ML19210C085

Affidavit,On Behalf of Sierra Club & Six Other Intervenors, Forwarding Excerpts from CA Public Utils Commission Hearing Transcript.W/Excerpts from Jo Schuyler & R Davis 790607 Testimonies,Pg&E Exhibit 89 & Certificate of Svc

ML19210C085
Person / Time
Site:	Humboldt Bay
Issue date:	10/16/1979
From:	Sherwood M SHERWOOD, M.R.
To:
Shared Package
ML19210C082	List: ML19210C081 ML19210C085
References
NUDOCS 7911130238
Download: ML19210C085 (26)

Text

,

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

PACIFIC GAS AND ELECTRIC COMPANY

)

Docket No. 50-133 License No. DPR-7 (Humboldt' Bay Power Plant, Unit No. 3)

)

)

AFFIDAVIT OF MICHAEL R. SHERNOOD MICHAEL R. SHERWOOD, being first duly s.Jorn on oath, states:

1.

I am one of the attorneys of record represent-ing Intervenors in this proceeding.

2.

Intervenors are also parties to the presently pending - proceeding before the Public Utilities Commission of the State of California captioned:

Application of Pacific Gas and Electric Company for authority, among other things, to increase its rates and charges for electric service (Electric)

Application No. 58545 Application of Pacific Gas and Electric Company for authority, among other things, to increase its rates and charges for gas service (Gas)

Application No. 58546 Investigation on the commission's own

~

motion into the electric resource plan and alternatives of Pacific Gas and Electric Company and the ratemaking implicat ions and options relating to the various plans O.I.I.

No. 26 Intervenors were represented in the said proceedings by William S. Curtiss (Esq.) of the Sierra Club Legal Defense Fund. 1320 017a3f 6/911130

9 Mr. Curtiss has since transferred from the San Francisco to the Denver office of Sierra Club Legal Defense Fund.

3.

The attached 22 pages are true and correct copies si pages excerpted from the record of the said Cali-fornia PUC proceedings.

Specifically, the attached items ar(:

a)

Pages 3286-3287 and 3294-3297 of the Reporter's Transcript of Hearing (found in Volume 35), before PUC Admin-istrative Law Judge Marcel J.

Gagnon, a portion of the record of the testimony on cross-examination of Roy Davis, called as a witness by PG&E on June 7, 1979.

The examination was con-ducted by James S.

Rood, attorney for the California Public Utilities Commission.

William H.

Edwards, Esq. represented PG&E; William S. Curtiss, Esq. represented Intervenors, b)

Pages 3464-3465 and 3487-3489 of the same Re-porter's Transcript of Hearing (found in Volume 36), a portion of the record of the testimony on cross-examination of James O. Schuyler, called as a witness by PG&E on June 12, 1979.

This examinatior. was also conducted by James S.

Rood, attorney for the California Public Utilities Commission.

William H.

Edwards represented PG&E.

c)

Cover and pages 5-7 of the Prepared Rebuttal Testimony of James O. Schuyler, a part of PG&E's Exhibit No. 77',

admitted on June 7, 1979.

d)

Cover and pages 1-3 of Humboldt Bay Unit No 3, Testimony of Roy Davis, admitted on June 7, 1979 as PG&E's Exhibit No. 79.

e)

Cover and pages 13-14 of PG&E Electric Depart-1320 018

e ment, Comparison Exhibit, dated June 1, 1979, admitted on June 13, 1979 as PG&E's Exhibit No. 89.

Dated:

October 16, 1979, San Francisco, California.

/hlk{e/.

ox/

MICHAEL R.

SHERWOOD "Pf4'~> p -[p$[;'c $. [h[

Subscribed and sworn to before me p

j [IJ: j UI

.no t.1. l.;r3E#3 I this

/d day of October, 1979.

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Notary Public, City andynty of San Francisco, California 1320 019

__J oo 1

MR. ROOD:

A'_1 right.

2 Let me teve to ahother~ area.

3 Q

Mr. Davis, would you refer to page 4 of your testi-a

{

4 mony.

i i-l 5

At the tcp you state:

I l

s "If it is dete_.nined Unit 3'cannot i

i 7

retumed to operation,.the i

i 6

c Com iss. En will determine how PGGE I

I I

will be fully compensated for net l

f

3 plant inve s tmen t and the balance. in

1 the acctunt. "

i I

_2 _0 Now, are.vou sugccestine that the Con:nis sion should o

I 13 issue an order sc that PG&E will recover all of its costs i

i t

i i

1.;

on the Humboldt

.u lear facility, if the plant shculd have f'

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.=

to shut down cerr.snentiv?

I l

i A

Yes, I be'ieve that's the icport of my testirony.

I

_o

.s -

Q nny co yc

nin,e these cos ts saould be recovere-

.a Humboldt never re: pens?

19 A

There are enrecovered capital costs.

It was a pro-ductive plant.

We used the best esticates of depreciation

,-0 allowances.

If : hey were not adecuate to cover the cost by I

22 the tire it shuts :cwn there would be scre unrecovered I

2-capital costs whi:~.- have served the customers over a neriod e

D**

"D'9' l

24 oI-tiCe.

i oc c

.l2 Con s e c.uen : ^_ v., it woulc seen ec.uitable to ce that e e:

i, 26 j

nese costs wou..._ c. ave to be covereu, oy ne ratepayers.

0 Whv do ve_ think the Coc-ission should make a Ze j udg=e n t a-

-"s

ire, in other words. cre'udre these issues I'

in this decision?

2 :-

1320 020

.v3 EDWAF.DS :

Frejudre -d

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=

1 MR. R 23:

The recovery issues the witness just 2

brought up.

e 3

MR. EDWARDS:

Gie witness has testified that he believes l

4 that the.Cctrission should order recovery if necessary

.i I

5 based upon the facts, th'e fact that it was used and useful.

6 Ncw I. don't see that there is any controversy,ver

~

that.

The plant did operate.

So that is all he is testify-S ing to.

3 MR. RC;3:

The problem is the if necessary.

10 i The ' staff feels that the Coc=ission should not issue l 11 an or der in this proceeding which will allow for future

'. 2 recovery of this money if it appears that the plant never 13 will recc.er without'some investic_ation into :he reasonable-9 l

t ness of this order.

i i

i li Tha: is my question.

[

li Q

W'.- -f is this reascnable?

i A

vculd cer:ninif concur : hat there sculd have to be

=

a hearing en how the proper rate-caking trea: ent would be 13 for any plant that was insufficient -- that had unrecovered 2:

capital ces:s.

2; Q

T would like to cove to another area, Mr. Davis, vour testiron rerarding Mendocino in Exhibi 77.

22

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the su.pervision 6f Mr.

Sch uler?

Y 2

A Mr. Schyu3er is fully aware of what is happening, as 3

I understand it, with_ hearings before the Nuclear Regulatory Commission.

5 0

All right, sir, with respect to Exhibit 79 and your 6

testimony at Page 1, Lines 18 through 20, and I will quote 7

from those --

~

8 A

What page, sir?

9 O

Page 1, quote:

10 "PG&E believes tha t the revenue 11 requirements for t.3 unit based on 12 capital in service as of 12/31.'78, 13 should be borne bv current rate-

• D'M l

1.

!D

• D pavers."

c

.::s 6e 15 In plain language, Mr. Davis,'what does that mean?

16 A

This means that we are seeking te have the Humboldt 17 Plant included as part of the rate base on which we are 18 entitled to earn at the capital cost acccunts as of 12/21/75, along with any maintenance and opcrating costs that are 23 incurred on site, property taxes and income tax ramifica: ions

• 2.

tax expenses asscciated with that,olant.

or in::me

'2

~

O Do you know, Mr. Davis, what the capital i n-s e r.-ice amoun: is as of 12/31/78?

A The depreciated cost is approximately S16 milli n.

w O

Can you tell me, sir, what portier of that S16 e,

I r.illi:n represents i.n ve s tme n t s in the plant that PG&E has i

l l

made since the plant was shut dcwr in 19 6?

i a

l A

Not specifically, but it isn't a. appreciable arr un. l i

I

+

l

T.ay be three to five -illicr d: lars, as a ball I

=;=<.

~~

1320 022

1 There have been additional expenditur'es since the 2'.

begirining of -- there have been.e'xpenditures, but they are 3

not included in this figure.

They are being cz.rried as construction work in 4'

5 and are not part of what we are. recommending to

progress,

.6 be included.in this case.

that are so being 7

O Do you know what the expenses are S

carried as construction work in oroa.res.s?

On.the order of twenty-plus-million dollars.

- 9 A

10 O

Twenty-plus million?

Twenty-two million may be a' good round number.

33 A

^^

12 That is what was anticipated to be in 1980, and we

,3 aren't making appreciable expenditures today.

14 O

Let's get back to the~16 million for a morent.

15 If your application is approved as requested, what 16 annually will be the recence to PG&E if the rate of return

'7 as requested is apprczed, and this 16 -illion is include:

in rate base, in round figures?

n

-r THE WITNESS:

May I have the question again?

20 ALJ GAGNON:

Read the question, please, Miss Reporter.

03 (Record read)

THE WITNESS:

We are seeking a 10.7-percent return on o

is :: cover bonds Drefe"r C'

"n

^^~.icn inve s tmen t, wnicn.

' D S

',D

' r' s

equity.

g hy L

uut b

I 16 million t res 10. -- 10 percent would be jus a

=c.

26 little more than 1.6 nillion of net revenue coverir; bcnds, l

i preferred, common.

l

.M R. CURTI3S:

C

! hank fou.

Am I to understand frer I

E' your testimcny a mone..: ago that with the !.mcunts -hat i,

t are new 'cc n: considersi as c onstructicn wo-+

~- oc.ezz,

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l320i 023

..._........_. _. c_....

t plus the,ar:unts of, the 16 million that have been spent j

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.:nder considerat. ion for inclusion in the ref te j.

I which are

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base, th a t P G t.E h a s s6cnt somewhere between twenty-five

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4 and twecEy'-eight million dollars on the Humboldt Plant since j

i 6

it was shut down in 1976?

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0 A

No. '

A.

.v.R. EDWADS :

Objection.

There is an ass =ction in the

.a e*

O question that is incorrect.

Well, maybe I will just let the witness -- I will 9

10 let the witness --

Il THE W T!,;ESS:

16 million was net investment of the

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plant, net investment being what it cost us criginally to

[

10

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13 build the ; ant, additions up until December 21st,

'78, t.

less the depreciation that had accrued for this plant.

I 14 i

is 16

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1 The $22 million is the amount that we 2

have spent basically since it was shut down.

3 MR. CURTISS:

Q All right, 4

So'$22 million approximately is the total expendi-5 tures that PG&E has made since' che plant was shut down on

. 6 Unit 3?

7 A

Yes.

S Q

Sow, was it a: your suggestien, Mr-Davis, tha:

l 9

PG&E has aske'd that this $16 million be included in rare j

i I

10 base?

11 What I an asking is w', ether as part of your job 12 duties e3 a PG&E employee do you recccmend that this be 13 includec in rate base?

'4 A

I so recocrended, but others participated in tha:

I.

decision.

I 16 l'

ALJ GAGNON:

Mavhe we should have it c1= '#4ad.

i As I understanc it, it is now in the rate yase, is

'S it not?

13 THE WITNESS:

It is in the rate base en a recorded 2;-

basis.

It was in the rate base for our '78 rest year.

We propose to :cntinue it in 1980.

22 ALJ GAG"OS:

Mr. Iurtiss, it is now in the rate base.

"4 The issue arises because the staff is savinr, that it sheuld mm m

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c' be exc_uce.

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od a

'5 o

MR. CUF.TISS:

I understand.- Thank.vou, vour Honor.

I Q

W.,uld you raccarendation be changed, Mr. Davis, if i

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l you were certain that :he plant would never recpen?

i, l

A I wculd cer:a nly have to reevaluate if : were 3

certain tha: the plan: vould r. aver be operariic and deve':p i

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shoulc ce 5 ndl:d 1320 025

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A

'a'ould you give ne the reference;. I got lost.

Q Lines s anc 9 on c. a re 3.

You state:

"I beliete :he earliest date ae coutc non.e.cc achieee co.eration would

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acceleration?

2 A

Yes.

h I

j j Q

Do you have any idea, Mr. Schuylar, of the cost -- p r;e l

~

l total cost of modifying the Humboldt plant to meet the 4

5

.25G opc.ating-basis earthquake and the.5G safe shutdown t

{

g earthquake?

1 A._ We have spent approximately $26.6 million in

)

7 modifications and in the geologic and seismological studies f

g f

up to the April, 1977 report.

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O Co you have any estimate as to what additional 13 amounts have been spent since April, 1977?

3, A

Well, excuse me, these -- the figure I just gave you

,o of 26.6 million was the amount that we have spent to date, f

13 a-of March; tne last figures I have as of March, the end l

of March, 1979, and most of that was spent prior to April, I

s l

1977.

3_ _.

We have spent approximately $2,700,000 in the most

,7 i

recent geologic and seismological studies.

O Can you give me a total component of that 26.6 million that recresents the cost of the studies to date?

20 I don't have that brcken down.

73 I

t I can give you a ball-park estimate.

I would say in the neighborhood of S5 million.

m.a Q

So, we do have something en the order of twenty-one

,a,.

to t /enty-two million that was spent for other things besid2s these studies.

D D

Can you tell me what general categories of expenses 7-make up :ha. twenty-cne to twenty-two million?

2 I.

A Yes.

• n modifying the clant to withstand a.25G

.: l operating-casis earthquake, we had to do a nuncer c:

1320 028 g

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1 structural mod-fications.

2 We had

reinforce the roof of the refueling l

1 3

building.

l 4

We had to reinforce the walls.

i 5

We had to take and replace some of the electrical l

o ec.ulo. me nt.

Most of it we either tried'to anal?:e,,or we did a

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i 10 And where we couldn',t do that, w h y,' then, we replaced l

i 11 1 it with new ec.ui.rment that was c.uaA1:1c

or :ne seism _c i

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levels.

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There was a larce extenditure on reanal.etin: the 13 t

o. i.c i nc. systems and.crovidinc. new cic.e, new cite s u r..t o r :s i

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for the cic. inc. :n the plant.

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Is l And in aidition, there has been the enrineering ::s : i l

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in doinc al.,

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c-O How much more money needs :o be spent on the

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Of the plant Oc

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and the.5G safe shutdown earthquake?

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! don't seem to have tha: nunter with me.

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At the end -of tha, we'll have to make another 2

decision t-to what the results.shcw, and at that point,

- I

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or ma./ ne recuire c.oinc. 2 head with future s:adies.

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-crogram could be as high as 57 million, Phasei l

-The next 1

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O Sc -hat I'm sure ! anders:and your answer, did you 6

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tell me that of the 33.2 million estimated ccs: of the l

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de have already spen: 2.7 million.

de '. ave an additional 3.2 million to ccmplete the 4

Phase 1 tr.c. ram, for an everall cost of about 5.9 million e

for Phase '

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Sc, we are locking at a potential cost through the 4

end of up :: sone:hinc like 12.3 million?

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L Application No. 58546 Exhibit No..

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PACIFIC GAS AND ELECTRIC COMPANY REBUTTAL TESTIMONY 0

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1320 031 0

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A 6 Continued -

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age dating analyaes, additional microseismic recording, and review

.' jpg g, j and re-interpretation of existing onshore and offshore seismic yg e li I reflee tion records.

I f.

When is the unit likely to return to service?

5 Q 7 Our current estimate for completion of the geologic investigations is h.

A 7

(}cy sft.

{

l61-1980. Af ter completion of the investigations and acceptance of

, y.'

i them by the NRC Staff, a public hearing will be required in order to C f!

]y I believe the earliest date obtain the required license amendment.

31, 1980.

we could hope to achieve operation would be December What is the nonthly cost of operation and maintenance of Humboldt Bay Q 8

7. hat is the cost when the plant Unit 3 when the plant is in service?

is not in service?

PC4E's nuclear plant expenses, excluding fuel, for the years 1979 and A 8 1980, as estimated for the current general rate case, Application flo. 58545, are $186,400 and $200,300 per month, respectively. These These 1979 expense estimates assumed full operation of the unit.

1973-1977, as 1978 and 1980 estimates were based on actual data for i

prepared.

data was not available when the rate case application wa9 (a) in service -

Pf&E's latest monthly estimates for 1979 and 1980 are:

)

t-

$222,500 for 1979 and $238,700 for 1980; (b) not in service - $182,300 J

for 1979 and $195,500 for 1980. Fuel expenses are excluded from all 1

2 these figures.

)

The differential in costs between full operation and shut-doan

?)

operation is not very great, as the fluelear Regulatory Commission (NRC)

?4 requires that the plant must be staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 365 days a 25 Lt i

1320 032

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A 8 Continued -

1 1

year, with a 7-man operating staff per shif t on site, and that the I

2 y'

2 full plant security system must be staffed and maintained. % hat,

g 3

3 economies have been obtained are due to (1) lower maintenance costs;

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4 (2) deletion of one chif t position saving four employees; and (3) h 5

5 where possible, delaying filling positions vacated by attrition.

6 6 Q 9 Y. hat has been the net cost to the system since the shutdown of flumboth 7

Day Unit 3 in tenns of increased cost of service?

8 A 9 The major effect on ne c' system costs because of the shutdown of the 9

liumboldt Day Unit 3 electric generating plant has been the cost of 7j 10 fuel to generate replacement power. Ilu:nboldt Bay Unit 3 generated 11 383 million Kwh in 1975, its last full year of operation, at a fuel 12 cost of 71,123,000 To datermine the true replacement cost of that ja 13 power each yea since then would require resimulating operations during 14 that period at a great expense of time and money.

15 However, an approximation of the cost can be made if certain f

16 simplifying assu. options are made:

(1) assume that replacement powcr 4

17 was generated in an oil-fuele 2 steam :et. ?ra tion plan t. Therefore the 18 cost can be based on th; average cost of fuel oil for the year esticata.4..

19 This is a reasonable assumption, as PC'A uses its most efficient low.

.h 20 cost sources of power first, gradually bringing on higher cost sources.

Thus, the most likely source of replacement power would be oil-fueled. h.

21 22 genera tion : (2) assume that the cost of capacity replac ement is zero; 23 (3) assume

.at 1975's output of 383 million Kwh is typical for the

.)

24 estimated years.

25 Given the above assumptions,,the net cost of re;1 acing Ilumboldt iJ 1320 03i 6

6

?: (i

h. fth' t M A 9 Continued -

4 1976 - $3,906,000; Day Unit 3 energy was approximately as follows:

(}y; 1977 - $7,890,000; 1978 - 78,691.,000.

The 1976 figure is approximately

<ln f 1'j(e l'

t half of the 1977 or 1978 figures because Unit 3 generated energy for 4

d,,({ r 6

only the first six conths of that year.

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Mr. schuyler, does that complete your testir:r,iy?

Q 10 l.1 j,f w

A 10 Yes, i t does.

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Application No. 58545 Application flo 58546 Exhibit No.

kvv/s Date / ~ )b s.

_ ' f 1

PACIFIC GAS AND ELECTRIC COMPANY REBUTTAL TESTIMONY ROY DAVIS HUMBOLDT POWER PLANT N

1320 035

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g HUMBOLDT BAY UNIT No. 3 j

TESTIMONY OF ROY DAVIS 1 Q l What is PGandE's position concerning rate base treatment and the 2

inclusion of operating expenses related to Humboldt Bay Unit No. 3 3

in Test Year 1980?

4 f 1 At the time Application No. 58545 was being prepared, Humboldt Bay 5

No. 3 was expected to be in operatior for the entire year 1980.

i l

6 Therefore PGandE included the unit in the test year.

At this time 7

it is not expected to be in operation until af ter the test year as 8

testified to by Mr. J. O. Schuyler.

PGandE therefore agrees with E

f 9

the staff that capital additions remain in Construction Work In 10 g

Progress (CWIP) and accrue an Allowance fer Funds Used During Con-j 11 struction ( AFUDC).

In PGandE's comparison exhibit Humboldt Bay j

12 capital costs as of 12/31/78 and 1980 operating expense have been p',

13 included.

f 14 Q 2 Has the Staff included Humboldt Bay Unit No. 3 in Test Year 1980?

I 15 A 2 No, with the exception of a allowance for on-site maintenance 16 and operation expenses.

17 Q3 Does PGandE disagree with the Staff's treatment?

j 18 A 3 Yes, PGandE believes that the revenue requirements for the unit I

19 based on capital in service as of 12/31/78 should be borne by

(

(

20 current ratepayers.

The plant has in the past operated to the 21 benefit of the ratepayer and is expected to continue to do so in 22 g

the future.

It has merely been temporarily shut down.

h:ER 1320 036 i

L.

1 Q 4 What was the Staff's recomendation for this unit?

2 A The Staff Operations Division (Exhibit 24, page 11-3, paragraph 14) t 3

recomended transferring this net capital cost into CWIP to accrue i

I 4

AFUDC until such time as the plant begins operating again.

However, l

5 th' Staff Finance Division (testimony of Anderson, page 825; Dun, 6

page 833-4) confirmed the statement by PGandE's witness (Mr. K. S. Tay; 7

p age'795-803 ) that this recommendation violates the Uniform System 8

of Accounts.

I 9 Q 5 How could the CPUC accomplish the goal of the utility's division

)

10 recomendation ?

l 11 A 5 As stated by Mr. K. 5. Taylor, PGandE could be ordered to accrue a

12 carrying costs and other costs for the unit for future rate a

l 13 treatment.

i 14 Q 6 What would be the nature of such an order?

15 A 6 I have had drafted certain language tb t could be included in the 16 decision which would accomplish the intent of the Utility Division's 17 recomendation.

It is as follows:

1 18 "The Comission Staff's recomendation to transfer Humboldt 19 Bay Power Plant, Unit No. 3 from plant-in-service to CWIP 20 will be rejected.

It is not appropriate to return operative 21 plant to CWIP.

However, the cost of Unit 3 for the adopted u

22 Tast Year 1980 will be excluded from the rate base, and oper-1 t

23 ating costs (except S for minimum on site production i

24 maintenance and operation expense) will be excluded from 9

25 expenses, as Unit 's is not currently being operated.

It is

[.

26 not the intent of this Comission to deny the recovery of k

i 1320 037 s

2 i

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llC I5 A 6 Continued -

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l return on m istment or expenses of this unit, but only 1

2 to deiay recovery until the Unit 3's future is known.

In 3

orc' a compensate che Company for the costs applicable to g

i 4

4 this unit, the Company is hereby directed to establish on i

5 the effective date hereof an approprirte account to record r,

4 l

6 all actual costs excluded from the costs adopted in this 7

proceeding.

Any increase or decrease in inco.:a taxes result-8 ing from the non-operation or operation of this unit must 9

also be recorded in the account.

This account will accumulate 10 costs for operations, maintenance, taxes and return on invest-11 ment.

The appropriate monthly rate applicable to the return 12 en investment and to average monthly balance in this account 13 g

is one-twelfth of the rate of return authorized by this 14 decision.

No depreciation shall be accrued for Unit No. 3 15 until further order of this Cormission.

16 After the unit is back in operation, the investment in 17 plant will be included in rate base and all costs of operation 18 for Unit 3 will be included in expenses to be adopted for the 19 next test year.

The balance in said account will be amortized 20

(

over the remaining life of the plant.

PGand: will ae ordered 21 to file within 60 days of the effective date Nreof a full j

22 description of the implementation of this procedure, includir:g 23 all proposed accounti., entries and an estimate of the annual

{

24 amounts to be recorded.

y g 1320 038 u,:.

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4 Ap li ation No. 58545 Exni8i t Jr o. 89 Date f ~/3-/7 9

)

Witness Roy Davis

J PACIFIC GAS AND ELECTRIC COMPAtlY ELECTRIC DEPARTMEtiT COMPARIS0N EXHIBIT JUNE 1, 1979

'320 039 C

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Pactfic Gas and Electric Company Electric Ocpart ent Otner Prohetion, fransaission, a,d Distributton "PUL Staf f, PGan1L's Enhibit No.10 anJ PGanJE's devised Estimate 5%owing PGan1E's Acceptance of Staf f A.nounts and Renaining Issues (00u's Jnt t teJ) l CPUC St af f Issues Account tahtbit PGandE Pb..dE Fren Ajdttions Line Nrb er Nos. 24, Eshtbit Esceeds htaff devised PGandE Revised Lt No.

h1'P@,I Accourt N3ma 30 aed No. 10 Staff Accept Q,s ur t E 5 t iMt e t's t im at e 90 l

td) 3 (d) t[

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A.E*F Electric Production Espensas j

Steam Po=er - Operat ton:

1

- MccountT-No Dif f erence 115,838 515,833 1

5 5 515,833 I?

2 500 760 Sw ervision & Engireer tr g 2.033 2,093 5

4 1

2,083 d.

3 525 704 Electric Erperses 19,582 19,614 32 24 8

19,590

)>

4 536 765 Mtsc. Steam Po.er Espenses 3,413 3,522 9

6 1

i 494 (k

5 Total - Steam Power Operation 41,001 41,047 16 M

10 41,011 d

Steam P0wer - Maintenance:

6

- I T ccunt - No Difference 3,431 3,4 31 3,431 (I

6 1 510 44 0 Supervision & Eriincertng 2,572 2,5S6 14 11 8 511 44 1 5tractores 920 977 7

6 2,575 7

1 921 1.

9 512 44 2 Bollers & Related Apoaratus 4,637 4,838 1

1 0

4,SJ 7 9

10 513 44 4 Main Turbogen Apperstas 5,196 5,259 63 49 14 5,210 10 11 513 45 " sin f arbogen. Asa lli ar ies 4,323 4,36u 32 25 7

4,335 11,

12 513 44 6 Accessory Electric f autp.

70 4 712 8

6 2

7C6 12 ]

13 514 44 7 Misc. Steam Plant 1.244 1,243 5

3 2

1.246 13 14 Tetal - 5 team P r. Maintenance 23,282 23,412 130 101 29 23,311 14 l

15 ictal - 5 tea.' P.r. M. & 0.

64,233 64,459 176 137 3)( a) 64,322 li Naciegr Pe ar - Operatton:

16 51 7 770 Tupervision & Engineering 152 59 (93)

(93) 59 1C 17 51 9 772 Loolants & water 49 59 10 10 59 17 18 520 773 St e ali Espenses 322 502 180 130 502 13 19 ti 3 775 Electric Espenses til 235 44 44 235 19

.~ 0 524 776 Misc. Nuclear Po.er Esps.

519 434 (35) p)

484 20 21 Total - Naclear P.r. Operations 1,233 1,333 106 106 1.339 21 Nuclear Po er - Maintenance:

22 528 450 Supervision & Engineering 97 141 44 44 141 22 23 529 451 Structares R2 34 (48)

(43) 34 23 24 530 452 Reactor & Related Apparatus 256

20 174 174 430 24 1

25 530 453 Reactor Plant Austitries 33 133 105 105 133 25 '

26 531 454 Main Turbogan. & Pelated Apparatus 6

136 150 130 106 20 27 531 455 Main Turbogen. Asstliaries 15 41 26 26 41 27 23 531 4'6 Access ory E lectr Ic Eqatp.

2 4

2 2

4 23 29 532 457 Misc. Nuclear Plant 55 91 3o 36 91 29 30 Total - Nuclear P r. Mainteriance 546 1,06 5 519 519 1,065 30 31 Total - % clear Par. M. & 0.

1,779 2,434 625 625 2,404 31 IDI H oraulic Po er. Operation:

t ll

- 7 ATc~ounts - Na Dif f erence W

W 7 7 V

32 Hydraulic Power - Maintenance:

I 33

- B Accounts - No Difference 4,713 4,713 4,113 33.

34 54 4 46 3 Prime Movers & Generators 1,523 1.8?3 300

_lj R

1.634

• 34 35 Total Hydro Po er Matetenance 6,?36 6,536 300 189 111 6,347 35 i 36 Total - Hydro Po.er M. & 0.

14.423 14,723 300 189 111 14,534 3b ICI Other Power 37

. Uperation Accts. - No Dif f erence 308 308 333 37 38

- 3 Montenance Accts - No Olfference 506 506 506 38,

39 Tots) - Other Po.er M. 1. O.

814 814 814 39 40

- 49 Accounts 1,105 Id) 1,105 40 t il Tot a l E lec tr ic Produc t t an 531,299 182,400 11,101 5326 5775 51,105 133,179 41 1

h 1320 040 l

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)

Description of Issues i

t i

(a) Aswaption by Staff that Geysers Unit 14 will not go into service

{j until September 1980; PGandE original estimate was June 1979.

p Staff disallowed 8/12 of PGandE's original 1980 estimate.

Staff Exhibit 24, page 11-1, and Transcript Pages 1104-1107, S. Han.

r k

PGandE's latest estimate Geysers Unit 4 is June 1, 1980, there-t i

fore disallowance should be 5/12, or $137,000, rather than $176,000.

[

D. E. Nielsen, Transcript pages 768-772.

5 (b) Assumption by Staff that Humboldt Bay Unit 3 will not be in service in 1980.

Staf' stimates that 1978's expenses (with certain adjust-jj ments) are more representative of standby operation than PGandE's original estimate, and used them as a basis for estimating 1980's s

ij i expense by factoring-up the adjusted 1978 expenses at 7% per year.

lj Staff Exhibit 24, page 11-2, S. Han D

PGandE's lastest estimate of expenses for Unit 3 in a standby status 3

is is $2,346,000 for 1980.

The difference between this estimate and PGandE's orf inal estimate is minimal.

Exhibit rebuttal testimony is of J. O.

, page 5, line 21.

0' >

.Tcli Y

a (c) Assumption b Staff that a 10-year amortization of a 1974 BELDEN

[

overspeed problem is better than PGandE's 5-year amortization.

PGandE accepts 10-year amortization but finds Staff's calculation

(

of the effect was overstated.

Staff adjusted for the total 10-year n

amnrtization rather than the difference between PGandE's 5-year n

amortization and a 10-year amortization.

j

s N

(d)

Effect of 1978 recorded expenses on estimates.

Information d

I available to Staff, but not to PGandE at time its estimate was 8

prepared.

This figure is net effect of differences in all produc-tion accounts.

CPUC witness E. Knolle, Transcript page 913, beginning at li 15 3i through 23, page 914, indicates that he would accept effect 1978 recorded data at 1/6 of its value; recorded 1978 data n u

n) entered by Knolle at Transcript pages 898-900.

a v

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R al 41 1

1320 041 t

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A CERTIFICATE OF SERVICE The foregoing document, Intervenors' Memorandum In Support of Answer In Opposition To Licensee's Motion To Hold Proceedings In Abeyance, has been served today on the follow-ing by deposit in the United States Mail, properly stamped and addressed:

Richard F.

Locke, Esq.

Counsel for Pacific Gas and Electric Company 77 Beale Street, 31st Floor San Francisec, CA 94106 Barry Smith, Esq.

Office of Executive Legal Director BETH 042 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Secretary U.S.

Nuclear Regulatory Commission Washington, D.C.

20555 Attn:

Docketing and Service Section Edward Luton, Esq., Chairc.4n Atomic Safety and Licensing Board Panel U.S.

Nuclear Regulatory Commission Washington, D.C.

20555 Mr. Gustave A. Linenberger, Member Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Dr. David R.

Schink Department of Oceanography Texas A & M University College Station, TX 77C40 Dated:

October 16, 19'9.

/

60 MICHAEL R.

SHERWOOD Attorney for Intervenors 1320 042