ML19330C560
| ML19330C560 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, Allens Creek  |
| Issue date: | 08/04/1980 |
| From: | Woodson H HOUSTON LIGHTING & POWER CO., TEXAS TECH UNIV., LUBBOCK, TX |
| To: | |
| Shared Package | |
| ML19330C554 | List: |
| References | |
| ISSUANCES-CP, NUDOCS 8008080500 | |
| Download: ML19330C560 (14) | |
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Affidavit of Dr. Herbert H. Woodson in Support of Motion for Summary Disposition I. As indicated in my curriculum vitae which is at-tached hereto, I serve as the Director of the Center for Energy Studies at The University of Texas. In this capacity I am involved in a wide range of energy related projects and I am familiar with.the various energy sources such as biomass conversion, which are best described as potential future energy sources. I have examined the 1974 Project Independence report cited by Mr. Potthoff in his contention. That report established that further research on this topic was needed to establish the commercial liahility of biomass conversion.
I have examined research data that has become available since the Project Independence report was prepared in 1974 and the conclusion to date is clear--marine biomass is not I
- now a commercially viable energy source for the production l of electricity. Substantial research and development must be undertaken, add technological problems overcome, before l
this energy source can be considered a viable alternative. ;
That it can become viable as an alternate energy source is )
not a certainty; and, in fact, its practical viability is highly doubtful.
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As an example, two recent reports by the Electric Power Research Institute have dealt specifically with marine biomass as an energy resource. The two studies are titled "EPRI/GRI Workshop on Biomass Resources and Conversion", WS 78-89,. Electric Power Research Institute, Palo Alto, CA.,
- July, 1979 (hereinafter " Reference 1"); and " Comparative Assessment of Marine Biomass Materials", AF-ll69, prepared l byl Science Applications Inc. for Electric Power Research Institute, Palo Alto, CA., September, 1979 (hereinafter
" Reference 2"). In Reference 1 on page 11-1, the statement is'made that:
...The technological and economic feasibility of
-marine energy farming remain unproven; however, the prospect is intriguing in the face of the current energy crises.
So far, we lack the basic information to develop a marine source of biomass. Some basic information is available, but very little research has been directed tcward marine organisms as biomass energy sources...."
Reference 2 at page 1-3 expresses the same senti-ment'more fully:
"Overall, we are still in the basic research stage of developing marine biomass resourcos. The present study is intended to help fill the most obvious gap in our knowledge: the lack of a comparative assessment of. marine biomass-source materials. There are other obvious. inadequacies, however. For instance, little is known about the growth dependence of marine plants on major vari- !
. ables such as water temperature, nutrient level, !
and plant density. Negative. influences such as !
- l disease, predators, and weather will undoubtedly play a' major role in determining the feasibility 4
of any biomass conversion program. The following list indicates some other major areas of uncer-tainty:
. Growth dependence on plant spacing;
.. Growth dependence on nutrients;
. Growth dependence .cn1 substrate depth;
. Growth dependence on water tamperature;
.. Susceptibility to disease;
. Susceptibility to weather change;
. Life' cycle."
The information contained in the EPRI reports is useful in demonstrating the numerous reasons why a marine biomass farm is not'.a viable alternative for ACNGS.
II .- The 100,000 acre farm postulated by the inter-venor, based on information from the Project Independence report, cannot possibly-produce the energy equivalent of Allens Creek.
In his dissent in ALAB-590, Dr. Buck asserts that 12 the 27x10 BTU /yr. of marine biomass production on 100,000 acres' claimed in the Project Independence report is insuffi-cient by a factor of about 4 to replace the Allens Creek Nuclear Generating plant of 1,200 MWe rating. I agree with
. this assessment with'the caution that when preprocessing energy requirements are taken-into account, the net energy
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yield from marine biomass will be reduced substantially (Reference 2, Appendix C); hence, even Dr. Buck's estimation of the acreage required may be too low.
III. Utilizing the conservative estimates front Reference 2 of the anticipated energy conversion potential of a marine biomass farm producing. crops with the highest energy yield obtainable from a marine plant which can be grown on a large scale, a marine biomass farm o'f over 900 square miles (576,000 acres) would be required to produce the energy equivalent of the ACNGS.
Assuming that the ACNGS unit is rated 1,200 MWe and operates at a capacity factor of 65 percent with a heat rate of 10,000 BTU /KWH, a yearly thermal input of about 12 70x10 BTU is required. In Reference 2 the marine biomass production potential of Texas Gulf coastal waters from the low water mark to the 200 mile linit of the Fisheries Con-9 servation Zone is, on the average, about 78x10 BTU / square 12 mile-year. Thus, _to produce the 70x10 BTU per year needed to replace ACNGS, about 900 square miles or 576,000 acres are required. Note, however, that this is on the basis of the total energy' content of the marine biomass without any allowance for the preprocessing activities of harvesting, transportation, drying, size reduction and other processing needed to produce useful energy.
When these preprocessing activities are taken into account, as described in Section 10 of Reference 2 and sum-marized in Table 10-2 on page 10-4, the maximum net energy recoverable by biological processes as methane is about 60%.
This raises the estimated area needed from 900 square miles (576,000 acres) to 1,500 square miles (960,000 acres) .
If energy is to be produced by self-sustained direct combustion, Table 10-2 of Reference 2 shows that, at best, 25% of the energy is recoverable, raising the 900 to 3,600 square miles (2,300,000 acres).
It is clear that a much larger acreage than cited in the Project Independence report is needed, and that there is substantial uncertainty as to exactly how much acreage J
would be required.
IV. No biomass farm of this size or a significant fraction of this size is now in existence or known to be under development.
As described in Section 12 of Reference 1, a biological test farm has been designed and was deployed in September 1978 off the coast of California. The test farm 2
has an area of almost 10,000 ft. or about one-fifth of an acre.
This test farm, which is more than 1,000,000 times smaller than that needed to replace ACNGS, is still only l
experimental and is intended to provide data on nutrient and other requirements necessary to produce kelp and how the production rate varies with many' parameters. This test farm can in'no way be classified as a prototype for a practical marine biomass energy farm.
V. Current estimates of the cost of operating a large scale biomass farm and converting its products to a fuel usable in a commercial size power plant demonstrate that the cost of marine biomass is nowhere near commercially viable.
Mission analyses-*/ have been performed to identify activities needed and estimate costs associated with the production of energy in a variety of biomass systems. The results of mission analyses reported in Reference 1 and smnmarized in Table 14-2 on page 14-5 include two systems involving marine biomass. The costs are cited in 1977 dollars for operation in 1985 and are: 20.7 dollars /million BTU for substitute natural gas (SNG) from kelp; and 26.9 dollars /million BTU for ethanol from algae. A gas fired power plant burning fuel at $20 per million BTU would cause
-*/ Mission analyses.are detailed examinations of the various component costs in commercializing any particular technology.
a fuel charge of roughly $2.00 per KWH. This figure, in 1977 dollars, should be compared with national average production costs of nuclear plants in 1977 which was 1.5 cents per KWH. These costs are clearly not competitive by a wide margin with ACNGS for production of electricity.
VI. If marine biomass is ever to become commercially viable as a large-scale energj source, it must go through research, development and demonstration.
Starting from the current state of knowledge in the field, as described in Reference 1, Sections 11 and 12, research needs to be continued to learn the conditions under which different species of marine biomas will grow at the needed rate. The number of species is large and the growing conditions involve a number of variables. For example, it J
bas been demonstrated that natural ocean currents do not
. bring nutrients to the plants fast anough for satisfactory growth rates. Hence artificial upwelling is necessary and this involves the mechanical pumping of nitrogen-rich waters to the surface from 500 to 1,500 foot depths. The rate of upwelling and the depth from which it must be done need to be determined experimentally in the ocean. A complicating factor in tnis study, as described in Reference 1, Section 12, page-12-8, is that a surface current of more than 0.1 l
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y knot will carry nutrients away from the plants - before the nutrients can be consumed; therefore, some sort of shelter from surface currents is required. To determine how up-welling rate, surface currents, temperature, wind and other factors interact to affect plant growth throughout the year will require at least five years and probably longer.
. As indicated in Reference 1, Section 12, a bio-logical test farm necessary to accomodate this research would involve a surface area of about 100 feet on a side or about one-fourth of an acre.
The information gathered in the research program would then have to be used to design a pilot-scale farm to demonstrate that the conditions found in the research pro-l gram to be necessary for adequate growth rates could actu-ally be achieved on a large enough scale to support a com-mercial operation. This would require several acres with all of the upwelling, anchoring and sheltering equipment needed to achieve the research results over this larger acreage.
At least ten years would be needed to demonstrate t.he growth, harvesting and processing on this several-acre pilot-plant scale.
Following success on the pilot-plant scale, a demonstration farm of several thousand acres would be needed to actually demonstrate all aspects of the operation as practical, economical, and environmentally acceptable. A demonstratien-farm and processing plant and system would re-quire at least 15 years for design, construction, start-up and operation before~the results would be widely accepted.
Following these 30 years of research, development and demonstration,_a commercial scale plant of around one million acres could be started; and, it is expected that fer all the various activities involved, the permitting would require a substantial amount of' time. As a consequence, it is expected that a commercial-scale marine biomass energy plant-would take at least an additional ten years for de-sign, permitting, construction and start-up.
-On the basis of the foregoing, it is clear that a ,
commercial-scale marine bicmass energy production system could not possibly be available until the year 2020 at the very earliest, if ever.
VII. There. currently appears to be no reasonable means
.of obtaining title to or use of the substantial amount of sea' space required to build a marine biomass farm sufficient to. replace ACNGS.
In Reference 2, Section 9, the total surface area between the low-water mark and the 200 mile Fisheries Con-servation Zone contained in-the' Gulf coastal waters from the
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biomass considered attractive as energy sources contain
. considerable sulfur. Reference 1, Section 6 indicates that.
for most speciesLthe ash is about 20 to 30 percent of the dry weight and the ash can contain aus much as 40 percent sulfur compounds. Furthermore, the ash contains significant amounts of manganese,. bromine, and arsenic, as well as many other worrisome elements. With such ash composition, it is likely that EPA would classify the ash as hazardous, if not toxic, waste and make it difficult and expensive to dispose of. Moreover, if the biomass solids are burned directly for energy production, the combustion gases will likely need to be scrubbed for both particulate and noxious gases to meet emission requirements.
IX. Conclusion. A large scale marine biomass farm is
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not now a viable alternative for all the reasons specified above. It is still a remote and speculative alternative energy source whose availability is not assured, whose' economics are not assured and whose environmental impacts
. appear to be far greater than those of ACNGS.
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Jr Dr. Herbert H. W odson o Curriculum Vitae
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Dr. Herbert H..Woodson, a native of Texas, attended
the Massachusetts' Institute of Technology after serving in the U.S._ Navy during World War II.. He received his S.B..and S.M. degrees in electrical engineering at M.I.T. in 1952.
After two years as an electrical engineer at the Naval Ordnance Laboratory in Silver Spring, Maryland, he returned
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to the graduate-school at M.I.T., receiving the Sc.D.' degree in 1956.- He then joined the M.I.T. faculty as Assistant
' Professor in Electrical Engineering. He was promoted in j- 1960 to' Associate Professor; in 1964, to Professor; and in 1967 he was appointed Philip Sporn Professor of Energy Pro-cessing. From July 1965 to July 1966, Dr. Woodson was on sabbatical' leave working as a staff electrical engineer in
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' -the Electrical Engineering Division of the American Electric Power Service Company in New York City.
In 1968, Dr. Woodson established and was the first 7
Director of the Electric Power Systems Engineering Laboratory at M.I.T.
In September 1971 he left M.I.T. to take over duties as Professor and Chairman of Electrical Engineering at The-
University of Texas at Austin. In January 1974 he was appointed Director.of the newly founded Center for Energy Studies at UT. The center is,an interdisciplinary research organization that carries 'cni,a diverse array of energy-related projects.
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Dr. Woodson's professional activities are primarily in electric power systems engineering and electromechanics.
He is a registered professional engineer in Texas and Massachusetts and holds three patents. A teacher for more than 20 years, he has written many papers and coauthored two textbooks, Electromechanical Dynamics (with J. R. Melcher) and Electromechanical Enercy Conversion (with D. C. White).
Dr. Woodson nas been a consultant for 14 firms, including a number of electric utilities and electric power aquipment manufacturers, and has served on several advisory panels for industry and government, including service on the Comanche Peak Design Review Team for Texas Utilities Company.
He is a Past President of the Power Engineering Society of the Institute of Electrical and Electronics Engineers and he is a Fellow of IEEE. He is a member of the National Academy of Engineering and of a number of other professional and honorary organizations.
Active in community affairs, Dr. Woodson is Vice President for Economic Development of the Austin Chamber of Commerce and a member of the Austin Electric Utility Commission, an advisory body appointed by the Austin City Council.
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UNITED STATES OF AMERICA g, 6 0 NUCLEAR REGULATORY COMMISSION --
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30G BEFORE THE ATOMIC SAFETY AND LICENSING BOAR $, offge ci the S,8C , i,-
pocketk1! 1 Err.c3 In the Matter of , S g
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cl, j j y HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 5
(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE j
I hereby certify that copies of the foregoing Applicant's Motion for Summary Disposition of Potthoff Con-tantion 6, Applicant's Motion for Summary Disposition of TexPirg Additional Contention 50, and Applicant's Response to Marrack's Motions.to Compel Answers to Interrogatories in the above-captioned proceeding were served on the follow-ing by deposit in the United States mail, postage prepaid, or by hand-delivery this 4th day of August, 1980.
Sheldon J. Wolfe, Esq., Chairm'an Hon. Charles J. Dusek Atomic Safety and Licensic.g Mayor, City of Wallis Board Panel.. P. O. Box 312 U.S. Nuclear Regulatory Commission Wallis, Texas 77485
-Washington, D. C. 20555 Hon. Leroy H. Grebe Dr. E. Leonard Cheatum County Judge, Austin County Route'3, Box 350A P. O. Box 99 Watkinsville, Georgia 30677 Bellville, Texas 77418 i
Mr. Gustave A. Linenberger Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory Commissic l
U.S. Nuclear Regulatory Commission Washington, D. C. 20555 i Washington,'D. C. 20555 l Atomic Safety and Licensing Mr. Chase R. Stephens. Appeal Board Docketing and Service Section U.S. Nuclear Regulatory Commissic
. Office of the Secretary Washington, D. C. 20555 l of the Commission '
l U.S. Nuclear Regulatory Commission Steve Schinki, Esq.
l Washington, D. C. 20555 Staff Counsel
( U.S. Nuclear Regulatory Commissic L Richard Lowerre, Esq. Washington, D. C. 20555' l Assistant Attorney General for the State of Texas.
-P. O. Box 12548 Capitol Station Austin, Texas 78711
Bryan L. Baker D. Marrack 1118 Montrose 420 Mulberry Lane Houston, Texas 77019 Bellaire, Texas 77401 J.'. Morgan Bishop Brenda McCorkle 11418 Oak Spring 6140 Darnell Houston, Texas 77043 Houston, Texas 77074 Stephen A. Doggett W. Matthew Perrenod P. O. Box 592 4070 Merrick Rosenberg, Texas 77471 Houston, Texas 77025 John F. Doherty -
F. H. Potthoff ,
4327 Alconbury 7200 Shady Villa, No. 110 Houston, Texas 77021- Houston, Texas 77055 Carro Hinderstein. Wayne E. Rentfro 609 Fannin, Suite 521 P. O. Box 1335 Houston, Texas 77001 Rosenberg, Texas 77471 James M. Scott 13935 Ivy Mount Sugar Land, Texas 77478
. William Schuessler
. 5810 Darnell Houston, Texas 77074 Darrell Hancock 7 %( '