ML18003A413

Responds to NRC to G Hart Re Need for Power from Proposed Site.Believes Truth Is Missing from Administrative Proceedings.Claims Forecasts Have Been Consistently Too High

ML18003A413
Person / Time
Site:	Harris
Issue date:	01/27/1979
From:	Eddleman W AFFILIATION NOT ASSIGNED
To:	Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
NUDOCS 7902120190
Download: ML18003A413 (8)

Text

ACCESS I F ACIL 0-40 1

50-402 AUTH.NAME E DDLEMAN,N.

RECIP.NAMF GOSSICK,L.V.

REGULATORY INFORAATI.()N DI STR,I BUTI0,SYS2'EM (RI DS) 9021201 DOC.DATE~ 79/01/27 N

ARIZED~

NO D()CKET a hearon Harris Nuclear Power Plant, Unit,1, Carolina 05000400 Shearon Harris Nuclear.Power Plant, Unit 2, Carol.ina 05000401 Shearon Harris Nuclear Power Plant, Unit 3,. Carolina 05000402 AUTHOR AFFILIATIONS 0

.Private Cdtizen (or Affiliation Unknown)g(~(G~~

RECIPIENT AFFILIATION Office of the Executive Director for Operations SUBJECT!'Responds to NRC 781220 ltr to G Hart re need for power from proposed site. Believes truth is missing from administrative proceedings. Claims forecas.ts have, been, consistently too high.

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Lee U. Oossick I'xecutive Director USNRC for.. Opera'Cions,

~ R, 1, Box 183 Durham

'HC 2770$.""

. J'anuary 1979 1

Bear Lee Gosaick:

its. 7rederick Maage of Pittsboro HC has asked me Co reset'd to your letter of 12-20-78 to Qary Hart re the need, for power from Che aronosed Shearon Harris Nuclear Power Plant (dockets 50-lg00/J)03}.

I believe your letter explains well haw the NRC has followed its administrative orocedures on this issue.

But one important inpredient of good decisionmaking is missing from these nrdceedings so fax".

the truth, as evidenced by the actual growth of CP h L's oeak load. I sm a

CP k I, stockholder of long stand<.ng (before they eve> decided Co risk mo~e mone~r than the whole co@}many is worth on this one. nuclear aslant),

and I use figures su~plied by CP & L throughout C), is letter.

Befo>e 1970, CP h, L had been moducing electricity at steadily declining cost, both in constant dollars and in cu"~eat dolla. s.

Since that time, CP 6 L's rates have risexn faster Chan inflation.

(Goinciddh-

Cally, CP 5 Lts fixst nuclear @lant came on 3,ine in 1971, I believe.

The large daMtal costs of nuclear mlants have accounted for a la~pe'er-',,",

centage of rate incr eases granted CP & L since then, accordi ng to C'P 5 L'8"'

o'wn zeoorts to shareholders, e.g.

"about 3/4." of a 15'+ increase, and a 355 incre'ase "orinciyally associated with the costs of brin@in@ the Bruns'-',

wick '{nuclear) units on 1ine"<).

Since 1972, demand has grown as Cp h X

has proJected it only in one year

{3.972-'73, when the rate of 4ncree.se was about 6g).

Due to increas4ng electricity costs, market saturation a.nd other factors, CP h L demand has averaped only a 3.3;o annual inca"&se"'rom 1973-76.

So far in 1979, the.e has been no new beak, though C~(b; L

'as been a winter-peaking system in recent years.

Thus, CP h L and the ASLB and Che NC Public Utilities commis..$ vn forecasts have one Ching in common:

They have been consistently

wrong, consistently too high.

Let me take the two le.test for ecasts I know aa examples:

'In December

1978, NCPUC pro)ected 5.24 growth in 0>

hc X aeak,

and on that basis asked CP h L to show cause why its entire construction'hhedule siiould not be delayed a yeax.

CP 6 L Chat same rmnt1; ~ro jecte4 prowth at a 5.35/ rate.

Taking the 1975 weak of about 5,$ 80 f~;f, eke.vr of these forecasts would imoly annual increases of about 270 to 300 IM ver yeax.

Peaks would then pro]ect as follows:

1976 $390 to 5l~20 Mi'>

1977 $660 to"'$720 351',

1978 5930 to 6020

~6f, 1'>79 6200 to 6320 '%.

'Phe actual 1978 veal. >>as 5,60/

N'zT. It'is plain -that such forecasts are already leaving reality far behind.

Xmdsdk,indeed,, I wouldn't be surmised if 1979 peak growth is so small that the 1973-79 ave~ape comnound growth rate works out to only about 3C.

Hy pro)ections using 3.3~/ (actual) oeak demand growth rates show the first "need" for the first harris unit would then be in the e<v ly 1990s Co mid 199QEs, outside the time frame the ASLB considered.

This board is not charged simply to >>eigh the arguments raised> but tc",

f~.nd the truth, as shown by the requirement for hea~inps even when the. e.

are n'...ntervenors arguing against a utility's claims.

The ASLB has not performed this duty, and Che evidence Chat it has not is steadily q growing.

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'I Loe V. Gassicg, Jan 27-79 re Shyaron Harris plant, 'dackets 50-.$00/1/3 1

moreover,. sneaking as a working conservation manager and energy consultant;, I know of many mechanisms whereby signIficant; cuts in electric demand cnuld be made t'hroughout t;he CP 5 L system without loss of any function now delivered by elect;ricity.

Amang the most obvious 'nf t'hose are bett;er insulated wat'er heat;ers, morv effic"ent motors and a~vliances, and waste heat recovery.

Construct'ing the,'giearon Harris alan'~ at a cost of'b..2 billion will simoly force electric rat~s that much higher and make t;he ecanom~ cs a

~ conservation, insulation, solar space and water heat'. ng, and other alternative sources of'nergy t}>at much more attractive.

'I

'2herefa~e it

< s my cans'I dered view t'hat the 3.onp term growth of demsnd on 'the CP

& L system w<jj be even jess Chan C}ie 1973-78 rate, i.e. 1ess than 3.3'mg annusl.jy.

)le shall see what actually hannens.

T may be wrang, and CP h L's experts may be -ight f'r t'e f5,-rst time in same years (nea>ly a decade).

Gut I want

+o emphasize the costs thev rnnt~~mue ta be w~nng.

Unnecessary construction on t;he Harris, facility cauld lead to

" nc eased electric bills long befo~e any sawer can be delivered, c}ue Co Construct~on 1lork '.n Progress charges.

anoraved, such. charges might; begin C}ds yea and continue into Che nid-or late 1980s wit;haut; any electricity be'ng delivered.

Ynreover, the enfire Ha ris aslant, if built, would overload the CP

& L system with baseload capacity.

Counting 700 lPrie at the Robinson nuclear aslant

and, 821 Pde at; each Brunswick nuclear unit, we have 23Jg2 l%Je committed baseload

capacity, not much less Cnan t;he existing annual base load (at the early morning }:ours when Che lowest demand on the system is reached.

)

Xf 3600 il'0e from the Harris @lant were added to t'hat, Chore Could be 59/2 f4e of baseload capacity in the 1980s on a system that has yet Ca noak above 5605vie for tot;a1 P~AK demand. Ta require near~y 60QO jjjle of'asejnad cauacktv imnlies a system made much more efficient through much greater baseRmzR loads, or a system neak of araund 12000-15000 }~~le. Such projections of system ~eak were mhde (at; an. 11+~o annual growth rate) in the earliest; pr o~osajs E'or the.}}arris slant,. but these have lang since been abandoned as unrealistic. tlhat t}sis means is Chat the jiar. is plant is built nn schedule, its capacity cannot be fu3.jy utilized. as a base load. Yet high caoacit;y factor s are Che basis af nuclear no"er ecc~nomics -- the tremendous ca~ital investment in nuclea olants must be spread among a large number of'~r6< t;c keep t}]e elect~<city costs cawaetitive. Zf the Harris slant is built when Chere is no need for such an enormous baselaad

caoacity, it; w'.ll actually force elect. ic b'lls even higher c}ue t;o be<nt;

~ nefficiently used. There is al.sn "}.e matter nf ht p~er custcmer charges Co nrovide a rate of return nn the 8}..2 biU.ian investment. Yiorenver thoro is evidence leakdd by 0" k L cost accnunV ng anc} other personnel Chat the ~c tuaj costs ma>r naw be between 46 anc} <" b"'11~ nn. For all these reasons Che Harris nlanC wijl daam t.tself'conomically by driv~ ny, un e1ectric ~ates w'hich will lead vennjo t;o turn to ot;her sources of energy and ol.iminate t}~e "need" far the Harris riant'. The~e could be f'ew worse financial disasters for a comnany Chan Ca huijd one plant warth ma-e C}ian all the rest of the comoany is, and f>> nd that't ib nat needed. J. would like to add these comments on at})er issues: Xt is likely'};e costs af t'e Barris @lant will exceed i.t;s benefit;s in any case due Co 'C}ce tremendous rate of cost increases ~ n nuclear vower njants. There $ s as yet; no snlutinn to the nrablem of nuclear wast;e. The ALAP. -J}77 decks<< n renuir:ng realistic olanh Co resolve all safety issues during construct" an has yet Cn be applied to tho Harris plant and may halt construction wk}ten it is aenlied (the sooner the better-why risk building, an unsafe z>lankt at }'reat cost'?).

. 0 ve 0 s i ~~ wa > >"<w '>>." We s "+g-~ ~ *< 1 K h, 4"~ rt ,1 I l

l Lee V. Goss'lck, JW>> 27-79 ze Shearon Harris~ant, dockets $0-,F00/Lg03 Thez e are ~any problems associated with long-term operation of large

reactors, e,gl "green grunge" in steam genera'Cors, steam genexator, Cube fa.".lures, stress Co cripes, vessels and welds from heat, pressure, radiate>> n, corzos" on etc, inatrunentx and electx ical fait.ures due Cc. heat, mc)store, pressure etc.

Any of these can require extensive repairs and long nutages for refitting. Thus we have operating experience ,telling us Chese p1ants 'wi11 have more problems than had 'been.-thought. and of course there is the issue of racU.etio'n protection. The 'riarris ~i plant is rrojected to release a whole-body dose of about 22.6 mrem/j'ear at the riant boundary. Uith the lega1 limit down to 2$ mre/year and Che Z~.6 be4np. based. on perfect operation, no abnormal

xeleases, the public, has reason for serious concern.

If, in Che light of new ev'"dence such as the Yancuso-Stewart-Kneale studies, radiation motect$.nh limits must be lowexed yet again,. the pub1ic may face excessive exposure froei Che Barris @lant. Nore importantly, experts such as Br. Thomas

Elleman,

,head of Che Nuclear T.'ngineering Bepartment at N'Q State, University, bell eve lower expo'sure standards for workers ( -80 mz cia/veer) wou3.Q fn~ce= the nuclea~ ."ndu<try to shut down entire'. This is a real, zoos'sibility' Chat is not being taken into account 3n current licensing. These additional issues give me even more reason to believe Chat %he Sheaxon Barr is nuclear power plant is an unnecessazy risk to Che public, the stockholders and, the taxpayers, Under these circumstances continuing investment in it is at best ill-advised. I have already petitioned the Commissioners of'he HBC to stop construction and reopen hearinH;s on this alan" for many reasons, including several cited. in this letter, I have yet to ~eceive a z esponse, oven a notification Chat my petitions have been received. I woulcj appreciate knowing what is being done with Che..e netitions or whether they have been lost in Che mai3.s,(I can,supply'omics). There <.s one last point I'd like Co make: the A~peal,Baard denied the <ntervenor s any further, hear" ngs on need for mower because the.new evidence (of 1978) favored their oositiOn, thus they were not."entit"ed Co cross-examine it. This view is ridiculous. It says Chat, because the

ntervenors may be right, they cannot have a hearing Co, deter<Aine if they

're, (Of course, if thev were shown t,o be wrong by the evidence, Che - same result would follow. IIoreover, as I~ve pointed out, the evidence continues to show the CP 5 L and HRC.Staff poaftions axe'wrong.) This is heads-they-win, tails-you-lose decisionmaking and there is too much = of Xtz going on in the NRQ. I am heax'tened by such sensible decisions as %he rejection of much of the "Basmussen ressort" ~ In these decisions" the facts have been recongnized. But in many others, e.g. this Shearon Harris case, the facts are still on the sidelines. h L Iooking at the situation at any p<.ven C" ~~ in this Shearon Haxrf s case, I'm su~e an+one could agree that Chere are many good arguments on both sides. But looked at ovex time, CP 6 L>s arguments aare seen to be collapsing under the weight of facts, although slowly and reluc-tantly. I submit Chat construction of this project should be. halted iamedlately so Chat consideration of the facts, when they finally prevail, will not be orevented by Che economic losses that. gould',be < nvolved in shutting down a aslant with billions invested in it. A loSs, of Che F500 million already invested is substantial, but,if the plant is not needed what is invo'1ved is not a $500 mi11iozz loss, but a savings 'f $3,7 bi11ion in capital and much more in electric bi11s ih,the-future.

Moreover, aa a shareholder I know Cp 6 L can survive a /$00 mild.9.on

loss, A g3 b51lion loss would bankrupt us, most likely-, wiping out all the shareholders~

investments. I Chink tire benefits of stooping construction now outweigh the coats by a substantial margin, giv'en Chb,. enormous losses possible if the +lant is built apd..not needed or not f'ufo' issuable. ...,i~/'ig ~q /J/g

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