ML20148A398
| ML20148A398 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 12/11/1978 |
| From: | Sohinki S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML20148A403 | List: |
| References | |
| NUDOCS 7812280351 | |
| Download: ML20148A398 (3) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g Wi g
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-HOUSTON LIGHTING & POWER COMPANY Docket No. 50-466 lN
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NRC STAFF'S RESPONSE TO AMENDMENT TO I
PETITION TO INTERVENE SU3MITTED BY F. H. POTTHOFF,'III j
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The NRC Staff opposes the additional contention submitted by Mr. Potthoff in his undated pleading postmarked November 20, 1978. Mr. Potthoff appears j
to be contending that as a result of a State constitutional amendment approved by the Texas voters on November 7,1978, solar and wind tech-I nologies are now economically feasible alternatives to the Allens Creek facility, contrary to the Staff's conclusion in the Final Supplement to i
the Final Environmental Statement. The proposed contention should be l
excluded as an issue in controversy for several reasons.
First, the amendment to the State constitution cited by Mr. Potthoff provided only that the legislature may exempt solar and wind equipment from taxes'.
Since the amendment is not mandatory by its tenns, it is only l
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- speculation that these technologies will, in fact, be exempted from taxes.
Even if they are exempted by the legislature, there is no basis for the allegation that the technologies, will, in the time frame needed, be viable alternatives to the Allens Creek facility.
Further, the Staff concluded in the Final Supplement (pp. S.9-7 and 9-8) that technological feasibility was lacking for solar and wind alternatives, i.e., they would not be available to replace a 1200 MW nuclear power station in the time frame in question. Mr. Potthoff fails to address the Staff's conclusion with regard to technological feasibility at all.
Finally, Mr. Potthoff's attempt, apart from the constitutional amendment, to demonstrate the economic feasibility of solar power is plainly based upon erroneous arithmetic.
Mr. Potthoff challenges the Staff's estimated cost for silicon solar cells of $20,000 per kilowatt (Final Supplement,
- p. S.9-7) by citing an article from " Rolling Stone" magazine in which the J
author estimates the cost of such solar cells at $15-$25 per watt.
Mr.
Potthoff has wrongly calculated the cost per k110 watt :s a result to be
$1500-$2500.
Actually, the correct figures are $15,000-$25,000, which j
bracket the Staff's estimated cost. There appears to be no disagreement, therefore, between Mr. Potthoff's source and the Staff's conclusion. Thus, there is no basis for the contention, even apart from the constitutional amendment cited by Mr. Potthoff.
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3-For the above reasons, the Staff believes that the additional contention proffered by Mr. Potthoff should not be allowed.
Res pectfully,submi tted, Stephe M. Schinki Counsel for NRC Staff Dated at Bethesda, Maryland, this 11th day of December,1978.
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