ML19254B266
| ML19254B266 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 07/31/1979 |
| From: | Hiestand O DAIRYLAND POWER COOPERATIVE, MORGAN, LEWIS & BOCKIUS |
| To: | |
| Shared Package | |
| ML19254B267 | List: |
| References | |
| PELD-790731, NUDOCS 7909270035 | |
| Download: ML19254B266 (18) | |
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In the Matter of
)
Docket No. 50-409
)
Amendment to DAIRYLAND POWER COOPERATIVE
)
Provisional Operating
)
License No. DPR-45 (La Crosse Boiling Water Reactor)
)
(Spent Fuel Pool)
APPLICANT'S MOTION FOR
SUMMARY
DISPOSITION Pursuant to 10 C.F.R.
S 2.749, Dairyland Power Cooperative (Dairyland or DPC), the applicant for an amend-ment to Provisional Operating License No. DPR-45 in the above-captioned proceeding, hereby moves for su=ary disposition of all of the Coulee Region Energy Coalition (CREC) contentions and for a decision by the Licensing Board in Dairyland's favor as to all of the matters involved in this proceeding.
In support of this motion, Dairyland states as follows.
HTRODUCTION The use of su=ary disposition to resolve tenuous issues raised in petitions to intervene has been encouraged by the Cornission and the Appeal Board.
See e.g.,
Northern States Power Co. (Prairie Island 1 and 2), CLI-73-12, 6 AEC 241, 242 7909270 0 3 F 1045 060
a
-2 (1973) aff'd sub nom., BPI v. AEC, 502 F.2d 424 (D.C. Cir.
1974); Mississippi Power & Lizht Co. (Grand Gulf 1 and 2),
ALAB-130, 6 AEC 423, 424-425 (1973); Duquesne Lizht Co. (Beaver Valley 1), ALAB-109, 6 AEC 243, 246 (1973).
Summary disposition is particularly appropriate in license amendment proceedings, (Boston Edison Co. (Pilgrim Nuclear Station, Unit 1), ALAB-191, 7 AEC 417 (1974); Virginia Electric and Power Co. (North Anna 1 and 2), Docket No. 50-338 SP (Order dated June 18, 1979)),
and its use has been specifically endorsed in license amendment proceedings involving, as here, the expansion of spent fuel storage pools.
Virginia Electric and Power Co. (North Anna 1 and 2), ALAB-522, 9 NRC 54, 56 (1979); Wisconsin Public Service Corp. (Kewaunee), LEP-78-24, 8 NRC 78, 85 (1978).
See also Public Service Co. of Oklahoma (Black Fox 1 and 2), LBP-78-30, 8 NRC 327 (Sept. 8, 1978) and Tennessee Valley Authoritv (Hartsville lA, 2A, 1B and 23), LBP-78-35, 8 NRC 513 (Oct. 31, 1978)
That summary disposition may be used to dispose of all the issues in a proceeding, thereby obviating the need for a public hearing, is clear from the Appeal Board's decision in another spent fuel pool expansion proceeding:
This does not perforce mean that there will be a need for an evidentiary hearing on all or any of CEF's conten-tions.
Even those contentions found to be acceptable for admission to the pro-ceeding will be susceptible to a motion for summary disposition under 10 C.F.R. 2.749.
VEPCO (North Anna 1 and 2),
ALAB-522, supra, 9 NRC at 56. (emphasis added).
1045 061
e 9
-3 The issues in this proceeding consist of revised CREC Contentions Nos. 1, 5, 6, and 7 which are set forth in the Appendix to the Board's September 5, 1978 Prehearing Con-ference Orders.
It is Dairyland's position that each of these issues can be resolved in Dairyland's favor by summary disposi-tion, since there is no genuine issue of material fact to be heard with respect to any of these contentions.
As will be shown below, CREC itself has as much as conceded that its con-tentions have no factual basis in its earlier responses to Dairyland's discovery requests.
Attached to this motion are "Dairyland's Statement of Material Facts as to which There Is No Genuine Issue to be Heard" (the Statement) and the affidavit of Dr. Seymour Raffety (Raffety Affidavit).
Dairyland believes that the attached Statement and affidavit, when read in con-junction with the NRC Staff's Safety Evaluation Report and Environ-mental Impact Appraisal related to this license amendment, compel the grant of su= mary disposition for the reasons summarized below:
CREC Contention No.
1.
It is CREC's contention that the application to amend submitted by Dairyland Power is incomplete, as it does not address the following issues:
Applicant has not discussed the long-term integrity of the various components of and in the spent fuel storage pool in light of the proposed compaction 1045 062
d i
-4 and increased amount of spent fuel at LACBWR.
The health, safety, environmental and economic impact of the loss of integrity of these com-ponenN due to more dense and increased storage of spent fuel must be evaluated.
(b)
Applicant should examine the effects of accelerated corrosion, microstructural changes, altert: ions in mechanical properties, stress hydrogen absorption and pr' granular corrosion, and corrosion, cracking, inter ecipitation by the stain-less steel alloys due to the proposed compaction and long-term storage of spent fuel at LACBWR.
BASIS:
The NRC Draft Generic Environmental Impact Statement On Handling and Storage of Spent Light Water Power Reactor Fuel, NUREG-0406, Volume 2, March 1978, p. H-23 states that these corrosion effects in underwater spent fuel storage require examination.
(c)
Because of the possibility of leakage and disintegration of spent fuel and its cladding over the long-term, Applicant must discuss the desirability of and methods for sensitivity monitoring to identify defective fuel elements.
BASIS:
In Behavior of Soent Nuclear Fuel in Water Pool Storaze, September 1977, Battelle North West Laboratories established on p. 76 the need fc. selected, focused, exploratory sur-veillance at present to confirm wet storage as an option and to define the condition of pool-stored spent fuel when removed to any alternative storage or to a reprocessing plant.
Applicant must also analyze the desirability of monitoring each individual spent fuel assembly.
(d)
Applicant should discuss the desirability of and various methods and effectiveness of encapsulating defective spent fuel elements upon discovering leakage of disintegration due to loss of cladding integrity.
This discussion is essential when considering longer-term storage and increased density of spent fuel at 1045 063
e 9.
-5 LACBWR.
Applicant should delineate anticipated thick-nesses of crud layers and crud tendency to influence corrosion of spent fuel and its cladding in light of increased spent fuel storage as proposed for LACBWR.
(f)
Applicant should analyze problems in handling spent fuel (e.g.,
including but not limited to transfer from one pool to another or within one pool during reracking, repositioning upon removal from the nuclear core and placement in spent fuel pools, encapsulation of defective spent fuel elements, placement in or removal from shipping casks), re-sulting from loss of integrity of spent fuel and its cladding as well as other components of and in the spent fuel storage pool due to more dense and in-creased storage of spent fuel as proposed by applicant.
Contrary to the allegation contained in this con-tention, there is simply no need to discuss or analyze the "long-term integrity" of the various components of and in the spent fuel pool in any greater detail than Dairyland did in its original application and subsequent submittals in this pro-ceeding.
For the reasons stated in Dairyland's earlier responses to CREC interrogatories, the attached Statement, and the Raffety affidavit, the concerns expressed in CREC Contention No. 1 are largely illusory.
In any event, the discussions and evaluatiens which CREC asserts should be made pertain to aspects of the pending application that have been so thoroughly discussed and analyzed by the Applicant and the NRC Staff in response to the initial contention that a genuine issue of material fact can no longer be said to exist concerning the long-term integrity of the components in the LACBWR spent fuel pool.
1045 064
-6 Moreover, the NRC Staff recently issued its Safety Evaluation Report (SER) and Environmental Impact Appraisal (EIA), dated July 13, 1979, supporting the facility modifica-tions necessary to increase the capacity of the spent fuel storage pool at the La Crosse Boiling Water Reactor (LACBWR).
With respect to Contention No. 1, the SER corcludes that:
The type 304 and 17-4 PH stainless steels and the type 348H stainless steel cladding used in the new storage racks are compatible with the storage pool environment, which is oxygen-saturated, high purity demineralized water and controlled to a pH 4.5-8 and a maximum tempera-ture of 150 F.
In this pool water environment the corrosive deterioration of the 304 alloy should not exceed 5.90 x 10-5 inches in 100 years, which is minute relative to initial thick-ness.
Dissimilar alloy interaction (electrolytic or galvanic corrosion) between the 304 and 17-4 PH stainless steels of the storage racks, the 348H stainless steel cladding of the spent fuel assemblies (or Inconel and Zircaloy in spent fuel assemblies considered for possible future use), and the 304 stainless steel pool liner will be of no significance because of the minute electrical potential differential.
Based on the discussion and evaluation above, we find that the new proposed Lacrosse spent fuel storage racks and the design and analyses performed for the racks and pool are in conformance with established criteria, codes and standards specified in the staff position for acceptance of spent fuel storage and handling applications.
SER at 8-9.
The CREC response to Dairyland's interrogatories seeking to elicit information concerning the basis for Centention No. 1 stated, inter alia, that 1045 065
-7 (1)
'CREC lacks at present the professional background necessary to describe specific mechanisms or processes by which component [s] would experience degradation;'
(2)
'CREC feels that Applicant has satis-factorily answered [CREC's] interroga-tories with regard to structural, mech-anical, physical, and other impacts;'
(3)
'CREC is not sufficiently conversant with specific monitoring rathods to identify defective fuel elements;'
(4)
'CREC has no information on methods for encapsulating defective spent fuel assemblies
.; ' and (5)
'CREC has no information at this. time from which to develop a clear correla-tion between crud and corrosion.'
See Intervenor's Response to Applicant's Interrogatories (November 6, 1978).
CREC's responses to Dairyland's interrogatories on Contention No. 1 were never supplemented pursuant to 10 C.F.R.
S 2.740(e)(2), and it must be assumed, as a matter of law, that CREC's position with respect to Contention No. 1, as ser forth in its original response to the Applicant's interrogatories, re-mains unchanged.
Cf. Northern States Power Co. (Tyrone 1),
LBP-77-37, 5 NRC 1298 (1977), and cases cited therein.
- Thus, CREC, in effect, has admitted that no genuine issue of material fact exists with respect to Contention No. 1.
Moreover, Licensing Boards and Appeal Boards addressing similar contentions in a number of other spent fuel pool expansion
,.5 066 4
4
-8 proceedings have found that both stainless steel and Zircaloy-clad fuel can be safely stored under water for long periods of time.
For example in Portland General Electric Co. (Trojan),
ALAB-531, 9 NRC (March 21, 1979 (slip op. at 22-23; foot-note omitted), the Appeal Board concluded that:
[T]he Staff's evidence established with-out contradiction that studies have de=on-strated that Zircaloy-clad fuel is rela-tively impervious to corrosion, even at the considerably higher temperatures to which the fuel is subj ected during reactor operation.
In this connection, following its removal after eleven years of storage in the spent fuel pool of the Windscale facility in the United Kingdom, a Zircaloy-clad fuel bundle was found upon metallo-graphic examination to be free of any corrosion attributable to that storage.
See Portland General Electric Co. (Troj an)
EEF-78-32, 8 NRC 413, 418-421 (1978).
Likewise, in Ducuesne Light Co. (Beaver Valley),
LBP-78-16, 7 NRC 811, 819 (1978), aff'd, ALAB-484, 7 NRC 984 (1978), the Board stated:
We find, based on the testimony presented, that there is no significant likelihood of loss of rod integrity and resulting in-creased radioactivity in the spent fuel pool due to long-term storage of spent fuel in the Beaver Valley spent fuel pool.
Finally, in Vermont Yankee Nuclear Power Corp. (Vermont Yankee), LBP-77-54, 6 NRC 436, 440-41 (1977), affirmed, ALAB-455, 7 NRC 41 (1978), the Board concluded:
1045 067
4
-9 The fuel essemblies utilized at Vermont Yankee contain zircaloy and stainless steel and Inconel 718.
While the pos-sibility of stress corrosion cracking of sensitized stainless steel or zircaloy cannot be eliminated entirely, its prob-ability is believed to be extremely low.
Past experience has shown no corrosion problems after residence of similar fuel assemblies in fuel pools for over ten years.
And calculations indicate that zircaloy clad's corrosion rate is suf-ficiently low to provide an adequate con-tainment for at least 100 years.
Even assuming that there is leakage of the fuel rods, this is not expected to be a problem for a number of reasons For all the foregoing reasons, Dairyland submits that there is no genuine issue of material fact to be heard with re-spect to Centention No. 1 and that the Licensing Board should summarily dispose of this contention in Dairyland's favor.
CREC Contention No.
5.
It is CREC's concertion that an increase in the number of spent fuel location." from 134 to 448 would present a threat to the :.afety of the pub-lic and the maintenance workers that would be completely unacceptable for the following reasons:
(a)
The design calls for an even smaller cask drop area. */
(b) (1)
The two-tier design greatly in-creases the chances for, and potential magnituce of, accidents in fuel handling and storage.
(b)(2)
The two-tier and higher density de-sign makes detection of problems in the lower tier difficult if not impossible.
-*/
Since Contention No. 5(a) is subsumed within Contention No. 6, this portion of Contention No. 5 will be acdressed in the section of this motion dealing with Contention No. 6.
1045 068
-10 (c)
The two-tier design reduces the level of water over the assemblies from ten feet to thirty inches, and thus reduces the margin of safety so far as loss-of-coolant accidents in the SFP are concerned to an unacceptable level.
(d)
Increased fuel would increase maintenance exposures because of an increase in the number of filter changes and resin volumes and intensities.
The attached Statament and the Raffety affidavit demonstrate there is reasonable assurance that the health and safety of the maintenance workers and the general public will be adequately protected in connection with the proposed ex-pansion of the LACBWR spent fuel storage pool.
Moreover, with respect to the issues raised in Contention No. 5, the SER issued by the NRC Staff states:
Fuel Handling Accidents The NRC Staff is generically considering load handling operations in the vicinity of spent fuel pools to determine the likelihood of a heavy load impacting fuel in the pool and, possible radio-logical consequences of such an event.
Because Lacrosse will be required to prohibit loads, other than a spent fuel shipping cask and reactor vessel internals which are stored in the pool during re-fueling, greater than the ncainal weight of a fuel assembly to be transported ovar spent fuel in the FESW, we have concluded that the likelihood of any other heavy load handling accident is sufficiently small that the proposed modifcation is acceptable and no additional restrictions on load handling operations in the vicinity of the FESW are necessary while our generic review is under way.
We have evaluated the potential consequences of postulated fuel handling accidents for the proposed modification, with fuel stored in double tiers.
The estimated potential consequences are 162 Rem to the thyroid and 2 Rem to the total body at the Ex-clusion Area Boundary (EAB).
The potential con-sequences at the Low Population Zone are smaller than 1045 069
-11 those at the EAB.
These are within the guidelines of 10 CFR Part 100 and are, therefore, acceptable.
SER at 10-11.
Criticality Analysis and Spent Fuel Cooling In su= mary, we find that when any number. of the fuel assemblies, with no more than 22.6 grams of anium 235 per axial centimeter of fuel assembly for the stainless steel clad fuel elements and no more than 16.6 grams of uranium 235 per axial centimeret of fuel assembly for the Zircaloy clad fuel elements, are loaded into the proposed racks, the neutron multiplication factor will be less than the 0.95 limit.
Based on the above we have concluded that the proposed rack design is acceptable from the standpoint of criticality.
SER at 4.
Wecalculatethatthemaximumpeakhgat load during the 1990 refueling could be 1.1 x 10 BTU /hr and that the maximum peak heat load for a full core off-load that essentially fills the pool could be 2.0 x 100 BTU /hr.
We also find that the maximum in-cremental heat load that could be added by increasing the number of spent fuel ass 9mblies in the pool from 133 to 440 will be 0.2 x. 100 BTU /hr.
Since the spent fuel pool cooling system is designed to remove 2.6 x 100 BTU /hr from 120 F fuel pool water with one pump operating, the maximum fuel pool outlet water temperature will be less than 120*F for the maximum heat load, 2.0 x 106 LTU/hr, which we calculate for any full core offload.
In the unlikely event that both spent fuel pool cooling pumps fail just after a full core offload which generates 2.0 x 100 BTU /hr the fuel pool water would heat up at a rate of about 9*F/hr.
- Thus, assuming an initial outlet water temperature of 120 F it would be ten hours before boiling would commence.
During boiling a makeup rate of four gallons of water per minute (gpm) would be required to keep the pool full.
In its January 31, 1979 letter, DPC stated that either the overhead storage tank or the Deuineral-ized Water Hose Station could provida this make up.
We have concluded that ten hours would be sufficient time to provide a 4 gpm cource of makeup water for the spent fuel pool.
1045 070
-12 Based on the above we have concluded that the present cooling capacity for the spent fuel pool at the La-Crosse Boiling Water Reactor will be sufficient to handle the incremental heat load that will be added by the proposed modifications.
We also conclude that this incremental heat load will not alter the safety considerations of the spent fuel cooling from those previously reviewed and found to be acceptable.
SER at 5.
Occupational Exposure We have estimated the increment in onsite occupational dose resulting from the proposed increase in stored fuel assemblies on the basis of information supplied by the licensee for dose rates in the spent fuel area from radionuclide concentrations in the FESW water and the spent fuel assemblies.
The spent fuel assemblies themselves in the double tier will con-tribute a small fraction of the dose rates in the pool area because of the depth of water shielding the fuel.
A Technical Spccification change will require the licensee to provide a minimum of 16 feet of water above the spent fuel assemblies.
This depth of water will reduce dose rate levels from the spent fuel elements to small fractions of that provided by the radionuclide concentration in the water.
Consequently, the occupational radiation exposure resulting from the additional spent fuel in the pool is negligible.
Based on present and projected operations in the spent fuel pool area, we estimate that the proposed modification would add less than one percent to the total annual occupa-tional radiation exposure at this facility.
The small increase in radiation exposure will not affect the licensee's ability to maintain individual occupa-tional doses to as low as is reasonably achievable and within the limits of 10 CFR Part 20.
Thus, we conclude that storing additional fuel in a double tier in the FESW will not result in any significant increase in doses rece.ived by occupational workers.
SER at 9.
In response to Dairyland's interrogatories to CREC concerning the basis for Contention No. 5, CREC stated, inter alia, that 1045 071
'\\
-13 (1)
'CREC has no prepared answer' to Dairyland's questions as to how the two-tier design increases the chances for, and potential magnitude of, accidents in fuel handling and storage.
(2)
'We find nothing peculiar er obj ection-able about the lower tier except for the fact that it will be buried by the second tier.'
(3)
'CREC opposes any two-tier design for LACBWR, but feels that if such a plan is to be implemented the 700' level should be used.'
(4)
'CREC obviously can provide no analysis to refute Applicant's analysis' concerning maintenance exposures.
See Intervenor's Response to Applicant's Interrogatories (November 6, 1978).
CREC subsequently supplemented this response to state that it had "not completed any analysis which is contrary to the infcrmation provided" by Dairyland.
See Supplemental Answers to DPC Interrogatories (Nov. 15, 1978)
Upon even a cursory examination of the SER and the materials which Dairyland has submitted, it is therefore apparent that no genuine issue of material fact exists to be heard with respect to Contention No. 5.
Accordingly, su= mary disposition should be granted in Dairyland's favor on this contention.
1045 072
-14 CREC Contention No. 6.
CREC contends that a significant increase in the SFP capacity and the resultant increase in spent fuel handling necessitated by Applicant's proposed amendment increases the risk of accidental releases to employees and the public in the event of a cask drop accident to an unacceptable level.
The attached Statement and Raffety affidavit demon-strate that the LACBWR employees and the public will be adequately protected in the event of a cask drop accident.
Moreover, the Staff addressed this issue in considerable detail in the SER and concluded as follows:
Cask drop analyses results indicate that although incurring permanent damage, the modified crash pad is capable of performing its intended function and will protect the pool floor from any damage.
Additional 3/8" stainless steel barrier plate will be provided on top of the pool floor liner under the rack structures to ensure that the existing liner will not be structural damaged.
With the additional barrier plate in place, a
dropped cask will not damage the pool liner or floor sufficiently to adversely affect the laak-tight integrity of the storage well (i.e., would not cause excessive water leakage from the FESW).
SER at 7-8.
The evaluction of the potential consequences of a drop of the spent fuel shipping cask into the FESW is considered in our Safety Evaluation dated October 22, 1975, for the first modification of the FESW.
The potential consequences in that evaluation would not be changed by this proposed action because the previous evaluation assumed that the pool was filled with spent fuel, including 24 freshly dis-charged assemblies (a normal refueling), and all this fuel was ruptured in the accident.
The proposed action, taking into account the additional old fuel that may be in the pool, would not change the con-clusion in the Safety Evaluation dated October 22, 1045 073
-15 1975, that the potential causequences of this postu-lated accident were within the 10 CFR Part 100 ex-posure guidelines are therefore, acceptable We have concluded that the potential consequences of a spent faci cask drop into the pool will be well within the exposure guidelines of 10 CFR Part 100 and therefore, acceptable.
SER at 11-12.
In response to Dairyland's interrogatories concerning the basis for Contention No. 5, CREC stated only that "CREC appeals to common sense in its assumption that the increase in spent fuel would increase the risk of accidental releases to employees and the public in the event of a cask drop accident."
Intervenor's Response to Applicant's Interrogatories (Nov. 6, 1978).
In its supplemental answers dated November 15, 1978, CREC again indicated that it had "not completed any analysis" concerning cask drops "that is contrary to the information pro-vided thus far by Dairyland Power Cooperative."
CREC has there-fore conceded that there is no factual basis for this contention.
Since no genuine issue of material fact exists with respect to this issue, summary disposition should be granted in Dairyland's favor on Contention No. 5.
CREC Contention No. 7.
CREC further contends that Applicant's proposed amendment to its provisional operative license should be denied due to the increased threat to the environment generally, and to maintenance personnel specifically.
The increased threat to which we refer is that of the storage of failed fuel rods, including several grossly failed rods, which results in a more danzerous and shortened storace life and increased storace ecscs.
As 1045 074
-16 stated in NUREG 0032, fuel failures ' compound the problems of storage, waste reprocessing, and disposal.'
As fuel failures are predicted for the future, ACRS, January 26, 1978, p. 173, and ex-pansion of SFP capacity would serve to produce even more unacceptable hazards and increase main-tenance exposures at LACBWR, which is already above the average for the nuclear industry in that regard.
On May 25, 1979, NRC issued Amendment No. 16 to Dairyland's provisional operating license for LACBWR.
This amendment established additional technical specifications de-signed to limit the occurrence of fuel failures at LACBWR.
Moreover, the attached Statement and the Raffety affidavit make it abundantly clear that there is no appreciable increase in storage costs, increase in exposure ricks, or decrease in storage life associated with the storage of failed fuel rods.
After discussing the presence of failed fuel in the LACBWR storage pool in some detail in the EIA, the NRC Staff con-cluded in tha EIA that:
Expansion of the storage capacity of the FESW will not create any significant additional radio-logical effects.
The additional total body dose that might be received by an individual or the estimated population within a 50-mile radius is less than 0.001 mrem /hr and 0.001 man-rem /hr, re-spectivaly.
These exposures are small compared to the fluctuations in the annual dose this population receives from background radiation.
The population exposure represents an increase of less than 0.17.
of the exposures from the plant evaluated in the DES.
The occupational radiation exposure of workers during removal of the present storage racks and in-stallation of the new racks is estimated by the licensee to be between 16 and 23 man-rem.
This is a small fraction of the total =an-rem burden frcm occupational exposure at the plant.
Operation of 1045 075
-17 the plant with additional spent fuel in the FESW is not expected to increase the occupational radia-tion exposure by more than one percent of the present total annual occupational exposure at this facility.
EIA at 14.
In response to the Dairyland interrogatories designed to elicit information on the basis for this contention, CREC could again only " appeal to common sense in its assumption that failed fuel rods present a more dangerous storage life and a shortened storage life."
Intervenor's Response to Applicant's Inuerrogatories (Nov. 6. 1978).
Based on the information presented in the attached Statement and the Raffety affidavit, the SER and the EIA, as well as CREC's own admission that this contention has no factual basis other than a statement taken out of context from NUREG-0032, it is apparent that there is no genuine issue of material fact to be heard with respect to this issue.
Accordingly, summary disposition with respect to Contention No. 7 should be,
granted.
1045 076
-18 CONCLUSION For all of the foregoing reasons, Dairyland submits that the attached Statement and affidavit, the prior pleadings in this proceeding, and the SER and EIA prepared by the NRC Staff amply demonstrate that there is no genuine issue of material fact associated with any of CREC's conteations.
Accordingly, pursuant to 10 C.F.R.
S 2.749, Dairyland respectfully requests that the Board grant su= mary disposition in Dairyland's favor with respect to all of these contentions and dismiss this pro-ceeding.
Respectfully submitted, G f
~ ~ -. : s
}
,- w tevs s
O. S. Hiestand Attorney for Dairyland Power Cooperative OF COUNSEL Kevin P. Gallen Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, D.C.
20036 Dated:
July 31, 1979 1045 077