ML20129F822

Answer to Util Motion for Summary Disposition on Pleadings Re Load Growth Projections,Consisting of App I Omitted from 850710 Mailing.Certificate of Svc Encl

ML20129F822
Person / Time
Site:	Braidwood
Issue date:	07/11/1985
From:	Bock C NEINER, B. (BOB NEINER FARMS, INC.)
To:	Atomic Safety and Licensing Board Panel
References
CON-#385-816 OL, NUDOCS 8507170467
Download: ML20129F822 (3)

Text

<w o-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Oc g ._,

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5

Li 15 pyg;N In the Matter of: )  %

) Uhh"[f ot :

COMMONWEALTH EDISON COMPANY ) 'INYN-

) DocketNos.50-456od#dNCI^"

(Braidwood Nuclear Power ) 50-457 o c.

Station, Units 1 and 2) )

INTERVENOR'S ANSWER TO COMMONWEALTH EDISON COMPANY'S MOTION FOR

SUMMARY

DISPOSITION ON PLEADINGS The enclosed Appendix was omitted from the mailing of July 10, 1985, and should be attached to Intervenor's Motion.,

C. AMdn' Bock

(

Attorney for Intervenor Bob Neiner Farms, Inc.

CERTIFICATE OF SERVICE I hereby certify that copies of the above were served on the persons _

listed below by depositing same in the United States mail, first-class postage prepaid, this lith day of July, 1985.

Atomic Safety and Licensing Board Panel Mr. William L. Clements U.S. Nuclear Regulatory Comission Chief, Docketing and Services Washington, DC 20555 United States Nuclear Regulatory Commission Ms. Lorraine Creek Office of the Secretary Route 1, Box 182 Washington, DC 20555 Manteno, IL 60950 Ms. Bridget Little Rorem Charles Jones, Director Illinois 117 North Linden Street Emergency Services and Essex, IL 60935 Disaster Agency 110 E. Adams Douglass W. Cassel, Jr.

Springfield, IL 62705 Timothy W. Wright, III BPI Atomic Safety and Licensing 109 N.

Dearborn Street,

Suite 1300 Appeal Board Panel Chicago, IL 60602 U.S. Nuclear Regulatory Commission Washington, DC 20555 Peter Thornton Rebecca J. Lauer Victor G. Copeland, Esq. Isham, Lincoln & Beale Isham, Lincoln & Beale Three First National Plaza Suite 840 Chicago, IL 60602 1120 Connecticut Avenue, N.W.

Washington, DC 20036 A/ u- -

C. AbTer Tock h

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.a APPENDLX ONE

'Ihe attached article by John J. Daugherty in IEEE Spectrum, Vol. 22 #1, January 1985, supports Intervenors argunent that applicants load growth projections are speculative at best and are potentially in considerable error. Likewise, the article points out an interesting proposition in regard to electric power delivery systerrs. This information potentially erodes the basis.for the conclusions of the "Getty Affidavit."

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-r were able to tske advantage of these scatures. with iIcwlett-Packed for 21 yeast in s.un,us posusons and was 1he betuty of this revolution in test equipment is thzt produc- operations mtnager for logie systems psoduct lines from 1976 un-(

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{ tivity and qur.lity,Iwo ettributes of grett importance for all engi- til his pesent appointment. Mr. Ilouse is a member of.%gwarum's 3e acers as well as for their company manageanents, are cadizaced. editmialboasd. $

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? ., Joine J. Donaginergy me pmrer asned ennes gy Hoso assawle poseer frons acimi suswces? I transported either as bulk fuel or electricity. And coalis not with-oui iss piobicms. Conveniiomd conibuuion of goat is ilireaiened "In the twenty 4/rst by such issues as that involving scid rain. Elecause of the steps centufy the United that inug bc taken to potecuhe envismunent, the once telausely States maEbe simple coal genciating station is becoming much mose complex DUying nUClearPOWBT to build and less etlicient to operate.

plants trom France," New ways have been descloped to usc our coal resources. Gasi-fication pocesses base provided relatively cican fuel f om coal, as typified by Southe n California Edison's combincd ecle so-totype plant at iraggett, Calif. AJvances have also been made in

,piy, fluidbed bed combustion, which piomises a coal filed genciat-

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ing stati m with less impact on the envisoiuuent. Iloth types of plants could bus n a vasiety of fuels with ahnost equal case, which Electric utilities are faced with two major interrelated problems: brings up yet another question. It has been suggested that wood, llow much addit hmal power will be needed between now and the cla>>itied as a reneweble enessy source, be bumed ami then be turn of the century? And how willit be generated? Nearly all replenished by reforestation. Ilowever, in the United States, it would take twice the entire anable land in the coutury to supply other problems can be considered subsets of these two issues.

During the economic recovery of the last 12 months in the bioinass pioducts to satisfy the U.S. appetite for clettricity.

Fuel cells offer an atu active way to conven t hydnocas bon fuels United States, kilowatthour consumption of electricity increased at a rate of 7 to 8 percent. Ahhough this use cannot be considcied into c!ccuisity in an eminomnentally acceptable way. 'f he first as a return to the pse-1973 load growth pattern, because il fol- onsating luct cellin a utility systein was inalci test in Japain at lows a flat load growth in the previous year, it seems clear that 'lokyo Liccarie Power Co. dming 19198 and ecs fuemed well.1he electricity consumption is tied closely to the Gioss National proliferation of slic technology is not immincut, however.

Product. This means that growth rates higher than those being it is also clear that such sources as solar, wind, and low-head used in most national projections can be anticipated. Ilut over hydro are not going to psovide even a signititant fraction of the last decade elect:icity has continued to increase its share of ene:gy any time soon. Until a totally new energy source becomes available (such as fusion), countries lik e the United States will be total energy consumption and is likely to continue that pattern, leading to the need for large new sources of electric energy. dependent on both coal and nuclear power to satisfy electric What is the status of nuclear power and coal 7 in the United energy needs.

What about electric-power delivery systems? Ilow inight these States, many nuclear plants have been completed and put on line in the past decade, but othens have been canceled os put on hold systems change in the yeass ahead? 'lhe recent trend toward and may never be completed. Still others ase scheduled to come higher distiibution vohages will probably continue as load densi-on line in the nest five years, but there are no new orders for ies increase. Similar increases in is aintinission voltages should oc-nuclear power plants. If the United Seates continues on this path, cut, but it now seems audikely Ihat a new tiansmission "over build this once promising source of abundant electricity will belost as a voltage" will be deployed before the turn of the century.

domestic option. 'the infrastructure to design and build such plants will dissolve, and it will be difficult to Imild it again.

AbONIIbf UNIbOT l Such a scenario makes plausible the possibility that in the John J. Ibugherty (F)is vice president of the Electrical Sys- l twenty first century the United States may be buying nmicar tems Division of the Electric Power Research Institute in Palo Aho, Calif. lie had pieviously been with the Philadelphia Elec-power plants from France or other overseas sources where the tric Co. for more than 24 yea s serving in various capacities nuclear option is alive and well.

before becoming engineer-in charge of the Ene gy Disuibution What about coal? 1he United States still has several hundred Research Section. Mr. Ibugheity is t hair man of the IEEE Itans-years' supply, but the question is whether it can be mined and

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John J. Dougherty Sectric Power Research Institute "), ; g"$a "

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