ML19274D067

Expresses Util'S Opinion That Policy Consideration Favor a Decision to Use Existing ASLB Process to Resolve the Alternate Site Question.Rejects Preparation & Recirculation of Suppl Environ Statement

ML19274D067
Person / Time
Site:	05000471
Issue date:	12/08/1978
From:	Rhonda Butler BOSTON EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19274D066	List: ML19274D065 ML19274D067
References
NUDOCS 7901090314
Download: ML19274D067 (3)

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Bo?.TCN Eo:SCN COMPANY Harold Denton December 8,1978 Page Two ..

the hign degree of dilligence and thoroughness that has gone into their effort.

2. Capital Cost .

Invoking the SES process will delay construction and operation of Pilgrim 2 by at least three months. The cost of the project will increase by $15 million dollars for each month that the project is pushed back. Thus a three month delay will cause a capital cost in-crease of at least $45 million. This cost will ultimately be borne by the customers of the joint owners of Pilgrim 2. We believe the costs to the people of New England of invoking this unnecessary SES recirculation process far outweigh the benefits.

3. Operating Costs The delay in operation of Pilgrim 2 will require unnecessary, costly reliance on burning of oil (if plants and fuel are available) to pro-vide the power that Pilgrim 2 would produce if on line. Pilgrim 2 will save approximately 750,000 barrels of ofi per month. Thus a delay of at least 3 nunths in commercial operation will result in the unnecessary burning of at least 2k million barrels of oil. This will have two important consequences. First, several million dollars in fuel adjustment charges will be passed on directly to the residents of New En gl and. We do not feel our customers should be required to bear this cost without receiving some benefit in exchange. Second, since most of New England's fuel oil is imported (presently ninety percent), most of the cil burned to supply replacement power would come from foreign suppliers; this is clearly contrary to the national colicy to reduce dependence on foreign oil.

4. Actual Merits of the Site are Not in Ouestion The merits of the Pilgrim site as an economical, environmentally sound location for Pilgrim 2 are not in question. No party to the pro-ceeding has proposed an alternate site. No member of the public has come forward with a superior site in the five years since docketing.

The recent NRC Staff analysis, which has not identified any obviously superior site, simply confirms the conclusion of the Staff analysis originally presented in the ASLB hearings.

79010903fy

8."'3 T O N DISCN COMPANY Harold Denton December 8,1978 -~

Page Three Nerefore, as we have previously indicated in regard to legal considerations, t e feel that policy considerations also militate in favor of utilizing the existing ASLB process to resolve the alternate sites cuestion. It is neither '

necessary, nor in the public interest, to employ the SES process.

Very truly yours ,

(fklV/!/.

WRG/mam cc: William Dircks (NRC)

Edward Soland (lj.S. House of Rep's)

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Harold Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

Mr. William J. Dircks of the NRC recently sent a letter to Congressmen Edward Boland (11/21/78, attached). This letter contained further information in regard to the NRC's tentative decision to invoke the Supplementary Environ-mental Statement (SES) process for the Pilgrim 2 alternate sites review. In that letter Mr. Dircks stated that Boston Edison had presented NRC with a memorandum explaining thTt the SES is legally unnecessary. He also alleged that Boston Edison had ' tiled to present any argument regarding the " policy" aspects of the decision m ,;repare and recirculate the SES. Boston Edison would like to set the record straight on the matter of policy.

First, in the 10/12/78 meeting between Boston Edison and NRC, detaileo discussions were held concerning both the legal and policy aspects of the SES question. At the conclusion of the meeting, it was agreed that Boston Edison would provide further input on legal questions by submitting a legal memorandum for consideration by yourself and NRC Legal Staff. Thus, the reason for the absence of policy arguments in our submitted memorandum was that it was agreed during our meeting with you that the subject of the document woulc be a legal argument. The lack of a discussion of policy questions in this memorandum should not be interpreted to mean there are no policy arguments against invoking the SES process.

Boston Edison and the thirteen other joint owners of Pilgrim 2 are convinced that policy considerations favor a decision not to prepare and recirculate an SES. These arguments are of several types, and are set forth below:

1. Existing Procedures are Adequate under NEPA Special steps such as SES recirculation need not be taken to demon-strate that NRC is implementing NEPA "to the fullest extent possible" because NRC procedures already in place conform to the letter and the spirit of NEPA. The existing NRC public hearing process for Pilgrim 2 already affords parties and the public an opportunity to become informed and comment upon the NRC Staff review of alternative sitas.

Thus, because of the existence of the hearing process parties and the public will not be deprived of the opportunity to review and comment upon the NRC Staff alternate sites review. The ASL? hearing process till also afford the "RC Staff an .Wequate opportunity to set forth