ML20086L046

Affidavit of Mf Lowe in Response to W Owen 840118 Affidavit Re Delay of Fuel Load & Testing Activities.Certificate of Svc Encl

ML20086L046
Person / Time
Site:	Catawba
Issue date:	02/03/1984
From:	Lowe M PALMETTO ALLIANCE
To:
References
NUDOCS 8402070153
Download: ML20086L046 (4)

Text

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'84 FEB -6 P1 :10 UNITED STATES OF AMERICA 77:cE :7 EEyj.P NUCLEAR REGULATORY COMMISS10N1: 'l 3,,br ,

a c .o BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

DUKE POWER COMPANY, et al. ) Docket Nos. 50-413

) 50-414 (Catawba Nuclear Station, )

Units 1 and 2) ) February 3, 1984 AFFIDAVIT OF MICHAEL F. LOWE ON BEHALF OF PALMETTO ALLIANCE IN RESPONSE TO AFFIDAVIT OF WARREN OWEN My name is Michael F. Lowe. I currently serve as Director of the Palmetto Alliance, Inc.

The Affidavit of Warren Owen, Duke Power Company Executive Vice President of Engineering and Construction, submitted January 18, 1984, stated that delay of fuel load and testing activities for Catawba Nuclear Station Unit 1 would cause "significant costs to the consumer in North and South Carolina". The history of Duke Power Company rate increases in South Carolina shows this statement to be both l false and misleading. According to figures set out in South I

Carolina Public Service Order 82-2, issued January 28, 1982,

[ introduction of Applicants' McGuire Nuclear Station, Unit 1, i

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caused an increase in rates of $48,843,000.00 to its South Carolina customers. This represents an overall 12% increase.

Palmetto Alliance was a party of record and participated as an active intervenor in this case.

Contrary to Mr. Owens' view, any delay at Catawba Unit I would also delay a significant increase in rates for Duke Power Company's South Carolina customers.

I, Michael F. Lowe, of lawful age, being first duly sworn, state that I have reviewed the foregoing affidavit and that the statements contained therein are true and correct to the best of my knowledge and belief.

/

e jMichaely)(Lowe l SWORN to before me this 3rd day of February, 1984 w 0d+v - 92-f Notary Pyj5 Tic for South Cans lina My Commission Expires: 6/Jd/90 t /

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket Nos: 50-413 DUKE POWER COMPANY, ET AL. ) 50-414

)

(Catawba Nuclear Station ) February 3, 1984 Units 1 and 2 )

CERTIFICATE OF SERVICE I hereby certify that copies of " AFFIDAVIT OF MICHAEL F. LOWE ON BEHALF OF PALMETTO ALLIANCE IN RESPONSE TO AFFIDAVIT OF WARREN OWEN" dated February 3, 1984, in the above-captioned proceeding, have been cerved on the following by deposit in the United States mail this 3rd day _of February, 1984:

James L. Kelley, Chairman Albert V. Carr, Jr., Esq.

Atomic Safety and Licensing Board Panel Duke Power Company U.S. Nuclear Regulatory Commission P.O. Box 33189 Washington, D.C. 20555 Charlotte, N. C. 28242 Dr. Paul Purdom Robert Guild, Esq.

235 Columbia Drive Attorney for the Palmetto Decateur, Georgia 30030 Alliance P.O. Box 12097 Charlestor., South Carolina 29412

D r,. Richard F. Foster l P.O. Box 4263 .

George E. Johnson, Esq.

! Sunriver, Oregon 97701 Office of the Executive Legal Director Richard P. Wilson, Esq U.S. Nuclear Regulatory Assistant Attorney General Commission P.O. Box 11549 Washington, D.C. 20555 Columbia, South Carolina 29211 Chairman Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555

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• Jesse L. Riley Scott Stucky Carolina Environmental Study Group Docketing and Service Section 854 Henley Place U.S. Nuclear Regulatory Charlotte, North Carolina 28207 Commission Washington, D.C. 20555 Carole F. Kagan, Attorney Atomic Safety and Licensing Don R. Willard Board Panel Mecklenburg County U.S. Nuclear Regulatory Depar tment of Environmental Commission Health Washington, D. C. 20555 Charlotte, North Carolina 28203 Karen E. Long Assistant Attorney General N.C. Department of Justice Post Ofice Box 629 Raleigh, North Carolina 27602

.Y Mf'ael F.f bwe, Director ralmetto Alliance, Inc.

2135 1/2 Devine Street Columbia, SC 29205 (803) 254-8132 l

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