. There is increasing skepticism of, and disillusionment with Commonwealth Edison's energy policies. The public concerns raised in this letter, whether voiced by many or few, should not be casually dismissed.

Respectfully, Jacob J.. Skala 231 River Dr.

Sharon Y.Skala 'alb, Illinois 60115 l 0 -

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ean M. Dale 111 So. Sycamore Norma M. Youhn Genoa, Illinois 60135 y

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l REPORT

SUMMARY

Ocamorwealth Mison will make amual 204 rate increase requests over the next six years which, if granted, will triple Northern Illinois electrical rates by 1986.

'these rate increases are being requested primarily to have ratepayers pay the financing costs for the construction of the $5,000,000,000 Byron and Brai&#ood power plants. -

Given demand growth trends since 1973, neither of the these plants are needed to meet electrical demand.

Since 1974, M ison's annual demand growth predictions have averaged 4.2 times actual armual load growth. 'the ocupany's decision in the late 1970's to contiue building these plants was rationalized by these exaggerated predictions, as are its current claims that the plants will "soon be needed."

'Ihrough the 1970's Edison has had tremendous emoess capacity and has only operated at an average of 55% of capacity. thlike businesses subjected to the .

discipline of the market, Edison has been abla, thrcugh its dcnninstion of the Illinois Commerce Commission (I(X:), to transfer to its custaaers the cost of this 454 i:11e capacity Men energy was cheap this cost was not so burdensame, .

but now that energy is becoming expensive the cost is hamning unaffordable.

4 Because they are not needed, the continued construction of the Byron and Ecaidwood power plants was and ocntinues to be a serious business mistake which should be paid fcr by the stockholdert. and not the ratepayers.

Edison has con;;inued construction of these unneeded plants for two reascms.

First, Edison's allowable profits are em1rmlated by the ICC (before the ICC sets prices) as a fixed percentage of its operating plant capacity (called the " Rate Base"). 'Iherefore once Mison started its plants, it wanted to ocuplete them as soon as pcssible to get them into this Rate Base. 'the bigger the Rate Base the bigger its profits, regardless of plant utilization. Second, Edison believed that it could get the IOC to pass the added costs of the additional idle capa-city onto the ratepayers.

thless these annual 20% rate increases are stopped, the tremendous waste s and inefficiency that Mison is fastering in our energy production could well undermine the entire Northern Illinois business climate.

By intervening in the rate case before the IOC, organizations and busi-nesses can help block the increase. Moreover, in the event the IOC does grant a substantial pertion of the permanent 20% increase (as vyyveed to the 94

" interim" increase granted in~ November), only intervening organizations and their individual members will get the increase back if the courts later overturn the increase.

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In August, Caemonwealth Edison (0:n M) requested 019.7% tcte hike fran j

the niinois 0:mmerce Onmaission (ICE). Approximately 80% of this rate hike and 60-80% of the sizeable rate hikes we can expect over the next 6 years are needed solely to finance can ES's $5 billion ocnstruction gogram of the Byron and Braidwood power plants. If this $5 binion constrtx: tion program continues on schedule, your electricity bills win probably triple in 6 years, including fuel cost increases which are passed on automatid.ly.(See p. 5, footnote (1).)

tept poler PuerfS ARE NOT PElEMD -

If these two new plants were needed, if generating capacity were not keeping te with constner demand, that would be one thing. But the plants simply are not needed.

J Graph 1 inustrates the extent of CBm ES's excess generating capacity in the 1970's. Se top line shows how much electricity Ccm Ed was c=_=hle of

,{ selling (Net Capacity); the bottan line charts the amount of electricity sold during the one hour of greatest use in the year (Peak Demand), usually the hot-test day of the == mar when air conditioners are working hardest. From 1973 -

1980, Ocun E$ maintained an average of 27.6% note generating capacity than it needed to meet g ak demand. H is is twice the reserve it needed even by its own liberal esticates. Since 1978, maintaining this excess capacity has cost rate-payers over hah a binion dollars.(See p. 5, footnote (2).)

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1972 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 '90 I years .

Assuming peak denand continues to increase in the 1980's at the same 1.9%

annual rate it has since the orset of the energy crisis in 1973, Graph 1 also shows that without the $5 billion Byron and Braidwced plants, Casa M will still have a capacity in 1990 that is wen above peak demand. If the plants are ocupleted on schedule in 1987, Cbm Ed will have a capacity that is 474 above peak dernand.

What Graph I does not show is that Ocun B5's average utilization of this generating capacity through these same years (1972-1979) was only 55%

(9,000 megawatts). No other business in America could survive a prolonged l

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period of using caly 55% of its plant capacity. Com M was a very profitable cmpany during these years only because the consumers were paying for the average 45% idle capacity.

C%N ED'S CONSISTINP OVER-PIEDICTIONS Graph 2 contrasts com M's yearly predictions of the increase in electrical demand with the actual growth in demand each year during the 1970's. W e graph shows that every year com M grossly over-predicted demand growth, and shcwed absolutely no interest in learning fran prior years' mistakes or from actual trend lines as the decade progressed. Since 1974, Cora M's annual growth pre-dictions have averaged 4.2 timos actua: annual growth.

121 GRAPH 2:

ANNUAL PEAK DEMAND GKMIH IN 1970'S Percent 82 of ,

annual increase '*

COM ED'S FORECASPS % 42 /

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2% '1972 73 74 75 76 77 78 79 to Years These inflated predictions are vitally inportant because they are used as the basis for com M's yearly power plant investment decisions. Sus year after year Cbm M used exaggerated predictions to justify the continuation of a construction program which actual growth figures clearly indicated was not needed.

(bm M continues this practice today. Com M's current prediction of a future 4% incrcase in peak demand is the demand growth Com Ed needs to justify its current projected completion dates for the Byron and Braidwood pwer plants.

h is 4% predicted growth is more than twice the average 1.9% actual annual growth since 1973. We actual annual increase in peak demand since 1977 has been an even lower 0.7% per year.

A SERIOUS INVESTMENT MISTAKE In 1976, Cbm Ed had only invested 2% of the now estimated $5 billion cost of the Byron and Braidwood power plants. But in 1976, at a tLme when it was operating at 55.2% of capacity, when it already had twice as much excess generating capacity as it needed to meet peak demand, and when peak demand had actually fallen by 1% over the last two years, com Ed predicted a 9.7% annual growth rate and began to pour billions of dollars into two unneeded new power l

plants. Why did Com M make this grave investment mistake?

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'rHE IUGE FINK 3URE HAS EN000 RAGED UNNEEEED PCHER PIANTS Under Illinois utility regulation allowable utility profits are <=1~1=ted (before rates are set) as a fixed percentage, around 104, of the An11ars the utility has invested in cxmpleted power plants and lines (the " Rate Base").

1 After the size of the profits h'as been set, the Illinois Caumecce Oza ission (IG:) sets the rates so that the ocupany can achieve this profit amount given 4

the volisme of ptojected sales.

Oza M has interpreted this fxmula singly to mean that the more power plants it builds, the greater will be its profits, regardless of whether those plants are needed or the electricity the plants produce is sold. If constaners don't buy the available electricity, if sales don't keep up with forecasts, the ICI: has in the past simply raised the constanars' rates for the smaller amount of electricity we do use. 'the less we buy, the noce we pay for what we do buy. -

Oza M's managers and owners therefore thought they had nothing to lose if ,

they overpredicted and overbuilt. Sey believed the IOC would singly pass the l costs of emoess capacity onto the ratepayers. And now that declining sales '

growth and massive construction oost overruns are squeezing com M's profit margins, they have predictably asked the IOC to do just that.

'IHE RISK BEZOGS 'r0 'IHE SIOCKHO[DERS Under capitalian, the cwners of a private business risk same of their own money by investing it in the hope that the resulting increase in sales will return their original investment to them plus a profit. Everything depends on their prediction of future demand and sales.

If their predictions are right, their wealth is increased. If they overpredict and thereface overinvest, they lose noney because they nust pay for the increased (and unused) capacity out of their own pockets rather than out of increased sales. %us if Com M were in a ccapetitive free enterprise situation, its owners simply could not afford to continue expanding its already excessive capacity.

'IHE IOC BAIIXXFP

% e IOC, in its regulation of the utility monopolies, is supposed to replace the ocupetitive free enterprise market and force these monopolies to be as efficient as possible. It is supposed to discourage the developamt of inefficient, wasteful excess capacity and protect the ratepayers who would otherwise be at the mercy of the utility n.v.,1y. It is sm-M to give the ocupany its allowable profits only if the coupany is managed efficiently.

But to-date the IOC has coupletely ignored this responsibility for enforcing efficiency. Instead it has operated on the peculiar principle that no matter how ill-advised Com M's business decisions may be, com M must be allowed to implement them and the ratepayers-rather than the owners-sust be forced to pay fa then.

In granting com M a 14% rate hike on February 6, 1980, the IOC wrote:

1 Thecretically, the shareholders bear the risks relating to (snagement's use of funds entrusted to them. As a practical matter, . . . as for the risks of the Cbnpeay's construction program . . , requiring stockholers to bear

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! certain risks may result in driving down the market value of the ocupany's p av=wwi stock to a level where more stock cannot be issued. 1

By its own admission therefore the IOC is violating the nost fundamental

> principle of the free enterprise system, namely that the private owners bear the l risks and pay fa the leases caused by investment mistakes.

1 j 'the IOC is justifying its approval of letting com ad finance and continue its investment mistakes with ratepsyers' money by claiming that in the long run l

it win cost the ratepayers less to subsidize the empletion of the two plants i now, and that delaying cmpletion until the plants are needed win only add to t5e eventual cost to the consumer. But this is only true because the ICC plans i to add the interest ===nses of carrying partiany-built plants to the Rate Base 1 (and therefore into consumers' rates) when the plants are empleted.

f If one strips away the circular logic from this argument, what the IOC is l

tolling us is that it is cheaper fa the ratepayers to pay for Oom Ed's invest-

ment mistakes now rather than later. But under the rules of free enterprise the ratepayers shoM never be fuoed to pay for these errors and none of the cxasts atenming from premature construction should go into the Rate Pase.

'tHE CHRYSIER ANhfiXiY l Chrysler, fa the very same reasons as com nd, got into deep financial

! trouble in the late 1970's. But while the Chrysler stockholders lost their i dividends, the com M investms continue to be paid a 13% dividend by the rate-l payers while an their risks and losses are passed onto the sane ratepayers.

Nearly all of the $389 million (144) rate increase the ICC gave com M in

! February of this year win go to Oca M shareholders in dividends in 1980.

Chrysler's losses fuoed it to change its investment strategy, but Otsn E is being given gcweenment go-ahead to mwd its problems by continuing its

unneeded building program. It is as if Chrysler had gotten the federal govern-ment to face an taxpayers to go eat and buy a big Chrysler Ingerial that they would not use and pay 20% more fm it to boot.

If Oom Bd reany believes its current prediction of a 44 annual growth in peak demand, it should risk its owners' --,ci act the ratepayers'-in its construction ,orogram.

A DANGER '!O OUR RISINESS CLIMATE l

l 'the American econcay can no longer affad the wastefulness and inefficiency of utilities that undertake vast expansion programs while underutilizing current facilities. Utilities are using up a large percentage of the available invast-ment capital in niinois at a time when it is desperately needed for j re-industrialization.

If the ICC allows our electrical rates to triple in 6 years, the entire 2 business climate in Northern niinois win be gravely endangered. 'the cost of ,

everything here win increase as producers, service agencies and local and state goverrunent pass on their increased costs. <

I Instead of throwing scarce capital away on makewak, we should be creating ,

jobs by retrofitting our businesses and hw.as to reduce energy waste.  ;

! Oonservation and reasonable investment for growth, not inflationary over-constructicri, are the keys to a secure energy future.

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i l REPORT D O C U M E N T A T I O N(3) l C A P A C I T Y(4) OCH ED FORIEASTS V. AC1UAL-1 YFAR BYIDI & BRAIDEXD OCNF110CTICN GM ED RMES V. .

ItWIATION (CPI)

MBGAMMTS (Def'S) PORBCASIED ACIUAL MIILIONS ESTIMMED ESTIMMED RMF/DEIR CONSLBER '

Per PEAK RESERVE DMF, OF GRONM GOODI OF S'S 'IUmL COST COST /W SYSTEM PRICE YEAR CAPACITY DEMAPO MMGIN FORECAST Ptt'S t ett'S t INVESITD IN MIILIGIS P1 m PLANFS AVERAGE IIHX 1973 14954 12462 19.0% 10M2 1000 8.5% 712 6.1% $1,838 $410 2.209 132 1974 15778 12270 30.8% 3M4 1298 10.4% -192 -1.5% 2.579 147 l 1975 16373 12305 36.2% 1M5 1230 10.04 35 0.3% $ 60 $2,117 $474 3.019 161 1976 16711 12907 29.5% 9AS 1195 9.7% 602 4.9% $ 138 $2,391 $534 3.259 170 1977 17169 13932 23.2% SM7 1083 8.4% 1025 7.9% $ 406 $2,392 $534 3.389 182 i ====

1978 17480 13720 27.4% llM7 618 3.7% -212 -1.5% $1,066 $3,140 $701 3.799 195 1979 17914 13804 29.8% 6M9 1350 9.8% 84 0.6% $1,417 $3,598 $787 4.229 217 l 900 17717(5) 14228_ s 24.5% 5/80 946 6.8% 424 3.1% $1,918 $4,926 $1,099 5.839 248 AVG 1BARLY 'e3.6%

INCREASE, 73-80 1.9% 1103 8.4% 261 1.9% 15% 154 15% 9%

1987:

GM ED PIAt6:23921 18723_ _ ] , $4,926 $4,926 PRCUECTIOtB BMED Qi BASED ON NEEDS OF i

AVG YEARLY IPCRERSES, CDET'N Pf0 GRAM:

1973-1980: 16243 47% $7,163 $1,598 17.499 (1) mis is a 20t m_=ided annual increase and is prr hnhly conservative. According to IOC Exhibit 10.2 of the last Coun Ed rate increase case, 00sn Ed will need 10% additional revenue per year for the next 6 years just to finance its construction prograsa.

i This c=1rm1= tion is probably too low as the estimated cost to couplete the 2 power plants has increased 404 since the calcu-I lttion was mde. Added to this 10% annual increase will be 1) automatically-passed-through fuel cost adjustments, which have

, cveraged 64 per year since 1973, and 2) the effects of inflation on normal operatirs expenses, asstuned conservatively here to l

be 44 per gear. Also sales have fallen 24 this year, and rates will have to rise just to casupensate E5ison for the lost revenue.

(2) To calculate the cost of excess capacity, we identified Mison's newest power plants which comptise the cospany's emoess capacity for each year analyzed. %e capital cost of coupleted plants, which if subtrr.cted fran Edison's synten capability i would yield a reserve margin in the range of 14% were added to arrive at a "value of excess capacity." h e value of the cacess capacity was then multiplied by 18% to active at an annual cost to constaners. Wis figure (value of excess capacity i mulitiplied by 18%) was then adjusted fer fuel cost benefits or penalties associated with plants representing excess capacity.

The costs in millions were:- 1978=$147.5, 1979=5178.5, 1980=$193.5 for a total of $519,000,000.

1 (3) All figures used in this repxt are based on Comnonwealth Edison Conpany <irv'==mts filed with the ICC for rate hearings.

l (4) All reserve margins were calculated using Edison's reserve formula in effect at the time of annual peak demand.

(5) Cn the 1980 peak day, Com Ed had over 3,000 79f's out of service, so that its actual reserve margin was such smaller.

%is is an exanple of Edison's management's inability to efficiently manage their operations and capacity.

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THE CRMPAIGi AGADUP ' HIE RATE HIl3 Se Campaign Against the Rate Hike is a coalition of businesses, Irv al governments, labor unions, neighbachood groups, social servloe agencies, church groups, citizen action groups, senice citizen groups, and individual citizens which is co-ordinating a campaign against the rate hike throughout Oom Ed's ser-vice area in Northern niinois.

Se Campaign's strategy is based on the belief that th ICC has already demonstrated its bias toward granting the rate hike request und will only be dissuaded fran doing so by a well co-ordinated camoaign combining: _

1) mass based political pressure exercised through the intervention-process;

2) sound, wen doctamented technical and econanic argunents in the hearings; i

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3) threatened legal action if the IOC grants com E a substantial increase;

4) effa ts to amend the law in Springfield to change the rules under which the IOC and Com E are operating.

NHY INTERVENE?

In the context of this 4-part atrats there are two <==111ng reasons why your organization should fzmany register as an interve.or ,in the rate case. -

First, it is only by intstvening that you can be sure that your voice is reany heard, that your concern win really be felt by the four ccumissioners who currently make up the niinois Commerce Canaission. S e ocamissioners are appointed by the Governce and are sensitive-as is the Governor himself-to public concern when it is expressed directly and facefuny. Without interevening, you can have no formal input into the process by which the rate request win be decided.

Second, if the IOC grants a substantial part of the request (as it did for the previous request on February 6,1980), the Campaign Against the Rate Hike win innediately take the ICC to circuit court for failure to carry out its responsibilities to regulate the utility under Ininois law. We believe we have a souM case with a good chance of winning in circuit court.

When we file this lawsuit we win ask the court to " stay" the rate increase for the intervenors while the court is deciding on the case. %is win prevent Oom Ed frca conecting the increase while the court hears the case, a process that could take a year or more. We believe that as long as the intervenors agree to pay the increase into a court-supervised escrow account the court win grant the stay (which it is empowered to do under nl. Rev. Stat. Ch in 2/3, sec. 75) because: 1) without a stay there could be (what the law cans)

" irreparable injury" to the intervenors (namely that without the stay the inter-venors could not get their money back fran oom E if the court decides to over-turn the rate hike), and 2) we will have a reasonable substantive argtsnent.

NON-INIERVE3 ORS WILL NCFF GET TPEIR MM!lY BACK If the. court later overturns the rate increase, only those covered by the stay (i.e. those who have intervened) win get their money back (with interest) from l the escrow account they have been paying into. For an those who did not for-nAlly intervene the increase will be considered a valid rate between the tine it was granted by the I(I and the time it was overturned by the court. (See Cerro i

-. - - _ _ - - - . _ . - - - . ~ . - . - . . . . - _ - - - . . - . - - _ - . - . . , . - - - - . ~ . - - - - - - - - - -

• .- 7_

Oopper Products Co. v. ICC, 65 Ill. App. 3d 764, 382 NE2d 143(4th dist.,1978)

'and Mandel Brothers, Inc. v. Chicago Tunnel Terminal Co. (1954) . ' 2 Ill.2d ..

205,117 N.E.2d 774.)

There are no disadvantages, liabilities or costs involved in intervening. The intervening organization can be as involved in the formal hearing process as it would like to be. We Campaign is organizing expert testimony fm the hearing and win. help co-ordinate the involvement of organizations that would like to participate.

An organization can intervene on behalf of its members and its members will then be protected by the court-issued stay if we have to go to court.

% e actual act of intervening is very simple to perform. Simply follow the directions in filling out the attached intervening forms, have them notarized and send them to the four indicated addresses.

A few of the ceganizations that have intervened as of November 5,1980 are:

Industry: Other Iocal Organizations:

U.S. Steel Corporation Winnebago County Council on the Bell and Bowell Oceporation Aging Chrysler Corporation Rockford YWCA General Mttoes (bcpocation National Council of Negrc Women, Nabisco Oceparation Rockford Chapter Sherman-Willians Corporation Board of Directors of Rockford Jewish Comnunity Center Goverrunents: United Auto workers Iccal 592 1

Ibekford School Board (Sunstrand)

Winnebago County Board of Health United Auto Workers Iccal 225 City of Dekalb (Mechanics)

Northern Illinois University International Association of City of Waukeegan Machinists District Iodge #10 City of Evanston Garfield Avenue Residents City of West Chicago Organization Illinois Department of Transportaton Blackhawk Federation of Teachers Illinois Attorney General Jerusalem Baptist Church States Attaney of Cook County Chicago Transit Authority Winnebago County Board I

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639b East Lincoln Highway DeKalb, IL 60115 February 24, 1983 Judge Ivan Smith c/o ASB/NRC Federal Building 310 South Court Street .

Rockford, IL 61101

Dear Judge Smith:

I am writing to you as a concerned citizen living in DeKalb who feels very strongly that the risks and the costs associated with the nuclear power plant at Byron are not worth it.

Ionizing radiation blows in the wind. Nuclear power plants have leaks and have accidents and have toxic wastes for which there is no easy disposal plan. The rate hikes that Com Ed would hand to us to finance the finishing of the plant are much more than I or anyone I know can afford. We don't need the Byron plant, we can't afford the Byron plant, and speaking for myself and dozens of friends and concerned citizens of this area, and, I am sure, other areas just like it, WE DON'T WANT 'IHE BYRON PLANT.

Please take these genuine fears and concerns into account. Thank you for listening.

Sincerely, of f4 A Cth[

Rebecca Parfitt l

I - . - . . .

NORTHWEST ILLINOIS CAMPAIGN

I AGAINST THE RATE HIKE

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20% INCREASE THIS TIME, 200% INCREASE IN SIX YEARS An infccmational report on the Ctanonwealth Edison's ,

i 19.7% rate hike request, stmmarizing the ciretnstances 1 surrounding the request and what yxr organization can  :

do to prevent it and protect yourself frca it. I 1

I Bx further infecmation or hwntation of facts used in the report contact the Caupaign at the address below.

i,

! November 5, 1980 321 WEST STATE STREET, SUITE 714, ROCKFORD, IL 61101 e (815)965 9668 1

I .._. _

aw l

.. In August, Oanmanwealth Edison (Ocur Ed) requested a 19.7% rate hike fra l the Illirr>is Oammerce Canaission (ICE). Approxiniately 80% of this rate hike and -

60-80% of the sizeable rate hikes we can expect over the next 6 years are needed l solely to finance Oom Ed's $5 billion construction program of the Byron and Braidwood power plants. If this $5 billion construction program continues on ,

schedule, your elsictricity bills will probably triple in 6 years, including fuel cost increases which are passed on autmatically.(See p. 5, footnote (1).)

NEN POWER PLANTS ARE NCFP NEEDED If these two new plants were needed, if generating capacity were not keeping up with constner demand, that would be one thing. But the plants simply are not needed.

Graph 1 illustrates the extent of Com Ed's excess generating capacity in the 1970's. We top line shows how much electricity Ccm Ed was capable of selling (Net Capacity); the botte line charts the amount of electricity sold during 'the one hour of greatest use in the year (Peak Demand), usually the hot-test day of the sunmer when air conditioners are working hardest. From 1973 -

1980, Oam M maintained an average of 27.6% more generating capacity than it needed to meet peck demand. %is is twice the reserve it needed ever, by its own liberal estimates. Since 1978, maintaining this excess capacity has cost rate-payers over half a billion dollars. (See p. 5, footnote (2).)

24,000 ,________

23,000 22,000 21,000 '

a 20,000 9e w

GRAPH 1: (

, 19,000, _ __ _ __ _ _ W M 90.P. - _ _ _ _

NE Em t 18,000 t+, -

NEN PIANTS t 17,000 gC ge ,.-

15 00 t}** %

14,000 13,004 M N*

12,000.

11,000 , , , , , , , , , , , , , , , , ,

1972 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 88 '90 years Asstating peak demand continues to increase in 1.he 1980's at the same 1.9%

annual rate it has since the onset of the energy crisis in 1973, Graph 1 also shows that without the $5 billion Byron and Brridwood plants, Oom Ed will still have a capacity in 1990 that is well above pea.k demand. If the plants are l coupleted on schedule in 1987, Cbm Ed will have a capacity that is 47% above peak demand.

What Graph 1 does not show is that Oom Ed's average utilization of l this generating capacity through these same years (1972-1979) was only 55%

(9,000 megawatts). No other business in America could survive a prolonged

1 l - <  !

l i period of using only 55% of its plant capacity. Com Ed was a very profitable cmpany during these years only because the consumers were paying for the average 45% idle capacity.

OCH ED'S CONSISTENT OVER-PREDICTIONS Graph 2 contrasts Com Ed's yearly predictions of the increase in electrical l demand with the actual growth in demand each year during the 1970's. We graph shows that every year Com Ed grossly over-predicted demand growth, and showed absolutely no interest in learning from prior years' mistakes or fim actual trend lines as the decade progressed. Since 1974, Com Ed's ar7.lal growth pre-dictions have averaged 4.2 times actual annual growth.

123 }

10%

GRAPH 2:

ANNUAL PEAK DEMAND GKWHI , .

IN 1970'S Percent ,

/

of annual 62 j increase /

CCM ED'S FORH: ASIS E .:

22 ACIUAL GIWIH PJ 0% j g

-2: '1972 73 7. 76 77 78 79 to Years These inflated predictions are vitally important because they are used as the basis fcr Cbm Ed's yearly power plant investment decisions. %us year after year Cbm a3 used exaggerated predictions to justify the continuation of a constructicn program which actual growth figures clearly indicated was not needed.

(bm Ed continues this practice today. Cbm Ed's current prediction of a l future 4% increase in peak demand is the demand growth Com Ed needs to justify j its current projected cmpletion dates for the Byron and Braidwood power plants.  ;

his 4% predicted growth is more than twice the average 1.9% actual annual l growth since 1973. %e actual annual increase in peak demand since 1977 has been an even Icwer 0.7% per year.

A SERIOUS INVESTENT MISTAKE In 1376, Com Ed had only invested 3% of the now estimated $5 billion ecst of the Byron and Braidwood power plants. But in 1976, at a time wnen it was l i

operating at 55.2% of capacity, when it already had twice as nuch excess generating capacity as it needed to meet peak demand, and when peak demard had actually fallen by 1% over the last two years, Com Ed predicted a 9.7% annual growth rate and began to pour billions of dollars into two unneeded new power plants. Why did Com Ed make this grave investment mistake?

THE RME S'IWC'IURE HAG B000 RAGED ins 5'mn PONER PLANTS

, under Illinois utility regulation allowable utility profits are r =1 & 1=ted l (before rates are set) as a fixed percentage, around 10%, of the th11ars the -1 4

utility has invested in ocepleted power plants and lines (the " Rate Base"). j

, After the size of the profits has been set, the Illinois commerce Commission i (IE:) sets the rates so that the ocupany can achieve this profit amount given j the voltane of projected sales.

l Com E has interpreted this fa mula simply to mean that the more power l plants it builds, the greater will be its profits, regardless of whether those

plants are needed oc the electricity the plants produce is sold. If consumers i don't buy the available electricity, if sales don't keep up with forecasts, the i IOC has in the past simply raised the constaners' rates for the smaller amount of l electticity we do use. Se less we buy, the acre we pay for what we do buy.

l com E 's managers and owners therefore thought they had nothing to lose if l they overpredicted and overbuilt. Sey believed the IOC would singly pass the costs of emoess capacity onto the ratepayers. And now that declining sales growth and massive construction cost overruns are scpeezing Cbm Ed's profit margins, they have predictably asked the IOC to do just that.

i THE RISK BEIONGS 'IO THE sp.uus.nDERS Under capitalian, the owners of a private business risk some of their own

soney by investing it in the hope that the resulting increase in sales will j return their original investment to them plus a profit. Everything depends on

. their prediction of future demand and sales.

4 I If their predictions are right, their wealth is increased. If they

} overpredict and therefore overinvest, they lose money because they must pay for i the increased (and unused) capacity out of their own pockets rather than out of

increased sales. Sus if Cbm E were in a ocupetitive free enterprise

{ situation, its owners simply could not affad to continue expanding its already i excessive capacity.

'IHE IOC BAIL-00T .

' We IOC, in its regulation of the utility nonopolies, is supposed to replace the ocupetitive free enterprise market and force these nonopolies to be as efficient as possible. It is supposed to discourage the developnent of '

inefficient, wasteful ewwm capacity and protect the ratepayers who would i otherwise be at the rnercy of the utility monopoly. It is supposed to give the ocupany its allowable profits only if the ot

npany is managed efficiently.

But to-date the IOC has ccupletely ignored this responsibility for enforcing efficiency. Instead it has operated on the peculiar principle that no i matter how ill-advised Oom E's business decisions may be, Otsn Ed must be i

allowed to implenent thun and the ratepayers-rather than the owners-sust be i faced to pay fa them. l l

In granting Oom Ed a 14% rate hike on February 6, 1980, the IOC wrote:

l l Theaetically, the shareholders bear the risks relating to management's use l of funds entrusted to them. As a practical matter, . . . as for the risks I of the ocupany's construction program . . , requiring stockholers to bear

9.

certain risks may result in driving down the market value of the Otmpany's l oczanon stock to a level where more stock cannot be issued.

By its'own admission therefore the IOC is violating the most fundamental principle of the free enterprise system, namely that the private owners bear the risks and my fcr the losses caused by investment mistakes.

, 'the IOC is justifying its approval of letting com Ed finance and continue its investment mistakes with ratepayers' money by claiming that in the long run it will cost the ratepayers less to subsidize the completion of the two plants

. now, and that delaying ocanpletion until the plants are needed will only add to l E eventual cost to the constaner. But this is only true because the IOC plans to add the interest ea s- a;; of carrying partially-built plants to the Rate Base (and therefore into consumers' rates) when the plants are ocupleted.

If one strips away the circular logic from this argtanent, what the ICC is telling us is that it is cheaper for the ratepayers to pay for Otsn Ed's' invest-ment mistakes now rather than later. But under the rules of free enterprise the ratepayers shcEIE never be forced to pay for these errors and none of the costs i stemming frcan premature construction should go into the Rate Base.

'ME CHRYSIER ANM&Y Chrysler, fcr the very same reasons as com Ed, got into deep financial trouble in the late 1970's. But while the Chrysler stockholders lost their dividends, the com Ed investors continue to be paid a 13% dividend by the rate- ,

payers while all their risks and losses are passed onto the same ratepayers.

Nearly all of the $389 millicn (14%) rate increase the ICC gave com Ed in i February of this year will go to com E shareholders in dividends in 1980.

Chrysler's losses forced it to change its investment strategy, but Otsn Bi is being given goverrunent go-ahead to r===x1 its problems by continuing its unneeded building program. It is as if Chrysler had gotten the federal govern-ment to force all taxpayers to go out and buy a big Chrysler Inperial that they did not need and pay 204 more for it to boot.

If Oczn M really believes its current prediction of a 44. annual' growth in peak demand, it should risk its owners' m ay not the ratepayers'-in its ..

construction program. .

A DANGER 'IO CITR BUSINESS CLD9tTE j 'Ibe American econczny can no longer afford the wastefulness and inefficiency i of utilities that undertake vast expansion programs while underutilizing current l facilities. Utilities are using up almost 20% of the available investment capi-tal in Illinois at a time when it is desperately needed for re-industrialization.

If the IOC allows our electrical rates to triple in 6 years, the entire business climate in Northern Illinois will be gravely endangered. 'the cost of j everything here will increase as producers, service agencies and local and state j government pass on their increased onsts.

Instead of throwing scarce capital away on makework, we should be creating jobs by retrofitting our businesses and hcznes to reduce energy waste.

Conservation and reasonable investment for growth, not inflationary over-construction, are the keys to a secure energy future.

_ __ _ ___ m _ _ . , _ _ _ _ _ _ _ . _ . _ _ . _ _ _ _ _ _

l REPORT D O C U M E N T A T I O N($) l _

C A P A C I T Y(4) CCM ED EDREDSTS V. ACIUAL-1 YEAR BYBON & BRAll100D IDUlHUCfICN 034 ED RNIES V.

• '

• INETATION (CPI)

MEDHATrS (N'S) FORECASTED ACIUAL MILLIONS ESTDSTED ESTIMATED RMIT/lGER CONSLMER mr PEAK RESERVE DME OF GRORM GIBUm OF $'S 'IUPAI/ 006T 00ST/lGi SYSTTM PRICE YEAR CAPYITY DEMAIO MAIGIN FOR TAST N'S  % N'S  % INVESTED IN MIILIONS FHCM PUNIS AVERAGE DOEX 1973 14954 12462 19.0% 10/72 1000 8.5% 712 6.1% $'1,838 9410 2.209 132 -

1974 15778 12270 30.8% 3/74 1298 10.4% -192 -1.5% 2.579 147

==== '

1975 16373 12305 36.2% 1/75 1230 10.0% 35 0.3% $ 60 $2,H7 $474 3.019 161

==

1976 167H 12907 29.5% 9/73 H95 9.7% 602 4.9% $ 138 $2,391 $534 3.259 170

==

1977 17169 13932 23.2% 5/77 1083 8.4% 1025 7.9% $ 406 $2,392 $534 3.389 182 1978 17480 13720 27.4% 11/77 618 3.7% -212 -1.5% $1,066 $3,140 $701 3.799 195

==

1979 17914 13804 29.8% 6/79 1350 9.8% 84 0.6% $1,417 $3,528 $787 4.229 217

==

1980 17717 14228 24.5% 5/80 946 6.8% 424 3.1% $1,918 $4,926 $1,099 5.839 248 AVG 1EARLY 27.6%

INCREASE, 73-80 1.9% 1103 0.4% 261 1.9% 15% 15% 15% 9%

1987:

I (IM ED PIANS:23921 18723 28% $4,926 $4,926 PR11ECTIOtB BASED (N l AVG YEARLY DCREASES, 1973-1980: 16243 47% $7,163 $1,598

! (1) Wis is a 20% empounded annual increase and is probably conservative. According to IOC Exhibit 10.2 of the last Oca M rate

! increase case, com Bd win need 10% additional revenue per year fcr the next 6 years just to finance its construction program.

This calculation is probably too low as the estimated cost to cmplete the 2 power plants has increased 40% since the calcu-lation was made. Added to this 10% annual increase win be 1) autmatically-passed-through fuel cost adjustments, which have c,veraged 6% per year since 1973, and 2) the effects of inflation on normal operating expewes, asstuned conservatively here to be 4% per year. Also sales have fallen 2% this year, and rates will have to rise just to conpensate Edison for the lost revenue.

(2) To calculate the cost of excess capacity, we identified Edison's newest power plants which cmprise the + y's excess capacity for each year analyzed. %e capital cost of cmpleted plants, which if subtracted fran Edison's system capability would yield a reserve margin in the range of 14% were added to arrive at a "value of excess capacity." %e value of the excess capacity was then multiplied by 18% to arrive a'. an annual cost to constners. Wis figure (value of excess capacity mulitiplied by 18%) was then adjusted for fuel mst benefits or penalties associated with plants representing excess capacity.

%e costs in minions were: 1978=$147.5, 1979=$178.5, 1980=$193.5 for a total of $519,000,000.

(3) All figures used .in this report are based on Conmonwealth Edison Conpany documents filed with the IOC for rate hearings.

l (4) All reserve margins were calculated using Edison's reserve formula in effect at the time of annual peak demand.

I 1

'IHE CAMPAIGN ACAINST 'IHE RATE HIKE The Canpaign Against the Rate Hike is a coalition of businesses, local goverranents, lahnr unions, neighborhood groups, social service agencies, church groups, citizen action groups, senicr citizen groups, and individual citizens which is co-ordinating a canpaign against the rate hike throughout Com Ed's ser-

'vice area in Northern Illinois.

Se Canpaign's strategy is based on the belief that the ICC has already demonstrated its bias toward granting the rate hike request and will only be dissuaded frczn doing so by a well cc>-ordinated canpaign ecznbining:

1) mass based political pressure exercised through the interventien process;

2) sound, well-doctznented technical and economic argtsnents in the hearings;

3) threatened legal action if the ICC grants Com Ed a substantial increase;

4) effcrts to amend the law in Springfield to change the rules under which 1 the ICC and Com Ed are operating. l WHY INPERVDE?

In the conteu of this 4-part strategy there are two ccmpelling reasons why l

> your organization should formally register as an intervenor in the rate case.

First, it is only by intervening that you can be sure that your voice is really heard, that your concern will really be felt by the four canissioners who currently make up tne Illinois conmerce conmission. %e ccumissioners are appointed by the Governor and are sensitive-as is the Governor himself-to public concern when it is expressed directly and forcefully. Without interevening, you can have no formal input into the process by which the rate request will be decided.

Second, if the ICE grants a substantial part of the request (as it did for l the previous request on February 6,1980), the Canpaign Against the Rate Hike will inmediately take the ICC to circuit court for failure to carry out its i responsibilities to regulate the utility under Illinois ler. We believe we have a sound case with a good chance of winning in circuit court.

When we file this lawsuit we will ask the court to " stay" the ra m increase for the intervenors while the court is deciding on the case. m is w n1 prevent Otzn Ed from collecting the increase while the court hears the case, a process .

that could take a year or more. We believe that as long as the intervenors agree to pay the increase into a court--supervised escrow account the court will i

grant the stay (which it is empowered to do under Ill. Rev. Stat. Ch 1112/3, sec. 75) because: 1) without a stay there could be (what the law calls) l " irreparable injury" to the intervenors (namely that without the stay the inter-venors could not get their money back frczn Oom Ed if the court decides to over-turn the rate hike), and 2) we will have a reasonable substantive argument.

NON-INPERVENORS WIIL NCfr GET 'IHEIR MONEY BACK

, If the court later overturns the rate increase, only those covered by the stay l

(i.e. those who have intervened) will get their money back (with interest) from 3 the escrcw account they have been paying into. Pbr all those who did not for-i mally intervene the increase will be considered a valid rate between the time it was granted by ,the ICE and the time it was overturned by the court. (See Cerro Copper Products Co. v. ICC, 65 Ill. App. 3d 764, 382 WE2d 143(4th dist., 1978)) ,

1 1

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, , i 1 S ere are virtually no disadvantages, liabilities or costs involved in

intervening. % e intervening organization can be as involved in the formal hearing process as it would like to be. %e Campaign is organizing expert testimony fa the hearing and will help cowxdinate the involvement of organiza-tions that would like to participate.

An organization can intervene on behalf of its menbers and its members will then be protected by the murt-issaed stay if we have to go to court.

%e actual act of intervening is very simple to perform. Sinply follow the directions in filling out the attached intervening forms, have them notarized ,

and send them to the four indicated addresses. l l

A few of the organizations that have intervened as of November 5,1980 are:

J 4 Industry $ Other Iocal Organizations:

U.S. Steel Corporation Winnebago County Council on the  !

Bell and Howell Corporation Aging  !

Chrysler Corporation Rockford YWCA  ;

General Motors Corporation National Council of Negro Wcnen, l Nabisco Corporation Ibckford Chapter Sherman-Williams Corporation Board of Directors of Rockford

, Jewish connunity Center Governments: United Auto Workers Im.al 592 Rockford School Board (Sunstrand) i Winnebago County Board of Health United Auto Workers Im.a.1225 City of Dekalb (Mech nics)

, Northern Illinois University Internati h Association of

, City of Waukeegan Machinists District Iodge #10 City of Evanston Garfield Avenue Residents 2

City of West Oiicago Organizatica Illinois Department of Transportaton Blackhawk Federation of Teachers Illinois Attorney General Jerusalem Baptist Church '

States Atta ney of Cook County Chicago Transit Authm ity C

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Utilities defend $20 million cost of ade -

By Dean Schott kinds of ==ra-== ranging trees cerand x.e.en, ICc ,====== anni,s year, uomen ease.

When Peoples Gee wested to charge lei cipes with their bins to corporate - director, said, " Utility advertising is so s00,000 customere St.s minion see

'ans utalties emnet meerly $20 w =at ad -

visible it creates constmastion mnons ca lie espemons, the amount was "igmanyear to advesties their eenicos Today, if advertising deals with toeners. We got letters frees consuonare and^' - prestice that commm- roeservation, safety, new prices or new askins why we let utilities advertise. I tag aMood to unnan by the commesse ease.

era compitin ===d3==dy adds to their el- services, the -==ers pay. Stochhaldare theesban== the U.S. Supcome Court sold "'" san Isot month. Peoples' aversgo eue.

high bins per eisetsletty, natural gas pay if the ads preenote the could." 44 esmes a peer a and homen. __- '--- or controversial court ruled in 1980 that a New temer of amwE anaue be. l of M ass John to many semesmess, utiuties

~

York State utility has First A===d-* the compensi vias possident.

I are - . " - that should use their ad- ye, essempio, customers wese not buted rights like anyone else and could advwtion. AT NORTHERN Humois Gee, the ad-money to rodeos custeeser bids, for Rdiana's sucent " Don't Take Toenor- Keenan said consumers' reaction against rather to produos ellek TV eosunw- - featuring advertising far outweighs its oise la a wtislag east for the eserego easteem ciale, billheards and monepeper advertiee- now actorfor John Granted" Hmessaan TV --'--

o's "is merry-go- utility *e budget. " Advertising is cafy a assounto to 12 eenes in an aumont anents. round that grinds to a halt without elec- email of a cosapany's esponditme," SM. ' ids compear apent mess % SS enR-1 If that happened, k would be more tricity.However,enesenere do pick up the he lies la 1 in.t the eesumeses eased

==ha*==== say asseutives tab for asesonal ads tauing theon about the elos it to seRect och $170,00f I syenbelissa thes JORN MAISON, Edison ad.wtising trema its 1.46 millies emberben 2 - m

< et Coenmenwealth Edimen, Peoples Gas shift to higher prices in the ==== and and Nosthera ini-man Gas.They say staitF the return to lower prices la autumn. supervisor, said the company's 1982 adver- 'I%e situation at IElmois BeR is difteend l An $800,000 newspaper kicked tising biu of $3.25 mihn pales in cost- beesuse af essapetition.

i biM would esa beteens as esses and 44 to saniala parisom <rith its 41 bution annual feel bib Rehest, E. 8%==h-4. "sR9s advestising cents a year for their aseseos sesidsmedal ett by Peoples Gas last m. ensanger, sold his company advertises fu

< custos=r. why astural.ses bide wwe rising wdl be and its $600 minion annual tax biu, At Dunois Ben, eincials seht its 3 mB* charged to =*anhhald==s. On a,==I radio "To euminaia advertising isn't yning to servlees and a "'- ""wbsse these9s som> ^

lion custeamers would and up amore advertleanents and brochures laserted with make s. difference," Manman said. "It seekan - - ^ and deelse on their hiDs, not less, if caespeaF enanthly blue warning custosness to be would be diaka==8 to claim bills would be telephones but does met advertas dropped its $12.8 miluen-a. advertle- aware of leeklag gas are paid for by changed drasticaHy if we cut out advertie. wbsse the cosapemy.has a esonopoly, sect adver* ing." as loset eeBlag.

ing programs. '1%e "I pts the someeres of th 1 , = ,

noe, than pays for heelt envings - Although f%==a= wealth Edison pre.

new ineoane, which helps keep rates lowere ADS BY IILIMOIS Ben teDing cus- posed spending $3.67 minion on advv.iis- payer, Caenpbelt sold. "If I got the in

, Bell enscutives laslet. toenere they can return broken "" ;' xx Ing this par, the -==sce aa==I=Ia= pression that advertising was act neces) to company envice contors for repiece- leet monta permitted Edison to bGl its 2.9 sery I aseid undesstand their angee sad NEVERTemt.Hful, 3dichael V. Nesten, to consumers. The eoss- million custeinere for only $750.000 ' Inst would seasst it too."

000 on the campaism but, amount represents 20 comte of the typical But he added,"Censumese ese peplN departing chairmee of the IHinois Com ---

anid, itment enved 84.3 areseeres esBuen voeldential t'a==Immia custeener's blu , enid,"of $648.34 Utility la a Isseadvertle bessume we pony peat de advertise."

las is a serious beso of ecstantion with G,a= the company could cut beek es.. '

and we have backed ewey et i nn======e, n-e unektes hoore in the =v===== People set ammoyed, and I rs.*a==s did not pay cost of news.

esuet any, I get nameyed tes." paper ads last escoth when Blinois Bou/

Largely becauss if federal lastelah in announced it aseded $186 naullen esces la Ir18, the commeres a-a== bas taken revenues. But they did pay last June who'n o tougher approach en which advestle6ng Beu won a $219.4 = mea = rate lacrease and suponses cosas hees -==="s pockets. the coenpeny the higher charges .

Beroes arra,enesumese owe for au na no ,e , aper ,

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4 MED! CAL IMPLICATIONS .

• s. dirty bombs. It also has a curious physicIl pra-OF NUCLEAR POWER I.;. bundles typical and 1000 megswatt each reactos bundle consists contains of 12 rods. The526 1 perty of igniting sponteneously when exposed te J' i air, thereby pruducing tiny aerosofised parti-i by Dr. Ilelen Caldicott [' redioactive uranium proouces heat by ilssion Australiaan.borse and educated. Dr. H18en Caldimt whlCh Is utilized 13 generate electftcity.During '

cles which are dispersed by wind etirrents and peart.ces pediatrics at Boston's CNidren's Hospital .; this process uranium is converted to many , available for Inhalation by' humans and' ~

tr [a le aad e la j, ,' '.l radioactive daughter products which are the animals. -

q hes or wastes M nuclear pown. Once a par of N.

fr *Irno NtEiInb*t b racN.ir By the year 2,020 in the U.S.A. the industry will' a one quarter of the rods are removed from the have produced 30,000 tons of plutonium, most of Nuclear power poses the greatest putGlc 5 reactor i hazard the world has ever encountered because y

core because their

, f ceased. The rods are both thermally and radle i generating.

life whichhaswill be. in. powdered

. l, form. There will be" '

j of the hievitable contarnination of the blosphere actively very hot. They must be stored on 3 g g 1 with plutonium and radioactive wastes. Cessa- racks in cooling ponds containing water for y  : g .

tion of all forms of nuclear power is the ultimate ,3 weeks prior to removal for more permanent , g form of preventive medicine. . { storage elsewhere or possible reprocessing. ,10 lbs. H " critical mass" which means that a y now contain a my larp amant M The fuel cycle of nuclear power plants is com;

! E a. spontaneous atomic explosion could eccur if 10 plex, but not too difficult to understand. It has , '" biologically dangerous radloactive materials Ibs. or more were compacted together in a finite Includng stmnh H, Mne W, ush W . space. One could envisage disastrous conse-j many biological and medical implications 4: ""d E " " '

I which must be understood by the average per-  ? quences if a truck were to crash and discharge J son in the street as well as by the politicians who h . some of its deadly contents.

! make most important decisions for society. 4, 'Reprocesstag. tventually it is hoped these .

.f The most crucial property of plutonium la a half i in this article, I describe the fuel cycle step by. f. rods ylit be transported in caskets to a life of 24,400 years, thalf life of a radioactive j step, and explain the medical dangers arising .( reproce.tstng plant where they will be dissolved .

• substance is the period of time for half a given

' from each step. . In nitric acid. quantity to decay, and a similar period for half

' During reprocessing, the plutonium is purified of the remaining radicactivity to decay, ad in-l 1. Minlag. Uranium is the fuel for atomic reac-I tors.When it is mined from the ground it emits a .' t and removed from the solution, in powder form finitum). Therefore radiation from man made plutonium will exist on earth for at least half a radioactive gas called radon which is often in- '( as plutonium dioxide. It will then be used as si either fuel for atomic bombs or fuel for million years.To illustrate the enormous medi-hated into the lungs of miners where it converts ,.

i breeder nuclear reactors" (reactors which cal problems arlPlog from the physical proper-l after four days to lead 210 which remains Hes of plutonium: N en individual dies of lu'ns

! radioactive for more than 1001 ears. Radiation .c brer:I plutonium). It is at this point in the fuel s cycle that the greatest dangers arise once the cancer engendered by plutonium, his body will In the body is carcinogenic (cancer-causingL It 1

! has been discovered in the U.S. that up to 20% of f plutonium is separated. Plutonium is an ex. ;j return to dust, but the plutonium lives on to pro-duce cancer in another human being.

I uranium miners die of lung cancer over a 20 {,! tremely potent cancer producing material, ap- j . ,.

year period of mining. ' propriately named after Pluto, the God of Hell. .?, Althc1gh it'will be used as "ftsel in breeder It entus the body by inhaladon d contaminaW t *

2. Milling. Afler the uranium is mined it is then j reactors, more plutonium will be produced than h a ,w is depsNed in b lungs. Becam will be utilized. So there will be a conUnual net i ' milled and refined. Thousands of tons of waste ' .o its potent cancer producing properties the ac , ; Increase in plutonium manufactured. The

! ore tcalled tallings) are discarded and left lying ** "***

' "E * * "" nuclear Industry has not yet decided what to do I in huge heaps on the ground.The tallings gener ',<

!, ated in the U.S.A. over the next 24 years may y

• mhnni d a gram (an invisMe parHeld ,; with all this plutonium, e

produce 45 cases oflung cancer in the , j tooworld per . will high. Cancer , . not l There appearis some until evidence 15 or 20 Y S.this Wastelevel has been Storage.There are noset ,,f perman?nt safe

{

year for tens of thousands of years.The causa- . I years after Inhalation. By extrapolation,11b of . methods of disposal and storage available at

! .tive agent is asala the gas radon which is con . ," (plutonium, universally dispersed,would be ade , i this point in time. After the plutonium is ex-j tinually emitted from the waste uranium in the . . t} quate to kill every man, woman and child.ond . i -

tracted from the radioacHve was% sery dan-J . tallings. *, , fearth. Because plutonium is the basic material i ,

gerous biological elements remain, which have

! of atomic . bombs, it is more valuable than I '

no further use and are pure waste products.

This remaining solullon contains some p

4. Earlehment and fuel fabricatlen. The ura- '. ' l vulnerable heroin onto.the theftblack market, by terrorists, and therefore racketeers, ' plutonium, radioactive lodine, strontium 90

/ nium is then enrl'ched and fabricated into fuel. - non nuclear nations and deranged indiveaunis. ecslum, as previously mentioned, and many rods which are transported to the nuclear other highly toxic radio-nuclides. Because it is Reactor grade plutonium makes ineNicient but extremely hot, the solution must be stored and

{

i

v. -

cfter being ingested in contamin: led milk, cod- . . - .- . ...

cooled continously for ye:rs. Currently tanks

~

is incorportted in hose beccuse it chemic::lly saf stm2 M w:sta is unsdived, and 'enn it,.

with a 30 ye:r lifespan cra being used. Ev:ry , resembles calclum. This clement c uses there were o present-dry solution, we could t-ol- l predlet a stab!c soclely' or world for half a m: nth numercus lecks of radioactive wtst:s . osteog:nic sarcoms-o highly malignsnt,1: thal

~ million ycars: we could nol guarantee locorrup l

• cro reported in the U.S.A. In quantitles from bone tumor, and leukaemia, a cancer of the lible guards, or moral politicans and we cer *

~

several gallons to 200,000 gallons. When this white blood ccIls. The blood cells are formed in . tainly cannot prevent earthquakes, cyclones or','

dangerous fluM leaks l'inevitablycontaminates  ! the bone marrow, and are therefore subjected the local water system and the various elements .

. even wars. Waste is leaking now, inevitably'It 4, to the effects of radiation from strontium 90 (n tre taken up by the food cycle. Radioactive . the adjacent bone.  ;'

will leak'In 'the future."%'e could thereferen' '

lodine, stronium 90, and ceslum are absorbed by

• - predict epidemics of cancer and teuksemia in '"

roots of grass and vegetables and are further . Ceslum 137 is deposited in muscles of the body .t j ' children and young adults,5and an increased' '

,) where it can produce malignant changes. f- Incidence of inherited dir. case'fthere are 2.000 '4 concentrated in the flesh and milk of animals

~~ described inh >rited diseasesi, it is 41so'inevite ,4 Plutonium is one of the most carcinogenic subs . i tances known. It is not absorbed through the [ ble that plutonium will Wtolen and utilized for ; 'l'

' 8 *c8Mn ucdon Q hns M plumnium ' . '

lodine 131. strontium 90 and plutonium are bowel wall, except in infants in the first four. i concentrated in milk, both human and animal. weeks'of life when it is Instested in milk. As pre- ,,

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C' " " d I",'" th',,U.S.A.)cy 6

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Ceslum is concentrated in muscle (meat) and vlously described, infants are extremely senst- , , . g g.,, , , j, ,3, ,,,, . .g .,.,g, plutonium is also concentrated 1,000 times in ) , .

Live to the toxic effects of radiation.The route of ,

b it has b,een clalNed tiiat 9d:90'JITEf. . . yall cancers,,,b, fish compared to the background water con- entry of plutonium is by inhalation of contami.lf i nated air into the lungs. Small' particles of' . may be caused by envir,onmental pollutants. ~

ceitration. These substances are Invisible, There was a 5W Increase in cancer in the U.S.A..: T t:st:less and odourless. It is impossible to know ' plutonium are deposited deep in the respiratory! .

passages, where they remain for years. It is ac.

In the first seven months of 1975..and a total 3%ti! -

when one is eating or drinking or Inhaling *

, . .. A .-

cepted that one millionth of I grem of's

• c rise in 1975W 4 -

• . . , ..v. ,

rcdloactive elements. l lg' .

J  : plutonium is sufficient to produce lung cancer ' ' M'. '.Govermsntsspenil mill'ons o'tdollars 'researc'h('

8. Clelegical properties of radleactive waste.

1W years anu inWal inhalaHon d W eW' !", Ing causes of cancer, leukaemia, and l'nh'erited'

ment. Plutonium.is also absorbed from the i v disease,' but" simultaneously ' spend' billionk of #

l All cells of the body have a central nucleus  !

lungs into the blood stream where it is carried s dollars in an Industry that will dir5ctly propagf.#f

. which contains genes, the baalc inherited .

N the Hm no produce a my mmHgnant Hwi . ,, ,g, these disFases? ' ' ' ~ ** " ' '

mtterial which controls all our characteristics car,cer), to bone (where like strontium 90, it' . ,mv n -

'..t ' ' -

(colour of eyes and hair, size, facial charac- -

causes osteogenic sarcoma and leuksemla), and .. . As a doctor,I appeal to my fellow medical col y teristics, enzyme systems etc.). Genes are chtnged by radioactive particles. Cells and

[t it is selectively taken up from the circulation bys [ ,- b.' . leagues :10. Investigete. Ihis enormous. present.. ,

the testes and ovsrles where, because of its Int .f r ,and, pote.nllat threat. lu nur. patients, and to) cs gInes v,hich are actively dividing (as in fetuses, ,

urgenHy inillate i programs e of.. prophylactic.of ,

- credible gene changing properties,'It may causef :. c ,,

habi:s and young children)are most susceptible . .

to the effects of radiation. If a gere which con- f an ine cased incidence of deformed and dis tj. ,;f,, ; medicine. .l. also ,a,ppeal to tht: Mothers. and , ,

l.

i cased cables, tioth now. and in future. genera n[. + .,Fathe s f the. world. to educate themsel,ved ,

trols the rate of cell division is altered by radia- i ;abmd di l dAngerd 'of nuclear power, tions. Plutonium also crosses the placents froml' ,.

il:n, the ce!! may divide in an uncontrolled

~

and from government a safe futur,e i fishion to produce cancer and leukaemia. It m y take from 15-30 years before cancer ap- , ,!.

L mother's blood into the blood .

ants.

of the fetus,where petrs after the cell is exposed to radiation. If a , ,

part of an organ, e.g. heart, brain, etc. causingt . f,. . '

gross deformities to occur in the developingi v. n g:n2 in the sperm or egg is altered by a radioac f 4 '

- fetus. This mechanism for production of fetals .* < .

tive particle, the young may be born either with' ./ is

(* an Inherited disease,,or, the baby may appear Il;.gdeformities j is called terntogenests andtdifferent -8 4

_g from the deformitles , caused ; by l

l normal, but will transm!t the damaged gene to future generations, to-become manifest in later .

genetic mutation in the egg or. sperm, becauseeC w ' . g, ,,,

yezrs.

although the basic gene structure of the cells of , . ' . ' ;yyggggg,ygggggg, yyyy yoy,ggy 99,,.q,

- ' the fetus is normal, an important cell in the l '

e Caldkot t 's new M r . , 'W .

Radioactive lodine is absorbed through the N,v bewtl wall, and migrates in the blood to the ' devel'oping fetus has localized deformity. been lStrtilar killed to the leadirig action of th to a/ .:. C  :$3;95 plbs' postage froar-#FS; ,

thyrcid gland where it may produce thyroid drug thalidomide). '

. n". N.,. 120K,eff'for orders of 3 o(sidre) csncer.

3 ,

. . . . NUCLEAR"' MADNESS BU '

'Strintium 90 ls aiso absorbed through the bowel an wlI p'ro u fu 'l' ; -Oo

• 1. 1. h* help Protehds B'f## MFS $2'.

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1217 Michigan Avenue Rockford, IL 61102 March 1,1983 To the NR C Licensing Board D ear sirs:

We ordinary citizens of Northern Illinois do not need the electricity w hich w ill be generated by the Byron Nuclear Pgw er Plant.

We cannot afford the repeated rate hikes needed to pay for Byron.

We are gravely disturbed over the dangers to human life and to the environment created by the growing number of nuclear pow er plants in Northern Illinois.

All nukes leak radiation. R adiation, cumulatively built up in the bodies of our children and grandchildren will endanger their lives.

It can cause mutations in their gene structure w bich w ill permanently effect the future of the human race.

l In i-finite w isdom, God set the sun 91 million miles aw ay from the i

earth. N ot in Byron, Illinois.

Doris Peters R ockford, Illinois

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hetk/ ' ADO IS BYRON WORTH THE R IS K ?

l96 y E03 N o.

T he demand for electricity is not there. C ommonwealth E dison can now produce 40% more electricity than w e can use. Byron is not needed now , and will not be needed for the next 30 years.

T he life of the nuclear plant at B yron may last 30 to 40 years, if they are lucky. In thirty to forty years w e just might need more electricity - but by then they w ill have to build another nuclear plant.

B yron costs $3 billion and is still not finished. P ape rwork, inspections, problems with the steam generators, an effective evacuation plan - all have to be resolved before B yron can l

be turned on.

l Putting Byron in cold storage for a number of years would actually improve C ommonwealth E dison's cash flow ($150 million the first year; $60 million in the years following).

l T o complete ths construction program, Com Ed needs at least three more 20% rate hikes.

A nd finally, nukes leak, whether they have an accident or not.

A nd the risk of a serious accident is there, especially if C em Ed rushes to turn on the plant.

So is the risk of ionizing radiation blow ing in the wind worth the benefits of more electricity that w e can't afford and can't use 7 N o.

Write to:

Judge Ivan Smith c/o A SB/NRC The Federal Building 20 Svum C vui6 C o. m Rockford, IL 61101

/

Tell him that you can do without the added risk of a nuclear I pow er plant operating in Byron, Illinois. '

spo v. .J Ly . C O !? C " R e e n c T T t v r y7 ;

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My name is Be th Galbreath. I am a Rockford resident (734

Parkview Av. 41107), a professional employee of a Rockford social

! service organization, a wife and mother of other Rockford.

residents, and a volunteer in community work. I and others like

, me care deeply about Rockford, its quality of life, and the

! heal th of its children, because we live here--so we care in a way i that visitors from Washington or Chicago cannot, no matter how

they c.ay try.

l It has been said to me that wt in Rockford should have no j concern about the Byron nuclear plant--that it is the concern i only of those who live in Byron and Oregon. Ye t we in Rockford i are only 15 miles away--well within the circle of its heaviest radioactive influence, even under normal operating conditions.

3 Our children, as well as the children in Ogle County, will  ;

i be affected by this plant. But our children ARE in fact citizens of Ogle County! I understand that Ogle has the highest concentra-j tion of youth camps in Illinois. My own daughter spends time each l j year at an Ogle County youth camp, and I lead groups of children i on camping trips to the same facility.

) As a youth leader I am aware Sow vulnerable the children

in a camp are. Most youth-serving agencies do not have the money j to have evacuation buses standing by during camp sessions. It is t

simply impossible to plan a quick mass evacuation of Ogle County you th camps wi th the resources and vehicles avail abl e--even assu-3 ming that the county's roads would not be blocked by private -

vehicle-owning evacuees. Even in the off-season, when I am there with my group, we do not have enough motive power to transport the whole group in an emergency.

I am sure the numbers of children involved, even at the height of the summer season, must seem small compared to the 3 number of people in Rockford and in Ogle County who would also i

need evacuating--but the ratio of cars to people is much higher among the permanent residents. And I woul d al so poin t ou t that children are most vulnerable to radiation damage. They are our j precious future--yet we build a nuclear plant in the middle of an area where they and others go for spiri tual nurture and for education about our natural heritage!

j I want to make it clear that I am not speaking for my agency

. or any other member of any youth agency, but only for myself and my family, though our concern includes all the children.

I also want to stress that I am not concerned only about l major ' accidents, but al so abou t everyday, so-called " normal "

. emissions. These emissions are said to be "well within safety limits" and pose "no h3zard to the public"--yet there is NO i evidence for a threshold of radiation danger. Every bit of radia-tion, ne matter how small, causes some damage--the less radia-tion, the fewer cases of damage, but there is still damage. And 1 children are the most easily damaged. l Again and again we are told tnat yes, the research'may show l

that radiation causes cancers, leukemia and genetic defects--yes, there is a una11 chance of a nuclear disaster-- but these chances

! are so small that we should accept the risks as part of the price

. of economic well-being. Nuclear power is good for business, we are told--and Rockford needs Jobs.

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A microcephalic infant has a normal sized face but underdeveloped cranial vault, leading to severe mentalretardation. This defect, sometimes genetic, has also been associated wirh exposure to ioni:ing radiation during pregnancy.

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I Well, northern Illinois has much more generating capaci-ty than its customers have needed for many years now, and it hasn't seemed to help yet. In spite of plentiful electricity,

industry continues to flee the area. How can we expect another nuclear plant to attract business--especially a nuclear plant I

which i s par t of a mul t i-bi l l i on doll ar construc t ion program that drains millions of investment dollars out of the northern Illinois economy every week? Especially a nuclear plant with

', some of the worst cost overruns in history--a plant which can do

! nothing but drive up the cost of electricity in northern Illinois?

4 I know that money talk is excluded by the rules of this

proceeding. But money is indeed a safety issue. j

First, i f Commonweal th Edi son is really the terrible manager

• l j it's demand projections suggest, and if it is really in the terri-  !

1 ble financial shape it claims each time it asks the state ICC for  ;

! a rate hike, then i t cannot be considered financially responsible i enough to be trusted with another radiactive baby. It can't be  :

trusted not to go bankrupt and dump the baby on the public dole.

, Nor can it keep coming to the people for more money.

Northern Illinois is suffering a depression--a depression brought on by many factors, but lack of electricity was NOT one of them.

The money to safely operate Byron for 40 years and then guard its remains for several thousand simply i s act here-- not in Common-wealth Edison's accounts, not in the state's coffers, not in the people's pockets. The money will not be there until northern Illinois is able to attract new-style industries to replace those we are losing permanently.

For. Commonwealth Edison, that means that corners have been cut in construction and corners will be cut in operation. And that is a safety issue.

Yet in the end no amount of money can operate a nuclear plant safely--because it is not systems, but people, who build and run machines. Three Mile Island never should have happened, but it did--because of people. People are not perfect. They cannot be perfect. So we cut corners and pretend we can set

" safe limits" for radiation exposure and try to ignore the fact that Byron's emissions will Just add to the emission burden already borne by northern Illinoisans from all of Commonwealth Edison's other supposedly " safe" nuclear plants. And the levels of radioactive materials in our air, water and food keep buil-j ding. And our risks of a real disaster keep mounting.

1 I ask this board, if it must be blind to economic arguments, to be TRULY blind to economic arguments! If the scales of Jus-

tice may not be weighted on the intervenors' side because the plant ts too expensive and not needed, then struggle mightily not .

d to weight the scales on Commonwealth Edison's side because of the I huge and foolish investment it has poured into this radioactive lemoa.

And if money is truly muzzled in these proceedings, then the l 1

voice of Reason will be clearly heard, saying " Don't fire up the 1 Byron plant!"

Beth L. Galbreath 734 Parkview Av.

Rockford IL 61107 2

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_ J_ _n_ _a _ _ _ _n_ .

Reprint Series # 3 W$LW hM$L$

A Branch of Public Citizen, Inc.

215 Pennsylvania Ave., SE -

Washington, DC 20003 M AG AZlN E Vol. Vill, No. 6 '

1 l

I.

NUKES FACE THE BOTTOM LINE by Joe Guerra r 31 he President's answer to the Since what nuctear power pro-

.R energy crisis has been to br,ld After thirty years duces is electricity. it can do abso-up free enterprise as the key to and 637 blilion of lutelv nothing to reduce our depen-increned energy production. The dence on the other 9? percent.

'orces of the market should dictate taxpayer support.

the allocation of our h mited _ ,,pg' ear power " " F percent of all its energy nerd, trom l' resources control < <hould be lifted. contritsuted less oil. If nuclear power suddeniv !

profits should increase. and got. energy Iant year than replaced every oil-fired generanne ;

ernment should get out of the enerav business.

IlreWOOd. station. we would still depend on oil for 67 percent of our needs-TlYs. the administration slashed hardly a state of energy inde-federal funding for solar energy. pendence.

alcohol fuels and conservation free market. The President got Alost of the oil consumed in this pros, rams by more than rwo-thirds. nearly %2 billion in taxpayer subsi- country is used for transportation and eliminated funds for ocean dies for the commercial nuclear and agribusiness. and as feed-thermal energy and hydropower industry. stocks for chemical manufacture.

, altogether. In the final energy The administration's rationale. We can't use nuclear power (i e .

budget. Congr ss sharply cut cost- of course. is that nuclear power is a electricity) to fertilize our crops.

efficien: programs such as conser- potentially " unlimited" source of just as we can't pave our highways vation and solar energy develop- energy, and therefore a solutior to with it refine it into ammonia, or ment-though not as severely as our dependence on foreign oil. The power our trucks with it.

the administration would have sad fact is. however, that in 1980 liked. The budget for solar energy, nuclear power provided only 3.7 till. the President seems so for uample, was, reduced by 45 percent of our total energy needs. enamored of nuclear power percent, instead of the 70 percent Af ter thirty years and 337 billion of that he has exempted it from his the President mught, taxpayer support, nuclear power commitment to free enterprise, per-When it cae.e to nuc lear power. contriWied Icss energy la<t year haps becau<e without the contin-how ever. the administration dis- than firewood. ued support of taxpayer money.

played precious little fanh in the .\ lore importantly. nuclear there is every reason to beliese that pow er is basically unrelatec8 to nuclear power would not <,urs is e

.7- Gume n . dg.,r ~/ Critical .\ta,, the oil shortage. Of all the oil con- the rigors of(ompetition.

Encrev Journal. <a Admh 4 /kw 6tr- sumed in this country. only 7 per- Even before the acrident ai v=. /* rent is used to generate electricity. Three .\ lite Island. new orders for

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nuclear plants had come to a com I plants will exceed those of new coal l plete standstill. Since 1973, fift) plants by 35-50 percent. ,

3

! {w previous orders have been can. "Thie suggests," the report con-celed. Wall Street analysts are cludes, "that many reactors steering their clients away from currently under construction could investments in nuclear por r. and be scrapped in favor of new coal-major imestors. such as insur- fired plants with advanced emis- By the time they come on-line. the ance companies and pension funds, sions contro' with little or no (co- electricity they generate is so are quietly pulling their money out nomic penalty." This is exceed. expenshe that consumers firid new of utilities with large nuclear ingly bad news for the nuclear ways to conserve.

programs. industry. whose main competitor is The bottom line is that in spite of in hlarch, hierrill Lynch, the no longer oil. but coal. Despite the huge lederal subsidies. nuclear Wall Street brokerage firm. pub- fact that for thirty years the federal power is dying of its own economic  ;

lished a study that listed eighteen gc.ernment has sought through weight. The promise of clean. inex. l planned plants as " ripe for cancel- enormous subsidies and protectise pensive atomic energy hes neser lation." The report. " Nuclear legislation to cicate a fasorable materialieed, and taxpayer money Power-The Outlook for the 80s," emironment for the nuclear indus- is being diserted to support an concluded that deciding not to try nuclear power is losing the bat- indusny that could not survive on l ,

build a nuclear facility would hase tie to coal. its ou n. j

" positive effects" on the near term Utilities are banking on in Sep tember the administra- l financial outlook for a consider- increased demand for tiettricity to tion umeiled its second round of l able number of major utilities. cmer the eser-increasirig (nas of I'iscal 1982 budget cuts. Once At the same time. Komanoff building nuclear plants. but they again nailcar spending emerged l Energy Associates. a New York- are caught in a viciou; inflation- essentially u nw a thed--a nd once l based group of energy economists, ary spiral. As capital costs rise, the agam renewable resource and con- l

' released a study showing that capi. price of elettricity is forced up, servation funding sustained deep i tal costs for nuclear plants thereby encouraging conservation. cuts. In fact. the administration is )

increased by 142 percent between in the eight ,, ears since the 1973 oil now diaussing the possibility of 1971 and 1978. (before the acci- embargo the nation's utilities have climinating these programs alto-dent at Three h!ile !$ land), and consistently m er-estima ted the gether m 1983 11 the President ,

that they can be expected to rise at demand for electricity-once by as insists on ending umernment sup-an equally dizoing rate during the much as 600 percent. Last year's 1 port for these programs. many of 1980s. The study. w hich compared percent increase fell for short of the whnh are c ost-eln. the and hase capital cost increases per kilowatt industrs's historical 3 to 4 percent aheady begun to help us break our hour for nuclear and . coal-fired projettions, mdicating once again dependem e on forciun oil. then he power plants, found that w hile that consumers are learning how to should end lederal hand-outs to the safety and environmental regula- use les energy more efficiently. nuclear industrv as well. After liv-tions will continue to drive up the The ulumate irony is that nuclear ing off taxpayers for thirty years.

costs of both, the lifetime generat- plants end up discouraging the it's time that nuclear power submit ing costs of new nuclear power demand they were built to supply, to the free market's judgment.m w p-

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Reprinted with the permission of Working Papers magazine, Vol. VH, No. 6, November-December 1981.

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Tw Pues 11 Otisal Nous Emugy Jourumi July ti Aagust 18. 391 t' Ratepayers' Money at Work ~

i l Nuclear Industry May Need .

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$42 Million to " Set the Record Straight" .

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la hGd. Jane, the ads appeared la HartisNrg. and away the largest ensamsmssor of g IM Rauldsste in that arup abendy have a Ah fersmation. Its $25 to $43 miBies budget wGl dwarf

1. ""lar me record straight.That's what the nuclear undermanent of anciser poesr.though and Edson k is Eisaric eartmis- the AIP's lastkute's $5 to1931 36 miBace public affers budge of $

laduiry hapes to do through a seria of sadio and TV ly est the oss the CEA hopes to convey. Sheetas the* hudest (caly a partnam of which is devoted to ancisa

, daigned to omba pahne fears about agots la such hostile territory is perhaps the said test

. imme sut as rednessen besords and wome esposal. of ther of'entevensus. k is not CIA. however, but immes).

Seam W er indstry ads have already appeared on Osmeral Puht.c Udlities, ourner of Tht!. that is pay-ulemen mations la the Harrisburg. Pa. area. home ing for the sposa, a curious assion is light of that  !

of the Three Mile Islead muensar plan'a utahry's a.uch-voussed financiallassah'lity.

Speaking before a gatheries of utihey enscutive "We're naturagy deligheed somsome is usias the last May. Gacrais Power Company Chairmas ads." CEA Derenor Harrts said, but he added that la Robsn Scherer unveiled five new ads developed by futm CIA wiB pay for Leisvision time. At thes point i i' t

l the industry-backed Committee for Energy the f*a==da= is afu trytag to simide esactly when Awarenres (CEA) that downsisy the risks of radia. and where to begia plasmas the ads, but Harris is dos ensam from operanas plaats and aspinia the hopeful that they*E be on the erwaves an=s'i-e la ladustry's pleas for ansposes of high4evel wests. the faE. . - i

• "We need to attack the festering problem my -,n,u . safe nam,, co -

f'aaer81 a conHtion of safe energy,inedia reform '

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ofpubh.c misunderstanding. . . agressw.ely> CEA s n,. m

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b has two fmme stafr i

and to provide enough funding to give our

• CEA does far more than advertue on behalf of the had y. ~ ugh. u a:so saas ,ro-a:isar .a.  :

4 efforts a. chance to make the difference. pp dersensats kom an*ional organizatacas dastributes laforenatson to civic groups and schools, and drrects 1

f la at lasst one semos, k is fkting the ads are makiss asal coerenacas grassroots lobbytas effons. CEA is  ;

"Wp and to enack the festering problem of puuic mend-mandles. . . aggrushely." Scherer tW bis themr ea=t==cial debut lab Hagrisburg. the spiritual Neueman ^"ana- tempossible for the " ; for hains of up con- the offiaat 4support o

ettery brahren. "and to provide amouth fuasuas to birthplace of CEA. The Comotines was forenad ores Peopta and the American Assoc 1auan of Val-give our efyorts a chance so make a dsfference." shoruy after the TM1 accidset,la na effort to set tas versky wesissa. and has aise emased groups suca es i a- of Rata'ed

. anning ths amore struieta, espasiany en a manon- resord straight as the amuos s worm musisar acc6 the tJrtas Langua. Assertena f 8 --

wide hans. is ganas to cost sonne anomey. CEA. which dama. vaterna todustry waschers may recas the prtet Persons and the Langue of Wossen Voters to joen i WW distribute and place the ads. is trytag to raise be- ads CEA ren tsack thus, lectuding one that made tae ks "Amartcan Saargy Week." as asauall evasitf .

i tween 325 and 542 minion fron't the industry, now fassous claim (or infamous, depamdag onfessuring your beaustry-ftmanced public forunts.

If ks enormous budget materiaEams, these outreach l prismaruy the utihty sector. That's up frosa ks 1931 posat of v6ew) that the accidssu preved the syssaan _l hungst of 54.5 miDios. Scherer. who chasrs CEA's worten. efforts wiB entainly facrease. And 6 aff director la 1930. the #'a==an,. comassed ahmast endrely Harrh is confident the money wiB be raised. "Most -

board of directors, cnDed for utility peerest*y when of utGlry enscutives who voiensaared thstr time, and of the industry agree that this prog h the Comunittee's fedressers come knocking. "The staff on loan front the Atontic ladustrial Forusa. To- he said. Which makes it Skely that th J probism the smedia -is TVstore serious,

- that can the help us is cries omre is more urgsat amf. day it teams a 14.== ah=r board of diressors and a public wiB soon be he exper.- fuD-timme staff of alas. And if the industry r=pa=da

• sive." he explanned. - fresa one ende of the issue.

The crisis, as the industry sees k. is ks derNaint to hit. Scharsr's ceB to arms. CIA ogi hacome far- . j 3 ,

popularwy with the public. "There's been a ad,,,v.of.,uhuc, . ,.se,,on.- CEA e - -

mi,sunderstandtag ds in about ancisar power p- which

• 7 c. ~is.Nu evi-,e.,et lear Industry Television A . ds: Two Examples

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l same had pres the indsc y has recevai, spoofical- ' leo

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ty, severage of "malfumejass, operadomal tasures and the emesing series of -=== - " wtuch have g,. ;. g,:y'yl 1.*g, . .*_7 . g y ,,, , g,,,,,

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. .-es unsois u. nma.rtal, ;:; sedimism.wmises at Amerma's to

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. c sagdene maic eds - madner smargy. Pese are=tnen pave dueoloped the aan ottal asy la spesses to fut amployament and a strong e,omony." . senderalam stds rusesrat, the-safe and permans disposal of ancier weste. la

~ podems la hosphal ' test. this presiiss is skandy hopealso in 13 ase6ses '=re=**F the

,y Da g,M,g samed the 30. and 'n aaaa=d spots in ship at sen -' p

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.' Gemd Rapids, t8acha r == pokas vieww befers ang ,~ ~. city aghts afts the ads were rua. Akhough the ransks of the ase; 13 assions esiered , "asur se'tressammt by esadsadse k. fedesiss hs voie

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