ML20246E535
| ML20246E535 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/21/1989 |
| From: | P0Llard S MASSACHUSETTS, COMMONWEALTH OF |
| To: | |
| Shared Package | |
| ML20246E416 | List: |
| References | |
| OL, NUDOCS 8908290170 | |
| Download: ML20246E535 (13) | |
Text
_ _ _ _ _ _ -
T
' UNITED STATES OF AMERICA before-the
. NUCLEAR REGULATORY COMMISSION
)
')
In the Mattere of.
)
Docket Nos. 50-443-OL c
)
5 0-4 4 4 -OL
- PUBLIC: SERVICE COMPANY OF
)
(Emergency Planning NEW: HAMPSHIRE. et _al.-
)
Issues)
)
- (Seabrook Station, Units 1 and 2)
)
)
)
AFFIDAVIT OF SHARON M. POLLARD I, Sharon M. Pollard, h. reby depose and say as follows:
1.'
I am the Secret ary of the Executive Office of Energy Resources'for the Commonwealth of Massachusetts.
I hold'a cabinet-level position in the - Administration of Gove enor Michael S. Duk ak i s.
2.
On August 16, 1989, I received and read the
- application for exemption f rom the requirement of 10 CFR part 50, Appendix E,Section IV.F.1, that an onsite emergency planning exercise be conducted within one year before the issuance of a f ull-power operating license for Seabrook Unit 1 made by the joint owners Public Service Company of New Hampshire (PSNH) et al.
I also received and read the affidavit of Edward A.
Brown, president and Chief Executive Officer of the New Hampshire Yankee Division of PSNH which was attachment p
A of the application.
8908290270 890321 PDR ADOCK 05000443 c _ __ _' O PDR r
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3.
In paragraphs 14,15,16, and~ 18 of Mr. Brown's affidavit, he asserts that. New England has experienced " severe short' ages of electrical power during both the summer. and winter peak demand periods," and suggests that operating Seabrook would be a reliable way to solve this problem.
Mr. Brown's affidavit paints. an-incorrectly bleak picture of the current electric supply situation and. ignores key f acts about!New Engl and's need for electricity.
4.
While. New Engl and is current ly in a tight energy supply situation, the region has not experienced severe shortages or blackouts due to New England-wide capacity deficiencies.
According.to the director of power planning for the New England Power Pool (NEP00L), there were only isolated, localized problems ' due to malf unctions in the distribution system during the record heat wave of 1988.
In fact, NEPOOL has demonstrated this year that with proper capacity planning and maintenance scheduling, the region can' accommodate its current demand for electricity without Se ab rook.
Because of improved pl anning, the region was able to manage its new summer peak without using any emergency operating procedures, and has had excess capacity to sell to neighboring grids.
5.
Mr. Brown correctly st ates th at New Engl and's electrical energy consumption increased 5.3% and 5.2% in 1987 and 1988 respectively.
But he neglects to report that power usage is up just 0.9 percent in 1989, according to NEP00L.
Because the economy in the region is slowing down, and utilities and customers are installing energy efficiency measures, the demand for energy 'is growing at a considerably 1
slower pace.
6.
Contrary to.Mr. Brown's assertion, the electricity 1
capacity situation is likely to change for the.better soon due-1 to increased conservation investments, and the growing i
i availability of independent cogeneration - and small power I
facilities.
l 7.
Six' of the Massachusetts utilities (and utilities in
-l I
, other New England st ates) are currently working collaboratively j
1 with the -Massachusetts Executive Office of Energy Resources, l
the Massachusetts Attorney General, and environmental groups to f
I design and implement energy efficiency programs for all j
j customer classes.
Those measures can be implemented within a i
six-month to two year time frame at one-third the cost of' l
l traditional power supply options.
In its 1987 report entitled i
" Power' to Spare," the New England Energy Policy Council fo und i
that,. at full efficiency, New England could be using less electri:ity and generating capacity than it is using today even with"the level and pace of economic growth predicted by the region's utilities by the year 2005.
A report prepared for the Boston Edison Company by a professor at Harvard University's Kennedy School of Government concluded that Boston Edison alone could save 1000 megawatts by the year 2000.
8.
With respect to cogeneration, developers bid projects totalling 11,763 megawatts in response to 8 utility l
l requests for proposals in 1987 and 1988, demonstrating the tremendous amount of energy ready to be developed in the region.
On August 15, 1989, Boston Edison Company received proposals for 48 projects representing a total of more than 2800 megawatts of generating capacity, in response to its solicitation for 200 megawatts.
i.
L
i 9.
Mr. Brown suggests that operating Seabrook would be-good for customers ' and businesses in the region.
The $5.6 billion current price tag for the reactor clearly makes it the most expensive energy option in New England.
Its steep cost te consumers would most likely result'in businesses leaving the region.
According to the New Hampshire Business and Industry Council 's s urvey, a substantial number of businesses said they would produce their own power if the plant came on line, and many said that they would leave the st ate.
It is also important to. note that NEP00L's data shows that the region will need a higher reserve margin with Seabrook operating than if it does not operate.
10..
planning for appropriate contingencies and proper maintenance scheduling are the key to an adequate supply of energy for the New England region.
Operating Seabrook unless each of the NRC. requirements are f ully met, is not in the public interest, and is most certainly not justified by New England's electricity supply needs.
I declare under penalty of
'ury that the foregoing is
/
true and correct.
l
~
e Sharon M. F ollard Executed on August 21, 1989.
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IN THE UNITED STATES COURT OF APPEALS-FOR THE DISTRICT OF COLUMBIA CIRCUIT
)
COMMONWEALTH OF MASSACHUSETTS,
)
et al.,
)
)
Petitioners,
)
)
v.
)
Nos. 89-1306
)
88-1821 UNITED STATES NUCLEAR REGULATORY,
)
88-1919 COMMISSION and the UNITED
)
88-1817 STATES OF AMERICA,
)
)
Respondents.
)
)
DECLARATION OF SHARON M.
POLLARD I, Sharon M. Pollard, hereby declare under the provisions of 28 U.S.C. 51'746 as follows:
1.
1 am the Secretary of the Executive Office of Energy Resources for the Commonwealth of Massachusetts.
I hold a cabinet-level position in the Administration of Governor Michael S. Dukakis.
2.
On May 22, 1989 I received and read the Declaration of Jr,mes D. Watkins, Secretary of Energy, filed in this case.
The Declaration is quite similar to testimony given on April 1 9 by W. Henson Moore, the Deputy Secretary of Energy thc U. S. Senate Committee on Energy and Natural Resources concerning electricity supply and demand in the Northeast region.
3.
Because, as I understand it, this Court will
-shortly rule on the Petitioners' Emergency Stay Motion
I concerning low power testing at the Seabrook Nuclear Power Plant, I have not had the opportunity to address specifically each point raised by Secretary Watkins.
However, the attached letter from me to Deputy Secretary Moore summarizes the responses of the Commonwealth of Massachusetts to the issues raised by both the Secretary and his Deputy.
4.
They are simply incorrect in arguing that " energy security, economic and environmental corrections" weigh against delay in Seabrook being issued a license.
Least-integrated planning, energy efficiency measures and cost load management will result 32 reliable, cost-effective and safe energy for New England, without the real environmental, safety and economic costs of operation of Seabrook.
I declare under penalty of per ry that the foregoing is true and correct.
e ouaron M. Po11 arf
~
Executed on May 23, 1989
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$NARON M.
POLLASO saca Tame 16171 727-4732 May 15, 1989 Honorable W.
Henson Moore Deputy Sec re tary U.S. Department of Energy i
Washington, DC 20585
Dear Deputy Secretary Moore,
I want ed to take this opportunity to respond to and clarify some of the issues you mentioned in your April 13, 1989 t e s t imo ny before the U.S. Senate Committee on Energy and Natural Resources' concerning electricity supply and demand in the Northeast region.
In your real to advocate for the commercial operation of the Seabrook nuclear plant, you made some arsertions that were simply false, a nd ignored other facts about New England 's need for electricity.
The most egregious " misstatement" in your teseisony occurs on page four where you refer to "... rolling blackouts which were experienced repeatedly in New England this past year..."
This assertion is false, and paints an incorrectly bleak picture of the current electric supply situation.
Contrary to your assertion, New England did not experi "ralling blac kouts" during the summer of 1988.
Accord director of power planning for the New England P o we r -
FOOL), there were only isolated, localized blacko to asifunctious in the distribution systes, not due te.
Is ad-wide capac ity deficiencies, as your states gests.
Whils we did not experience any rolling blackouts last y ee a r, we de share your concern about the region's energy supply situation.
That concern led the New England Governors' Conference, Inc. (NEGC) to study the issue and prepare a report on its findfags in late 1986.
The study assessed New England's electricity supply situation under base and contingency scenarios and concluded that supplies would be tight for the
D near future, but could be adequate for the l o n g-t e rm if a 1
serica of actions were taken regulators and immediately by utilities, state policy ma ke rs.
g The Massachusetts Executive Of fice of Energy Resources (E0ER) has been working since early 1987 to implement the recommendations of that report.
effort to establish "least cost Specifically, E0ER ha s led the integrated planning" sta t e 's Depart me nt of at the Public Utilities (DPU), which would j
clarify and streamline electric utiliti regulation in i
Massachusetts and prioritize those the most resource options that are economically and environmentally sound.
One of those options includes energy ef ficiency measures, which can be implemented within a six month to two year time f ra me ac one-third the cost of traditional powe r supply options.
In its 1987 repbrt entitled " Power to Spare,"
the New England Energy ef ficiency, New England couldPolicy Couacil found that, at full be using less electricity and generating capacity than it is using today even with the level and pace of economic growth predicted by the by the region's utilities year 2005.
Similarly, Edison Company by a professor ata report prepared for the Boston School of Government Harvard University's Kennedy concluded that Boston Edison alone i
save 1000 megawatts by the year 2000.
could potential, E0ER is working with the To fully realize this utilities in New England in c olla bo ra ti ve effort to design and implement a
reduce and be tter ma programs to these measures, nage elec tricity demand.
that E0ER believes along with additional resources, further use of cogeneration, natural gas power supplies, small and independent acd the creation of new electric utility generation will lead us towa rd a more reliable ene rgy f u ture.
Within the least-cost plants such as Seabrook are planning framework, nuclear powe r seen in a different end revealing light.
The $5.6 billion current clearly makes it the most price tag for toe reactor England.
Its steep cost expensive energy option in New to consumers would most in businesses leavfug the regioc.
likely result Hampshire Puainssa and Industry Ceuecil's sutveyAccording to the New number of yesinesses said ther would substertial
, a the pla produce their own po we r i f en on line, and many said that they would leave the state,-
slan importar,t to acte that NEP00L's data s ho ws that t on will need a higher reserve marFin with Seabrook op e ra ti a f.f it does not operate.
As I es sure you are aware, o tate's conce rn a bout the plancing, in addition to the adequacy of evacuation kept Seabrook from being cost and re li a bili t y issues, ha ve Commonwealth h of Ma s sac hu se t ts.whole-heartedly supported by the In conclusion, I would reitera t e. cha t New England is experiencing a tight short-term energy supply situation.
But by working ag g re s si ve ly with utilities to realize our
_ _, _ _ - - - ~ ~ - -
_,---n conservation and load management potential, and with a. sound least-cost in t eg ra t ed p3anning process, E0ER feels that we can develop enough reliable, cost effective and safe energy to maintaines competitive economy for New England, without exposing citizens of Ma s s ac hu se t t s to the risk, both economic and otherwise, of an operating Seabrook nuclear power plant.
Despite our respective positions on Seabrook--a matter which will ultimately be decided in the Federal Courts-- it would se r ve us, a nd the ra t ep ay e r s of New England we ll if we agroed to disagree on Seabrook and to move ahead cooperatively on alt ernatives whic h we need whether or not Seabrook ever operates.
I ha ve enclosed a copy of our State Annual Torecast of Energy Resources and a copy of the New England Gove rnors' Conference report for your information and wo uld be happy to provide any other information, about the state's effort in energy planning if you desire.
SAncerely, c
g Q
snaron M.
Pollar SecretaryhfEnergy?esources
'\\
Enclosures SMP/rs cc:
Socratary James D.
Wa t ki n s, U. S. Dep a r t me nt of Energy U.d,5 enate Committee en Erargy and Natu ra l Retsou rec t med Govern ors Conf erence, Inc.
N ad Energy Directors Ne aae Power Po si 3448C
___-_____a
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}Tg UM:
UNITED STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION 89 AUS 22 R2:02 crn DOCn !<
)
1,,
In the Matter of
)
Docket Nos. 50-443-OL P'k"
)
50-444-OL PUBLIC SERVICE COMPANY
)
(Emergency Planning Issues)
OF NEW HAMPSHIRE, EI AL.
)
)
(Seabrook Station, Units 1 and 2)
)
August 21, 1989
)
CERTIFICATE OF SERVICE I,
Stephen A. Jonas, hereby certify that on August 21, 1989, I made service of the within RESPONSE OF MASS AG TO APPLICANTS' APPLICATION FOR AN EXEMPTION FROM THE REQUIREMENT OF 10 C.F.R.
PART 50, APPENDIX E, SECTION IV.F.1.,
by First Class Mail, and by Federal Express as indicated by [*] and by hand delivery as indicated by (**]
to:
Ivan W.
Smith, Chairman Kenneth A. McCollom Atomic Safety & Licensing Board 1107 W.
Knapp St.
l U.S. Nuclear Regulatory Commission Stillwater, OK 74075 East. West Towers Suilding 4350 East West Highway Bethesda, MD 20814 Dr. Richard F. Cole Robert R.
Pierce, Esq.
Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Pethesda, MD 20814 Docketing and Service
- Thomas G. Dignan, Jr.
U.S. Nuclear Regulatory Commission Ropes & Gray Washington, DC 20555 Or.e International Place Boston, MA 02110
I(
L5l l
i L
- Sherwin E. Turk, Esq.
Richard Donovan i
- Gregory Berry, Esq.
FEMA Region 10 U.S. Nuclear Regulatory' Commission 130 228th Street, S.W.
L
, Office of.the. General Counsel Federal Regional Center 130 11555-Rockville Pike, 15th Floor Bothell, WA 98021-9796 Rockville,.MD 20852 H.; Joseph Flynn, Esq.
Atomic Safety & Licensing Assistant General Counsel Appeal Board Office of General Counsel U.S. Nuclear Regulatory Commission Federal Emergency Management Washington, DC 20555
. Agency-500 C Street, S.W.
Washington, DC 20472 Robert A.
Backus, Esq.
Atomic Safety & Licensing Board Backus, Meyer & Solomon U.S. Nuclear Regulatory Commission 116 Lowell Street Washington, DC 20555 4
P.O.
Box.516 Manchester, NH 03106
)
Jane Doughty Dianne Curran, Esq.
~
Seacoast Anti-Pollution League Harmon, Curran & Towsley I
Five Market Street Suite 430
.Portsmouth, NH 03801 2001 S Street, N.W.
Washington, DC 20009 Barbara St. Andre', Esq.
Judith Mizner, Esq.
f
~Kopelman & Paige, P.C.
79 State Street 77 Franklin Street Second Floor
' Boston, MA 02110 Newburyport, MA 01950 Charles P. Graham, Esq.
R.
Scott Hill-Whilton, Esq.
Murphy & Graham Lagoulis, Hill-Whilton & Rotondi 33 Low Street 79 State Street Newburyport, MA 01950 Newburyport, MA 01950
,)
Ashod N. Amirian, Esq.
Senator Gordon J..
Humphrey
)
-145 South Main Street U.S. Senate P.O.
Box 38 Washine on, DC 20510 Bradford, MA 01835 (Attni Tom Burack) 1 Senator Gordon J. Humphrey John P. Arnold, Attorney General
]
One Eagle Square, Suite 507 Office of the Attorney General Concord, NH 03301 25 Capitol Street (Attn:
Herb Boynton)
Concord, NH 03301 Phillip Ahrens, Esq.
William S. Lord Assistant Attorney General Board of Selectmen Department of the Attorney General Town Hall - Friend Street Augusta, ME 04333 Amesbury, MA 01913 l 1
Fe\\:
.-.=
's G. Paul Bollwerk, Chairman Alan S. Rosenthal Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing U.S. Nuclear Regulatory Commission Appeal Board East West Towers Building U.S. Nuclear Regulatory Commission 4350 East West Highway East West Towers Building Bethesda, MD 20814 4350 East West Highway Bethesda, MD 20814 Howard A. Wilber Atomic Safety & Licensing
- Kenneth M. Carr Appeal Board Chairman U.S.
U.S. Nuclear Regulatory Commission Nuclear Regulatory Commission East' West Towers Building 11555 Rockville Pike 4350 East West Highway Rockville, MD 20852 Bethesda, MD 208140555
- Thomas M. Roberts, Commissioner
- Kenneth C. Rogers, Commissioner U.S. Nuclear Regulatory Commission 11555 Rockville Pike U.S. Nuclear Regulatory Commission Rockville, MD 20852 11555 Rockville Pike Rockville, MD 20852
- James R. Curtiss, Commissioner U.S. Nuclear Regulatory Commission Dr. Emmeth A. Luebke 11555 Rockville Pike U.S.
Nuclear Regulatory Commission Rockville, MD 20852 5500 Friendship Boulevard Apartment 1923N Chevy Chase, MD 20815 Peter Bloch, Chairman Atomic Safety & Licensing Board Dr. Jerry Harbour Nuclear Regulatory Commission Atomic Safety & Licensing Board U.S.
U.S.
Washington, DC 20555 Nuclear Regulatory Commission Washington, DC D 20555 4
Respectfully submitted, JAME3 M. SHANNON ATTORNEY GENERAL j
A i
1 hen A.
nas Deputy Attorney General Chief, Public Protection Bureau Department of the Attorney General One Ashburton Place Boston, MA 02108 (617) 727-2200 Dated:
August 21, 1989