ML19345G498

Responses to Joint Intervenors' Interrogatories 1-1 Through 2-16 Re Contentions 1 & 2 Alleging Util Has Not Shown Facility Operation Is in Public Interest.Affidavits & Certificate of Svc Encl.Related Correspondence

ML19345G498
Person / Time
Site:	Waterford
Issue date:	03/25/1981
From:	LOUISIANA POWER & LIGHT CO.
To:	AFFILIATION NOT ASSIGNED
References
NUDOCS 8104070390
Download: ML19345G498 (99)

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. , ; pen .orN' March 25, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinc Board In the Matter of )

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LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

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(Waterford Steam Electric Station, )

Unit 3) )

APPLICANT'S RESPONSES TO /M JOINT INTERVENORS' INTERROGATORIES /'Ii bh '

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LOUISIANA POWER & LIGHT COMPANY RESPONSES TO JOINT INTERVENOR' S INTERROGATORIES ON CONTENTIONS ONE AND TWO Introduction to Responses This transmittal constitues Louisiana Power & Light Company's responses to the interrogatories filed by the Joint Intervenors under Contentions One and Two. These two contentions, in brief, allege that LP&L has not demonstrated that the operation of Waterford 3 is in the public interest. The contentions rest on the Intervenor's disagreement with portions of the method LP&L uses to project power demand, its reserve capacity policy, its estimates of fuel and decommissioning costs, as well as the estimated capacity factor for Waterford 3. In the Waterford 3 Operating License Stage Environmental Report, Amendment No. 2, dated October,1980, LP&L showed that the timely operation of Waterford 3 would result in not only a very substantial savings to the public, but also a significant improvement to the reliability of the service to LP&L's customers.

The Joint Intervenor's contentions and interrogatories were based on the initial submittal of the Operating License Stage Environmental Report, published in September,1978. That submittal discussed the demand forecast methodology used in the late 1960's and early 1970's , which was the period when LP6L undertook the planning for the construction and operation of Waterford 3.

However, since the mid-1970's , in order to more accurately predict energy demands for the increasingly complex economic and social environment, LP6L has refined its forecast methodology through the utilization of an econometric model. This model is comprised of a set of antlytical and structural models designed to provide a forecast of megawatt hour consumption by class of service and megawatt peak demand. 'this projection methodology has replaced the earlier approach, and has been a

completely described in Amendment No. 2. It is now the metnodology applicable as the basis for responding to the interrogatories concerned with electrical energy usage and forecasting approaches.

In addition, other changes since the mid-1970's have occurred in the economic and regulatory environment and in power generation technology.

As discussed in Amendment No. 2, these changes have stimulated LP&L to to initiate reassessment of its established reserve margin, to attempt improve its future fuel mix for greater system reliability, and to continue to manage its system for the greatest possible cost savings to its customers. The interrogatory responses given below have been prepared within this context, rather than that reflecting the earlier conditions described in the 1978 submittal of the Environmental Report.

Question No.

1-1 What do you calculate to be the percentage difference between actual usage and forecasted power demand (peak loads) of LP and L contained in the following data sources:

a) Estimated peak loads for 1970-1979 from " Questions and Answers to Environmental Report" dated June 11, 1971 (Exhibit 4: AEC Docket 50-382, 50-383).

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b) Actual peak load expressed in ER Table 1.1-10, and including peakloads for 1978 and 1979 ('79 summer peak July 5).

Response

72e comparison is as follows:

' Estimate Actual Peak Percent Year Peak Demand (MW) Demand (MW) Deviation 1970 - 1,872 1971 2,3 10 2,084 9.78 1972 2,605 2,389 8.29 1973 2,936 2,563 12.70 1974 3,310 2,676 19.15 1975 3,730 2,883 22.71 4,205 3,180 24.38 1976 4,7 40 3.5 15 25.8 4 1977-1978 5.342 3,852 27.89 1979 6,0 20 4,091 32.04 l

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I Question No.

1-2 What reasons do you gave (sic) for the discrepancy in j

actual peaks and the percentage difference, if any?

Response

There will always be some variation between the actual and f projected peak loads. for a utility system, due to the uncertainties within the estimation process. Some of these l uncertainties can be attributed to data bases, projection methodologies and exogenous variables. In the case of LP&L, *.wo major factors contributed to the variation that l

' oce ui between actual and projected peak demands for the tima period in Question No. 1-1: (1) information contained in the data base; and (2) exogenous economic forces during th e 1970 's .

In the initial planning phases for Waterford 3, the data base used in developing LP&L's electrical load forecasts consisted of the historical load of the 1960's which showed a load growth in the LPSL system exceeding 10 percent per year. The utilization of these relatively hign growth

. trends for load forecasting purposes for the 1970's produced a projection of continued high peak demand levels. However, the economic recession of 1973 to 1975

' and the sharp increases in the price of oil during the 1970's induced a decline in the demand for electricity, which contributed significantly to the variations that exist between the projected and the actual peak demands.

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l Question No.

I 1-3 What reason, if any, can you give that future projections of power demands as shown in ER Table 1.13 (sic) will not be subject to similar discrepancies? ,-

Res ponse l

As noted in the introduction to these responses, the methodology utilized in forecasting electric power demands within the LP&L service area has undergone significant changes since the initial transmittal of the OLZ1. 2e l response to Question No.1-2 details the primary f actors ,

which contributed to the variations between the predicted and actual electric power usage within LP&L's service area. These pradictions utilized LP&L's former forecast methodology which consisted of projecting electric power i

demand based on previous usage and their judgement of future business potential. However, during the 1970's ,

electric power usage became increasingly affected by several exogenous factors and LP&L realized that their former forecasting technique was inadequate to address these f actors. It was this realization that led LP&L to adopt an econometric model (as developed in 1979 by Data l

l Resources, Inc) which could incorporate there f actors.

The utilization of this model is expected to reduce the variation between actual and forecasted electric power I

usage within the LP&L service area. The following paragraphs describe the various model components and the f actors utilized in developing a forecaat.

The LP&L Load Forecasting System consists of three major components: the Service Area Economic Model; the Energy Model; and the Peak Demand Model. These- three components or submodels form a model structure, which determines the peak demand for the LP&L service area. The Service Area Model is an economic and demographic model of the ares LP&L server, and the product of this model is the outlook for the local economy in the area LP&L serves. The second model, the Energy Model, translates .the outlook of the t

local economy,' assumptions concerning local weather conditions, energy prices, energy supply constraints and technological factors, into the expected future consumption of electricity by major user classes: residential, commercial, industrial and othtr. The third model in the system,,the Peak Demand Model, calculates the expected peak demand based on the contribution to peak demand of the weather sensitive components and base load requirements of each user class.

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The model, as previously stated, utilizes an econometric approach for the analysis of both historical data and forecasts. The analysis consists of determining factors or predictors which correlate with experience changes in electricity usages.

Since energy usage is dependent on economic activity, the prediction of future customer energy needs is highly dependent on econcaic forces. By carefully examining the way customers utilize electricity in industrial processes, in commercial establishments and in households, the model can take into account the various determinants of demand for electricity by each customer sector, and the crucial f

' linkages between the activities of these sectors. The

! major strengths of the econometric f'tmework are that it makes explicit assumptions of various factors that affect energy usage, it insures internal consistency among the sectors based upon economic conditions, it allows for constant input and update of new data, and it allows the

.ser to determine the impact of alternative eccuomic conditions in each sector.

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Question No.

1-4 Nhat is the actual percentage demand growth for LP and L System for 1978 - 1979 (July 5)?

Response

The actual percentage change in the annual LP&L Systems

' peak demand from 1978 to 1979 was 6.2 percent, as shown in revised (Amendment No.2) Table 1.1-3 o f the OLER. The annual peak demand represents the maximum hourly load, which is tha maximum peak demand that occurs during a specific year.

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Questio No.

1-5 How does it compare with L'! and L demand projections of 5.6 percent from 1978 - 1980?

Respense Question No. 1-4 , quests the actual percentage demand growth from l'" .s/9, while this interrogstory requests a comparison of actual 1978-1979 to projected 1978-1980. A true comparison of actual versus projected demand can not be drawn when the subject time periods do not coincide.

3 sis response therefore, will compare the actual percentage change in peak demand to the projected change for the time period of 1978-1979. As noted in the response to Question No. 1-4, the actual percentage change in the annual peak demand from 1978 to 1979 was 6.2 percent, while the projected growth in demand for the same time period was 10.7 percent.

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Question No.

1-6 What reasons, if any, can you give that the projected demand growth as outlined in ER 1.1.2.2 (paragraph 2) is correct in light of question #4?

Rassponse The projected average annual growth in peak demand outlined in the initial sdomittal of (September,1978) ER Section 1.1.2.2, is as follows: 5.6 percent from 1978 to 1980, 8.1 percent for the period of 1980 to 1985, 6.6 percent for the period 1986 to 1990, and 7.u yercent for the period subsequent to 1990. In Amendment No. 2 to the Waterford 3 OLER (October, 1980), revisions were made in the annual grou!h rates for peak demand, based on a new forecast methodology - an econometric model - which incorporates the -

actual growth in peak demand from 1978 to 1979 (see Introduction to Responses). A description of the econometric model is contained in revised section 1.1.2.3 of the OLER. The revised projections yi.elded the following results: 0.24 percent for the period fs5m 1978 - 1980 and 4.6 percent for the period from 1980 - isos. It will te noted that the 1978 - 1980 projected annual increase in peak demand is only 0.24 percent while the actual 1978-79 growth was 6.2 percent. Part of this disparity results from a one-time loss in 1980 of peak demand normally utilized by Rural Electric Cooperatives (see ' footnote to revised Table 1.1-4 of the OLER).

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r Question No.

1-7 What do you calculate to be the year by year deviation of the following LP and L data:

a) Estimated pcwer demand of LP and L from 1972 - 1977 4

from the Environmental Report Addenda, Table I-B-1, August 11, 1972 Vs.

b) Actual peak load 1972 - 1977 in ER Table 1.1-10 Re sponse _

The comparison is as follows:

Estimate Actual Peak Percent Year Peak Demand (MW) Demand (MW) Deviation 1972 2,500 2,389 4.442 1973 2,770 2,563 7.47 1974 3,098 2,676 13.62 1975 3,459 2,882 16.68 1976 3,853 3,180 17.68 1977 4,3 10 3 ,5 15 18.45 1-7.1 I

Questica No.

1-8 '4 hat is the reason for such deviation in Question No. 7, if any? ,

Response

The response to this question is the see as the response presented for Question No.1-2. .

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Questien No._

1-9 In ER 1.1.2.2.1 the last sentence reads a) follows:

" Table 1.1.-10 compares the forecast estimate with the actual maximum which occurred in the years 1966-1977."

iihen were each of these forecasts actually madef

Response

Ll%L typically makes one annual forecast of their peak electrical power demand. Stese forecasts are developed between the months of January and May of each year (before the annual stammer peak load occurs).

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Question No.

1-10 Compute deviatioc. on a year by year basis from the foil wing data sources for Middle South Ut6lities:

a) F,stimatedpowerdemana(peakload)forMSUash1undin Environmental Report, June 11, 1971 Exhibit 4, AEC Docket 50-38., 50-383.

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Actual peak load 1971-1979 '79 MSU summer peak b)

August 6.

Response ._

The cogarison is as follows:

Estimate Actual Peak Percent Year Peak Demand (MW) Demand (MW) Deviation 1970 - 6,148 7,044 6,8 18 3.21 1971 7,727 7,622 1.36 1972 8,490 7,972 6.10 1973 9,336 8,532 8.61 1974 10,266 8,504 17.16 1975 11,306 9,345 17.34 1976 12,464 9,780 21.53 1977 22.58 13,753 10,648 1978 15,182 10,687 29.61 1979 l

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Question No.

1-11 Mtat is ths reason for such deviation?

Response

The same f actors that are presented in the response to Question No.1-2 also contributed to the variation that exists between actual and projected peak demand for the MSU system. Dierefore, the response to Question No.1-2, also applies to this question.

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Question No.

1-12 What reasons, if any, can you give that present projections of power demands will not be subject to similar errors?

Response

Since the econometric model, which is described in the response to Question No.1-3, is also utilized to predict the MSU system peak demand, the response to Question No.

. 1-3 also applies to this question.

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Question No.

1-13 What is the MSU actual peak demand growth for 1978 - 1979 (August 6)?

Essponse The actual percentage change in the annual MSU Systes peak demand from 1978 to 1979 was .37 percent, as shown in revised Table 1.1-5 of the Waterford 3 OLER.

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Question No.

1-14 How does this compare with the forecasted 1978 - 1979 MSU demand growth of 7.7, as stated in the ER.

Ressonse In Tab:e 1.1-6 of the original operating License Stage Enviromwscal Report (OLER), the MSU system maximum hourly load is projected to increase from 10,802 MW(e) in 1978 to 11,535 MW(e) in 1979, which is a 7.7 percent growth race, and can be compared to the actual growth increase from 10,648 MW(e) in 1978 to 10,687 MW(e) in 1979 which represents a percentage increase of 0.37 percent for the

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Question No.

1- 15 '4 hat reasons, if any, can you give that demand projections for Middle South Utilities are correct for the decade 1979 - 1989 in light of the answer to Question #147

Response

Comparison of projections should be for the period of 1979 -

1984, which was projected to have an average annual growth in peak demand of 7.0 percent, as illustrated in Trale 1.1-6 of the original OLER. These projections have been revised, utilizing the econometric model which incorpora.tes the actual growth in peak demand for 1978 - 1979 (see Introduction to Re sponses) . The revised projections yielded the following results for the MSU System: 2.1 percent for the period from 1979 - 1984 and 2.5 percent for the period from 1979 - 1986.

These revised projections not only include the new forecast methodology, but also the one - time loss in 1980 of peak demand normally utilized by Rural Electric Cooperatives which was not included in the forecasts contained in the table referenced in Question No. 1-10. (See response to Question No.1-3 for a detailed description of the econometric model.)

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Question No.

1-16 *a hat is meant by the following sentence as shown on ER Table 1.1-7 (bottom): " Projected peak loads (1978-1984) are based upon non-si:nultaneous loads of S'a?P member systems"?

Response

he sentence means that the projected S'a?P peak loads were obtained as the sum of the individual member systems' forecasted annual peak loads. Since the individual member systems can peak on different days or hours, the sum of the individual member systems' annual peak loads occur in a non-simultaneous manner resulting in a non-simultaneous peak.

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Question No.

t 1-17 What is the rationale for basing reserve margins on non-simu'.taneous demands rather than on simultaneous demands?

Response

Diversity is considered in determining an individual In addition, it utilities recommended minimum reserve.

should be noted that the reserve margin criteria established for the SWPP member groups is actually less stringent than the MSU's reserve margin criteria.

Therefore, compliance with MSU's reserve margin criteria will ensure compliance with the SWPP's criteria.

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Question No.

1-18 What equations do you use f or calculating minimum reserve electrical level on non-simultaneous loads, indicating definitions of all symbols used.

Re sponse Pianning of capacity additions must provide that the total generating capacity available to the Southwest Power Pool system shall be suca that the capacity available shall exceed the predicted annual peak load obligation by a margin of 15 percent, or as an alternative, a probability study made so as to insure that the probability ( load exceeding capacity available shall not be greater tutn one

' occurrence in een years provided that in no case shall the reserve be less than the peak load obligation by 12 percent.

Tae method of calculating the probability of load exceeding available capacity shall include consideration of uncertainty in prediction of load and shall employ the best available statistical data on generator forced outage races. The method will also consider hour-by-hour characteristics of the load, availability of quick-start generation and ef fects of interconnections and agreements with neighboring companies. There shall be no greater dependence upon interconnections with adjacent areas than is agreed to by said areas or is deemed prudent by good engineering judgment. 2 e maximum capability assigned to any generating unit shall be that which has been demonstrated by actual test under the most adverse conditions that might exist during the loading period being considered.

Equations used to calculate the percent reserve are as follows:

1) Load Responsibility = Peak Load - Firm Purchases

2) Capability = Owned Capability + Non-Firm Purchases apa ili y - L a esp nsibility x 100

3) Perecnt Reserve = Load Responsibility

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Question No.

I 1-19 What was the actual si:aulcaneous percent detaand growth for the South West Power Pool for the year 1978 - 1979 (suunser j i

peak)?

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Response

i The actual percentage change in the annual si:sultaneous peak '

demand from 1978-1979 was minus 1.0a percent , as derived from Table 1.1-7 of Amendment No. 2 to the Waterford 3 OLZR.

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Question No.

1-20 What was the si:nultaneous peak load for the St.PP in 19787

Response

The actual si:multaneous peak load for the SWP in 1978 was 39,191 MW(e), as shown in Table 1.1-7 of Amendment No. 2 to the Waterford 3 OLER.

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Question No.

1- 21 What was the simultaneous peak load for the S'n?P in the susmer of 19797

Response

The actual simultaneous peak load for the SWPP in the stamer of 1979 was 38,783 MW(e), as shown in Table 1.1-7 of Assendment No. 2 to the Waterford 3 OLIR.

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Question No.

1-22 What is the meaning of the following sentence found in 1.1.1.2(b): " Conservation efforts cannot be expected to eliminate the need for this additional power."

i Re sponse As stated in Section 1.1.3.1 of the OLER as revised by Amendment No. 2, a primary benefit of a 1983 commerical operation of Waterford 3 will be a very substantial economic gain to LP&L's custooers in the form of reduced fuel expense. This benefit will be realized by LP&L's customers , independent of conserration ef forts, since it is not expected that decreases in electrical power demand due to conservation will eliminate the economic benefits bhich LP&L's custome-s will obtain from the timely operation of Waterford 3. Another benefit is the increase in LP&L's reserve margin from the addition of the nuclear fueled Waterford 3 which will enhance system reliability over the life of the station by increasing the available electrical

. power supply to LF&L's system. System reliability will also be enhanced by adding a new fuel type to the system which will lessen LP&L's dependence upon natural gas and oil and thereby tend to moderate the effects of shortages, curtailments, etc on the supplies of these fossil fuels.

Therefore, although conservation is an important consideration af*ecting electric power usage, it is not expected to eliK.D Ate the need for the electrical power to be supplied by Waterford 3.

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Question No. ,

1-23 What is the meaning of the phrase "Ilectrical conservation efforts which are easily implemented and accepted" as found in ER 1.1.1.2.3(a) .

Rasponse The complete statement as contained in the initial submittal of the OLIR, Section 1.1.1.2.3(a) is as follows, "Those electrical conservation efforts which are easily implemented and accepted are primarily of f peak loads and will h ie little effect, if any, upon peak demand". The peak electrical power demand is the critical planning situation for electric utilities and it is the situation upon which reserve margins are based. Therefore, although conservation can reduce electric power demands, it is not expected that conservation efforts can significantly reduce the electrical power usage during LP&L's peak which usually occurs on hot workday afternoons.

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l Question No.

1-24 Give details of such conservation efforts.

Reeponse .

l' LP&L efforts include, but are not linited to, curtailment of non-essential loads within generating plants and l offices, appeals to the general public to use electricity in a wise an efficient manner, and encouragement of the use ,

of efficiency-promoting techniques and programs. A more detailed discussion of LP&L's activities, including both internal company policies and consumer programs , is contained in Section 1.1.4.6.2 of the revised OLER.

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Question No.

1- 25 Should easy acceptance and implementation be ene final criteria in light o f ER 1.1.1.2.3. (h) ?

Response

Section 1.1.1.2.3(h) of the initial OLER is entitled

" National Fuel Independence", and, as stated in this section, of the major fuels, the United States is self-suf ficient in only coal and nuclear fuel. LP&L is introducing a nuclear-fueled unit into their system, and thereby utilizing a fuel which is present?.y available in sufficient quantities in the U S. Instead of depleting the supplies of scarce fossil fuels, therefore, LP&L is contributing to the effort of nacional fuel independence.

The addition of Waterford 3 to LP&L's system will also increase the reliability of energy supplies because of the addition of a new fuel type to the system will reduce the potential effects of shortages, curtailments, and other factors influencing the stability of fossil fuel supplies.

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Question No.

1-26 Give references for the statement found in ER 1.1.1.2.3(b): ". . . .this tendency is expected to accelerate".

Response

This interrogatory utilizes a quotation from a section of the original draf t of the OLER entitled, " Pollution Avoidance."

The quotation is based on the assumption that pursuant to 40CPR, Parts 51, 52, and 124, limitations on allowable emissions become more stringent when the available increments for specified pollutants are or have been exceeded, industrial and/or ccanarcial operations within the area LP&L serves will be confronted with a choice.

Fueling of the industrial or commercial process in question can be instituted by either: 1) installing control technology which is capable of the lowest achievable emission race and further obtaining the required offsets or; 2) utilizing electricity. LP&L expects that customers will frequently find that the latter choice will be preferred.

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Question llo.

1-27 Give references for the statement found in ER 1.1.1.2.3(d): "Most customers are not in a position to contract for long-term energy (sic) supplies".

Response

The statement as contained in the original section 1.1.1.2.3(d) stated thar "Ms.t customers are not in a position to contract for long-term fossil fuel supplies" The term "fosei". fuel supplics," as used in this context is typicallf limited to oil, natural gas and coal. Therefore, the applicant is stating that energy users may not be able to contract for long-term fossil fuel supplies. This statement is based on the applicants previous experience concerning the uncertainty of the future availability of fossil fuel energy suoplies within its (applicant) service area and the service areas of the MSU and SWPP member systems. The response to Question 1-28 gives the applicant's rationale for this statement.

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Question No 1-28 What evidence forms the basis for your assertion that the top 20 energy users in the LP and L area are "not in a position to contract long-term energy (sic) supplies".

Response

The statement as contained in the original section 1.1.1.2.3(d) stated that "Most customers are not in a position to contract for long-term fossil fuel supplies".

Most LP&L customers, including residential, industrial, and commercial users, may not be able to enter into long-term agreements for fossil fuel supplies, specifically oil and natural gas, due to the uncertainty surrounding these supplies. Therefore, most customers may be expected to substitute a more reliable source, such as electrical energy from utilities. Furthermore, during the 1980's as deregulation increases the price of oil and natural gas, and as long-term natural gas contracts expire and cannot be renewed as a result of the Power Plant and Industrial Fuel Use Act of 1978, it can be expected that the trend will be continued and that the nuclear fueled Waterford 3 will provide a less costly source of energy than the other oil and gas fired units which LP&L presently operates.

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Question No.

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• Aat evidence exists that the top 20 industri~al customers in the Middle South Utilities area are "not in a position to contract for long-term energy (sic) supplies".

Response

The response is the same as the response presented for Question No.1-28, except it applies to the Middle South

• Utilities System instead of the LP&L system.

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Question No.

1-30 What evidence exists that the top 20 industrial customers South West ver Pool are 'not in a position to contract for long-term energy (sic) supplies' .

Response

The response is the same as the response presented for Question No.1-28 with -- exception that the response applies to the South 'Wr.,u ??wer Pool (S'WPP) instead of the LP&L system. In addition, it should be noted that since LPEL is only an operating utility in one the member groups (MSU) which comprises the S'4PP changes in electrical power usage could occur within the S'WPP without directly affecting LP&L.

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Question No.

1-31 What impact does the President's program of 202 solar energy by die year 2000 have upon your assertion found in ER 1.1.1.2.3(e):". .. Electricity is the only energy being employed in new homes and businesses."?

Response

The sentence from which this statement was extracted is,

" Increasingly, electricity is the only energy being employed in new homes and busine.ises". This sr.: -ent describes the trend for new homes and businesses within the area LP6L serves to utilize electricity instead of alternate fuels to supply their energy needs.

LyEL': present electrical energy forecasts do not specifically incorporate allowances for solar energy through the year 2000. However, the econometric model, which LP&L and MSU utilize to forecast electrical energy requirements, has the capability to include judgment and information available through field surveys, engineering studies and other exogenous studies into the final forecast. Therefore, at the present time, the proposed solar energy program does not affect LP&L's electrical load forecasts nor does it ultimately affect the savings wuich LP6L's customers will obtain from an early commercial operation date of Waterford 3 (see revised OLER Section 1.1.3.1).

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Question No.

1-32 What are the methods LP&L will assist Td the~ i:splementation of this study?

Response

LP&L has instituted a policy to assist customers in coordinating the installation of solar equipment to meet a portion of their energy requirements'. In addition, LP&L is actively supporting -esearch in the area of solar energy utilization through Tulane University and through LP&L's membership in the Electric Power Research Institute.

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Question No. .

1-33 What do you calculate to be the power needs of LP&L's service area until the year 2000 based on the program?

Response

Electrical energy demands for recent years in the area LP&L serves have been quite variable primarily due es the effects of exogenous influences such as the recession, the oil embargo, etc. The utilization of an econometric model has allowed LP&L to include the effects of these exogenous influences on forecasts of electrical energy demand.

However, LP&L's recent experience has indicated that, although their forecasting techniques can develop forecast, for a twenty year period, developing a forecast under the present variable economic conditions for the year 2000 would be quite speculative. Therefore, LP&L considtrs it to be inappropriate to estimate, at this time, the effects of solar energy on electrical energy forecasts in ehtir service area for a twenty year period. Furthermore, it should be noted that, should solar energy usage infit.ence electrical energy demands in LP&L's service area, electrical energy forecasts will be modified accordingly via the econometric model.

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Question No.

1-34 What is the basis for the following phrase found in ER l 1.1.1.2.3(g) (sic): " .. it is at d2e time of f amily formation that the f amily traditionally first enters the  !

l housing market."?

Re spons e The complete statement as presented in Section 1.1.1.2.3(f) of the OLE 3 from which this comment is derived is as follows, "The rate of new f amily formation is more significant than the rate of population growth, because it is at the time of f amily formation that the family traditionally first enters the housing market". The context of this statement is a discussion of the factors which influence demand growth, and this subsection is establishing the interrelationship between a socio-economic factor and electric power demand.

The period of new f amily or household formation, which can either occur as a result of marriage or individuals permanently leaving their homes, induces an increase in the demand for new or additional housing. This new demand for housing results in new residential electrical energy customers, which can signif* Scantly affect the demand for electricity in a service are a.

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1-34.1

- _ .~. _ _ _ _ _ . . . _ - ,- . _ _ _ ._ _

Question No.

1-35 Justify this in light of a tigat money market.

Response

A tight meney market (high interest rates) will only depress the segment of the housing market which pertains to home ownership, such as single family homes and condominiums. Se other segments of the housing market, such as rental units and mobile homes, become the alternatives to private home ownership and they typically absorb the new demand for housing created by new household -

formations.

1-35.1

Question No.

1-36 '4 hat do you assume to be the minimum income necessary for the purchase of a new home, in the LPSL service area?

Rasponse As described in the respcuse to Question No.1-35, increases in residential demand for electricity are not a function of private home ownership. Rather, if economic conditions prevail which preclude or reduce new private ownership, the demand for new or additional housing is typi ally absorbed within the available alternatives (eg.

rentil units and mobile homes).

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1-36.1

Question No.

1-37 'Aat is the average inceu of newly formed families.

Response

The average annust real disposable income (in 1977 dollars) for a household (f amily) in the area LP&L serves is

$9,262. The income figure was derived from the 1977 real disposable per capita income in the area LP&L serves. Bis value is a data input in the MSU ece 7stric model (see response to Question No.1-3) . ~!he 1977 average persons per household was derived from U.S. Bureau of Census data.

4 1-37.1

. . - . _ _ _ . . ~ _ . . _ . . ._. , . . . - _ . - _ .. . . _ _ _ _ __ _ _

l Question No.

1-38 Do LP and L's demand projections contain a discount factor for the use of co-generated power and process steam by LP and L's industrial and commercial customers.

Re sponse LP&L estimates there is presently approximately 150 MW of cogeneration within their service area. All of this generation is owned and operated by LP&L's customers. LP&L is not aware, at this time, of any specific plans for additional cogeneration within its service area. Due to this limited amount of cogeneration, LP&L does not presently employ any discount factors in its forecasting loads for cogeneration. Furthermore, even if these load forecasts were adjusted to reflect this small amount of cogeneration, the benefit of the less expensive electrical power which Waterford 3 will produce fo. LP&L's customers is not attenuated.

I 1-38.1

Question No.

1-39 Of so, state what amount of a discount f actor has been applied.

Response

Since cogeneration usage is presently only a small fraction of LP&L's total generation, LP&L does not include any discounts for cogeneration.

1-39.1

Question No.

l-40 If not, state why no such discount f actor has been applied.

Hasponse 2

Since cogeneration forms a small portion of LP&L's current total generating requirements, LPSL does not incorporate a

• discount for this demand in its load forecasts.

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1-40.1

Question No.

1-41 State what discount factor for co-generated power you intend to apply for future demand projections.

Response

LP&L works very closely with its large industrial customers in coordinating powr requirements for the future. If cogeneration becomes a more significant portion of LP&L's generating requirements, LP&L will modify their load forecasts via the econteatric model to reflect it.

d 1-41.1

Question No.

1-42 Identify and state the power usage for 1974-1979 of the twenty largest customers served in the LP and L's service area.

Re spons e The twenty largest customers served for each of the years from 1974-1979 are listed in Table 1-42.1, along with the total annual electrical energy consemed by these users.

i 1-42.1

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TABLE 1-42.1 TWENTY LARGEST CUSTOMERS (PRINC11'AL ACCOUNT ONLY).

FOR EACH OF THE YEARS 1974 THRU 1979 (in Mwh) 1975 1976 1977 1978 1979 Customer 1974 Agrico Gesical Co * * * * *

• Amtsrican Cyanamid * *

• AMAX Inc *

• Big Three Industries * *

• C F Industries Inc * * '* * *

• Crown Zellerbach * * * *

• Georgia Pacific Corp *

• Good Hope Refineries * * * *

• Gulf oil Corporation * * * *

• Booksr Chem & Plastics * * * *

• Incarnational Paper Co * *

• Kniser Alum & Chem * *

• Marcthon Oil Cogany ' * * * *

• Menscuto Company * *

• 011nkraft Inc (Manville) * * * * *

• Sholl Oil Company *

• Shall Pipe Line Corp * * * *

• Tann2co Inc * * *

• Tcxcco Inc * * * *

• Unica Carbisa Corp

• Continental can Co * * *

• Murphy Oil Corp * *

' Triad memical * * *

• E I duPont de Nemours Me Celotex Corp

• Avondale Shipyards Inc

• National Phosphate Corp

• International Min & Chem ANNUAL.WH 3,801,937 4,188,292 5,368,312 5,892,528 6,282,166 7,506,054

• Me asterisks indicate that the specific customer was among LP&L's twenty largest industrial customers for that particular year.

So+trc ,: Louisiana Power and Light.

1-42.2

l Question No.

1-43 a. What is the basis for MSU's reserve requirement of "16 percent of annual peak lead responsibility?"

ERI .l .4 2.

b. Is there any statutory, regulatory or other legal basis for such requirement?

c. If so, state the exact statute, regulation or other basis?

d. Is there any engineering, technical or scientific basis for such requirement?

e. If so, state all pertinent references

f. What is the present cost to the LP and L system of maintaining a 16 percent peak load reserve within the system?

Response

The 16 percent reserve requirement was developed frea experience and using engineering judgment as to the performance of future units. There is no statutory, regulatory or other legal basis for establishing a 16 percent reserve level.

Reserve capacity represents a cost savings to the customer, for, if excess capacity is available during- emergencies, it can be used in lieu of purchases from outside companies. , ,

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Question No.

1-44 What is the overall historical capacity f actor?

Pksponse The average annual capacity f actor for the LP&L system for the period of 1965 to 1979 was 52.6 percent. This overall capacity f actor is the average of LP&L's annual capacity factors for the above mentioned time period, which are derived from the system's total annual net energy requirements (in kWh) in relation to total capability (in kWh). The data used to make these computations is presented in Table 1.1-3 of Amendment No. 2 to the OLER.,

It should be noted that the LP&L system capacity factor includes both base loaded and peaking units. Individual units within the system will operate at higher capacity factors.

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j l-44.1

Question No.

L-45 What contracts for uranium fuels do you now have?

Ra 4 pnsee LPEL presently has the following two contracts for uranium fue1:

1) Fabrication contract with Combustion Engineering, Inc.

2) Fabrication contract with Gulf United Nuclear Fuels, Corporation.

Refereuces:

1. " Contract for Nuclear Fuel Fabrication Services" between LP&L and Combustion Engineering, Inc. effective July 28, 1970.

. 2. " Agreement between Middle South Services, Inc. and Gulf United Nuclear Fuels Corporation" effective April 3, 1972.

1-45.1 -

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4 Question No.

1-46 If none, when do you expect to finalize concracts?

Itasponsea ,

LML has the two Contracts for uranism fuel which are listed in the response to Queetion No.1-45.

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1-46.1 4

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Question No.

If contracts exist, give details:

1-47 a) Iangth of Contract .

b) Pricing ar-angements through working life of iJacerford 3 (40 yean? including any cost escalators.

Response

For the two contracts noted in the response to Question No.

1-45, the information requested in this Question is propietary and it is, therefore, not provided herein.

1-47.1

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l Question No.

1-48 What is the percentage of the Fuel Cycle costs as listed in ER Table 8.2-2 that reflects the price of uranium fuel?

Response

Approximately 77% of the Fuel Cycle costs as listed in ER Table 8.2-2 reflect the cost of uranium fuel, which consists of costs of yellow cake, costs of conversion, costs of enrichment, and costs of fabri-cation. The remaining 23% represents the cost of spent fuel shipping and disposal.

Re fe re r.ce :

CINCUS Input data.

1-48.1

Question No.

1-49 What is the historical relationship between the price of uranium fuel with other parts of the fuel cycle:

4) Milling and Mining b) Conversion c) Enrichment d) Fuel preparation and fabrication e) Reprocessing f) Transportation

' g) Waste Managment Show calculations and reference.

Rasponse LP&L has prepared cost estimates of the various fuel cycle components on the basis of a fractional portion of the fuel costs. However, since a historical data base suitable for making predictions of costs does not presently exist, LP&L has developed estimates of the fuel cycle component costs based on available industry guidance (1),(2) . The following discussion presents LP&L's estimates of the relationship of these fuel cycle costs with the cost of uranium ruel.

a) In the late 1960's and early 1970's the price of yellowcake ranged from about $6.00/ pound to 7.00/ pound. Beginning in early 1974 the price of

' yellowcake rose until in early 1976 it had reached

$ 40.00/ pound. The price remained in the $40.00/ pound en $44.00/ pound range until the beginning of 1980, vnen the price began dropping steadily, reaching

$27.00/ pound by December 31, 1980. It is estimated that the cost of yellowcake represents about one third of d2e cost of the fuel, b) The cost of conversion services has ranged from about

$1.00/ pound of uranium in 1975 to $2.00/ pound of j uranium in 1981. LPSL estimates that the cost of conversion represents about 1-2 percent of the cost of the fuel.

c) The cost of enrichment has ranged from $30/SWU in 1971 to S110/SWU (AFC) in 1981. LP&L estimates that enrichment costs represent about one third of the cost of the fuel.

1-49.1 A

w-=v i .y r-p- - - - + -p 6- ,,e - .' .- sr

• t- y =r-s- p--+---w-e

• l d) LPSL estimates that one sixth of the cost of the fuel represents f abrication costs.

e) Reprocessing is not a viable consercial alternative in the United States. Hence, there is no historical relationship between the cost of reprocessing and the cost of the fuel.

f) Ihe transportation of spent fuel for ultimate disposal purposes is not commercially viable in the United States, and LP6L has no historical data base to relate the cost of transportation to the cost of the fuel.

An allowance for the cost of this component step in the fuel cycle is included in the waste management costs presented below. ,

l g) Waste management is not commercially viable in the United States. LP&L does make an allowance for the transportation and disposal of spent fuel which represents about one sixth of the cost of the fuel.

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i 1-49.2 l

l Question No.

1-30 What contracts exist for the parts of the Fuel Cycle (a-g) listed in Question No.1-497 1

I Respons_e ,

l The following contracts presently exist for the fuel cost components listed in question No.1-49 for k'aterford 3: j a) Milling and mining: None b) Conversion: Contract between Allied Clemical and Middle South Services dated August 22, f 1975, later transferred to Systems Fuels, Inc, on June 15, 1980.

c) Enrichment: Contract #DE-SC05-79UEC4551 between the Department of Energy and Systems Fuels ,

Inc. , dated September 30, 1979.

d) Fuel preparation and fabrication: Contract for nuclear fuel f abrication services between LP&L and Combustion Engineering I

Inc. effective July 28, 1970.

l Contract for nuclear fuel f abrication services between LP&L and Gulf United Nuclear Fuels , Corp. , ef fective April 3, 1972.

e) Reprocessing: None (See response to Question No.1-49) f) Transportation: None (See response to Question No. 1-49) g) Waste Management: None (See response to Question No. 1-49) l l-50.1 l

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Question No.

1-31 If contracts do not exist (or do not extend through the full working life of the plant), justify ER Table 8.2-2?

Response

Table 8.2-2 of the OLER is concerned with the fuel cycle costs for the initial year (1983) of operation of Waterford

3. Hence, it is not necessary to have contracts which extend carr, ugh the full working life of the plant to support . infor: nation in this table.

No contract exists for yellowcake (the product of the mining and milling step of' the nuclear fuel cycle) because LP&L's uranium inventory is already large enough to encompass the initial core and several coreloads. W contract exists for the reprocessing step since federa.

policy has not permitted reprocessing of commercial nuclear fue 1.

No contracts exist for the spent fuel transportation or waste management steps of the nucicar fuel cycle as the method for disposing of high level wastes has yet to be determined by the federal government and as LP&L has sufficient storage space for spent fuel onsite.

I l-51.1

Question No.

1-52 Doctment Fuel Cycle costs from the following parts of the 1!. censing process for Waterford 3:

a) Application b) Construction permit c) Is suance of Final Safety Analysis Report and Environmental Report.

Easoonse _ _ . . . _

. s.) Application for Construction Permit:

Ten year levelized fuel cost beginning in 1975 was estimated to be 1.89 mills /ke. .

b) Construction Permit:

No official fuel cost projection was made at the time of construction permit issuance.

c) Updated fuel costs as contained in Revised (Amendment No. 2, October 1980) 6LER: 1983 fuel costs are estimated to be 8.91 mills /k*.

Reference s:

a) Section I-C of the Waterford 3 Preliminary Environmental Report.

b) Not applicable.

c) Revised (Amendment No. 2) Section 8.2 of the Waterford 3 Final Environmental Report.

j 1-52.1

Question No. ~

1-53 Is this increasing trend properly cost accounted as continuing throughout the life of the plant? Stov calculations and references.

Response

LML does take into account such variable f actors as cost of money, escalation, and perturbecions in : arket conditions when making fuel cost estimates. Dese atinates are typically made no further than ten years into r.se future due to the uncertainty associated with applying current data to long-range projections, me fuel cost estimates are calculated using CINCUS, a computer code which is widely used in the nuclear induser . As reflected in Section 1.1.3.1 of the revised OLER, the trend in nuclear fuel costs for Waterford 3 is estimated to be the following:

1983 8.91 mills /kWh 1986 7.38 mills /kWh

' 1989 12/58 mills /kt.h I

l 1-53.1 l

l

. T' Question No.

1-54 What effect, if any, will uranium carcelization as documented in hearings of the Federal House of Representatives (Subcommittee on Oversight and Investigation, L2ternational Uranium Cartel, Y6.IN 8/4:

95-39) have on uranium fuel prices throughout the working life of Waterford 3? Show calculations and references.

Response _

The Lapact of an alleged international uranium cartel on the price of uranium fuel would be limited to the cartel's influence over the price of yellowcake, a single step in the nuclear fuel cycle. Assuming tha? such a cartel has been in existence, past history demonstrates that the cartel does not necessarily dominate the yellowcake

( market. For example, the NUEECO exchange value shows that the price of yellowcake has dropped from $43.40/ pound in mid-1979 to $27.00/ pound by the end of 1980. Additionally the introduction of new independent uranium producers, such as Australia, would further reduce the potential influence of a cartel.

Based on these past and potential perturbations to the yellowcake market, it i! unrealistic to presume any specific effect of a urasium cartel on the price of uranium fuel during the working life of Waterford 3.

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d l Referenc e:

"NUEXCO Monthly Report on the Uranium Market," No. 149, January, 1981.

1-54.1

l .

Question No.

1-55 What is the maximum credible price of uranium fuel through the working life of Waterford 37 S2ow calculations and references. 1 I

Re sponse LP&L presumes that the maximum price of Waterford 3 nuclear fuel vill occur at or near the end of the unit's working life (approximately 40 years after the start of commercial operation). Due to die uncertainty associated with applying current data to long-range projections, LPSL typically makes nuclear fuel cost estbaates no further than ten years into the future. As noted in the response to the Question No.1-54, the NUEICO exchange value shows that price of yellowcake has dropped from $43.40/ pound in mid-1979 to $27.00/ pound by the end of 1980.

Attempting to project the maximum credible price of nuclear fuel during the lifetime of Waterford 3 would be a moot, unrealistic, and insupportable exercise.

e 1-55.1

O

• Question No.

1-56 Which decossissioning alternative as listed in ER Table 5.8-1 nas LP and L decided on? .

Essponse At this time LP&L has not decided upon any of the

, decommissioning alternatives listed in OLER Table 5.8-1.

t 1-56.1

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Ouestion No.

1-57 If this decision has not been made, when is this decision expected to be made?

a) before OL issuance b) before fuel loading c) before initial criticality d) before commercial operation Response _ ___

A decision as to the preferred decommissioning alternative will be made near the end of the station's useful lifetime. At that time LPEL will perform a detailed study to determine the preferred alternative, both in terms of cost and environmental impact. LP6L believes that it is better to wait until near the end of the station's lifetime to perform this study, because only at that time will the actual technological, economic and regulatory conditions be known and therefore, taken into account.

l l-57.1 e ' , ,

Question No. Is the cost of deconnaissioning figured into ER Table 8.2-27 1-58

Response

Since a specific plan for deconnaissioning Waterford 3 has not been decided at this timw, the decommissioning costs have not been determined and therefore they are not included in the costs presented in OLER Table 8.2-2.

1-58.1

l Question No. -

1-59 If not, why not?

Response

At the present time, LP&L is considering several possible alternative schemes for decommissioning of Waterford 3. At this time the exact technological requirements have not been detailed for Waterford 3 for any of the decommissioning alternatives being considered (see OLF.R Section 5.8 for a discussion of these alternatives). De experience gained in the continued use of these alternative methods and any developing variations for nuclear plant decosumissionings in the interia years will enable LP&L to select the most cost effective and technologically efficient alternative. Since it would be extremely difficult to predict the technological and regulatory requirements for decommissioning Waterford 3 at tae end of its design life (ie 2023), LP&L feels it would be inappropriate to develop a deconnaissioning cost estimate at this time. Merefore, the costs estimates on Table 8.2-2 do not include an allowance for decommissioning.

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- * - - - - p g ,__ ,_

. E Question No.

1-60 What provisions are being made to insure decommissioning costs are not paid by ratepayers or taxpayers of the future? Ehow calculations and references.

Re spons e The costs associated with decorsissioning of Waterford 3 Furthermore since LP&L has not will be borne by LP&L.

l determined the decommissioning technology to be employed at I

Waterford 3 (see responses to Question No.1-57 and 1-61),

! the method for financing decommissioning costs has not yet l been established. However, since the costs of electrical l

generation, including capital and opsrating costs are incorporated into LP&L's race base, it is probable that the rate base will be adjusted at some point to reflect these

! costs. At this time, it is not anticipated that Federal, state or local taxes will be utilized for decommissioning i purposes.

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i 1-60.1

Question No.

1-61 What deconnaissioning alternative is available for Waterford 3 in which security would not be necessary? Show references.

_ Response The only deconnaissioning alternative available for Waterford 3 W ich would not require security persoccel onsite is Coglece Reooval/ Dismantling since all buildings, including those sich contained radioactivity, will have been removed.

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1-61.1

Question No.

1-62 A professional paper form Stanford University (Trcce Elements in Reactor Steel: Implications for d

Decommissioning, John J Stephens, Jr and Robert 0 Pohl, Report #2882) challenges the major reference of ER Table 5 8-1 (AIF/NESP-009) in regards to the radiological significance in decommissioning of nickel-59 and niobium-94. Do you agree with the findings of Stephens and Poh17 What, if any, are the errors which you attribdte the analysis of the Stanford study? Show calculations and references. -

Response . ._

LP6L agrees with Stevens and Pohl of Cornell University (1) that AIF/NESP-009(2) did not include the proper radioactivity level post reactor operation of niobium-94. LP&L believes that the nickel-59 difference between the two studies is not due to improper methodology, but to slightly different assump tions . This difference is similar to the higher cobalt-60, iron-59 and nickal-63 activity levels reported in Reference 2 and haa insignificant radiological impact during decommissioning.

Recent analysis performed by Battelle Pacific Northwes't Laboratory for the US Nuclear Regulatory Connaission(3)

(which was published at approximately the same time that the OLER was originally submitted) includes niobium-94 in its estimates of radioactivity levels and dose rates which result from the neutron activation of the reactor vessel and its isternals. These radioactivity levels and dose rates are shown in Figure 1-62.1. This figure shows that the dose race is dominated by cobalt-60 until approximately 90 years after reactor shutdown. Therefore, the inclusion of niobium-94 in decoezissioning dose rate calculations would have negligible radiological significance on the prouet Esmoval/ Dismantling Decommissioning option, because, during the actual period of dismantling and removal, niobium-94 makes a very sesil contribution to the total l dose race (less than 0 1 percent). The ssra conclusion can be made when considering the initial years f the Mothballing or Entombment Decommissioning e.iternative when I

preparation of the facility for the storage period is undertaken. Also, since the dose rate is so low after about 90 years its contribution to the delayed Removal / Dismantling Decommissioning options total dose can l be made negligible through the implementation of radiation protection procedures. These procedures would not be as elaborate as those reauired for decommissioning via the proupt Removal / Dismantling option but it would be scre significant than those assumed in Reference 2.

1-62.1

- - . .. - . - . - - - - . = - . - - . ---. - ---

Re ferences: - --

1. J J Stevens, Jr. , and R 0 Pohl, " Trace Elements in Reactor Steels:

Iglications for Decoussissioning", Report # 2882, Laboratory for Atomic and Solid State Physics and Material Science Center, Cornell University, August 1977.

I

2. Atomic Industrial Forus, "An Engineering Evaluation of Nuclear Power Beactor Decomunissioning Alternatives", AI7/NESP-009 AIF Wasnington, DC , 1976.

3. Battelle Pacific Northwest Laboratory, " Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station", NUREC/CR-0130, June 1978'.

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4 1-62.2

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55 Fe CURIES E1 -

< - 60 TOTAL CURIES as Co CURIES aa -

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'2 -=

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. TOTAL DOSE RATE W

< 10

-3 e

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1000SE RATE

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[ Ni DOSE RATE g ._

55 Co DOSE

. , Fe DOSE RATE RAE i i i 1 g -7 e 12 0 140 0 20 40 60 80 100

( YEARS AFIER REACTOR SHUTDOWN t _

$.- L.k .C"1220%*AE "non .

.. _ ~~~~ 7

- - - _ _ - - - - - - . . . . . . . . I"*

LOUISlANA POWER & LIGHT CD. TIME DEPENDENCE OF RACICACTIVITY LEVELS AND COSE j,g,)

IN THE ACTIVATED REACTCR CCMPCNENTS Waterford Stecm l . .- !:ilectric Station

Question No.

2-1 The Bouse Government Operators (sic) Committee has received evidence which in its report No. 95-1090 indicates that the above capacity factor of large plants is 55%. If Waterford 3 runs at a 55% capacity, what ndil be the cost per kilowatt hour produced at Waterford 37

Response

The statement presented above is taken fran page 27 of the House report, and it infers that large nuclear plants have an average capacity factor of 55 percent as campared with 70 percent for coal-fired units with scrubbers. The l

stacament is based upon data presented up through 1976. A l more recent study complaced by the U.S. Department of Energy (DOE)(1) examines data from the same time period as the House report,' and it indicates that the average capacity factors of nuclear power plants fram 1968 to 1977, as shown in Tabte 2.1-1, is considerably above 55 percent.

In fact, as stated in the response to Question No. 2-2 (below), Combustion Engineering's two most recent nuclear stations have achieved design electric capacity f actors of approximately 75 percent.

In only two years of the ten years which the D01 study examined (1968 and 1974) did the average capacit 'accor l

for all nuclear units average 55 percent or slif < below, and for the remaining years the average capacity mor for nuclear units ranged from 60.3 percent to 71.8 pet ut.

Also during this period, on only three occasions a the average capacity factor of the coal-fired units inc. ded in the study exceed those of nuclear units (1968,1971 d f

1974), and the average capacity f actors for coal-fire units exceeded 70 percent on only one occasion (70.9% a 1968). Therefere, based on the more recent informatiot from the DCL report and Combustion Engineering's recent units, it is apparent that Waterford 3 can be operated . a capacity factor significantly exceeding 55 percent. In fact LP&L presently expects to operate Waterford 3 at a long term average capacity factor of approximately 75 percent following an allowance for lower capacity factors (see response to Question No. 2-2) typicatl experienced during the first three years of operation (y) 1 . However, solely for the purpose of responding to this question, L?&L

' estbaates that if Waterford 3 does operate at the 55 percent capacity factor, the cost per kilowatt hour of energy produced at Waterford 3 will be 75.34 mills /kWh.

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)

Reference s: -.- . ...

I

1. U.S. Department of Energy, Econciaic Regulatory Administration, Update Esport on the Performance of 400 Megawatt and Larger Nuclear and_ ,

Coal-Fired Generacing Units, January,1981. )

4 2-1.2

TABLE 2-1.1 NATIONAL AVERAGE CAPACITY TACTORS FOR NUCLEAR AND COAL-FIRED GENERATING STATICNS (1968 to 1977)

CAPACITY FACTOR All Nuclear Units _ Coal 1. h its YEAR l

53.2% 70.9%  !

1968 70.9 68.5 f 1969 71.8 62.0 ,

1970 l 60.5 62.2 1971 60.3 59.3 1972 67.9 63.5 1973 55.1 57.1 1974 62.2 57.3 1975 61.3 58.7 1976 67.6 56.6

'977 NOTE : 1. Die analysis included 42 nuclear stations and 100 coal-fired stations.

Source: U.S. Department of Energy, Office Economic Regulatory Administration, Update Raport on the Performance or 400 Megawatt _ ______ _.

and Larger Nuclear and Coal-Fired Generating Units, . . . . ..

January , 1981.

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Question No.

2-2 a) What is the projected capacity factor of Waterford 32 b) Wnat is the record of Combustion Engineering in meeting its projected capacity? (Include average for all

' nuclear plants built by Combustion Engineering)

Easponse LPEL has projected, to the year 1990, the capacity factor for Waterford 3 to be as follows:

1983 -

54.8%

1984 - 64.8%

1985 -

70.0%

1986 -

75.1%

1987 -

75.1%

1988 -

75.1%

1989 -

74.7%

The above projections are the estLaates used in the revised CLER as the basis of calculating the economic benefits provided to the consumers, as given in Chapter 1.

In responding to this interrogatory, it is important to note that Combustion Engineering does not independently estimate the capacity factor for thei; units , since the operation and need for power is a function of a particular utility's electrical energy requirements. For example, because Waterford 3 will provide a less costly supply of electrical power than other LPEL units and because LP&L operates under economie dispatch (i.e. the delivered

' incremental cost of all energy sources, whether generated or purchased, is as low as possible for each hour), the projected capacity factor of Waterford 3 reflects LP&L's expectation that this unit will be base loaded and therefore used as often as possible.

Since Combustion Engineering is not calculating the projected ce;4 city factor for Waterford 3, it is not directly reless.nt to investigate their previous performance in meeting projected capacity factors. Mavertheless, a review of the capacity factors of Combustion Engineering's recently operated nuclear power stations supports LP&L's projections. Table 2-2.1 gives the design rating capacity factor and the maxim 2m dependable capacity factor for all Combustion Engineering plants. For the design capacity factor (DCF), the total possible electrical power

' 2-2.1

production is calculated using the design electrical racini; of the plant as specified in the Safety Analysis Kaport.

The equation used to calculate the DCF is Actual electrical power produced (1) DCF = (Design Electrical Racing) x (Iocal possible nours of operation)

For the maximum dependable capacity factor (MCF) the total possible electrical power production is calculated using the maximum dependable capacity rating. The maximum dependable l

capacity (MDC) is defined by the NRC as "Dopendable main unit gross capacity, less sescion service loads, winter or summer, whichever is smaller. The dependable capacity varies because the unit efficiency varies during the year due to cooling water temperature variations. It is the electrical output as asasured at .the output terminals of the turbine generator during the most restrictive seasonal conditions (usually summer)." The equation used to calculate the MCF is:

(2) MCF = Actual electrical power produced (MDC rating) x (Total possible hours of operation)

Table 2-2.1 demonstrates that the capacity factor currently projected for Waterford 3 is in accord with that achieved by other operating Combustion Engineering nuclear plants, and may actually be a somewhat conservative projection when compared to the two most recent plants.

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e TABLE 2-2.1 CUWLATIVE ELECTRICAL CAPACITY FACTORY

SUMMARY

Maximum Dependable Design Rating Rating Capacity Factor _ Capacity Factor _

Category of Plants 62.0% 64.4%

All C-E** Plants (1972 - 1980) 65.7% 69.4%

All C-E. Plants (1977 - 1980) 75.0% 77.6%

C-E's Two Most Recent Plants (1977 - 1980)

~~

• Data current to November,1980

• • C-E: Combustion Engineering

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Question No.

2-3 If Combustion Engineering plants have' n'ot 'mec ~their predicted capacity factor, what is the basis for asserting that Combustion Engineering's Waterford 3 plant will match their predictions?

Response

As indicated in the response to Question No. 2-2, Combustion Engineering does not develop the capacity factor projections for its units, including that for Waterford 3.

Therefore, an investigation of Combustion Engineering's ability to predict the capacity factor of Waterford 3 is inappropriata. Nevertheless, a review of capacity factors of Combustion Engineering nuclear units (see responce to Question No.1-2) indicates that their capacity factors and that projected for Waterford 3 do not differ substantially. LP&L has based its projection on the following considerations: 1) engineering judgment on the operating capabilities of Combustion Engineering units, particularly the more recently operated units, and 2)

Waterford 3's use as a b.ase loaded unit to maximize the benefits which LP&L's customers can accrue from its less expensive electrical power.

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l Question No.

2-4 The House Committee on Covernment Operations Report 95-1090 concludes that large plants breakdown more frequently than small plants resulting in greater need for back-up sources

- of electricity. In the event of a) two weeks; b) four weeks; c) 8 weeks; d) 20 weeks; f) 1 year shutdown of waterford 3, which plants will supply reserve electricity?

Response

l The discussion of the above comment is taken from page 29 '

of the House report, which infers that nuclear (large) plants breakdown more frequently than coal-fired (small) plants. A recent DOE study presents information (see Table 2-4.1) on forced out' age rates for both nuclear and coal-fired units, which illustrates a somewhat different phenomenon. The term " forced outage" as defined by the DOE study is the occurrance of a component failure or other condition which requires that the unit be removed from service Lunediately or up to and including the very next weekend. ,

Table 2-4.1 illustrates a comparison of forced outage races j

for nuclear and coal-fired units for dse tima period from l 1968 to 1977. During this period nuclear units had lower forced outage rates in six of the ten years. With the exception of the first year of data, the forced outage rates of nuclear fueled and coal-fired stations are quite l comparable with nuclear units having somewhat lower forced outage races. The first year of. data presented on the table appears to be an anomaly since the forced outage i

rates for the next nine successive years do not even approach the value for the first year. Nevertheless, even r

with the inclusion of the anomalous year, dse yearly average for the 10 years is less for these nuclear units than for these coal units.

Therefore, based upon the data presented in the DOE study, large nuclear units do not necessarily breakdown as frequent as the House Government Raiations Report would suggest.

In addition, the data presented in Table 2-4.2 indicates that the forced outage rates of nuclear stations investigated in the DOE study decreases, on the average, with the unit's years of service. In contrast, the forced outage rate for coal-fired units remains f airly constant at approximately. the level of a nuclear unit with three years of service.

If Waterford 3 did breakdown for the above dsscribed time L

period, replacement power would be provided by the other i MSU operating companies 'or by outside purchase. l

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TABLE 2-4.1 NATIONAL AVERKE FORCED OUTAGE RATES FOR NUCLEAR AND COAL-FIRED GENERATING STATIONS (1968-1977)

FORCED OUTAGE RATES Nuclear Units Coal Lbits YEAR 37.3% 9.3%

1968 13.0%

1969 7.0%

5.4% 14.7%

1970 13.7%

1971 10.0%

5.3% 16.8%

1972 13.1%

1973 10.1%

20.3% 16.0%

1974 13.5 197.5 15.7%

15.0% 13.5 1970 15 .1%

1977 8.7%

NOTE: 1. 'Dse analysis included 42 nuclear stations and 100 coal-fired stacions.

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l Source: U.S. Department of Energy, Economic Regulatory Administration.

Update Report on the Performance of 400 Megawatt and Larger ~ ~ ~ ~ ~ ~ - ^

Nuclear and Coal-fired Generating Units, January,1981. ,

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TA3LE 2-4.2 NATIONAL AVERAGE FORCED QUTAGE RATES 3Y AGE OF PLANT FOR '

NUCLEAR AND COAL-FIRED GENERATING STATIONS FORCED OUTAGE RA~ES Nuclear Units Coal Units YEAR 17.3% 14.0%

1 17.0% 13.0%

2 14.6% 13.3%

3 10.6% 13.8%

4 10.5% 14.2%

5 6.8% 13.2%

6

• 9.5% 14.4%

7 2.6% 15.9%

8 2.3% 13.8%

9

- 15.1%

10 NOTES: 1. 'Ihe analysis included 35 nuclear stations and 101 coal-fired stations. *

2. None of the nuclect units included in the analysis were in operation for 10 years.

.(J

- . . Source: U.S. Department of Energy, Economic 2egulatory Administration, Update Report on the Performance cf 400 Megawatt and Larger Nuclear and Coal-Fired Generating Units, January 1981.

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l Question No.

2-5 In the event that one of the plants supplying reserve electricity is also shut down for 1-3 months, which plant will supply the needed electricity.

Response i I Replacement power would be provided by the other MSU operating companies or by outside purchase.

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Question No.

2-6 4) See p. 31, Governement (sic) operations committee reports 95-1090 cites studies performed at M.I.T. and Harvard which showed that since 1964 nuclear construction costs increased more than 10 times d2e rise in the consumer price index? If that rate holds true for Waterford 3, what will the costs of Waterford 3 be upon completionf b) O. Irvin Bapp, one of the authors of d2e study has stated that capital costs for light water reactors show no sign of stabilizing and are rising at alarming rates? What evidence is there that capital costs of nuclear plants have stabilized?

Response

The revised total estimated cost for the construction of Waterford 3, as stated in Amendment No . 2 t o the OLZR, i s approximately $1.491 billion (in.1983 dollars).

An analysis of both nuclear and fossil-fuel plant costs, presented in the U.S. Department of Energy's UPDATE, indicates that the cost per kilowatt for nuclear stations, that are e tpected to commence commercial operation in the i l 1980's rate (II.wi!.1 continue to rise, but at a decreas ng annua *'able 2-6.1 kilowatt according to the expected year of commercial operation. The values predicted from this study, which were computed by the use of regression analysis, using dollars per kilowatt as a function of year of commercial oraration, indicate an actual overall decreasing trend in the annual percentage rate of change throughout the 1980's, except for the years of 1984.co 1985 (see Table 2-6.1).

Therefore, the data presented in this analysis seems to indicate that the unit costs of a nuclear plant, even though they are projected to increase, will be increasing at asch smaller rates.

Reference:

1. U.S. Department of Energy , Of fice of Nuclear Reactor Programs ,

UPDATE , July /Auguet , 1980.

2-6.1

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TABLZ 2-6.1 COST PER KILOWATT - NUCLEAR STATIONS Cost Per Percentage Rate of Change t

Year of Operation Kilowatt 1981 $ 1,100 1,200 9.1 1982 8.3 1983 1,300 1,400 7.7 1984 1,550 10.7 1985 6.5 1986 1,650 1,750 6.1 1987 1,850 5.7 1988 1,950 5.0 1989 i

j Source: U.S. Lepartment of Energy, Of fice of Nuclear Reactor Programs ,

i UPDATE , July / Augus t , 1980. .

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Question No.

2-7 a) Explain the factors which led to the 400 cost overrun of Waterford 3, particularly in light of the fact that in the ten years since 1970 the plant cosa.-o verruns are outstripping inflation by 200%.

b) Which f actors mentioned above will be likely to continue to cause increased costs?

l Response __ - .

i The estimated total cost of Waterford 3 has increased from that given in the early 1970's to the estimate now utilized for two basic reasons: 1) schedule delays and; j

2) regulatory and other design changes. Each of these

- reasons has resulted from a complex interaction of f actors occurring throughout the decade, many of which reflect changes in the economy and regulatory environment of the nation as a whola.

t These f actors could continue to influence the schedule

! and/or cost of Waterford 3. However, since construction is i

near completion and a revised firm schedule for final licensing review has now been obtained frem NRC, L?&L, at this time, does not anticipate significant changes to the l

schedule or current cost estimate for Waterford 3.

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2-7.1

Question No.

2-8 David Snow of Mitchell Hutchins , Inc. a Netr York investment firm, concluded that domestic mining capacity could not be expanded rapidly enough to avert a shortage through 1982 and beycad, resulting in the necessity to import foreign uranitan. '4hich countries will supply the uranium shortage?

Response

In the evest of mining capacity shortages, countries outside of Coumunist areas which could be sources of uranism i= ports into the United States include Australia, Canada, Republic of South Africa, Niger, Gabon, France, Namibia, Argentina, Brazil, Mexico, Spain, Chile, 3elgium, and Portugal.

Referenc e:

"NUEICO Sonthly Report on the Uranita Market," No.147, November, 1980.

2- 8 .1  !

Cuestion No.

2-9 Assuming that a uranium exporting carte 1~ begins raising uranium prices in 1980 at d2e saae race 0.P.E.C. has raised oil price 1974-1979, what will be the cost of Waterford 3's uranium in 19857

Response

The assumption on which this question is based is questionable for the following two reasons:

1) LPEL already has purchased, prior to 1980, a sufficient inventory of uranium to fuel Waterford 3 in 1985. Hence, an increase in the cost of uranium between 1980 and 1985 vill not result in an increase in the cost of uranium used in Waterford 3 during 1985.

2) Contrary to the assumption wnich forms the basis of this question, the price of uranium has decreased rather than increased during 1980. The NUEICO exchange value indicates that the price of yellowcake has dropped from S40.75/ pound at d2e beginning of 1980 to $ 27.00/ pound at the end of 1980. This represents a 33.74% decrease in d2e price of yellowcake.

Re ferenc e:

"NUEICO Monthly Report on the Uranium Market," No . 149, January , 1981.

2-9 .1

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Question No.

2-10 Assuming the above, what would the effect~ of a shutdown in production of the largest uranium producer (much like Iran) for one year be on the price of uranium?

Respons e The analogy between oil production and uranium production that as postulated in this question is not particularly apt. Iran is neither the world's largest producer of oil nor uranium. To understand the relative magnitude of the postulated analogy, consider the world petroleum production in 1978, before the political instabilities took place in Ir an. Iran was the fourth largesc petroleum producer at that time, accounting for 8.6 percent of the total world production.

Using 1979 uranium production statistics, the largest uranium producer was the United States, accounting for 37 percent of the world uranium production outside of Communist areas. A one year shutdown of uranium production in the United States would be a very remote possibility.

If a country whose uranium production was 8.6 percent of the total world production outside of Communist areas was to shutdown production for one year, the effect on the price of uranium would be minimal. Many utilities have an inventory of uranium sufficient to fuel their reactors for several years. Hence, there would be no need for these utilities to purchase uranium on the open market during that time. The impact of such a shutdown on the price of uranium in this country should be further minimized since the 1980 uranium supply-demand balance in the United States was equivalent to a relative inventory of 6.5 years.

Reference s:

1) "NUEICO Monthly Report on the Uranium Market", No. 145, September, 1980.

2) "NUEICO Monthly Report on the Uranium Market", No. 147, November, 1980.

2-10.1

Question No.

2-11 The House Gover:nnent Operations Conunittee i~n its Report 95-1090 has received evidence that diccaces that no more new reactors be started until "pocantial resources become known reserve s". 'what increase do you project in known reserves of economically feasible uranium?

Response

LML has made no projections.

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2-11.1

Question No.

2-12 The House Committee on Government Operations Report No.

95-1090, has received evidence that using the unattractive case of $1000/kW and a twenty percent capacity factor with no concentration,.the busbar cost for alternative generating methcds should be somewhat less than cuclear power in 1985. Considering that Waterford 3's costs are already over $1000/kW - why shouldn't L? and L invest an alternative productions methods?

Response _ . _ _ _

The statement presented in this question is derived from page 57 of the House report and is from a sesorandum written by Jim Harding, a special advisor to the California Energy Commission on the coJes of solar energy cells. All of the dollar figures on page 57 of the House report pertaining to die costs per kilowatt for solar cells are from the Harding memorandum. These capital costs present beliefs or assumptions withcut the benefit of actual costs, on the approvismes capital costs for solar cells, which range from S280/kW(e) to $2000/kW(e). "he vide range of costs per kW(e) for solar energy, even considering that these values were based on assumptions and beliefs, demonstrates the uncertainty inherent in the estimate.

In a sinority report to the House repor. (pp.95-109),

Marjorie and Aden Meinel, both of the University of Arizona, present testimony based upon research they conducted for the Energy 3asearch and Development Administration and the U.S. Department of Housing Development. The results of the research indicate that the economic validity of solar energy is questionable. The Meisels developed data which compared the break- ven value, cost estimates and current costs of three major proposed uses fer solar energy, which are presented in Table 2-12.1. In this table, the break-even value repredents the cost that would make specified applicatien of solar energy economically viable; whereas the current cost represents the actual cost. The data presented in this table clearly demonstrate that, in the present time frame, solar energy l

I is not economically viable and could not be considered competitive vita either nuclear or coal generation, bets proven technologies. Further, solar energy has not been proven to be sufficiently advanced as a proven technology for large scale use, at this date, and it would, therefore, not provide a reliable source of energy for LP&L's systas.

2-12.1

TABLE 2-12.1 CURRENT COST AND BREAK-EVEN VALUE FOR DIFFERENT USES OF SOLAR ENERGY (1)(2)

Break-Even Current Value Case Application

$13.34 S 28.9 5 Space Beating 40.00 Water Pumping 7.33 19.83(3) 100.00 Electric Power NOTES: 1. In dollars per square foot of solar collector.

2. Average for 7 companies on 96 ERDA and HUD projects.

3. Values derived on the basis for competing electrical power at 50 mills /kWh.

Source: House Government Operations Comittee Report, No. 95-1090,

p. 106.

2-12.2

d Questic No. -

2-13 The House Conamittee on Government Operations- Report No.

95-1090 cites a Dow Chemical Co. study that the U.S.

industry could meet 1/2 of its electrical needs by 1985 by co-generation. Assuming that it is true in Louisiana (explain why not and what factors indicate if not) la a) 1985 ; b) 1987, and c) 1989, what will the need be for power from Waterford 3 in LP&L's area? How does that projection compare with LP&L's estimates?

Response _ .--.

The current level of co-generation within LP&L's system is approximate.ly 150 MW(e). It is estimated that , in 1985, industrial demand for electrical power within LP&L's system will be 40 percent of the entire peak load. It is extremely doubtful at this time that a 50 percent conversion of such a large portion of LP&L's generation could occur in such a short time interval. LP&L estimates

.nat a maximum conversion of an additional 350 MW(e) may occur by 1990.

Although LML feels it is highly imporbable that a 50 percent conversion to co-generation will occur by 1989 within the area LP&L serves, LML has nonetheless estimated the capacity which would be utilized by co-generation only for the purpose of responding to this question. Based on present estimates of the industrial electrical power demand for the above listed years, and hypothetically assuming that co-generation could reduce industrial electric power demand by 50 percent, co generation would reduce LP&L's peak loads by 965 MW(e) in 1985,1049 MW(e) in 1987 and 1118 MW(e) in 1989.

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- s Question No. What would the effect of a 207. drop in-electrical demand by 2-14 1990 have on the need for Waterford 3's electricity?

Response

Since Waterford 3 will provide LP&L's customers with a source of relatively inexpensive electrical poier, the need for the operation of Waterford 3 will be unaffected by such e

a postulated hypothetical drop in electrical demaad.

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2.14.1

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4 Question No.

2- 15 a) What persons or firms are responsible for escimating LP and L's power needs?

b) Are these persons (firms) still employed by LP&L?

c) What f acts indicate that these personnel (firms) are significantly more accurate than they were in 1970.

Response - .

Mr J Saacks, Manager of System Planning of LP&L, is the person responsible f'er developing L?&L's Electrical Load Forecasts as shown '.n the OLER and as presently developed.

With the utilization of the econometric mode 1, LP&L's ability to more accurately forecast peak loads has improved. 1he response to Question Nc.1-3 presents a detailed description of the model's components.

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Question No.

2-16 a) What means do you plan to utilize to-increase the operating efficiencies of Waterford 37 b) What research is being performed t;7 you or within the industry to increase the operating c fficiency of Waterford 37 c) What discounts has applicant employed in calculating the operating basis efficiency of Waterford 3?

d) What research is being performed by you or within the industry to increase the inef ficiencies caused by steen generator degradation?

e) What discount has applicant employed in calculating the inefficiencies caused by steam degradation?

1 Basponse _

The design basis for Waterford 3 utilized state-o f-the-art engineering for pressurized water reactors to ensure that the operating efficiencios would be mav1mized and at the same time minimizing capital and operating costs. For

- example, a " Turbine Generator Cycle Study" was performed by Ebasco Services , Inc tc select equipment compatible with the reactor. Also, the selection process for station equipment included an analysis of not only the capital costs, but whers appropriate, the associated operating costs were factored into cost comparisons, and penalties were added to the capital costs of the more inefficient equipment. Thus, the operation of Waterford 3 is expected to include the most efficient and cost-eff etive t equipment which was available at the time it was obeuined by LP&L.

LP&L is a member of both the Edison Electric Institute and the Combustion Engineering Owners Group which both are engaged in the research and development of methods and technologies to optimize the operation of power plants.

The Combustion Engineering group can provide research which is of direct importance to the improvement of the operating efficiencies of the Waterford 3 station, for its Nuclear Steam Supply System was designed by Combustion Engineering. In addition, this group can assemble operating proble=a and experience relating to other nuclear

( stations with sbailar reactors as that of Waterford 3's to '

i increase unit productivity and efficiency.

i Research efforts to reduce the effects of steam generator

' degradation is continuing within the nuclear industry. .

LP&L has profited from this research and, for example, the design of the steam generator at Waterford 3 has incorporated state-o f-the-art technology to minimize staan )

generator degradation. The feedwater heater tubes have been replaced with stainless steel tubes to offset problems anticipated with copper alloy tubes, and phosphate chemistry has been replaced to volatile chemistry for steam 2-16.1

' - --- .,-._e __ , ,_ _

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generator feedwater control, etc. mese examples are illustrative of some of the measures which have been engineered into Waterfe ed 3 to ensure that operating efficiencies are maximized.

Me applicant has not provided a response to items (c) and (e) of this ques:: ion since the correlation between discounts and operar.ing basis efficiencies anc'.

inefficiences caused by steam degradation have not been defined nor are these correlations readily apparent.

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- -- -. . -, .. - " ' " ' "-*-"m, v ,y _

UNITED STATES OF AMERICA NUCLEAR REGULAIORY COM!ISSION 3efore the Atemic Safety and Licensine Board In the Matter of )

)

LOUISIANA PCWER & LIGHT COMPANY ) DOCKET No. 50-382

)

(Wate: ford Steam Electric Station, )

Unit 3) )

AFFIDAVIT OF R. W. PRADOS State of Louisiana )

) SS Parish of Orleans )

R. W. Prados, being duly sworn according to law, deposes and says that he is Waterford 3 Licensing Engineer with Louisiana Power & Light Company; that the information contained in Applicants' Responses to Joint Intervenors Intt regatory Nos. 1-56, 1-57, 1-58, 1-59,-1-60, 1-61 and 1-62 is true and correct to the best of his knowledge and belief.

^_^

R. W. Prados Waterford 3 Licensing Engineer s

Sworn to the subscribed before tae this Ay?" day of ,fp@py [fg h l il

}f' ,. b' &

No,tary Publie' My Commission expires [ [N

UNITED STATES OF AMF.RICA NUCLEAR REGULATORY COMMISSION 3efore the Atomic Safety and Licensing Board In the Matter of )

)

LOUISIANA POWER & LIGHT CCMP u;Y ) DOCKET No. 50-382

)

(Waterford Steam Electric Station, )

Unit 3) )

AFFIDAVIT OF R. M. WILKINS State of Louisinna )

) SS Parish of Orleans )

R. M. Wilkins, being duly sworn according to law, deposes and says that he is an Associat,e Enguieer with Louisiana Power & Light Conpany; that the information contained in Applicants' Responses to Joint Intervenors Interrogatory Nos. 1-45, 1-46, 1-47, 1-48, 1-49, 1-50, 1-51, 1-52, 1-53, 1-54, 1-55, 2-8, 2-9, 2-10 and 2-11 is true and correct to the best of his knculedge and belief.

kN W R. M. Wilkins 5

Associate Engineer

! -Sworn to the subscribed before ne this J y day of 8/d 8(0 8 [ [ [ /

/

n

/ /  !

[

,f , -

INotary Public V

My Commission expires /1I[h/'M

UNITED STATES OF JLECA NUCLEAR REGULATORY CCMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

LOUISIANA PCWER & LIGHT COMPANI ) DOCKET NO. 50-382

)

i (Waterford Steam Electric Station, )

Unit 3) )

AFTIDAVIT OF J. J. SAACKS State of Louisiana )

) SS Part.sh of Orleans )

J. J. Saacks, being duly sworn according to law, deposes and says that he is System Plann*ng Manager with Louisiana Power & Light Ccmpany; that the information contained in Applicants' Responses to Joint Interrenors l Interrogatory Nos. 1-1 through 1-44, 2-1 through 2-5, 2- 13, 2-14 and 2-15 is true and correct to the best of his knowledge and belief.

[ 9e f

J ~ . Saacks tem Planning Manager I

l Sworn to the subscribed before me thish y Y day of $A{7p// /

fff /

j ' '

kf.

1p* pry Pub 1?c' t

v My Commission expires [7-/ ,[ M l

l .-

March 25, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board In the Matter of )

)

LOUISIANA POWER & LIGHT COMPANY .' Docket No. 50-382

)

(Waterford. Steam Electric Station, )

Unit 3) )

CERTIFICATE C' SERVICE I hereby certify that copir.s of Applicant's Responses to Joint Intervenors' Interrogatories 1-1 Through 2-16 and Applicant's Responses to Joint Intervenors' Interrogatories 17-1 Throuch 17-136,.and transmittal letter, dated March 25, 1981, were served upon those persons on the attached Service List, by deposit in the United States mail, postage prepaid,

- this 25th day of March, 1981.

am B. Hamlih  ;

el for Applicant l Dated: March 25, 1981 1

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UNITED STATES OF AMERICA NUCLEAR REGLrATORY COMMISSION Before the Atomic Safety and Licensinc Board In the Matter of )

)

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

)

(Waterford Steam Electric Station, )

Unit 3) )

SERVICE LIST Sheldon J. Wolfe, Esquire Lyman L. Jones, Jr., Esquire Chairman, Atomic Safety and Gillespie & Jones Licensing Board Suite 201 U.S. Nuclear Regulatory 1420 Veterans Memorial Boulevard Commission Metairie, Louisiana 70005 Washington, D.C. 20555 Stephen M. Irving, Esquire Dr. Harry-Foreman Suite 1601 Director, Center for One American Plaza Population Studies Baton Rouge, Louisiana 70825 Box 395, Mayo University of Minnesota Luke B. Fontana Minneapolis, Minnesota 55455 824 Esplanade Avenue New Orleans, Louisiana 70116 Dr. Walter H. Jordan 881 West Outer Drive Atomic Safety and Licensing Oak Ridge, Tennessee- 37830 Board Panel U.S. Nuclear Regulatory Joseph R. Gray, Esquire Commission Office of the Executive Washington, D.C. 20555 Legal Director U.S. Nuclear Regulatory Atomic Safety and Licensing Commission -Appeal Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission

Docketing and Service Section(3) Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

_ . . _ , __